Effective as of June 3, 2024

When you use vaffli, you are trusting us with personal information. We are committed to keeping that trust, which is why our policy as a company is to take every step to ensure that individual user's data and privacy rights are protected and to provide transparency about our data practices.


The primary purpose of our Privacy Policy is to provide a clear understanding of what data we collect, how it is used and shared, and how you can control it.
We recommend that you read this Privacy Policy in full along with our Terms of Use, but here are a few key takeaways we hope you will find useful:

• The data that serves you

When you use vaffli, we may collect your Personal Data and use it to improve the user experience, such as increasing the accuracy of predictions, personalizing the insights you get, etc. For research activities we use only de-identified or aggregated data, which can not be associated with you.

• You can contribute to the growth of vaffli community

Provided we receive your consent, we may use technical information about you (your unique technical identifier, age group, subscription status, and the fact of application launch) for promotion purposes to reach more people like you. You can always withdraw your consent to share this data.

• You are in control

You may access your Personal Data, modify, correct, erase, and update it by writing to us at support@vaffli.com

• We protect the privacy of children

That is why you should be at least 16 to use vaffli. We do not intentionally collect information about children, and we do not allow people to use the App if they are younger than 16.

• Data transfers are under legal control

vaffloi complies with the EU - U.S. Privacy Shield Framework and Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce.

• You can freely talk to us

We believe in transparent and open dialogue, so we strongly encourage you to contact our Support Team or send a message via our dedicated email if you have questions about this policy, how we collect or process your Personal Data, or anything else related to our privacy practices.

Introduction
This Privacy Policy explains how vaffli (“Company” or “we” or “us”) collects, stores, uses, transfers and shares Personal Data from our users (“you”) in connection with:

• the vaffli mobile application,
• vaffli website ("Website"),

(all collectively, the “App”).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Policy explicitly. Please review our Website and the App for the latest updates on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

General Information
When you sign up to use the App, we may collect Personal Data about you such as:

• Full name;
• Email address;
• Gender;
• Date of birth;
• Place of residence and associated location information;
• ID (to prove your identity in certain cases).

Personal Data we may collect automatically
When you access or use the App, we may automatically collect the following information:

• Hardware model;
• Device Information:
• Information about the operating system and its version;
• Unique device identifiers (e.g. IDFA);
• Mobile network information.

Location Information:

• IP address;
• Time zone;
• Information about your mobile service provider.

App usage data, including, among others:

• Frequency of use;
• Areas and features of our App you visit;
• Your use patterns generally;
• Engagement with particular features.

To collect this information, we may also send cookies to your mobile device or computer or engage other tracking technologies. Cookies are small data files stored on your hard drive or in device memory.

Data from external sources. We may use third-party tools like AppsFlyer that provide us some of your attribution data that we further utilize to customize and personalize your App experience. We may also use such data for statistical purposes and analytics.

How we use your Personal Data
We may use your Personal Data for the following purposes:

• to analyze, operate, maintain and improve the App, to add new features and services to the App, to support the existing functions of the App
• to customize content and materials you see when you use the App
• to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders
• to customize product and service offerings and recommendations to you, including third-party products and offerings. You can opt-out anytime by contacting us at support@vaffli.com
• to verify your identity when it is required by law
• to send you technical notices, updates, security alerts and support and administrative messages
• for billing (invoicing), account management and other administrative purposes, if applicable
• to respond to your comments, questions and requests and to provide customer service
• to monitor and analyze trends, usage and activities in connection with our App
• solely with respect to information that you mark for sharing, for Company promotional purposes
• to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service, to use in training AI
• for scientific and academic research purposes
• for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy

Principles of processing

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly needed for the mentioned purposes.

No sale of Personal Data. We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy.


Your privacy rights
It does not matter what country or region you come from. We are committed to providing you vast privacy rights for your Personal Data.


Correction of Personal Data
If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data.


Restriction of Processing
You also have a right to request that the processing of your Personal Data be restricted, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.

Information rights and access to your Personal Data (including in portable form)
The App gives you the ability to access Personal Data within the App. You have a right to request information about what Personal Data we have about you, to access all your Personal Data and receive a copy of it, including in a structured and portable form (.json).

Erasure of your Personal Data
You may ask us to erase your Personal Data, if you withdraw your consent to processing, if you believe such processing is not compliant with applicable law and in some other cases. Please be aware that erasing some Personal Data may affect your ability to use the App and its features.



Personalization of content.
We personalize the content you see in the App based on Personal Data that you insert into the App. You have a right to opt-out from such automated decision-making. Please note that this may affect your App experience.

How to exercise your privacy rights
Сontact us at support@vaffli.com to exercise any of your privacy rights.
We will exercise them within 30 days after receipt. It may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.

