Levly / Privacy Policy

Levly Privacy Policy

Effective date: 1 September 2026

This Privacy Policy explains how Neave Labs (“we”, “us”) handles personal data in connection with the Levly mobile app and the website https://www.levly.co. We are established in the Netherlands, so the EU General Data Protection Regulation (GDPR / AVG) applies. This policy is written to stay consistent with Levly’s App Store privacy labels and Google Play Data Safety information.

1. Who we are

The controller for Levly personal data is Neave Labs, registered with the Kamer van Koophandel (KvK) under number 87172992.

Company: Neave Labs
Legal form: Eenmanszaak (sole proprietorship)
Country: The Netherlands
Address: Lark 6, 8446 PL Heerenveen, The Netherlands
Email: support@levly.co
KvK: 87172992 (Kamer van Koophandel (KvK))
VAT (btw): NL004368463B43

Privacy requests: support@levly.co.

2. Information we collect

What we process depends on how you use Levly. For the Levly product, that can include:

Account information — identifiers used to create or sign in, such as an email address or an Apple or Google sign-in identifier if those options are available in the production app.
Profile information — details you choose to add, such as a display name or avatar.
Habit and Task data — habits, tasks, schedules, completion history and related notes you create.
Reward and progress data — XP, Coins, streaks, achievements, Personal Rewards, league standing and similar progress information.
Subscription status — whether you have an active trial or paid subscription, the store it was purchased through, and related entitlement information. Payment card details are handled by Apple or Google, not by Levly.
Notification tokens — a device token used to send reminders you request, if notifications are enabled.
Device and application information — technical information needed to run and secure the app, such as app version, device type and operating system.
Support communications — information you send when you contact us, including account deletion requests from this website.

This website does not require cookies for core functionality and does not include advertising or analytics trackers. If analytics or non-essential cookies are added later, this policy and any required consent notices will be updated first.

This list reflects Levly’s current product. It will be reviewed against the production app, Apple App Privacy labels and Google Play Data Safety information, and updated if those differ.

3. How we use information and legal bases

We only process personal data when a GDPR legal basis applies. For Levly, that is typically:

Contract (GDPR art. 6(1)(b)) — to create and manage your account, provide Habits, Tasks, rewards and progress features, sync your data, send reminders you request, and check subscription entitlement.
Legal obligation (GDPR art. 6(1)(c)) — to keep records we must retain under Dutch tax, accounting or other law, and to handle privacy requests.
Legitimate interests (GDPR art. 6(1)(f)) — to keep Levly secure, prevent abuse, answer support messages, and operate this website. You may object to processing based on legitimate interests.
Consent (GDPR art. 6(1)(a)) — where we ask for it, for example optional notifications on some devices. You can withdraw consent at any time without affecting processing that already took place.

We do not sell your personal data and we do not use it for third-party advertising.

4. Service providers / third parties

We use service providers that process data on our instructions, and app stores that handle distribution and billing:

Supabase — Authentication, database and backend infrastructure for accounts, Habits, Tasks, rewards and progress data
RevenueCat — Subscription status, entitlements and App Store / Google Play purchase receipts
Superwall — In-app paywalls and subscription offers
Hostinger — Hosting of this website and the support@levly.co mailbox
Apple — App distribution and in-app subscription billing when you subscribe through the App Store
Google — App distribution and in-app subscription billing when you subscribe through Google Play

This list will be updated if production providers change. Superwall, RevenueCat and some Apple/Google processing may take place outside the EEA; see section 11.

5. Data sharing

We share personal data only when needed to operate Levly, including:

with service providers who process data on our instructions
with Apple or Google for app distribution and subscription billing. They act as independent controllers for store accounts and payments
if required by law, a valid legal request, or to protect users and the service
in connection with a business transfer, if Neave Labs is involved in one, with appropriate safeguards

6. Data security

We use reasonable technical and organisational measures to protect personal data, such as access controls and encrypted connections where appropriate. No method of transmission or storage is completely secure. We cannot promise that information will never be accessed without authorisation.

7. Data retention

We keep personal data for as long as your account is active. After deletion or closure, we keep data only as long as needed to finish the request, resolve disputes, or meet legal duties. Dutch tax law can require us to keep certain financial records for up to seven years. When data is no longer needed, we delete or de-identify it.

8. Account and data deletion

You can request erasure of your Levly account and associated personal data under GDPR art. 17. How to do that is explained here, not only inside the app:

Delete your Levly account

After we verify the request, we delete associated personal data except information we are legally required to retain. We handle verified requests without undue delay and within one month, unless the GDPR allows a longer period. Deleting your account does not necessarily cancel an Apple or Google Play subscription. See Manage or cancel your subscription.

9. Your rights

Under the GDPR you may, where the conditions apply:

access the personal data we hold about you
rectify inaccurate data
erase data (including via the account deletion page)
restrict or object to certain processing
receive data you provided in a portable format (data portability)
withdraw consent where processing is based on consent
lodge a complaint with a supervisory authority

For Levly, the lead supervisory authority is the Autoriteit Persoonsgegevens . If you live in another EU/EEA country, you may also complain to your local authority.

To make a request, use the account deletion page or email support@levly.co. We may need to verify your identity before completing a request.

10. Children’s privacy

In the Netherlands, the age at which a child may consent to information society services is 16 (GDPR art. 8). Levly is not directed at children under 16. If you are in the EEA and under 16, you may use Levly only with a parent or guardian. App Store and Google Play age ratings describe content suitability only; they do not replace this rule. Levly is not in the Apple or Google kids categories. The intended App Store content rating is 4+ and describes content only. If you believe we have collected personal data from a child under 16 without appropriate authorisation, contact us and we will take appropriate steps.

11. International users and data transfers

Neave Labs is established in The Netherlands. Personal data may be processed in the EEA and, where a provider is located elsewhere, in other countries. Where we transfer personal data outside the EEA, we use an appropriate safeguard, such as an adequacy decision or the European Commission’s Standard Contractual Clauses, unless a GDPR exception applies. Apple and Google may process subscription and account data in the United States and other countries under their own terms and privacy policies.

12. Changes to this Privacy Policy

We may update this policy as Levly or the law changes. The effective date above will be updated when we do. If a change is material, we may also provide notice in the app or on this website. Where the law requires consent for a new use of data, we will ask for it.

13. Contact

Company: Neave Labs
Legal form: Eenmanszaak (sole proprietorship)
Country: The Netherlands
Address: Lark 6, 8446 PL Heerenveen, The Netherlands
Email: support@levly.co
KvK: 87172992 (Kamer van Koophandel (KvK))
VAT (btw): NL004368463B43