Recovery Cooler Privacy Policy

SeMo Group Privacy Policy Effective 6 May 2026 | Last updated 17 August 2026 1. Who We Are 2. Information We Collect 3. How We Use Information 4. How We Share Information 5. Sensitive and Health-Related Information 6. De-identified and Aggregated Information 7. International Data Transfers 8. Data Retention and Deletion 9. Your Choices and Privacy Rights 10. Region-Specific Disclosures 11. Children and Teen Users 12. Journals, Notes and User Content 13. Safety, Crisis and Support Resources 14. Security 15. Third-Party Links and Services 16. Changes to This Policy 17. Contact Us Effective date: 6 May 2026 Last updated: 17 August 2026 Recovery Cooler is a recovery and healing support app operated by SeMo Group. Recovery is personal, and the information you put into Recovery Cooler is some of the most sensitive information you can share with an app. This Privacy Policy explains what we collect, how and why we use it, when we share it, how long we keep it, and the choices and rights available to you. This Policy applies to the Recovery Cooler mobile application, our websites, support channels, surveys and any other product or service that links to this Policy (collectively, the "Services"). 1. Who We Are Recovery Cooler is operated by SeMo Group, Sandton, Johannesburg, South Africa. For privacy questions, contact semogrouptech@gmail.com. Recovery Cooler is a self-help and progress-tracking tool. It is not a medical device, and it does not provide medical advice, diagnosis or treatment. It is not a substitute for professional care or emergency services. 2. Information We Collect Information you provide: - Account information such as your name or nickname, email address and password. - Recovery information you choose to enter, such as your start date, clean-day streaks, the habits or substances you are tracking, milestones, mood check-ins, triggers and journal entries. - Support messages, feedback, survey responses and anything you send us directly. Information collected automatically: - Device and app information such as device model, operating system, app version, language and time zone. - Usage information such as screens viewed, features used, session length and crash or diagnostic logs. - Approximate location derived from your IP address, used for security, fraud prevention and regional compliance. We do not collect precise GPS location. We do not require you to use your real name. You may use a nickname or initials. 3. How We Use Information We use information to: - Provide the Services, including tracking clean days, streaks, milestones and reflections. - Sync your data across your devices and restore it if you reinstall the app. - Send reminders, motivation and milestone notifications you have enabled. - Diagnose crashes, improve reliability and develop new features. - Protect the Services against abuse, fraud and unauthorised access. - Comply with legal obligations and enforce our terms. We do not sell your personal information, and we do not use your recovery or journal content for advertising or targeted advertising. 4. How We Share Information We share personal information only: - With service providers who host, store, secure, analyse or support the Services under contract, and only for those purposes. - Where you direct us to, for example if you choose to export or share your progress. - For legal reasons, where required by law, legal process or a valid government request, or to protect the rights, safety or property of users, the public or SeMo Group. - In a business transfer such as a merger, acquisition or sale of assets, subject to this Policy. 5. Sensitive and Health-Related Information Information about addiction, substance use, mental health and recovery is sensitive. Where required by law, we process it only with your consent or another lawful basis, use it strictly to provide the features you have chosen, and restrict internal access to staff who need it to operate or support the Services. You may withdraw consent at any time by deleting the relevant entries or your account. 6. De-identified and Aggregated Information We may create de-identified or aggregated statistics, for example the total number of milestones celebrated across all users. This information cannot reasonably be used to identify you, and we do not attempt to re-identify it. 7. International Data Transfers We may store and process information in countries other than your own. Where we transfer personal information across borders, we use appropriate safeguards required by applicable law. 8. Data Retention and Deletion We keep your account and recovery data for as long as your account is active. If you delete an entry, it is removed from your account and deleted from active systems, with residual copies removed from backups within a limited period. If you delete your account, we delete or de-identify your personal information within a reasonable period, except where we must keep records to comply with law, resolve disputes or enforce our agreements. 9. Your Choices and Privacy Rights Depending on where you live, you may have the right to access, correct, delete, port, restrict or object to the processing of your personal information, and to withdraw consent. You may: - Edit or delete streaks, milestones and journal entries in the app at any time. - Turn notifications on or off in the app or your device settings. - Delete your account from the app settings. - Submit an access, correction or deletion request through our privacy request form or by emailing semogrouptech@gmail.com. We will not discriminate against you for exercising these rights. 10. Region-Specific Disclosures South Africa: We process personal information in accordance with POPIA. You may lodge a complaint with the Information Regulator of South Africa. European Economic Area and United Kingdom: We rely on consent, contract performance, legitimate interests and legal obligations as lawful bases. You may lodge a complaint with your supervisory authority. United States: We do not sell or share personal information for cross-context behavioural advertising, and we do not process sensitive personal information for purposes other than providing the Services. 11. Children and Teen Users Recovery Cooler is not directed to children under 13, and we do not knowingly collect personal information from them. If we learn that we have collected such information, we will delete it. Teen users should involve a trusted adult or professional in their recovery where possible. 12. Journals, Notes and User Content Your journal entries, reflections and notes are private to your account by default. We do not publish them, and we do not share them with other users. We may access content only where necessary to provide support you request, to investigate a security incident or where required by law. 13. Safety, Crisis and Support Resources Recovery Cooler does not provide crisis intervention. If you are in danger or experiencing a medical or mental-health emergency, contact your local emergency services or a qualified professional immediately. Any resources listed in the app are provided for convenience and are not endorsements. 14. Security We use technical and organisational measures such as encryption in transit, access controls and monitoring to protect your information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please use a strong, unique password and keep your device secure. 15. Third-Party Links and Services The Services may link to third-party websites, resources or app stores. Their privacy practices are governed by their own policies, and we are not responsible for them. 16. Changes to This Policy We may update this Policy as Recovery Cooler develops. Where a change is material, we will provide notice in the app or by email and obtain consent where required by law. The version history below records material changes. 17. Contact Us Privacy contact: SeMo Group - Recovery Cooler Privacy Office: Sandton, Johannesburg, South Africa Email: semogrouptech@gmail.com You may also contact the privacy or data-protection regulator in your region. South African users may contact the Information Regulator of South Africa. Copyright 2026 SeMo Group. All rights reserved. Recovery Cooler is operated by SeMo Group, Sandton, Johannesburg, South Africa. Privacy contact: semogrouptech@gmail.com

Version History

Version 1.1 — 17 August 2026
Expanded health-data, retention, security and regional rights disclosures.
Version 1.0 — 6 May 2026
Initial Recovery Cooler privacy policy.