What else?
Please keep in mind that if we receive a vague request, we may engage the individual to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.
We might also require you to prove your identity in some cases. This is made to ensure that no rights of third parties are violated by your request.

Notification requirements.
We commit to notify you, when it is needed under the law, within a reasonable period of time and your data protection authority within the timeframe specified in applicable law about Personal Data breaches related to your Personal Data.

Data Protection Authorities.
Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with applicable law.

Third parties processing your Personal Data
We will not share your Personal Data with any third parties except as specified below.
Processing to find new planzz users
To accomplish the above-mentioned goal, we may share certain Personal Data with the integrated partners as indicated below.

Here is a step-by-step description of how we utilize our partners:

1. You become a vaffli user and opt-in for sharing Personal Data, strictly limited to the following set:
a) Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Android ID (in Android devices), Google Advertiser ID, Customer-issued user ID and other similar unique technical identifiers.
b) Your subscription status;
c) The fact of application launch.

2. App sends your data to our partners, which analyze it and provide us reports and insights on how to optimize our promotional campaigns.

3. At the same time, our partners send your data to some of their integrated partners to find people like you on different platforms, including social media websites. These integrated partners analyze your data (so-called “custom audience”) and show relevant information about the App to people who might be potentially interested in it or remind you about revisiting the App, if you stopped using it (so-called “lookalike audience”).

4. This is how you and new users find out more about planzz. You contribute to the growth of the planzz community by providing your consent to use the planzz app.


Opt-out options. You can withdraw your consent to sharing of your Personal Data in accordance with this subsection anytime by using one of the following options:

1. By contacting us at support@vaffli.com
2. By adjusting your device settings in iOS or Android in order to stop sharing your IDFA or Android Advertising ID with any third parties. In this case no third party will be able to utilize your Personal Data in accordance with this Section of the Privacy Policy.

Processing to make the App run
We engage processors that perform particular operations with your Personal Data for us.

Processors are companies that help us run the App, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. Processors act only in accordance with our instructions and process only such amounts of Personal Data as we instruct them to process. We remain fully liable for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.

Here is the list of our main processors:

• AWS (Amazon Web Services, Inc.)
• SendGrid (SendGrid, Inc.)
• SurveyMonkey (SurveyMonkey Inc.)
• Apple. Inc.
• Zendesk (Zendesk Inc.)
• Looker (Looker Data Sciences, Inc.)
• Google
• Stripe (Stripe, Inc)

Aggregated information
We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, with our partners or research institutions.


Special circumstances
We may also share some of your Personal Data in the following special circumstances:

• in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);
• when disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal Data (e.g. resetting your password to avoid unauthorized access);
• when disclosure is directed or consented to by the user who has input the Personal Data;
• in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

Retention of your personal data
We will retain your Personal Data as long as your account is active or needed to provide you Services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can erase your Personal Data in accordance with the Privacy Policy.

After you stop using the App
If you choose to delete the App or deactivate your account, or your account becomes inactive for a while, we will retain your Personal Data for a reasonable period in case you decide to re-activate the Services.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated or deleted in an aggregated, anonymized form. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

Personal Data you elect to share with third parties
Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern the processing of your Personal Data.

Security of your Personal Data
We take all reasonable and appropriate measures to protect all Personal Data collected from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:

• Pseudonymization and tokenization of certain categories of your Personal Data;
• Encryption of your Personal Data in transit and in rest;
• Systematic vulnerability scanning and penetration testing;
• Protection of data integrity;
• Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
• Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of the Company’s merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information will not be intercepted while being transmitted to us.


Security breaches
If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in Section 3 of the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach, including, but not limited to, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to the App please contact us at security@vaffli.com

Children’s privacy
General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 16 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 16. If you are aware of anyone under 16 using the App, please contact us at support@vaffli.com and we will take the required steps to delete such information and (or) delete her account.


Age limitation for the European Union residents.
Due to legal requirements you shall be at least 16 years old to use the App. We do not allow the use of the App by the European Union residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at support@planzz.me and we will take steps to delete such information and (or) delete her account.

Communications
We may contact you from time to time via email or through other means to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end the transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us. We may ask such users to provide their consent for any such communications at the registration screen or separately.

Storage and international Personal Data transfers
The Company is based in the United States, and Personal Data we collect is governed by U.S. law. Please be advised that U.S. law and laws of other countries may not offer the same protections as the law of your jurisdiction.

In addition, you agree that Personal Data collected may be stored and processed in Canada and the United States, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of Personal Data outside of your country.
European Union and Swiss residents


Please bear in mind that we may transfer your Personal Data to the United States whose data protection is not deemed adequate under applicable data protection law.
However, we comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles (the “Principles”), the Privacy Shield Principles shall govern.

Complaints and Dispute Resolution
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at support@vaffli.com