Privacy Policy

The controller of personal data is A&I SOLUTIONS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, registered in Poland at UL. KOŁO 67, 20-508 LUBLIN, POLSKA.

For questions regarding privacy, personal data, account deletion, withdrawal of consent, and exercise of user rights, you may contact:

• legal and privacy inquiries: office@navia.land;
• user support: info@navia.land.

This Policy applies to NAVIA users in Ukraine, the European Union, the United Kingdom, the United States, and other countries where the service is available, subject to mandatory requirements of applicable local law.

NAVIA is intended only for users aged 18+. The service is not intended for children or minors. If NAVIA learns that an account was created by a person under 18 or below the age of majority in their jurisdiction, such account may be restricted or deleted.

In connection with the purchase and use of tokens, digital gifts, consumable features, and voluntary NAVIA support, NAVIA may also process information about purchased token packages, token balance, token accrual and spending history, activated features, sent and received digital gifts, voluntary support status, payment amount, currency, payment method, transaction identifiers, refunds, disputed payments, and technical payment metadata.

NAVIA does not treat internal tokens as money, cryptocurrency, electronic money, or a means of payment. Token data is processed as data about the service's internal digital functionality and the user's payment history.

NAVIA may process the following categories of data if the user provides them, they are created through use of the service, or they are necessary for NAVIA features to operate.

NAVIA is a dating and communication platform focused on values, serious relationships, and compatibility. The user may voluntarily provide information about faith, denomination, spiritual values, and related preferences.

Such information may constitute special categories of personal data or sensitive data in some jurisdictions. NAVIA processes such data only with the user's voluntary and explicit consent where such consent is required by applicable law.

The user understands and agrees that voluntarily provided faith/denomination information may be displayed to other users in the profile, used for compatibility search, recommendations, filters, and NAVIA features. The user may delete or change such information in the profile or withdraw consent through settings or by contacting support.

NAVIA may use precise geolocation if the user has granted permission at the device or application level. Geolocation is used to find relevant users, display distance or proximity, and improve compatibility and service safety.

NAVIA must not display the user's exact coordinates to other users. The interface may show approximate distance, city, region, location relevance, or other generalized information where provided by service features.

The user may disable geolocation in device or application settings. If geolocation is disabled, some NAVIA features may be unavailable or less accurate.

NAVIA provides chats and private messages. Under the current service model, voice messages, video calls, and attachments/photos in chat are not provided.

NAVIA does not claim to manually read all private messages on an ongoing basis. However, authorized staff or moderators may access correspondence and related materials if the user submits a complaint, a dispute arises, there is suspicion of a rules violation, fraud, a safety threat, a technical necessity, or a lawful request from a competent authority.

At the time of preparation of this version, automatic/AI moderation is not stated as an active feature. If NAVIA implements automatic moderation in the future, this Policy may be updated.

NAVIA may use intelligent systems to analyze profiles, preferences, compatibility, recommendations of potential partners, and communication advice.

NAVIA's AI features are auxiliary and informational in nature. They do not guarantee compatibility, relationships, reciprocity, meetings, marriage, or any other specific outcome. The user independently decides on communication, disclosure of information, meetings, and relationships.

If external technical providers are used for AI features, NAVIA must apply contractual and organizational data protection measures, including limiting processing purposes and confidentiality measures.

• creating, verifying, and maintaining the user account;
• operating the profile, questionnaire, search, matches, recommendations, and chats;
• displaying the profile and voluntarily provided information to other users;
• using geolocation for search, distance, relevance, and safety;
• operating AI profile analysis, AI recommendations, and AI communication advice;
• processing premium subscriptions, auto-renewal, boosts, purchase and use of tokens, digital gifts, consumable features, re-display, and account top placement;
• processing payments, receipts, refunds, voluntary NAVIA support, disputed payments, anti-fraud checks, and interaction with payment providers;
• user support, complaint handling, moderation, and safety;
• preventing fraud, abuse, spam, fake accounts, and rules violations;
• sending service notifications, emails, Telegram messages, and push notifications;
• marketing messages and advertising where permitted by law and user settings;
• analytics, service improvement, testing, bug fixes, and product development;
• fulfilling legal, tax, accounting, and regulatory obligations;
• protecting the rights, interests, users, and lawful requirements of NAVIA.

