Last updated: October 2025

Acua.app (“Acua”, “we”, “our”, or “us”) is operated by Hawkrel Inc., a technology company based in Switzerland.

This Privacy Policy explains how we collect, use, store, and protect personal information when you use the Acua mobile application, our website (acua.app), or any related services (collectively, the “Services”).

By using Acua, you agree to this Policy. If you do not agree, please do not use our Services.

1. Who We Are

Data Controller:

Hawkrel Inc.

[Insert registered address, Switzerland]

Contact email: privacy@acua.app

Hawkrel Inc. is responsible for ensuring that your personal data is processed in accordance with applicable laws, including the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR) where relevant.

2. Information We Collect

Acua is designed around user consent and transparency. We collect only what is necessary to provide our services and reward mechanisms.

(a) Information you provide voluntarily

• Account details (name, email address, optional profile photo)
• Verification data (if you choose to verify your identity for eligibility or compliance purposes)
• Survey responses or feedback you submit voluntarily

(b) Information collected automatically (with consent)

• Device data (model, operating system, language, app version)
• Usage data (app activity statistics, screen time patterns, interaction events)
• Optional “data programs” metrics (if you opt in to participate in specific reward initiatives)

All such data is anonymized or aggregated whenever possible before analysis.

(c) Cookies and similar technologies

On our website, we may use essential and analytics cookies to ensure functionality and improve user experience. You can manage cookie preferences via your browser settings.

3. How We Use Your Information

We use the information we collect to:

1. Operate and improve the Acua app and website
2. Provide personalized dashboards and reward tracking
3. Administer optional data programs and deliver rewards
4. Maintain security and detect fraud or misuse
5. Comply with legal obligations and audit requirements
6. Communicate service updates or policy changes

We do not sell, trade, or rent your personal data to any third parties.

4. Legal Basis for Processing (EU/EEA & Switzerland)

We process personal data only where one of the following applies:

• Your consent (e.g., joining a data program or newsletter)
• Contractual necessity (to deliver core app features)
• Legitimate interest (e.g., improving service functionality or security)
• Legal obligation (where applicable under financial or data laws)

You may withdraw consent at any time through in-app settings or by contacting privacy@acua.app.

5. Data Storage & Security

• Data is stored on secure, encrypted servers operated by reputable providers within the EU and/or Switzerland.
• We use industry-standard encryption and access controls to prevent unauthorized access.
• Only authorized personnel may access identifiable user data, and solely for legitimate service operations.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described above or as required by law.

You can request data deletion at any time via the app or email contact.

7. Data Sharing & Third-Party Processors

We may share limited data with trusted partners who process it on our behalf (e.g., cloud hosting, analytics, email delivery).

All partners are bound by data-processing agreements ensuring confidentiality and security.

We never share data for marketing purposes without explicit consent.

8. International Data Transfers

If data is transferred outside Switzerland or the EEA, we ensure adequate protection through Standard Contractual Clauses or equivalent legal safeguards.

9. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access a copy of your data
• Request correction or deletion
• Restrict processing or object to certain uses
• Port your data to another service
• Withdraw consent without affecting past processing

To exercise these rights, email privacy@acua.app.

We will respond within 30 days.

10. Children’s Privacy

Acua is intended for users aged 16 and above.

We do not knowingly collect data from children under 16. If we learn we have done so, we will promptly delete such information.

11. Links to Other Sites

Our website or app may contain links to external sites or partners. We are not responsible for the privacy practices of those sites. Please review their policies independently.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect operational or legal changes. The “last updated” date indicates the latest revision.

Material changes will be notified via email or in-app notice.

13. Contact Us

For questions, requests, or concerns about this Policy or your data, please contact:

Hawkrel Inc.

Email: privacy@acua.app

Website: https://acua.app