PRIVACY POLICY

Last updated June 23, 2026

This Privacy Notice for Divpreet Dhingra (doing business as Vavvy) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at https://www.vavvy.app or any website of ours that links to this Privacy Notice

Use Vavvy. Vavvy is a creator loyalty platform that lets fans claim digital Wallet passes, earn experience points through creator engagement, receive personalized loyalty updates, and access a creator’s latest content. Creators use Vavvy to manage fan memberships, send Wallet pass updates, and view aggregate engagement analytics.

Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@vavvy.app.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://vavvy.app/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

14. THIRD-PARTY PLATFORM INTEGRATIONS

15. SERVICE USAGE, CREATOR ANALYTICS, AND PUBLIC PROFILES

16. DO WE MAKE UPDATES TO THIS NOTICE?

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names

email addresses

usernames

passwords

contact or authentication data

date of birth

city, state or province, and country

creator-submitted social media profile information and account identifiers

creator-submitted content and links

billing addresses

fan profile information, such as display names, usernames, and any avatars or profile images a user may choose to provide

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Payments and subscriptions are processed by Stripe. Vavvy does not directly collect or store complete payment-card numbers. Stripe may process payment, billing, transaction, device, and related information in accordance with its privacy policy. Vavvy receives limited billing and transaction information needed to create and manage subscriptions, confirm payment status, and provide customer support.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://vavvy.app/cookie-policy.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Google API
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

If you interact with us on a social media platform using your social media account (e.g., Facebook or X), we receive personal information about you from such platforms such as your name, email address, and gender. You may have the right to withdraw your consent to processing your personal information. Learn more about withdrawing your consent. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that their own use of your information is not governed by this Privacy Notice.

2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

To create and manage accounts and memberships. To create, authenticate, maintain, and administer creator accounts, fan accounts, memberships, and associated Apple Wallet passes.

To connect creator platforms and deliver creator features. To connect authorized social media accounts, retrieve permitted profile and content information, detect creator content, route fans to creator content, and deliver creator updates through Apple Wallet passes.

To provide loyalty, analytics, and service-security features. To record eligible clicks and engagement activity, calculate XP and loyalty status, provide creator-facing analytics, prevent misuse, troubleshoot errors, and maintain the security and functionality of the Services.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services

Analyze how our Services are used so we can improve them to engage and retain users

Diagnose problems and/or prevent fraudulent activities

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

Payment Processors

Cloud Computing Services

Data Storage Service Providers

User Account Registration & Authentication Services

Website Hosting Service Providers

Social Networks

Digital wallet and push-notification service providers

Content creators and other members of creator communities

Communication & Collaboration Tools

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://vavvy.app/cookie-policy.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than one (1) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to minors.

Vavvy is a general-audience service and is not directed to children under 13 years of age. Fans must be at least 13 years old to use the Services. Creator accounts, social-media integrations, and paid creator subscriptions are available only to individuals who are at least 18 years old. Users between 13 and 17 years old may use the fan-facing portions of the Services with the permission of a parent or legal guardian where required by applicable law. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will deactivate the associated account and take reasonable steps to promptly delete the information. If you believe that a child under 13 has provided personal information to us, please contact us using the contact information provided in this Privacy Policy.

10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by By deleting the digital wallet pass from their device or disabling 'Allow Notifications' on the back of the pass., or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://vavvy.app/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at privacy@vavvy.app.

11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES

B. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	YES
C. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
D. Biometric information	Fingerprints and voiceprints	NO
E. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
F. Geolocation data	Device location	YES
G. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	YES
H. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
I. Education Information	Student records and directory information	NO
J. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
K. Sensitive personal Information		NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete or anonymize the information, except that we may retain limited records for longer where reasonably necessary to comply with legal, tax, or accounting obligations; prevent fraud or protect security; resolve disputes; enforce agreements; or maintain temporary backups subject to defined deletion schedules.

