Privacy Policy

1. Who we are

The Service is provided by BornToRise Technologies Pvt Ltd, the entity responsible for your personal data (the "data controller" / "Data Fiduciary").

• ·Registered name: BornToRise Technologies Pvt Ltd
• ·CIN: U86900PB2024PTC062928
• ·Registered office: H.No. 976, Urban Estate, Chachoki, Kapurthala, Phagwara, Punjab, India, 144632
• ·Contact address: Incubex, 1121 (Ground Floor), 22nd Cross Rd, Parangi Palaya, Sector 2, HSR Layout, Bengaluru, Karnataka 560102
• ·Email: connect@superlivingapp.com

2. Information we collect

We collect the categories of information below. We only collect data that is relevant to providing and improving the Service.

3. How we collect it

We collect information: (i) directly from you, when you register, complete your profile, log health data, chat with the AI, upload content, or contact us; (ii) automatically, through your use of the app and technologies such as SDKs and identifiers; (iii) from connected health services such as Apple Health, Google Fit, Health Connect, and wearables, with your permission; and (iv) from third parties, such as Apple or Google when you use their sign-in, and our service providers.

4. How we use your information

We use your information only for the purposes below, and we connect each use to a genuine function of the Service:

We do not sell your personal information, and we do not use your health or wellness data for third-party advertising.

5. Legal bases for processing

Where data-protection laws such as the EU/UK GDPR or India's Digital Personal Data Protection Act, 2023 (DPDP Act) apply, we rely on the following legal bases:

• Your consent — for collecting and using health and other sensitive data, for connecting external health services, and for optional communications. You may withdraw consent at any time (see Section 12).
• Performance of a contract — to provide the Service you sign up for and process your subscription.
• Legitimate interests — to secure, maintain, and improve the Service and prevent misuse, where not overridden by your rights.
• Legal obligation — to comply with applicable laws, such as tax, accounting, and lawful requests.

6. AI features and automated processing

The Service uses artificial intelligence to power features such as the AI wellness coach, AI personas, food scanning, and blood-report analysis. When you use these features, the inputs you provide — which may include your messages, voice, images, and health information — are processed by AI models to generate responses, suggestions, and insights for you.

To deliver these features, we use trusted third-party AI/model providers who process your data on our behalf under contractual data-protection obligations that restrict them to providing the service to us. The outputs are generated automatically and are for general wellness and informational purposes only; they are not a medical diagnosis or professional advice, and they may not always be accurate. You remain responsible for decisions you make, and we encourage you to verify important information with a qualified professional. We do not use these AI features to make decisions that produce legal or similarly significant effects about you without a lawful basis and, where required, your consent.

7. Health data, Apple Health & Health Connect

We apply extra protections to health and fitness data, including data you read into the Service from Apple Health (HealthKit), Google Fit, Android Health Connect, and connected wearables:

• We access this data only after you grant permission, and only to provide the health and fitness features you request.
• We do not use Apple Health, Google Fit, or Health Connect data for advertising, marketing, or any use-based data mining.
• We do not sell this data, and we do not share it with third parties except as needed to provide a feature you enable (for example, an AI provider that generates insights for you), or with your explicit consent, or as required by law.
• Our use of Apple Health data follows Apple's requirements, and our use of Health Connect data follows Google's Health Connect and User Data policies.
• You can revoke access at any time in your device settings (Apple Health / Health Connect / Google Fit permissions) and within the app.

8. How we share information

We share personal information only in the limited circumstances below, and never sell it:

• Service providers (processors / Data Processors): Companies that host our infrastructure and store data (cloud hosting providers), that provide analytics and crash reporting to help us understand and improve the Service, and that provide AI/model processing to power app features. These providers act on our instructions under contracts that require them to protect your data and use it only to provide services to us.
• AI/model providers: To generate coaching responses and analyze inputs such as meals and lab reports, relevant inputs — which may include health information and images — are processed by AI providers on our behalf, subject to confidentiality and data-protection obligations.
• Payment platforms: The Apple App Store and Google Play process your purchases under their own privacy policies. We receive subscription status and transaction identifiers, not your card details.
• Legal, safety, and compliance: When required by law, legal process, or a government request, or to protect the rights, safety, and security of our users, the public, or SuperLiving.
• Business transfers: In connection with a merger, acquisition, financing, or sale of assets, subject to this policy continuing to protect your data.
• With your direction or consent: When you choose to share content publicly (for example in the community) or otherwise ask us to share your information.

Where we share analytics or diagnostic data, we minimize and, where feasible, de-identify or aggregate it. We do not share your health and wellness data for third-party marketing or advertising.

9. International data transfers

We are based in India, and our service providers (including cloud hosting and AI providers) may process your data in countries outside your own, including outside India and the EEA. Where we transfer personal data across borders, we take steps required by applicable law to protect it — for example, using contractual safeguards such as Standard Contractual Clauses and requiring recipients to maintain appropriate security. By using the Service, you understand that your information may be processed in these locations.

10. Data retention and deletion

We retain your personal information for as long as your account is active and as long as needed to provide the Service. When you request deletion, or when we no longer need your data, we delete or anonymize it as described below:

• We retain account and health data while your account remains active.
• When you delete your account or request deletion, we delete or irreversibly anonymize your personal and health data within 90 days, unless we are required or permitted by law to keep it longer.
• We may retain limited information beyond this period where necessary to comply with legal obligations (for example, financial and transaction records may be retained for up to 8 years to meet tax and accounting requirements), resolve disputes, prevent fraud and abuse, or enforce our agreements.
• De-identified or aggregated data that can no longer be linked to you may be retained to improve the Service.
• Backups are deleted or overwritten on a rolling schedule.

You can request deletion of your account and data at any time in the app, or at https://superliving.app/delete-account or by emailing connect@superlivingapp.com.

11. How we protect your data

We use industry-standard technical and organizational measures to protect your information, including encryption of data in transit (for example, TLS) and encryption at rest, access controls that limit who can access personal data, and monitoring for unauthorized access.

12. Your rights and choices

Subject to applicable law, you have the right to:

• Access the personal data we hold about you and obtain a copy.
• Correct inaccurate or incomplete data.
• Delete your data and account (subject to legal retention requirements).
• Withdraw consent at any time, including for health-data processing and connected health services, without affecting processing already carried out.
• Object to or restrict certain processing, and opt out of promotional communications.
• Nominate another individual to exercise your rights in the event of death or incapacity (under the DPDP Act).
• Lodge a complaint with a data-protection authority (see Section 14 and the region-specific notes below).

To exercise any right, use the controls in the app or contact us at connect@superlivingapp.com. We will respond within the timeframes required by law and may need to verify your identity first.

13. Subscriptions and billing

• Paid subscriptions are billed through your Apple App Store or Google Play account upon confirmation of purchase.
• Subscriptions renew automatically unless canceled at least 24 hours before the end of the current billing period.
• You can view, manage, or cancel subscriptions in your App Store or Google Play account settings.
• SuperLiving does not store your payment-card details; Apple and Google process all transactions securely under their own terms.

14. Age requirement and children

The Service is intended for adults aged 18 and older. We do not knowingly collect personal data from anyone under 18. If you are under 18, please do not use the Service or provide any information. If we learn that we have collected personal data from a person under 18, we will delete it promptly. If you believe a minor has provided us data, contact us at connect@superlivingapp.com and we will take appropriate action. Where required by the DPDP Act and other laws, we do not process children's data or use it for tracking or targeted advertising.

15. Region-specific disclosures

16. Cookies and similar technologies

Our website and app use cookies, SDKs, and similar technologies to keep you signed in, remember preferences, measure usage, and improve performance. You can control cookies through your browser settings and manage advertising identifiers in your device settings. Some features may not work properly if certain technologies are disabled.

17. Third-party links and services

The Service may link to or integrate third-party websites, content, and services that we do not control. Their handling of your data is governed by their own privacy policies, and we encourage you to review them. We are not responsible for the practices of third parties.

18. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy with a new "Last updated" date and, where appropriate, notify you in the app or by email. Your continued use of the Service after an update means you accept the revised policy, except where your fresh consent is required by law.

19. Grievance & Data Protection contact

In accordance with the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Digital Personal Data Protection Act, 2023, the contact details of our Grievance Officer are below:

How to submit a complaint:

Email the Grievance Officer with your name and contact information, a description of your complaint, and any relevant screenshots or supporting information. The Grievance Officer will acknowledge complaints within 24–48 hours and endeavor to resolve them within 15 days of receipt. You may raise concerns about content, data privacy, or any other issue relating to the Service.

20. Contact us

If you have questions about this Privacy Policy or your data, contact us at: