EN
RU
Privacy Policy
of the Instant Messaging Service
“Solovo”
Effective date: 1 April 2026
1. General Provisions
1.1. This Privacy Policy of the “Solovo” service (hereinafter — the “Policy”) is an official document of Limited Liability Company “NASA2” (TIN: 02856493, Registration number: 286.110.1225108, registered address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street) (hereinafter — the “Company”), and establishes the procedure for processing and protecting information (hereinafter — the “Information”) about individuals (hereinafter — “Users”, “You”) who use the instant messaging service “Solovo” (hereinafter — the “Service”, the “Messenger”) under the User Agreement (hereinafter — the “Agreement”).
1.2. The current version of this Policy is always available at: https://solovo.app/privacy.
1.3. The Company may unilaterally amend this Policy by publishing changes and/or a new version at the link above. Any amendments take effect upon publication, unless otherwise specified in the new version. If the User disagrees with this Policy and/or any amendments thereto, the User must immediately cease using the Service.
1.4. By using the Service, the User confirms that they have read and agree to this Policy.
1.5. The following key terms and definitions are used in this Policy:
Instant messaging service (Messenger) “Solovo” — a software application designed and used exclusively for the exchange of electronic messages between its users, whereby the sender designates the recipient(s) and the application does not provide for the posting of publicly available information on the internet.
User — an individual who has legal capacity under applicable law and has registered an account in the Solovo Messenger by providing a mobile phone number.
2. Composition of User Information and Purposes of Processing
2.1. The Company processes the following User data, the content, legal bases and purposes of which are set out in the table below:
Data Category
Specific Data
Purpose & Legal Basis
Retention Period
Identification Data
Phone number, username
Account registration and authentication. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
Profile Data
First name, last name, profile photo (optional)
Interface personalisation. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
User Content
Messages, media files, documents
Provision of Service functionality. Legal basis: performance of the Agreement
No less than 6 months
Contacts
Phone book contacts (if permission is granted)
Finding users within the Service. Legal basis: User consent
Not stored on the Company’s servers; used once to find users and not cached
Technical Data
Device model, OS, Messenger version, IP address, network type
Compatibility, debugging, security. Legal basis: performance of the Agreement
90 days
Usage Data
Activity timestamps, features used, clicks and navigation
Analytics, Service improvement. Legal basis: User consent (may be disabled)
Anonymised — 1 year
Crash Data
Error logs, stack traces
Bug fixing, stability assurance. Legal basis: performance of the Agreement
30 days
Message Metadata
Send time, file size, content type
Message delivery, Service optimisation. Legal basis: performance of the Agreement
No less than 6 months
2.2. The Company collects and subsequently records, systematises, accumulates, stores, clarifies (updates, modifies) and retrieves Information in order to operate and provide the Service. The Company does not intentionally collect or process special categories of personal data or biometric data.
2.3. The functionality and terms of use of the Service may permit Users to post information other than that specified in clause 2.1 of this Policy, provided it does not conflict with applicable law. By posting personal information, the User acknowledges that such information may be accessible to other Users in accordance with their privacy settings.
2.4. The Messenger uses the following third-party services to provide its functionality:
2.4.1. Google Play Services — provides application updates and licensing. Data collected: device identifier, installation information. Google Privacy Policy: https://policies.google.com/privacy.
2.4.2. Firebase Analytics (optional) — anonymous analytics of Service feature usage. Users may request disabling of data collection by contacting privacy@solovo.app. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.3. Firebase Crashlytics — error tracking and resolution. Collects error logs and technical device information. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.4. Hosting provider — data storage and Service infrastructure. All data is stored in compliance with applicable personal data protection requirements.
2.5. Cookie Processing. The Service may use cookies when the User accesses it through the web interface. Cookies are small data fragments stored locally on the User’s device that enable the correct operation and personalisation of the Service. The User may opt out of cookie processing in their browser settings, in which case the Company will use only strictly necessary cookies required for the Service to function.
3. Processing of User Information
3.1. Processing of User Information is carried out in accordance with the following principles:
3.1.1. lawfulness of the purposes and methods of processing Information;
3.1.2. good faith;
3.1.3. compliance of the purposes of processing Information with the purposes determined and declared at the time of collection;
3.1.4. proportionality of the volume and nature of Information processed, and the methods of processing, to the purposes of processing;
3.1.5. inadmissibility of combining databases containing Information that were created for incompatible purposes.
3.2. The Company processes Information through collection, recording, systematisation, accumulation, storage, clarification (updating, modification), matching, retrieval, use, transfer, blocking, deletion and destruction.
3.2.1. Storage and Use of Information.
Information about the User is processed and stored exclusively on electronic media using automated systems, except where non-automated processing is required in connection with compliance with applicable legal requirements.
Information is retained by the Company until the purposes of processing are achieved and while legal grounds exist, and after termination of the Agreement — for the period required by applicable law.
In the event that the User deletes their account, the Company retains necessary User data for the period required by applicable law.
3.2.2. Transfer of Information.
User Information is not transferred to any third parties, except as expressly provided in this Policy. The Company may transfer Information to third parties exclusively within the established purpose and on legal grounds. Such parties may include:
(a) service providers — companies that provide hosting, analytics (in anonymous form), notification delivery and other infrastructure necessary for the operation of the Service. Such parties act in accordance with the Company’s instructions and are required to comply with confidentiality requirements;
(b) parties engaged by the Company to perform the Agreement, including mobile network operators and technology partners involved in implementing the Service functionality;
(c) parties providing the Company with mobile analytics and/or web analytics services for the purpose of obtaining aggregated statistical and/or analytical information;
(d) competent state authorities — transfer of Information is carried out strictly in accordance with the procedure and on the grounds provided by applicable law, including in response to an official and lawful request (written request, order, court act). When fulfilling such a request, a mandatory legal assessment of its lawfulness and reasonableness is conducted. The Company provides only the minimum amount of data expressly required under applicable law.
Cross-border transfer of data. As part of using Firebase Cloud Messaging (Google LLC, USA) for delivering push notifications to the User’s device, technical device information is transferred to Google LLC. This transfer is based on the User’s consent given at the time of application installation and is governed by Google’s Privacy Policy (https://policies.google.com/privacy). No other cross-border transfer of Users’ personal data is carried out.
The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
3.2.3. Cessation of Information Processing.
Upon achieving the purposes of processing Information or upon termination of the legal grounds for processing, the Company shall cease processing Information. Notwithstanding the foregoing, the Company may continue processing Information where there are lawful grounds under applicable law.
4. Rights and Obligations of Users
4.1. Users have the right to:
4.1.1. request that the Company rectify, block or delete their data if such data is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purpose of processing;
4.1.2. obtain from the Company, upon request, information concerning the processing of their personal data;
4.1.3. receive their data in a structured, machine-readable format (right to data portability);
4.1.4. withdraw previously given consent to the processing of personal data in the part based on such consent;
4.1.5. opt out of analytics data collection by submitting a request to privacy@solovo.app;
4.1.6. exercise other rights provided by applicable personal data protection legislation.
4.2. To exercise the rights set out in this section, the User submits a request to: privacy@solovo.app. The request must include the User’s name, username and phone number, and describe which right the User wishes to exercise. The Company processes requests within no more than 10 business days from receipt. In certain cases, additional verification of the User’s identity may be required.
4.3. The User may delete their account by submitting a request to support@solovo.app or by using the relevant feature in the Messenger settings. After deletion is confirmed, all User data will be permanently destroyed within 10 days.
5. Measures to Protect User Information
5.1. The Company implements technical and organisational measures to protect User Information against unlawful or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions.
5.2. Technical protection measures include:
- encryption of the data transmission channel (TLS/WSS);
- encryption of data at rest (AES-256);
- server infrastructure protection (firewalls, DDoS protection);
- regular security assessments and independent audits;
- SMS verification upon every account login.
5.3. Organisational protection measures include:
- training of employees on privacy and information security matters;
- access control based on the principle of least privilege;
- regular review and update of information security policies and procedures;
- an incident response plan for data security incidents.
5.4. Information is processed automatically without access by the Company’s employees and/or contractors. Where such access is granted, it is only to the extent necessary for the performance of their duties. Such persons are required to comply with security and confidentiality requirements.
5.5. In the event of a data breach that may pose a risk to the rights and freedoms of Users, the Company undertakes to:
- notify Users within 72 hours of becoming aware of the incident;
- disclose the nature of the breach and the measures taken;
- provide protective recommendations;
- notify the relevant supervisory authorities where required by applicable law.
5.6. Users are also responsible for the security of their devices and credentials. The Company recommends:
- using strong passwords/PIN codes to lock the device;
- keeping the operating system and Messenger version up to date;
- not sharing credentials with third parties;
- using only official versions of the Messenger;
- not sharing SMS verification codes with third parties.
6. Minor Users
6.1. The Service is not intended for persons under the age of 13 (or such other minimum age as established by the law of the User’s country of residence). By registering for the Service, the User confirms that they have reached the specified age.
6.2. The Company does not knowingly collect personal data from persons who have not reached the age specified in clause 6.1 of this Policy. If the Company becomes aware that personal data of such a person was collected without the appropriate consent of parents or legal guardians, the Company will take all necessary measures to delete such data without delay.
6.3. Parents and legal guardians have the right to contact the Company to request deletion of a minor’s personal data and to obtain information about the processing of such data at: privacy@solovo.app.
7. User Inquiries
7.1. Information about the processing of the User’s personal data in connection with their use of the Service is provided to the User or their representative upon application (request).
7.2. Requests are submitted in writing to the Company’s registered address or electronically in accordance with the requirements of applicable law.
7.3. Contact information:
SOLOVO LLC
Address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street
Registration number: 286.110.1225108
General enquiries: support@solovo.app
Privacy enquiries: privacy@solovo.app; response time: 10 business days.
8. Regulatory Compliance
8.1. This Privacy Policy has been developed in accordance with:
- Google Play Store and Apple App Store requirements regarding privacy policies of mobile applications;
- the General Data Protection Regulation (GDPR) of the European Union — to the extent applicable to Users from the EU;
- other applicable international and national acts in the field of personal data protection.
8.2. The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
Version dated 01.04.2026
EN
RU
Privacy Policy
of the Instant Messaging Service
“Solovo”
Effective date: 1 April 2026
1. General Provisions
1.1. This Privacy Policy of the “Solovo” service (hereinafter — the “Policy”) is an official document of Limited Liability Company “NASA2” (TIN: 02856493, Registration number: 286.110.1225108, registered address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street) (hereinafter — the “Company”), and establishes the procedure for processing and protecting information (hereinafter — the “Information”) about individuals (hereinafter — “Users”, “You”) who use the instant messaging service “Solovo” (hereinafter — the “Service”, the “Messenger”) under the User Agreement (hereinafter — the “Agreement”).
1.2. The current version of this Policy is always available at: https://solovo.app/privacy.
1.3. The Company may unilaterally amend this Policy by publishing changes and/or a new version at the link above. Any amendments take effect upon publication, unless otherwise specified in the new version. If the User disagrees with this Policy and/or any amendments thereto, the User must immediately cease using the Service.
1.4. By using the Service, the User confirms that they have read and agree to this Policy.
1.5. The following key terms and definitions are used in this Policy:
Instant messaging service (Messenger) “Solovo” — a software application designed and used exclusively for the exchange of electronic messages between its users, whereby the sender designates the recipient(s) and the application does not provide for the posting of publicly available information on the internet.
User — an individual who has legal capacity under applicable law and has registered an account in the Solovo Messenger by providing a mobile phone number.
2. Composition of User Information and Purposes of Processing
2.1. The Company processes the following User data, the content, legal bases and purposes of which are set out in the table below:
Data Category
Specific Data
Purpose & Legal Basis
Retention Period
Identification Data
Phone number, username
Account registration and authentication. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
Profile Data
First name, last name, profile photo (optional)
Interface personalisation. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
User Content
Messages, media files, documents
Provision of Service functionality. Legal basis: performance of the Agreement
No less than 6 months
Contacts
Phone book contacts (if permission is granted)
Finding users within the Service. Legal basis: User consent
Not stored on the Company’s servers; used once to find users and not cached
Technical Data
Device model, OS, Messenger version, IP address, network type
Compatibility, debugging, security. Legal basis: performance of the Agreement
90 days
Usage Data
Activity timestamps, features used, clicks and navigation
Analytics, Service improvement. Legal basis: User consent (may be disabled)
Anonymised — 1 year
Crash Data
Error logs, stack traces
Bug fixing, stability assurance. Legal basis: performance of the Agreement
30 days
Message Metadata
Send time, file size, content type
Message delivery, Service optimisation. Legal basis: performance of the Agreement
No less than 6 months
2.2. The Company collects and subsequently records, systematises, accumulates, stores, clarifies (updates, modifies) and retrieves Information in order to operate and provide the Service. The Company does not intentionally collect or process special categories of personal data or biometric data.
2.3. The functionality and terms of use of the Service may permit Users to post information other than that specified in clause 2.1 of this Policy, provided it does not conflict with applicable law. By posting personal information, the User acknowledges that such information may be accessible to other Users in accordance with their privacy settings.
2.4. The Messenger uses the following third-party services to provide its functionality:
2.4.1. Google Play Services — provides application updates and licensing. Data collected: device identifier, installation information. Google Privacy Policy: https://policies.google.com/privacy.
2.4.2. Firebase Analytics (optional) — anonymous analytics of Service feature usage. Users may request disabling of data collection by contacting privacy@solovo.app. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.3. Firebase Crashlytics — error tracking and resolution. Collects error logs and technical device information. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.4. Hosting provider — data storage and Service infrastructure. All data is stored in compliance with applicable personal data protection requirements.
2.5. Cookie Processing. The Service may use cookies when the User accesses it through the web interface. Cookies are small data fragments stored locally on the User’s device that enable the correct operation and personalisation of the Service. The User may opt out of cookie processing in their browser settings, in which case the Company will use only strictly necessary cookies required for the Service to function.
3. Processing of User Information
3.1. Processing of User Information is carried out in accordance with the following principles:
3.1.1. lawfulness of the purposes and methods of processing Information;
3.1.2. good faith;
3.1.3. compliance of the purposes of processing Information with the purposes determined and declared at the time of collection;
3.1.4. proportionality of the volume and nature of Information processed, and the methods of processing, to the purposes of processing;
3.1.5. inadmissibility of combining databases containing Information that were created for incompatible purposes.
3.2. The Company processes Information through collection, recording, systematisation, accumulation, storage, clarification (updating, modification), matching, retrieval, use, transfer, blocking, deletion and destruction.
3.2.1. Storage and Use of Information.
Information about the User is processed and stored exclusively on electronic media using automated systems, except where non-automated processing is required in connection with compliance with applicable legal requirements.
Information is retained by the Company until the purposes of processing are achieved and while legal grounds exist, and after termination of the Agreement — for the period required by applicable law.
In the event that the User deletes their account, the Company retains necessary User data for the period required by applicable law.
3.2.2. Transfer of Information.
User Information is not transferred to any third parties, except as expressly provided in this Policy. The Company may transfer Information to third parties exclusively within the established purpose and on legal grounds. Such parties may include:
(a) service providers — companies that provide hosting, analytics (in anonymous form), notification delivery and other infrastructure necessary for the operation of the Service. Such parties act in accordance with the Company’s instructions and are required to comply with confidentiality requirements;
(b) parties engaged by the Company to perform the Agreement, including mobile network operators and technology partners involved in implementing the Service functionality;
(c) parties providing the Company with mobile analytics and/or web analytics services for the purpose of obtaining aggregated statistical and/or analytical information;
(d) competent state authorities — transfer of Information is carried out strictly in accordance with the procedure and on the grounds provided by applicable law, including in response to an official and lawful request (written request, order, court act). When fulfilling such a request, a mandatory legal assessment of its lawfulness and reasonableness is conducted. The Company provides only the minimum amount of data expressly required under applicable law.
Cross-border transfer of data. As part of using Firebase Cloud Messaging (Google LLC, USA) for delivering push notifications to the User’s device, technical device information is transferred to Google LLC. This transfer is based on the User’s consent given at the time of application installation and is governed by Google’s Privacy Policy (https://policies.google.com/privacy). No other cross-border transfer of Users’ personal data is carried out.
The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
3.2.3. Cessation of Information Processing.
Upon achieving the purposes of processing Information or upon termination of the legal grounds for processing, the Company shall cease processing Information. Notwithstanding the foregoing, the Company may continue processing Information where there are lawful grounds under applicable law.
4. Rights and Obligations of Users
4.1. Users have the right to:
4.1.1. request that the Company rectify, block or delete their data if such data is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purpose of processing;
4.1.2. obtain from the Company, upon request, information concerning the processing of their personal data;
4.1.3. receive their data in a structured, machine-readable format (right to data portability);
4.1.4. withdraw previously given consent to the processing of personal data in the part based on such consent;
4.1.5. opt out of analytics data collection by submitting a request to privacy@solovo.app;
4.1.6. exercise other rights provided by applicable personal data protection legislation.
4.2. To exercise the rights set out in this section, the User submits a request to: privacy@solovo.app. The request must include the User’s name, username and phone number, and describe which right the User wishes to exercise. The Company processes requests within no more than 10 business days from receipt. In certain cases, additional verification of the User’s identity may be required.
4.3. The User may delete their account by submitting a request to support@solovo.app or by using the relevant feature in the Messenger settings. After deletion is confirmed, all User data will be permanently destroyed within 10 days.
5. Measures to Protect User Information
5.1. The Company implements technical and organisational measures to protect User Information against unlawful or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions.
5.2. Technical protection measures include:
- encryption of the data transmission channel (TLS/WSS);
- encryption of data at rest (AES-256);
- server infrastructure protection (firewalls, DDoS protection);
- regular security assessments and independent audits;
- SMS verification upon every account login.
5.3. Organisational protection measures include:
- training of employees on privacy and information security matters;
- access control based on the principle of least privilege;
- regular review and update of information security policies and procedures;
- an incident response plan for data security incidents.
5.4. Information is processed automatically without access by the Company’s employees and/or contractors. Where such access is granted, it is only to the extent necessary for the performance of their duties. Such persons are required to comply with security and confidentiality requirements.
5.5. In the event of a data breach that may pose a risk to the rights and freedoms of Users, the Company undertakes to:
- notify Users within 72 hours of becoming aware of the incident;
- disclose the nature of the breach and the measures taken;
- provide protective recommendations;
- notify the relevant supervisory authorities where required by applicable law.
5.6. Users are also responsible for the security of their devices and credentials. The Company recommends:
- using strong passwords/PIN codes to lock the device;
- keeping the operating system and Messenger version up to date;
- not sharing credentials with third parties;
- using only official versions of the Messenger;
- not sharing SMS verification codes with third parties.
6. Minor Users
6.1. The Service is not intended for persons under the age of 13 (or such other minimum age as established by the law of the User’s country of residence). By registering for the Service, the User confirms that they have reached the specified age.
6.2. The Company does not knowingly collect personal data from persons who have not reached the age specified in clause 6.1 of this Policy. If the Company becomes aware that personal data of such a person was collected without the appropriate consent of parents or legal guardians, the Company will take all necessary measures to delete such data without delay.
6.3. Parents and legal guardians have the right to contact the Company to request deletion of a minor’s personal data and to obtain information about the processing of such data at: privacy@solovo.app.
7. User Inquiries
7.1. Information about the processing of the User’s personal data in connection with their use of the Service is provided to the User or their representative upon application (request).
7.2. Requests are submitted in writing to the Company’s registered address or electronically in accordance with the requirements of applicable law.
7.3. Contact information:
SOLOVO LLC
Address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street
Registration number: 286.110.1225108
General enquiries: support@solovo.app
Privacy enquiries: privacy@solovo.app; response time: 10 business days.
8. Regulatory Compliance
8.1. This Privacy Policy has been developed in accordance with:
- Google Play Store and Apple App Store requirements regarding privacy policies of mobile applications;
- the General Data Protection Regulation (GDPR) of the European Union — to the extent applicable to Users from the EU;
- other applicable international and national acts in the field of personal data protection.
8.2. The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
Version dated 01.04.2026
EN
RU
Privacy Policy
of the Instant Messaging Service
“Solovo”
Effective date: 1 April 2026
1. General Provisions
1.1. This Privacy Policy of the “Solovo” service (hereinafter — the “Policy”) is an official document of Limited Liability Company “NASA2” (TIN: 02856493, Registration number: 286.110.1225108, registered address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street) (hereinafter — the “Company”), and establishes the procedure for processing and protecting information (hereinafter — the “Information”) about individuals (hereinafter — “Users”, “You”) who use the instant messaging service “Solovo” (hereinafter — the “Service”, the “Messenger”) under the User Agreement (hereinafter — the “Agreement”).
1.2. The current version of this Policy is always available at: https://solovo.app/privacy.
1.3. The Company may unilaterally amend this Policy by publishing changes and/or a new version at the link above. Any amendments take effect upon publication, unless otherwise specified in the new version. If the User disagrees with this Policy and/or any amendments thereto, the User must immediately cease using the Service.
1.4. By using the Service, the User confirms that they have read and agree to this Policy.
1.5. The following key terms and definitions are used in this Policy:
Instant messaging service (Messenger) “Solovo” — a software application designed and used exclusively for the exchange of electronic messages between its users, whereby the sender designates the recipient(s) and the application does not provide for the posting of publicly available information on the internet.
User — an individual who has legal capacity under applicable law and has registered an account in the Solovo Messenger by providing a mobile phone number.
2. Composition of User Information and Purposes of Processing
2.1. The Company processes the following User data, the content, legal bases and purposes of which are set out in the table below:
Data Category
Specific Data
Purpose & Legal Basis
Retention Period
Identification Data
Phone number, username
Account registration and authentication. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
Profile Data
First name, last name, profile photo (optional)
Interface personalisation. Legal basis: performance of the Agreement
For the entire duration of the account, but no less than 3 years
User Content
Messages, media files, documents
Provision of Service functionality. Legal basis: performance of the Agreement
No less than 6 months
Contacts
Phone book contacts (if permission is granted)
Finding users within the Service. Legal basis: User consent
Not stored on the Company’s servers; used once to find users and not cached
Technical Data
Device model, OS, Messenger version, IP address, network type
Compatibility, debugging, security. Legal basis: performance of the Agreement
90 days
Usage Data
Activity timestamps, features used, clicks and navigation
Analytics, Service improvement. Legal basis: User consent (may be disabled)
Anonymised — 1 year
Crash Data
Error logs, stack traces
Bug fixing, stability assurance. Legal basis: performance of the Agreement
30 days
Message Metadata
Send time, file size, content type
Message delivery, Service optimisation. Legal basis: performance of the Agreement
No less than 6 months
2.2. The Company collects and subsequently records, systematises, accumulates, stores, clarifies (updates, modifies) and retrieves Information in order to operate and provide the Service. The Company does not intentionally collect or process special categories of personal data or biometric data.
2.3. The functionality and terms of use of the Service may permit Users to post information other than that specified in clause 2.1 of this Policy, provided it does not conflict with applicable law. By posting personal information, the User acknowledges that such information may be accessible to other Users in accordance with their privacy settings.
2.4. The Messenger uses the following third-party services to provide its functionality:
2.4.1. Google Play Services — provides application updates and licensing. Data collected: device identifier, installation information. Google Privacy Policy: https://policies.google.com/privacy.
2.4.2. Firebase Analytics (optional) — anonymous analytics of Service feature usage. Users may request disabling of data collection by contacting privacy@solovo.app. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.3. Firebase Crashlytics — error tracking and resolution. Collects error logs and technical device information. Privacy Policy: https://firebase.google.com/support/privacy.
2.4.4. Hosting provider — data storage and Service infrastructure. All data is stored in compliance with applicable personal data protection requirements.
2.5. Cookie Processing. The Service may use cookies when the User accesses it through the web interface. Cookies are small data fragments stored locally on the User’s device that enable the correct operation and personalisation of the Service. The User may opt out of cookie processing in their browser settings, in which case the Company will use only strictly necessary cookies required for the Service to function.
3. Processing of User Information
3.1. Processing of User Information is carried out in accordance with the following principles:
3.1.1. lawfulness of the purposes and methods of processing Information;
3.1.2. good faith;
3.1.3. compliance of the purposes of processing Information with the purposes determined and declared at the time of collection;
3.1.4. proportionality of the volume and nature of Information processed, and the methods of processing, to the purposes of processing;
3.1.5. inadmissibility of combining databases containing Information that were created for incompatible purposes.
3.2. The Company processes Information through collection, recording, systematisation, accumulation, storage, clarification (updating, modification), matching, retrieval, use, transfer, blocking, deletion and destruction.
3.2.1. Storage and Use of Information.
Information about the User is processed and stored exclusively on electronic media using automated systems, except where non-automated processing is required in connection with compliance with applicable legal requirements.
Information is retained by the Company until the purposes of processing are achieved and while legal grounds exist, and after termination of the Agreement — for the period required by applicable law.
In the event that the User deletes their account, the Company retains necessary User data for the period required by applicable law.
3.2.2. Transfer of Information.
User Information is not transferred to any third parties, except as expressly provided in this Policy. The Company may transfer Information to third parties exclusively within the established purpose and on legal grounds. Such parties may include:
(a) service providers — companies that provide hosting, analytics (in anonymous form), notification delivery and other infrastructure necessary for the operation of the Service. Such parties act in accordance with the Company’s instructions and are required to comply with confidentiality requirements;
(b) parties engaged by the Company to perform the Agreement, including mobile network operators and technology partners involved in implementing the Service functionality;
(c) parties providing the Company with mobile analytics and/or web analytics services for the purpose of obtaining aggregated statistical and/or analytical information;
(d) competent state authorities — transfer of Information is carried out strictly in accordance with the procedure and on the grounds provided by applicable law, including in response to an official and lawful request (written request, order, court act). When fulfilling such a request, a mandatory legal assessment of its lawfulness and reasonableness is conducted. The Company provides only the minimum amount of data expressly required under applicable law.
Cross-border transfer of data. As part of using Firebase Cloud Messaging (Google LLC, USA) for delivering push notifications to the User’s device, technical device information is transferred to Google LLC. This transfer is based on the User’s consent given at the time of application installation and is governed by Google’s Privacy Policy (https://policies.google.com/privacy). No other cross-border transfer of Users’ personal data is carried out.
The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
3.2.3. Cessation of Information Processing.
Upon achieving the purposes of processing Information or upon termination of the legal grounds for processing, the Company shall cease processing Information. Notwithstanding the foregoing, the Company may continue processing Information where there are lawful grounds under applicable law.
