Making Recovery Manageable, No Matter What Life Brings

Feel Less Overwhelmed, Be More Objective And Accountable, Gain Confidence In Your Recovery

At Enso Ventures we aim to empower individuals, to address feelings of overwhelm, unmanageability and self-destructive ways of coping. In doing this, we are committed to protecting and respecting your privacy in connection with your use of our content and products via our applications, including the My 12-Step Coach mobile app (“Apps”) or other delivery methods (collectively referred to as our “Products”).

For the purposes of data protection laws (including the GDPR), Enso Ventures S.à r.l.-S, registered in Luxembourg, is the data controller responsible for the processing of your personal information via our Platform.

We deliver coaching and support services using these Products or via other delivery methods. Throughout this Privacy Policy, we refer to all our Products and Services collectively as our “Platform.” This Privacy Policy covers the “personal information,” meaning information about an identified or identifiable individual that is collected through our Platform.

Depending on how you interact with us, the following may also apply to you:

Some components or features of our Platform may include additional privacy notices, such as optional features that use your personal information in a unique way. Similarly, you may have been given access to our Products or Services in a manner that includes additional terms or privacy notices, such as from your employer. These additional terms and privacy notices supplement this Privacy Policy unless there is a conflict, in which case those additional terms will apply.
You may follow links contained in our Platform or provided by other users to third-party websites or products not operated by us. This Privacy Policy does not apply to third-party websites or products. We strongly recommend reviewing their privacy policies to understand how your personal information is handled by those third parties.
You may use single sign-on (SSO) features to access our Platform, such as via your social media accounts. The use of these features may be subject to the terms and privacy policies of your SSO provider, and we encourage you to review them before using these features.
This Privacy Policy does not apply to Enso Ventures employees or applicants. Please read the following carefully to understand our practices regarding your personal information. We also encourage you to review our end-user terms and conditions.

Table of Contents

This Privacy Policy is provided in 10 sections. We provided summaries for each section, and we encourage you to read each section in detail.

Section

1. Collection of personal information

We collect your personal information through our Platform, including both our app and website, or when you share your information with us. This may include information provided directly by you or collected automatically as you engage with the Platform. We do not use tracking technologies for marketing or advertising purposes.

2. Use of personal information

We use your personal information primarily to operate our app and website, and to deliver services. Additionally, we may use your personal information for communications, payment processing, legal compliance, or improving features.

3. Sharing of personal information

We do not share or sell your personal information for marketing or advertising purposes. We may share your personal information with third-party service providers to help our Platform function. This means that we use trusted external services to support essential operations like hosting, payment processing, analytics, and communication. These providers only receive the information necessary to perform their specific functions and are required to protect your data in compliance with applicable privacy laws.

4. Data security and retention

Your personal information’s security is critical to us. We maintain safeguards to protect it and retain your data as long as necessary for the purposes outlined in this policy.

5. Your privacy rights

You have choices in how your personal information is used. We provide you the right to request actions like data access, correction, or deletion, depending on your jurisdiction.

6. Children's Privacy

Our Platform is intended for adults aged 18 and over. We do not knowingly collect personal information from children.

7. Cookies

When you visit our website, we may collect certain information automatically through cookies and tracking technologies. These cookies are used for functionality, performance analytics, and security, as well as to personalise content. We do not use cookies or other tracking technologies for advertising purposes. You can control cookie deployment via your browser settings or our cookie settings.

8. Changes

We may update this Privacy Policy to reflect changes to our services, data practices, or legal obligations. Notifications of changes will be provided as appropriate.

9. Contact us

You may contact us with questions or to exercise your privacy rights by emailing privacy@ensoventures.com.

10. Supplemental notices

This section provides additional information for specific jurisdictions, including the European Union (EU), the United Kingdom (UK), and other worldwide jurisdictions where our Platform is available.

1. Collection of personal information

We may collect and process personal information that you provide directly, information we receive from others, and information automatically collected when you interact with our Platform.

(a) Information you provide to us

i. Contact information: We may ask for your name and email address when you create an account or interact with our Platform.

ii. Account information: If you set up an account, we collect details such as your name, email address, and password. For paid subscriptions, transaction details are processed by Apple or Google. We do not collect or store any payment card information directly.

iii. Sobriety dates and emotional check-ins may involve sensitive data. We only process this data with your explicit consent in accordance with Article 9(2)(a) of the GDPR.

iv. Survey information: If you complete surveys or provide feedback on the app, we collect those responses to improve our services.

v. Communication information: We may collect the content of your communications with us, such as emails, chats, or support requests.

(b) Information from others

i. If your access to My 12-Step Coach is sponsored by a third party (e.g., an employer), we may collect relevant information from them to facilitate your access.

ii. We may also collect referral information if you share the app with others.

i. Our Platform may automatically collect device information, such as IP address, device type, and usage data (e.g., pages visited and features used).

(d) Aggregated and de-identified data

i. We may aggregate and anonymise personal information to generate statistics and insights for improving our Platform. De-identified data is not subject to this Privacy Policy. De-identified data means data that has been stripped of all personal identifiers and cannot be linked to any individual.

2. Use of personal information

(a) Payment-related data is processed under Article 6(1)(b) (contractual necessity) and Article 6(1)(c) (compliance with legal obligations such as tax law). Payments are handled securely by Apple or Google. We do not process or store payment card details directly. For more information, see Apple’s Privacy Policy and Google’s Privacy Policy. We may use your personal information in the following ways:

i. To provide and maintain the app’s functionality, including content delivery and interactive features;

ii. To communicate with you about updates, changes, new features, or relevant offers;

iii. To process payments, manage subscriptions, and account for taxes;

iv. To provide support, handle requests or complaints, and improve user experience through trend and feedback analysis;

v. To ensure the security of the Platform, detect fraud, and maintain a trusted environment;

vi. To comply with legal obligations and respond to legal processes.

vii. We do not use your personal information for advertising or targeted marketing purposes.

3. Sharing of personal information

(a) Sensitive personal information, such as sobriety dates or emotional check-ins, is used solely for the purposes outlined above, including tracking progress and improving user experience. We process analytics and crash data either based on your consent or, where appropriate, under our legitimate interest (Article 6(1)(f)) to maintain and improve our Platform. You may opt out via settings. We do not use sensitive personal information for marketing or advertising purposes. We may share your personal information in the following circumstances:

i. Service Providers: We may share your personal information with trusted third-party service providers who perform essential functions necessary to operate our Platform. These providers include:

· Cloud hosting services to securely store your data and ensure that it is accessible across your devices.

· Payment processors to handle transactions securely. We do not store your payment information; it is processed directly by these third-party services.

· Analytics providers to help us understand how users interact with the app and improve functionality. This data is anonymised wherever possible.

· Email and communication services to send you updates and notifications about the app.

· All third-party providers are contractually obligated to use your data only for the purpose of performing these specific functions and must comply with applicable privacy laws and regulations.

ii. Compliance with Legal Obligations: If required by law or legal process, we may disclose personal information in response to a court order, subpoena, or other legal requests.

iii. Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the new entity. We will notify you of any such changes that impact the handling of your data.

4. Data security and retention

(a) The security of your personal information is a top priority for us. We implement industry-standard practices, including technical, administrative, and physical safeguards, to protect your data from unauthorised access, loss, or misuse.

(b) While we strive to protect your data, no system can be guaranteed 100% secure. If you suspect any unauthorised use of your account or data, please contact us immediately at security@ensoventures.com.

(c) We retain your personal information as long as necessary to fulfil our obligations to you or to meet legal requirements. Our retention periods are based on factors such as the duration of our relationship with you, legal obligations, and any pending litigation or investigations. For example, we retain your account information (such as name, email address, and password) for as long as your account is active. When you delete your account, all associated personal data is permanently and irreversibly deleted. We may retain fully anonymised, non-identifiable data for statistical or research purposes, provided it cannot be linked back to any individual.

5. Your privacy rights

(a) You have control over your personal information and are entitled to certain rights, including:

i. Access: You can request a copy of the personal information we hold about you.

ii. Correction: You may correct your personal information (such as name, email, and sobriety date) at any time via the settings in the app.

iii. Portability: You can request your personal information in a machine-readable format (e.g., CSV) and, where feasible, transfer it to a third party.

iv. Deletion: Under certain circumstances, you may request the deletion of your personal information.

v. Restriction: You can request the restriction of your data's use in certain cases.

vi. No retaliation or discrimination: You have the right to exercise these rights without facing any retaliation or discrimination.

vii. Objection: You may object to the processing of your personal information where we rely on legitimate interests as a legal basis (e.g., anonymous analytics). If you object, we will stop processing unless we demonstrate compelling legitimate grounds.

(b) To exercise any of these rights, please contact us at privacy@ensoventures.com. We aim to respond to requests promptly and will notify you if additional information is needed. Some exceptions may apply, including legal obligations and the need to verify your identity. There is generally no fee to process requests unless excessive or unfounded.

6. Children’s privacy

(a) My 12-Step Coach is intended for users aged 18 and over. We do not knowingly collect personal information from individuals under 18. If you believe a child has provided us with personal information without parental consent, please contact us at privacy@ensoventures.com, and we will take appropriate action to remove the data.

7. Cookies

(a) When you visit our website or app, we may collect information through cookies and similar tracking technologies. These cookies are used for functionality, performance analytics, and security, as well as to personalise content. We do not use cookies or other tracking technologies for marketing or advertising purposes.

(b) You may opt out of anonymous analytics and crash reporting at any time through the app’s settings. This supports your right to object under Article 21 of the GDPR.

8. Changes

(a) This Privacy Policy is effective as of the date indicated at the top. We may update this policy to reflect changes in our services, data practices, or legal requirements. Significant updates will be communicated through the app or website, or via the email you provided upon registration.

We encourage you to periodically review this policy to stay informed about how we handle your personal information.

9. Contact us

(a) If you have any questions or concerns about this Privacy Policy, or wish to exercise your privacy rights, please contact us at privacy@ensoventures.com.

10. Supplemental Notices

(a) Depending on your jurisdiction, you may have additional rights related to your personal information under local privacy laws. We provide this section to comply with those laws and inform you of your rights. If your jurisdiction is not listed below, it does not imply a lack of respect for your privacy. Please contact us with any questions or concerns at privacy@ensoventures.com.

(b) Privacy Notice for the European Union (EU) and the United Kingdom (UK): Enso Ventures S.à r.l.-S is the data controller responsible for your personal information under the GDPR. We comply with the General Data Protection Regulation (GDPR) for users in the EU and UK. As data controllers, we ensure that your personal information is processed in accordance with the GDPR’s requirements.

(c) Data Transfers: Some of our service providers (such as Google, for Firebase services) may process data outside the EU. We rely on the EU-U.S. Data Privacy Framework and other legally valid mechanisms for such transfers.

(d) Legal basis for processing: We process your personal information based on one or more legal bases, including your consent, the need to fulfill contractual obligations, or our legitimate business interests. For example, we rely on Article 6(1)(b) of the GDPR (“performance of a contract”) to process personal data necessary to provide our core services, including account creation and access to personalised features.

(e) Your GDPR rights: If you are an EU or UK resident, you have specific rights, including the right to access, correct, delete, or restrict the use of your personal information. You can also lodge a complaint with your local supervisory authority if you believe your rights have been violated.

(f) Privacy Notice for United States (US) Residents: We comply with privacy laws in California, Virginia, Connecticut, Colorado, Utah, and Nevada. Although privacy laws differ slightly by state, you are generally entitled to the following rights:

i. Right to Know and Access: You have the right to know what personal information we collect and how it is used.

ii. Right to Delete: You may request the deletion of your personal information under certain circumstances.

iii. Right to Correct: You can request corrections to inaccurate or outdated personal information.

iv. Right to Opt-Out: You can opt out of the sale or sharing of your personal information, although we do not sell your data for monetary gain. In some states, you may also opt out of targeted advertising or profiling (though we do not use profiling).

v. Right to Non-Discrimination: You will not face discrimination for exercising your privacy rights.

For more detailed information on how to exercise your rights, or to submit requests, please contact us at privacy@ensoventures.org.