Privacy Policy - Phroniva

Last Updated: August 2025

At Phronesis / Phroniva (“Company,” “we,” “our,” “us”), your privacy and trust are very important to us. We are committed to protecting your personal data and ensuring transparency about how it is used. This Privacy Policy outlines in detail the ways we collect, process, store, share, and protect your information when you use our products and services (“Services”).

By accessing or using our Services, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

1. Scope and Application

1.1 This Privacy Policy applies to all websites, mobile applications, digital platforms, and offline services operated by Phronesis, including but not limited to:

  • Beautify (AI-powered skin and supplement analysis system).

  • Adora (eco-friendly toothpaste tablets).

  • Sonos Books (subscription-based audiobook platform).

  • LAC (supplement and preventive health products).

  • Health Investor (educational health and wellness initiative).

1.2 This Policy applies regardless of how you access our Services (web, app, in-store, via partner, or third-party platform).

1.3 If you do not agree with this Policy, you should not use our Services.

2. Categories of Data We Collect

We may collect and process the following categories of data:

2.1 Personal Identification Data

  • Name, surname, date of birth, gender, contact details (email, phone, postal address).

  • Account login credentials (username, password, security questions).

2.2 Transactional and Financial Data

  • Payment card details (processed securely by payment gateways).

  • Billing address, transaction history, subscription records.

  • Order fulfillment and shipment data.

2.3 Health and Lifestyle Data

  • Voluntary data provided for Beautify (skin scans, photographs, health questionnaire results).

  • Data related to supplement recommendations (dietary habits, wellness goals, allergy information).

  • Non-clinical data provided to Health Investor for personalization.

Important: Phronesis is not a medical provider. The collection of health-related information is for personalization and product/service delivery only and is not considered medical data under healthcare law.

2.4 Device & Technical Data

  • IP addresses, device identifiers, operating system type, browser type/version.

  • Geolocation (if you enable location services).

  • Log data on app usage, navigation, and features accessed.

2.5 User-Generated Data

  • Feedback, reviews, testimonials, photographs, and submissions.

  • Social media posts when tagging or interacting with Phronesis official accounts.

2.6 Partner Data

  • Data shared by healthcare providers, franchise partners, or third parties with whom we collaborate.

3. How We Use Your Data

We process personal data for the following purposes:

3.1 To Deliver and Improve Services

  • Provide product recommendations, skin analyses, audiobook access, and supplement subscriptions.

  • Manage account functionality, authentication, and personalization.

3.2 Customer Relationship Management

  • Send confirmations, invoices, delivery updates, subscription renewals.

  • Provide support via email, chat, or telephone.

3.3 Marketing & Communications

  • Send promotional offers, newsletters, and updates.

  • Display personalized advertisements based on browsing/usage behavior.

3.4 Research and Development

  • Improve product performance using aggregated usage statistics.

  • Conduct anonymized data analysis for product development.

3.5 Legal & Compliance

  • Comply with consumer protection, financial reporting, and data protection laws.

  • Prevent fraud, security threats, and misuse of Services.

4. Legal Bases for Processing (GDPR)

Where GDPR applies, we rely on the following legal bases:

  • Consent: When you opt-in for marketing, health data input, or newsletter subscription.

  • Contractual necessity: To deliver products and services you purchase.

  • Legal obligation: To meet financial, tax, or regulatory requirements.

  • Legitimate interests: To ensure platform security, product development, and customer engagement.

5. Sharing & Disclosure of Data

We may disclose data under limited circumstances:

5.1 Within the Phronesis Group

Among subsidiaries, brands, and divisions (Beautify, Sonos, Adora, LAC, Health Investor).

5.2 Service Providers

Third parties performing services such as hosting, IT support, analytics, logistics, and payment processing.

5.3 Business Partners

Franchise and clinical partners providing services under our supervision.

5.4 Legal Requirements

When disclosure is required to comply with laws, enforce Terms, or protect rights.

5.5 Corporate Transactions

In case of merger, acquisition, restructuring, or sale of assets.

We do not sell or rent your personal information.

6. International Transfers

Your data may be transferred to jurisdictions outside your country (e.g., servers in Singapore, Europe, or the United States). Where required, we implement safeguards such as Standard Contractual Clauses (SCCs) or Data Processing Agreements (DPAs) with partners.

7. Retention of Data

We keep personal data only for as long as necessary:

  • Account data: kept until account deletion.

  • Transactional data: kept for 5–7 years as per tax laws.

  • Health/wellness data: deleted or anonymized upon account closure.

8. Data Security

We use:

  • SSL/TLS encryption.

  • Secure data centers with firewalls and intrusion detection.

  • Role-based access control.

  • Regular audits and penetration tests.

No method of storage is 100% secure, but we strive for industry best practices.

9. Your Rights

Depending on your jurisdiction, you may have rights to:

  • Access and obtain a copy of your personal data.

  • Correct or update your information.

  • Request deletion (“right to be forgotten”).

  • Restrict or object to processing.

  • Data portability.

  • Withdraw consent for marketing at any time.

Requests can be made to tergel@phronesis.com.

10. Cookies and Tracking

Our websites and apps use cookies, pixels, and tracking technologies for analytics, personalization, and marketing. You may adjust browser settings to disable cookies, though this may impact functionality.

11. Children’s Privacy

Our Services are not intended for users under 13 (or local minimum age). If data is collected inadvertently, it will be deleted promptly.

12. Changes to Privacy Policy

We reserve the right to update this Policy. Significant changes will be communicated by email or platform notice.

13. Contact Us: Phronesis / Phroniva

Contact: 976-94060603

Location: 8A-57 ,Orchlon complex, 6r floor, BZD - 1 khoroo, Ulaanbaatar 14210