4. Rights and Obligations of Users
4.1. Users have the right to:
4.1.1. request that the Company rectify, block or delete their data if such data is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purpose of processing;
4.1.2. obtain from the Company, upon request, information concerning the processing of their personal data;
4.1.3. receive their data in a structured, machine-readable format (right to data portability);
4.1.4. withdraw previously given consent to the processing of personal data in the part based on such consent;
4.1.5. opt out of analytics data collection by submitting a request to privacy@solovo.app;
4.1.6. exercise other rights provided by applicable personal data protection legislation.
4.2. To exercise the rights set out in this section, the User submits a request to: privacy@solovo.app. The request must include the User’s name, username and phone number, and describe which right the User wishes to exercise. The Company processes requests within no more than 10 business days from receipt. In certain cases, additional verification of the User’s identity may be required.
4.3. The User may delete their account by submitting a request to support@solovo.app or by using the relevant feature in the Messenger settings. After deletion is confirmed, all User data will be permanently destroyed within 10 days.
5. Measures to Protect User Information
5.1. The Company implements technical and organisational measures to protect User Information against unlawful or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions.
5.2. Technical protection measures include:
- encryption of the data transmission channel (TLS/WSS);
- encryption of data at rest (AES-256);
- server infrastructure protection (firewalls, DDoS protection);
- regular security assessments and independent audits;
- SMS verification upon every account login.
5.3. Organisational protection measures include:
- training of employees on privacy and information security matters;
- access control based on the principle of least privilege;
- regular review and update of information security policies and procedures;
- an incident response plan for data security incidents.
5.4. Information is processed automatically without access by the Company’s employees and/or contractors. Where such access is granted, it is only to the extent necessary for the performance of their duties. Such persons are required to comply with security and confidentiality requirements.
5.5. In the event of a data breach that may pose a risk to the rights and freedoms of Users, the Company undertakes to:
- notify Users within 72 hours of becoming aware of the incident;
- disclose the nature of the breach and the measures taken;
- provide protective recommendations;
- notify the relevant supervisory authorities where required by applicable law.
5.6. Users are also responsible for the security of their devices and credentials. The Company recommends:
- using strong passwords/PIN codes to lock the device;
- keeping the operating system and Messenger version up to date;
- not sharing credentials with third parties;
- using only official versions of the Messenger;
- not sharing SMS verification codes with third parties.
6. Minor Users
6.1. The Service is not intended for persons under the age of 13 (or such other minimum age as established by the law of the User’s country of residence). By registering for the Service, the User confirms that they have reached the specified age.
6.2. The Company does not knowingly collect personal data from persons who have not reached the age specified in clause 6.1 of this Policy. If the Company becomes aware that personal data of such a person was collected without the appropriate consent of parents or legal guardians, the Company will take all necessary measures to delete such data without delay.
6.3. Parents and legal guardians have the right to contact the Company to request deletion of a minor’s personal data and to obtain information about the processing of such data at: privacy@solovo.app.
7. User Inquiries
7.1. Information about the processing of the User’s personal data in connection with their use of the Service is provided to the User or their representative upon application (request).
7.2. Requests are submitted in writing to the Company’s registered address or electronically in accordance with the requirements of applicable law.
7.3. Contact information:
SOLOVO LLC
Address: Republic of Armenia, Yerevan, Nork-Marash district, 44/26 Charents Street
Registration number: 286.110.1225108
General enquiries: support@solovo.app
Privacy enquiries: privacy@solovo.app; response time: 10 business days.
8. Regulatory Compliance
8.1. This Privacy Policy has been developed in accordance with:
- Google Play Store and Apple App Store requirements regarding privacy policies of mobile applications;
- the General Data Protection Regulation (GDPR) of the European Union — to the extent applicable to Users from the EU;
- other applicable international and national acts in the field of personal data protection.
8.2. The Company may instruct affiliated persons who are able to provide Service analytics services to process the collected User data to the extent set out in this Policy, for the purposes of improving the quality of services provided, countering fraudulent activity and creating a safe environment for using the Service.
Version dated 01.04.2026