Privacy Policy
Version 1.0 — Last updated: 17 April 2026 — Effective: 17 April 2026
1. Controller & Contact
The data controller for personal data processed through our services is:
MYSOVA LTD
Company number: 17154283
Registered in England and Wales
Registered office: London, United Kingdom (provided by our company secretary service; full address available on the Companies House public register)
Data protection enquiries: privacy@mysova.co.uk
Designated data protection contact: Pavel Vassiltsenko (Director)
ICO registration: Filed April 2026 (registration number to be added once issued)
Throughout this policy, "MYSOVA", "we", "us", and "our" refer to MYSOVA LTD. "You" and "your" refer to the individual using our services, whether as a consumer or venue owner.
Data Protection Officer. MYSOVA LTD has fewer than 250 employees and does not carry out large-scale processing of special-category data or systematic monitoring on a scale that triggers the statutory obligation under UK GDPR Article 37 to appoint a Data Protection Officer. The Director acts as the accountable owner for data protection and is the contact point for all enquiries.
2. Scope
This privacy policy applies to all personal data processed through:
- MYSOVA App — our consumer mobile application for nightlife discovery, check-ins, and social features (iOS and Android)
- MYSOVA Business — our web-based dashboard for venue owners to manage analytics, events, promotions, and operations
- mysova.co.uk — our marketing website and landing pages
- Support channels — email, in-app support, and any other channels through which you contact us
This policy does not cover third-party websites or services linked from our platform. We encourage you to review the privacy policies of any third party you interact with.
3. Eligibility
MYSOVA is a nightlife platform. All users must be aged 18 or over to create an account or use our services. We enforce this through an age gate at signup and reserve the right to verify your age at any time. If we discover that an account belongs to someone under 18, we will terminate it immediately and delete all associated personal data.
4. Data We Collect
We collect the following categories of personal data, depending on how you use our services:
Account Data
Full name, email address, phone number, date of birth, profile photo, and authentication credentials. Collected at registration and maintained throughout your account lifecycle.
Location Data
Precise GPS coordinates when you perform check-ins at venues, and approximate location for venue discovery. Dwell time at venues is calculated from check-in/check-out events. Location data is collected only when the app is in active use and you have granted location permission.
Social & Activity Data
Check-in history, Paths connections (mutual opt-in social connections), direct messages between connected users, block/report actions, XP and level progression, and achievements.
Payment Data
Payment processing is handled entirely by Stripe. We receive confirmation of payment status, subscription tier, and transaction identifiers. We do not store credit card numbers, CVVs, or full bank details on our servers.
Device & Technical Data
IP address, device type, operating system, app version, browser type (B2B dashboard), crash reports and performance diagnostics (via Sentry), and session identifiers.
Venue Owner Data
In addition to account data, venue owners provide: business name, business address, role/position, venue details (type, capacity, operating hours), and proof of ownership or authority documents (e.g., license, lease, or utility bill).
5. Purposes & Lawful Basis
Under UK GDPR, we must have a lawful basis for each purpose we process your data. The table below sets out each processing activity, its purpose, and the lawful basis we rely on.
| Purpose | Data Used | Lawful Basis |
|---|---|---|
| Account creation and authentication | Name, email, phone, DOB | Contract |
| Venue check-ins, XP, levelling, and gamification | Location, activity data | Contract |
| Paths social connections and messaging | Social data, messages | Contract |
| Venue analytics and insights for venue owners | Anonymised/aggregated check-in and activity data | Contract |
| Payment processing and subscription management | Payment data, subscription tier | Contract |
| Venue owner onboarding and claim verification | Business details, proof documents | Contract |
| Fraud prevention, abuse detection, and platform safety | Account, device, location, activity data | Legitimate Interest |
| Service improvement and product analytics | Anonymised usage patterns, device data | Legitimate Interest |
| Error monitoring and crash reporting | Device data, IP, crash logs | Legitimate Interest |
| Precise location for check-ins and discovery | GPS coordinates | Consent |
| Marketing communications and promotional offers | Email, name, preferences | Consent |
| AI-powered recommendations and matching | Activity data, preferences | Consent |
| Tax, accounting, and legal obligations | Payment records, account data | Legal Obligation |
Where we rely on consent, you may withdraw it at any time by adjusting your settings in the app or contacting us at privacy@mysova.co.uk. Withdrawal does not affect processing carried out before you withdrew consent.