Where GDPR, UK GDPR, or similar rules apply to processing, NAVIA relies on one or more legal bases for processing: performance of a contract, consent, explicit consent for special categories of data, legitimate interest, compliance with a legal obligation, and protection of legal claims.

NAVIA may disclose data only to the extent necessary for operation of the service, payment, safety, support, analytics, advertising, compliance with law, or protection of rights.

NAVIA must not sell personal data in the ordinary sense of a sale for money. If in the future advertising or analytics technologies are considered a "sale" or "transfer/sharing" of data under applicable law, NAVIA must provide users with legally required notices and opt-out mechanisms.

• payment providers, app stores, and payment infrastructure operators, including Stripe, Apple, Google, and other payment systems, where necessary for payment, subscriptions, tokens, voluntary support, refunds, disputed payments, and anti-fraud;
• hosting, cloud infrastructure, database, storage, and technical support providers;
• email, push notification, Telegram communication, and customer support providers;
• AI technology providers where used for profile analysis, recommendations, and advice;
• moderators, support staff, and authorized contractors where needed for complaints, safety, and support;
• analytics, advertising, and marketing tool providers where such tools are used and permitted by law;
• lawyers, auditors, accountants, consultants, and insurance organizations;
• government authorities, courts, law enforcement, or regulators where disclosure is required by law;
• potential successors in reorganization, sale of business, merger, investment transaction, or transfer of assets, subject to applicable data protection requirements.

Data about tokens, token balance, spending history, digital gifts, and voluntary support is used to correctly provide features, support users, accounting, fraud prevention, refund handling, and protection of NAVIA's rights.

Digital gift data may be visible to the sender, recipient, and, in limited cases, authorized NAVIA staff where necessary for operation of the feature, support, complaint handling, safety, or legal compliance.

Voluntary NAVIA support is processed as a payment in favor of the NAVIA project. NAVIA may retain information about such payment for accounting, tax purposes, payment confirmation, fraud prevention, and communication with the user regarding support.

NAVIA may offer a premium subscription with monthly auto-renewal, purchase of internal tokens, boosts, re-display, account top placement, digital gifts, consumable features, voluntary project support, and other one-time paid features.

Payments may be processed through Stripe, Apple, Google, bank cards, and other available payment methods. NAVIA receives information necessary to confirm payment, manage subscriptions, accrue and spend tokens, provide digital gifts and consumable features, process voluntary support, refunds, and tax and accounting records: transaction identifier, payment status, product type, amount, currency, payment date, tariff, subscription term, refund information, disputed payment status, and technical payment metadata.

Full bank card data is generally processed by the payment provider or app store. NAVIA must not store full card data unless such processing is supported by separate lawful, technical, and certified infrastructure.

NAVIA may use advertising, manual analytics, technical logs, cookies, pixels, device identifiers, and similar technologies on the website and in the application where necessary for operation of the service, safety, measuring effectiveness, product improvement, or marketing.

If NAVIA implements third-party analytics or advertising tools, information about such tools, processing purposes, data categories, and consent/opt-out mechanisms must be disclosed in the Cookie Policy, application settings, or a separate notice.

For users in regions where prior consent is required for non-essential cookies, advertising, or tracking, NAVIA must request such consent before using the relevant technologies.

NAVIA is globally accessible, and technical providers, payment providers, app stores, support services, messaging services, AI, analytics, and hosting may be located in different countries.

If data is transferred outside the European Economic Area, the United Kingdom, Ukraine, or another applicable jurisdiction, NAVIA applies available legal mechanisms for data transfers, including processor agreements, standard contractual clauses, additional security measures, adequacy decisions, or other lawful grounds where required by applicable law.

Information about payments, subscriptions, token purchases, token balance, token spending, digital gifts, voluntary support, refunds, and disputed payments may be retained for as long as necessary to provide features, accounting and tax records, fraud prevention, handling of claims, and compliance with applicable law.

NAVIA retains personal data no longer than necessary for the purposes described in this Policy, unless longer retention is required by law, accounting obligations, safety, investigation of violations, dispute resolution, or protection of legal claims.

The user may request deletion of the account and related data through application settings, the website, or by contacting support at info@navia.land.

After account deletion, the profile ceases to be available to other users, except for technical delays, backups, and cases where retention of certain data is necessary for compliance with law, payments, safety, investigation of violations, disputes, or protection of the rights of NAVIA and other users.

Depending on the user's country of residence and applicable law, the user may have the right to:

To exercise their rights, the user may contact office@navia.land or info@navia.land. NAVIA may request additional information to verify the user's identity and protect the account from unauthorized access.

• obtain confirmation of processing and access to their personal data;
• rectify inaccurate or incomplete data;
• delete data or the account;
• restrict processing of data;
• receive a copy of data in a portable format, where applicable;
• object to processing based on legitimate interest;
• withdraw consent without affecting the lawfulness of processing before withdrawal;
• opt out of marketing messages;
• lodge a complaint with a competent data protection authority.

If California or other U.S. privacy laws apply to NAVIA, the user may have additional rights: to know what categories of personal information are collected, used, and disclosed; to request deletion or correction of data; to receive a copy of data; to opt out of sale or certain sharing of personal information; and to limit use of sensitive information where such right applies.

NAVIA must not discriminate against the user for exercising privacy rights unless otherwise permitted by law. If certain features are impossible without the relevant data, they may become unavailable or operate in a limited manner after deletion of data, withdrawal of consent, or disabling of processing.

NAVIA may use automated processing and profiling for recommendations, compatibility search, personalization, safety, and service improvement. Such features are intended to assist the user and do not constitute a decision that by itself produces legal effects for the user.

The user understands that recommendations and compatibility assessments are probabilistic and auxiliary. NAVIA does not guarantee the accuracy, completeness, psychological, spiritual, or life suitability of recommendations.

NAVIA applies reasonable technical and organizational measures to protect personal data, including access controls, limitation of employee and contractor rights, secure data transmission, logging, backup, measures against abuse, fake accounts, and unauthorized access.

No online service can guarantee absolute security. The user must protect their login credentials, not share their password with third parties, and exercise caution when communicating with other users.

NAVIA may send the user service messages related to the account, safety, payments, subscription, document changes, complaints, moderation, technical notices, and operation of the service.

NAVIA may also send marketing or informational emails, Telegram messages, and push notifications if the user has given consent or if such messaging is permitted by applicable law. The user may opt out of marketing messages through settings, an unsubscribe link, or by contacting support. SMS messaging is not stated as part of the current service model.

NAVIA is intended exclusively for users aged 18+. NAVIA is not intended for children and is not directed at collecting data from minors. If a user believes a minor has created an account or provided data to NAVIA, they should report this to support.

NAVIA may update this Policy at any time. Non-material changes may take effect without separate personal notice. Material changes may be communicated to users through the website, application, email, push notification, or another available method.

Continued use of NAVIA after the updated Policy takes effect constitutes the user's acknowledgment of the current version, unless otherwise required by applicable law. If separate consent is required for new processing, NAVIA must request such consent separately.

For all questions regarding privacy, data processing, account deletion, withdrawal of consent, complaints, and exercise of user rights, you may contact:

• A&I SOLUTIONS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
• UL. KOŁO 67, 20-508 LUBLIN, POLSKA
• Legal and privacy inquiries: office@navia.land
• User support: info@navia.land

This Policy has been prepared taking into account the following regulatory references and industry requirements. Before public launch, the document should be reviewed by local counsel with regard to NAVIA's actual architecture, contractors used, payment model, and launch countries.

• General Data Protection Regulation (Regulation (EU) 2016/679): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679
• European Commission — Digital Services Act: https://digital-strategy.ec.europa.eu/en/policies/digital-services-act
• California Attorney General — CCPA: https://oag.ca.gov/privacy/ccpa
• ICO — Special category data under UK GDPR: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-lawful-basis/special-category-data/
• European Data Protection Board — Guidelines 05/2020 on consent under GDPR: https://www.edpb.europa.eu/our-work-tools/our-documents/guidelines/guidelines-052020-consent-under-regulation-2016679_en
• Apple Developer — App Privacy Details: https://developer.apple.com/app-store/app-privacy-details/
• Google Play — User Data policy / privacy policy requirements: https://support.google.com/googleplay/android-developer/answer/10144311
• Stripe — Data Processing Agreement: https://stripe.com/legal/dpa