Levl Privacy Policy

This Privacy Policy explains how Cultura Cortes LLC ("Cultura Cortes," "we," "us," or "our") handles information in connection with the Levl mobile application and related services ("Levl," the "App," or the "Service").

Levl is designed to operate primarily on a local-first basis, meaning that the personal entries and progress information you create within the App are generally stored on your device rather than transmitted to a Levl-operated backend.

By using Levl, you acknowledge the practices described in this Privacy Policy.

1. Information Collection and Storage

Levl does not require you to create an account or provide your name, email address, date of birth, or other identifying account information to use the core Service at launch.

Information you enter or generate within Levl may include items such as:

• onboarding and educational-assessment responses;
• streak and progress information;
• journal entries;
• urge and relapse logs;
• daily check-ins or reports;
• recovery-related progress information; and
• other information you voluntarily enter into the App.

This information is stored locally on your device and is not transmitted to a Levl-operated backend. Cultura Cortes LLC does not maintain a centralized database containing your journals, recovery logs, assessment responses, streak information, or other locally stored behavioral data.

2. Purchases and Subscription Information

Levl may offer paid subscriptions or other in-app purchases.

Purchases made through the Apple App Store are processed by Apple. Cultura Cortes LLC does not directly receive or store your complete payment-card information.

Levl uses RevenueCat to help manage subscriptions and purchase entitlements. RevenueCat may process:

• an anonymous App User ID generated for subscription management;
• offerings, purchase, receipt, subscription, and entitlement information; and
• standard technical information associated with operation of its SDK, which may include device and operating-system information, IP address, last-seen time, and App Tracking Transparency status.

Levl does not send locally stored journal entries, recovery information, urge or relapse logs, assessment responses, daily reports, streak or progress information, or similar behavioral information to RevenueCat.

Your purchase may also be subject to Apple's privacy practices and applicable terms.

3. Streaming, Video, and Audio Services

Certain content within Levl is delivered through third-party content-delivery and streaming services, including services such as YouTube and Cloudflare.

This may include:

• videos and playlists;
• podcasts;
• course lessons;
• guided exercises;
• relaxation media;
• other audio or video content.

When your device connects to one of these services, the provider may receive standard technical information necessary to deliver the requested content, such as your IP address, device or browser information, and information about the request being made.

Levl does not send your locally stored journal entries, recovery information, progress information, relapse or urge logs, or other personal behavioral entries to these streaming or content-delivery providers.

Your interaction with third-party content may also be governed by that provider's own privacy policy and terms.

4. Analytics, Advertising, and Tracking

At launch, Levl does not use dedicated:

• advertising services;
• behavioral tracking services;
• third-party analytics platforms;
• dedicated crash-reporting services;
• account-storage services;
• cloud-storage services for your personal recovery data.

Levl does not sell your personal information to advertisers.

If Levl's technical infrastructure changes in the future, this Privacy Policy will be updated as appropriate.

5. Data Retention, Export, and Deletion

Because your personal entries and progress information are stored locally on your device, Cultura Cortes LLC generally does not possess a server-side copy of that information to retain or delete.

Levl includes a Backup & Restore feature that allows you to export a copy of your locally stored application data. If you choose to save or share an exported backup through your device's share functionality, including to Files, iCloud Drive, or another third-party service, that copy may remain after Levl is deleted from your device. The storage, retention, security, and deletion of an exported copy are governed by the location or service you choose. Levl deletes its temporary export after the sharing process is completed.

Deleting Levl from your device removes the App and its locally stored application data from the active installation, subject to how your device and operating system manage backups and restoration.

Copies of application data may, in some circumstances, remain within device backups, cloud backups, exported backups, or other backup systems controlled by you, Apple, or another service you select. Cultura Cortes LLC does not control those systems.

If application data is restored from a backup, previously stored information may be restored with it.

Information maintained independently by third-party providers such as Apple, RevenueCat, YouTube, or Cloudflare is subject to those providers' own retention and deletion practices.

6. Children's Privacy and Minimum Age

You must be at least 14 years old to use Levl.

Levl is not intended for children under 14, and Cultura Cortes LLC does not knowingly operate Levl for children under that age.

At launch, Levl does not require users to submit their name, email address, date of birth, or other identifying account information to access the core Service.

If we learn that information has been collected in a manner inconsistent with applicable children's privacy law, we will take appropriate steps as required by law.

Users who are under the age at which they may independently consent to applicable privacy practices in their jurisdiction may require the involvement or permission of a parent or legal guardian where required by law.

Access to Levl through the Apple App Store or another marketplace may also be subject to the age ratings, family settings, parental controls, and other restrictions maintained by that platform.

7. International Users

Levl may be available to users in multiple countries.

Privacy, consumer-protection, and age-of-consent requirements can vary depending on where you live.

Where applicable law provides you with rights that cannot be limited by this Privacy Policy, those rights remain unaffected.

Because Levl's core personal entries are stored locally rather than in a Levl-operated account or cloud database, Cultura Cortes LLC may not possess the underlying information necessary to access, correct, export, or delete those locally stored entries on your behalf.

8. Third-Party Services

Levl relies on certain third-party services to provide functionality, including app distribution, purchases, subscriptions, and media delivery.

These providers may process technical or transactional information independently under their own privacy policies. Such providers may include:

• Apple, for App Store distribution and payment processing;
• RevenueCat, for subscription and entitlement management;
• YouTube, where applicable, for video or media content; and
• Cloudflare, where applicable, for content delivery and streaming infrastructure.

Cultura Cortes LLC does not control the independent privacy practices of these third parties.

If you choose to export a backup using Levl's Backup & Restore feature, the exported file is provided to the destination you select through your device's share functionality. Any third-party service you choose to receive or store that file may process it according to that service's own privacy practices.

9. Health and Wellness Information

Levl contains educational and wellness content related to habits, behavior change, urges, emotional regulation, abstinence, journaling, and personal development.

Information that you voluntarily enter into Levl concerning these topics is stored locally on your device under the current architecture and is not transmitted to a Levl-operated backend.

Levl is an educational and general-wellness application and is not a medical, psychiatric, psychological, or other healthcare service.

For additional information about the limits and appropriate use of Levl's wellness content, please review our Terms of Use, including the Health & Wellness Disclaimer.

10. Security

Levl's local-first architecture is designed to minimize the amount of personal behavioral information transmitted to or stored by Cultura Cortes LLC.

However, no device, software system, network connection, or third-party service can be guaranteed to operate without security risks.

You are responsible for maintaining reasonable security over your device, device passcode, Apple account, backups, exported backup files, and other systems through which your locally stored information may be accessible.

11. Your Consent

By using Levl, you acknowledge this Privacy Policy and the information practices described in it.

Where required by applicable law, additional consent may be requested before certain information is collected or processed.

Your agreement to Levl's separate Terms of Use is governed by the acknowledgment presented within the App.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time as Levl's features, technology, third-party services, or legal obligations change.

When material changes are made, we may provide notice through the App or another reasonable method.

The most current version of this Privacy Policy will display its effective date at the top of the page.

13. Contact Us

If you have questions about this Privacy Policy or Levl's privacy practices, you may contact: