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Privacy Policy​

The Your Sammy website and Sammy WhatsApp Business Account are operated by Revolv GmbH, Sandhoferstrasse 176, 68305 Mannheim, Germany.  (referred to as “we”, “us” or “our” in this Privacy Policy). 

 

This Privacy Policy describes how Sammy (the “Site and WhatsApp Chat” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site. 

 

Contact 

If you want to exercise your data subject rights or if you have any other questions concerning this Privacy Policy, please submit/email your request to: hello@revolv.vc 

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Revolv GmbH, Sandhoferstrasse 176, 68305 Mannheim, Germany.   

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We respect your privacy and are dedicated to safeguarding your personal information. This Privacy Policy outlines how we collect and manage your personal data and establishes the framework for processing any personal data we collect from you or that you provide to us. Your use of our website or mobile application (collectively referred to as our “Platform”) is subject to this Privacy Policy. The policy also applies whenever you communicate with us, whether in person, by letter, phone, email, or any other method. Please read the following carefully to understand our practices and how we handle your personal data. 

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This policy is updated periodically. The most recent version, updated on 12th February 2025, is available on this page of the Platform. All subsequent updates will also be published here. 

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Collecting Personal Information 

Website 

When you visit the Site, we collect certain information about your device and your interaction with the Site. We may also collect additional information if you contact us for customer support. See the list below for more information about what Information we collect and why. 

 

Device information 

  • Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site. 

  • Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels. 

  • Other Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site. 

 

When you interact with our website, we collect data to enhance your user experience and improve our services. All such data collected is anonymized, ensuring that it cannot be used to identify you personally. We may track how you interact with the site, including but not limited to, pages visited, links clicked, and time spent on the site. This information is used solely for analytical purposes to understand user behavior and improve our website's functionality and content. 

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What Data We Collect via WhatsApp (Sammy) 

Why and how do we process your personal data within the framework of Sammy WhatsApp Support? 

 

Purpose: To provide personalized support and guidance through WhatsApp, including reminders, tips, and tailored health-related advice. 

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Identification Data 

Personal Data: 

  • Nickname: Used to personalize communication and make interactions feel friendly and relevant. Helps Sammy address you in a familiar way during chats. 

  • Phone Number: Required to communicate with you via WhatsApp and associate your interactions with your profile. 

Legal Basis: Performance of a contract (GDPR, Article 6.1(b)) 

Deletion Period: During the time you use the WhatsApp support service or until you withdraw your consent. 

 

Interaction Data 

Personal Data: 

  • Messages you send to Sammy during WhatsApp chats 

  • Timestamps of chats and reminders 

  • Responses to feedback prompts, polls, and surveys 

Purpose: To improve user experience, provide timely reminders, and personalize content based on your engagement. 

Legal Basis: Legitimate interest (GDPR, Article 6.1(f)) – enhances service quality and user experience. 

Deletion Period: During the time you use the service or until you withdraw your consent. 

 

Health-Related Data (Special Category Data) 

Personal Data: 

  • Information about bladder symptoms, frequency, and potential triggers 

  • Reflections on exercises, dietary habits, and wellness routines 

Purpose: To provide tailored health-related support and recommendations. 

Legal Basis: Explicit consent (GDPR, Article 9.2(a)) – required for processing special category data. 

Important: Health-related data is treated with the highest level of protection and processed in compliance with applicable data protection laws. 

Deletion Period: During the time you use the service or until you withdraw your consent. 

 

Optional Feedback 

Personal Data: 

  • Participation in polls, ratings, and comments aimed at improving the user experience 

Purpose: To gather insights for service improvement and personalization. 

Legal Basis: Consent – only processed if you choose to participate. 

Deletion Period: During the time you use the service or until you withdraw your consent. 

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User-Submitted Data 

All data shared by users during WhatsApp chats is voluntary. You are not required to share sensitive information to use the service. Any health-related data is processed only with your explicit consent.Any health-related data is processed only with your explicit consent, which will be obtained directly through the WhatsApp chat prior to any exchange of such information. You must provide clear permission for us to access and process this data in order to deliver personalized advice that best suits your needs. You may withdraw your consent at any time by notifying us directly in the WhatsApp chat or by contacting our support team, after which no further health-related data will be processed, and any previously collected data will be deleted or anonymized in accordance with applicable legal requirements.

 

If you choose to share media—such as images, voice notes, text messages, videos, or audio recordings—this content is treated as part of your interaction data. It is: 

  • Stored securely 

  • Encrypted during transmission and storage 

  • Accessed only by authorized personnel 

 

Sammy does not use user-submitted media for profiling, marketing, or automated decision-making. 

 

By sharing data via WhatsApp, you acknowledge that Sammy is a wellness-only platform. Sammy does not verify, medically assess, or diagnose any user-submitted data. You are responsible for the accuracy and relevance of the information you provide. Sammy is not liable for any outcomes resulting from incomplete, inaccurate, or misinterpreted user-submitted data. 

