🔐 PRIVACY POLICY

VitaAvanza

Last updated: [20/01/2026]

1. Introduction

VitaAvanza (“we”, “our”, “us”) is committed to protecting your privacy and handling your personal data in a transparent, fair, and lawful manner.

This Privacy Policy explains:

• what data we collect,
• why we collect it,
• how it is used,
• how long it is retained,
• and the rights you have under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

VitaAvanza is designed as a consent-first life-navigation platform. No personal data is processed without a clear purpose and user control.

2. Data Controller

The data controller is:

VitaAvanza

Contact email: hello@vitaavanza.com

(Company legal details may be added here when finalized.)

3. Personal Data We Collect

We only collect data that is necessary to provide the service.

Depending on how you use VitaAvanza, we may collect:

4. What We Do Not Collect

To be explicit, VitaAvanza does not:

• act as a bank or financial institution
• collect credit scores by default
• make medical diagnoses
• make automated legal or financial decisions
• share your data with third parties without your consent

5. Purpose of Processing

We process personal data for the following purposes:

• to provide and operate the VitaAvanza platform
• to generate guidance, next actions, and plans requested by the user
• to compute and display the Development Value Index (DVI)
• to ensure system security and integrity
• to comply with legal obligations
• to improve the quality and reliability of the service

Each processing activity is linked to a specific and explicit purpose.

6. Legal Basis for Processing (GDPR)

Under GDPR, we rely on the following legal bases:

• Consent (Art. 6(1)(a)) — where you explicitly agree to specific processing
• Contractual necessity (Art. 6(1)(b)) — to provide the service you request
• Legal obligation (Art. 6(1)(c)) — where required by law
• Legitimate interest (Art. 6(1)(f)) — for security, fraud prevention, and service reliability (balanced against your rights)

You may withdraw consent at any time.

7. Consent Management

VitaAvanza uses a granular consent model:

• No data is shared by default
• Consent can be granted, limited, or revoked
• Revocation does not affect lawfulness of prior processing

You can manage consent directly within the platform.

8. Data Sharing

We do not sell personal data.

Data may be shared only:

• with your explicit consent
• with service providers acting under strict data-processing agreements
• when legally required by authorities

Institutions accessing aggregated or mediated information do so only within the scope of explicit consent.

9. Automated Processing & Profiling

VitaAvanza uses automated systems to:

• generate structured guidance
• compute DVI indicators

These processes:

• are explainable
• do not produce legal or similarly significant effects on their own
• always allow human interpretation and contestability

10. Data Retention

We retain personal data only as long as necessary for the stated purposes.

You may:

• delete your account
• request data export
• request erasure (subject to legal obligations)

11. Your Rights (GDPR)

You have the right to:

• access your data
• rectify inaccurate data
• request erasure
• restrict processing
• data portability
• object to processing
• lodge a complaint with a supervisory authority

Requests can be sent to: hello@vitaavanza.com

12. Security Measures

We apply appropriate technical and organizational measures to protect data, including:

• access controls
• encryption where appropriate
• audit logging
• regular security reviews

No system is risk-free, but security is treated as a core design principle.

13. International Transfers

If data is transferred outside the EU, appropriate safeguards are applied in accordance with GDPR.

14. Changes to This Policy

We may update this Privacy Policy to reflect legal or operational changes.

Users will be notified of material changes.

15. Contact

For any privacy-related questions: hello@vitaavanza.com