7. AI Processing
MYSOVA uses artificial intelligence to enhance your experience. We are transparent about how AI is used and what safeguards are in place.
Provider
We use Anthropic's Claude models for AI-powered features. Anthropic is a US-based AI safety company. Data sent to Anthropic is processed under our data processing agreement and is not used to train their models.
What AI processes
- Venue recommendations based on your check-in history and preferences
- Social matching suggestions for Paths connections
- Venue insights and trend analysis for venue owners
- Content moderation assistance
Inputs and outputs
AI inputs include anonymised activity patterns, venue categories, and user preferences. AI outputs are recommendations, scores, and text summaries. No raw personal data (names, emails, phone numbers) is sent to AI processors.
Safeguards
- No solely automated decisions with legal or significant effects are made by AI
- All AI recommendations can be ignored — they do not restrict your access to features
- You can opt out of AI-personalised recommendations at any time
- AI outputs are logged for quality assurance and bias monitoring
- Human review is available upon request for any AI-influenced decision
8. Third-Party Processors
We share personal data with the following third-party processors, solely to provide and operate our services. Each processor is bound by a data processing agreement.
| Processor | Purpose | Data Location |
|---|---|---|
| Supabase | Database hosting, authentication, real-time data | EU (Frankfurt) |
| Stripe | Payment processing, subscription billing | US / EU |
| Sentry | Error tracking, crash reporting, performance monitoring | US |
| Mapbox | Map rendering, venue location display, geocoding | US |
| Anthropic | AI recommendations, matching, content moderation | US |
| Resend | Transactional and marketing email delivery | US |
| Vercel | Web hosting, edge functions, serverless compute | US / EU (edge) |
| Twilio (planned) | SMS one-time passwords for venue owner verification — not yet wired | US / EU |
| Upstash (planned) | Distributed rate limiting (Redis) — not yet wired | EU |
We do not sell your personal data to any third party. Data is shared with processors only as strictly necessary to deliver our services. We maintain a current internal subprocessor register and will update this policy when new processors are added or removed. Each processor operates under a written data processing agreement (typically the processor's standard DPA, accepted electronically). Copies are available on request.
9. International Transfers
MYSOVA is a UK-based company and our primary database is hosted in the EU (Frankfurt). However, some of our third-party processors operate in the United States, as indicated in the table above.
Where personal data is transferred from the UK to countries without an adequacy decision, we implement appropriate safeguards including:
- UK International Data Transfer Agreement (IDTA) — the post-Brexit transfer mechanism issued by the Information Commissioner's Office
- EU Standard Contractual Clauses (SCCs) with the UK Addendum — used in the alternative where a processor's template DPA is built around the EU SCCs
- Data processing agreements with each processor, specifying security measures and data handling obligations
- Transfer risk assessments where required, evaluating the legal framework of the recipient country and supplementary measures (e.g. encryption, pseudonymisation)
You may request a copy of the relevant transfer safeguards by contacting privacy@mysova.co.uk.
10. Data Retention
We retain your personal data only for as long as necessary for the purposes set out in this policy, or as required by law. The table below sets out our specific retention periods.
| Data Category | Retention Period | Reason |
|---|---|---|
| Account data (name, email, phone, DOB) | While account is active + 30 days after deletion | Service delivery; grace period for account recovery |
| Payment and billing records | 6 years after transaction | HMRC tax record-keeping requirements |
| Raw location data (GPS coordinates) | 90 days | Aggregated after 90 days; raw data deleted |
| Check-in history (anonymised) | While account is active + 30 days | Core service feature; XP and level history |
| Direct messages | 1 year after account closure | Safety investigations; regulatory compliance |
| Verification documents (venue ownership) | 30 days after approval | Deleted once venue claim is verified |
| Crash reports and error logs | 90 days | Debugging and service stability |
| Marketing consent records | Duration of consent + 2 years | Evidence of consent under PECR |
| Block/report records | 3 years | Platform safety and abuse prevention |
When retention periods expire, data is securely deleted or irreversibly anonymised. Aggregated, anonymised data (which cannot identify you) may be retained indefinitely for statistical and research purposes.
12. Your Rights
Under the UK GDPR, you have the following rights in relation to your personal data:
To exercise any right, email privacy@mysova.co.uk. We will respond within one calendar month of receipt, in line with our obligation under UK GDPR Article 12(3). We may ask for proof of identity before processing your request. There is no fee unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or refuse the request (in which case we will tell you why and how to complain).
13. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:
- Encryption at rest — all personal data stored in our database is encrypted at rest using AES-256
- Encryption in transit — all data transmitted between your device and our servers is encrypted using TLS 1.2 or higher
- Least privilege access — database access is restricted through Row Level Security (RLS) policies, ensuring users can only access their own data
- Authentication security — passwords are hashed using bcrypt; session tokens are rotated regularly
- Audit logging — access to sensitive data and administrative actions are logged for security review
- Rate limiting — API endpoints are rate-limited to prevent brute force and denial-of-service attacks
- Vulnerability monitoring — we use automated tools to detect and remediate security vulnerabilities in our dependencies
No system is completely secure. If you believe your account has been compromised, contact us immediately at privacy@mysova.co.uk.
14. Age Restrictions
MYSOVA is a nightlife platform and our services are intended exclusively for individuals aged 18 and over. We implement the following measures:
- An age gate at account registration requiring date of birth confirmation
- Accounts created by individuals under 18 are terminated and data is deleted
- We reserve the right to request additional age verification at any time
- Venue owners are required to be at least 18 and authorised to represent their business
If you believe someone under 18 is using MYSOVA, please report it to privacy@mysova.co.uk and we will investigate promptly.
15. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our services, legal requirements, or operational practices. When we make changes:
- The version number and effective date at the top of this page will be updated
- For material changes, we will notify you via email and/or an in-app notification at least 14 days before the changes take effect
- Previous versions of this policy will be available upon request
- Continued use of our services after the effective date constitutes acceptance of the updated policy
16. Contact & Complaints
If you have any questions, concerns, or requests regarding this privacy policy or our data practices, contact us:
MYSOVA LTD — Data Protection
Email: privacy@mysova.co.uk
Response time: Within one calendar month of receipt
If you are not satisfied with our response, you have the right to lodge a complaint with the UK supervisory authority:
Information Commissioner's Office (ICO)
Make a complaint: ico.org.uk/make-a-complaint
Website: ico.org.uk
Helpline: 0303 123 1113
Live chat: ico.org.uk/global/contact-us/live-chat
We encourage you to contact us first so we can try to resolve your concern directly.
MYSOVA and the owl device are trademarks of MYSOVA LTD, registered with the UK Intellectual Property Office (UK00004373417 / UK00004373474).
6. Social & Location Disclosures
What other users can see
When you check in to a venue, other users at the same venue may see your first name and profile photo. Paths connections (mutual opt-in) can see your check-in history and send you direct messages. Your XP level and achievements are visible on your profile.
What venues see
Venue owners receive anonymised and aggregated analytics only: total check-ins, footfall trends, peak hours, demographic breakdowns (age ranges, not individual ages), and dwell time averages. Venue owners cannot see individual user identities, precise locations within their venue, or private social activity.
Phantom Mode
Users can enable Phantom Mode to check in privately. When active, your check-in is recorded for your own history and XP, but you become invisible to other users at the venue. Venue analytics still receive your visit as an anonymous data point. You can toggle Phantom Mode on or off at any time from your profile settings.