Legal

Privacy Policy

Last updated December 21, 2025.

This Privacy Notice for Progio ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

- Visit our website at https://www.progio.io (or any website of ours that links to this Privacy Notice)
- Use our AI-powered habit tracking app (a website used for tracking progress)
- Engage with us in other related ways, including any marketing or events

Questions or concerns?
Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.
If you still have any questions or concerns, please contact us at support@progio.io.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below.

- What personal information do we process?
  When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
  Learn more: Personal information you disclose to us.

- Do we process any sensitive personal information?
  Some information may be considered "special" or "sensitive" in certain jurisdictions (for example: racial or ethnic origins, sexual orientation, religious beliefs).
  We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
  Learn more: Sensitive information we process.

- Do we collect any information from third parties?
  We do not collect any information from third parties.

- How do we process your information?
  We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
  We may also process your information for other purposes with your consent.
  Learn more: How we process your information.

- In what situations and with which parties do we share personal information?
  We may share information in specific situations and with specific categories of third parties.
  Learn more: When and with whom we share your personal information.

- How do we keep your information safe?
  We have organisational and technical processes and procedures in place to protect your personal information.
  However, no electronic transmission or storage can be guaranteed 100% secure.
  Learn more: How we keep your information safe.

- What are your rights?
  Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
  Learn more: Your privacy rights.

- How do you exercise your rights?
  The easiest way to exercise your rights is by visiting https://www.progio.io/accounts/account/ or by contacting us.
  We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect?
Review the Privacy Notice in full below.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.
The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

- Names
- Email addresses

Sensitive Information.
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

- Images

Payment Data.
We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument.
All payment data is handled and stored by Stripe.
Stripe privacy notice: https://stripe.com/en-lt/privacy

Social Media Login Data.
We may provide you with the option to register with us using your existing social media account details. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Google API
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements:
- https://developers.google.com/terms/api-services-user-data-policy
- https://developers.google.com/terms/api-services-user-data-policy#limited-use

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short:
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

- To facilitate account creation and authentication and otherwise manage user accounts.
  We may process your information so you can create and log in to your account, as well as keep your account in working order.

- To save or protect an individual's vital interest.
  We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

AI-related data categories (as referenced in this policy):
- Images (for AI insights)
- Progress (for AI insights)

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short:
We only process your personal information when we believe it is necessary and we have a valid legal reason (legal basis) to do so under applicable law, such as: consent, compliance with laws, contractual obligations, protection of rights, or legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. We may rely on:

- Performance of a Contract.
  We may process your personal information when necessary to fulfil our contractual obligations to you.

- Legal Obligations.
  We may process your information where necessary for compliance with legal obligations.

- Vital Interests.
  We may process your information where necessary to protect your vital interests or the vital interests of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short:
We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.
We have contracts in place with our third parties designed to help safeguard your personal information.

Categories of third parties we may share personal information with include:
- Data Storage Service Providers

We may also need to share your personal information in the following situations:
- Business Transfers.
  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short:
We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies ("AI Products").

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI.
As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in this Privacy Notice.
You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products are designed for the following functions:
- AI insights

How We Process Your Data Using AI
All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreement with third parties.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short:
If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services may offer the ability to register and log in using third-party social media account details.
Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the provider, but will often include:
- Your name
- Email address
- Profile picture
- Other information you choose to make public

We will use the information we receive only for the purposes described in this Privacy Notice or as otherwise made clear to you on the relevant Services.
We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:
We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or securely store it and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:
We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.
However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.
You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short:
We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information.
If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data.
If you become aware of any data we may have collected from children under age 18, please contact us at support@progio.io.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:
In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include:
- Request access and obtain a copy of your personal information
- Request rectification or erasure
- Restrict the processing of your personal information
- Data portability (if applicable)
- Not be subject to automated decision-making

In certain circumstances, you may also have the right to object to the processing of your personal information.

To make such a request, contact us using the details in "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

Complaints:
- EEA: Member State data protection authority: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
- UK: UK data protection authority: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/
- Switzerland: Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/en/home.html

Account Information:
If you would like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@progio.io.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate.
At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short:
Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice.
If we make material changes, we may notify you by prominently posting a notice or by directly sending you a notification.
We encourage you to review this Privacy Notice frequently.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@progio.io.

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.
These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please visit:
https://www.progio.io/accounts/account/