 

Legal Basis for Processing 

You may withdraw your consent at any time by replying “STOP” in the WhatsApp chat. Withdrawal does not affect the lawfulness of data processing carried out before consent was withdrawn. 

 

How We Use Your Data 

Your data is used to: 

  • Provide personalized tips, exercises, recipes, and motivational support 

  • Track your progress and help identify patterns over time 

  • Deliver spontaneous content such as motivational notes or mini challenges 

  • Collect feedback to improve the service experience 

 

Disclaimer: Sammy is a wellness-only platform. All advice provided by Sammy or its experts is general wellness guidance and not medical advice. 

If an expert believes medical attention may be necessary, they will recommend that you consult a qualified healthcare professional. 

 

Data Storage and Security 

We take data security seriously: 

  • Data is encrypted both in transit and at rest 

  • Access is restricted to authorized personnel only 

  • Systems are monitored and updated regularly to prevent unauthorized access 

 

Data Retention 

We retain your data to support your experience and track long-term patterns: 

  • Chat data and health-related information: Retained for 12 months 

  • After 12 months, personal identifiers are removed or anonymized 

  • Aggregate data may be used for research and service improvement, without identifying individual users 

 

Your Rights Under UK GDPR 

Under the UK General Data Protection Regulation (UK GDPR), you have the right to: 

  • Access your personal data 
    You can request a copy of the personal data we hold about you. 

  • Correct inaccuracies 
    You can ask us to rectify any incorrect or incomplete data. 

  • Withdraw consent at any time 
    If we rely on your consent to process your data, you can withdraw it whenever you choose. 

  • Request deletion (“Right to be Forgotten”) 
    You can ask us to delete your personal data in certain circumstances. 

  • Restrict processing 
    You can request that we limit how we use your data. 

  • Data portability 
    You can ask to receive your data in a structured, commonly used format and transfer it to another controller. 

  • Object to processing 
    You can object to processing based on legitimate interests or direct marketing. 

  • Rights related to automated decision-making and profiling 
    You have the right not to be subject to decisions made solely by automated means. 

 

To exercise any of these rights, please contact us at: hello@revolv.vc 

We will respond within one month, in accordance with the UK GDPR guidelines. 

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Third-Party Processing 

  • All data processing is done internally 

  • WhatsApp acts solely as a messaging platform and cannot access your health data due to end-to-end encryption 

  • We do not share your data with third parties for marketing or advertising purposes 

 

For more information, refer to: 

Children and Vulnerable Users 

  • Sammy is intended for adults aged 18+ 

  • We do not knowingly collect data from children 

  • Parents or guardians should not submit data on behalf of children 


Behavioural Advertising 

As described above, we use your anonymised personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example: 

  • We share information about your use of the Site, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location) 

 

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

 

You can opt out of targeted advertising by: 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/. 

 

What rights do you have and how can you assert your rights? 

If you have declared your consent regarding certain collecting, processing, and use of your personal data, you can revoke this consent at any time with future effect. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with the basic tariffs. 

Pursuant to the applicable data protection law you have the right (i) to request access to your personal data, (ii) to request rectification of your personal data, (iii) to request erasure of your personal data, (iv) to request restriction of processing of your personal data, (v) to request data portability, (vi) to object to the processing of your personal Data (including objection to profiling), and (vii) to object to automated decision making (including profiling).  

To exercise your rights please contact us as stated under Sec. 1 (Contact us) above.  

 

Changes to this Privacy Policy 

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. 

We recommend that you periodically review this Privacy Policy for any updates. The changes to this Privacy Policy will become effective once they are posted on this page. 

 

Cookies and other tracking technologies 

This website or app uses cookies. For further information please visit our Cookie Policy  

 

How long do we keep your Personal Data? 

Your personal data will be retained as long as necessary to provide you with the services and products requested. Once our relationship has come to an end, we will either delete your personal data or anonymize your personal data, unless statutory retention requirements apply (such as for taxation purposes). Also, we may be required by applicable law to retain certain of your personal data for a period of 10 years after the relevant taxation year. We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need-to-know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship. 

 

Children's Privacy 

Our Service is not directed to individuals under the age of 13. We do not intentionally collect personally identifiable information from individuals under 13 years of age. If you are a parent or guardian and you become aware that your child has provided us with Personal Data without your consent, please contact us immediately.  

In the event that we discover we have collected Personal Data from an individual under the age of 13 without parental consent, we will take appropriate steps to delete such information from our records. Should we need to rely on consent as the legal basis for processing your information, and if your jurisdiction requires parental consent, we may seek your parent's consent before collecting and using your information. 

 

Links to Other Websites 

Our Service may include links to external websites that are not operated by us. If you click on a third-party link, you will be redirected to that third party site. We strongly recommend reviewing the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. 

Complaints 

As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above. 

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: Information Commissioner's Office  

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Last updated: 17/11/2025

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