Category B - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete or anonymize the information, except that we may retain limited records for longer where reasonably necessary to comply with legal obligations, protect security, prevent fraud, resolve disputes, enforce agreements, or maintain temporary backups subject to defined deletion schedules.

Category C - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete or anonymize ordinary purchasing and subscription profile information, except that we may retain limited transaction, invoice, payment, refund, chargeback, tax, accounting, fraud-prevention, security, dispute, and enforcement records for longer where reasonably necessary or legally required. Temporary backup copies may also remain until deleted under our backup retention schedules.

Category E - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete or anonymize identifiable activity information, except that we may retain limited aggregated, anonymized, security, fraud-prevention, dispute, and enforcement records for longer where reasonably necessary, as well as temporary backup copies subject to defined deletion schedules.

Category F - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete or anonymize identifiable location information, except that we may retain limited aggregated or anonymized regional information, limited security or fraud-prevention records, and temporary backup copies for longer where reasonably necessary and subject to defined retention schedules.

Category G - For the duration of the user’s account and up to 30 days after account termination or a deletion request. After that period, we delete uploaded visual information, except that temporary backup copies may remain until deleted under defined backup retention schedules and limited records may be retained where reasonably necessary for security, fraud prevention, dispute resolution, or legal compliance.

Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Category A. Identifiers

Category B. Characteristics of protected classifications under state or federal law

Category C. Commercial information

Category E. Internet or other electronic network activity information

Category F. Geolocation data

Category G. Audio, electronic, visual, and similar information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request the deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to non-discrimination for exercising your rights

Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

How to Exercise Your Rights
To exercise these rights, you can contact us by visiting https://vavvy.app/contact, by emailing us at privacy@vavvy.app, by visiting https://vavvy.app/contact, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

offer you the products or services that you want

respond to or help with your requests

manage your account with us

confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

14. THIRD-PARTY PLATFORM INTEGRATIONS
Vavvy allows creators to connect, designate, or otherwise associate accounts and channels from third-party platforms, including TikTok, Instagram, and YouTube, with the Vavvy service. These integrations are optional and are used to identify newly published creator content, display connected content in the creator dashboard, route fans to creator content, provide related creator analytics, and update or support creator Wallet-pass experiences. TikTok and Instagram. When a creator authorizes a TikTok or Instagram integration, we may receive and process information permitted by the creator and the applicable platform, such as a platform-specific account identifier, username, display name, profile image, profile URL, connected-account status, access and refresh tokens, and public account or media information. Depending on the permissions granted and features enabled, media information may include media or video identifiers, URLs, captions or descriptions, thumbnails, media type, publication timestamps, update timestamps, and account or media insights made available through the applicable platform. We also process operational information relating to authorization, token refreshes, webhook events, synchronization status, errors, and disconnection. Creators may disconnect an authorized TikTok or Instagram account through the controls we make available or by revoking Vavvy’s access through the applicable platform. Disconnecting an account stops future authorized access and may disable related synchronization, routing, analytics, and Wallet-update functionality. Following disconnection or a valid deletion request, we will revoke or invalidate applicable access credentials and delete or de-identify connected-platform information that we no longer need, subject to the retention practices, legal obligations, fraud-prevention needs, security requirements, dispute-resolution needs, and backup schedules described elsewhere in this Privacy Policy. YouTube. Vavvy uses YouTube API Services and public push-notification or subscription technologies to monitor a public YouTube channel designated by a creator. Vavvy may receive and process public information such as the channel identifier and URL, video identifiers and URLs, video titles and descriptions, thumbnails, publication and update timestamps, and operational information relating to subscriptions, callbacks, synchronization, and errors. Vavvy may associate this information with Vavvy-generated routing, Wallet-update, and aggregate engagement records. The current YouTube integration does not require Vavvy to receive a creator’s YouTube password and is not intended to access private videos, private watch history, private subscriptions, or private account-management functions. Vavvy does not upload, modify, or delete a creator’s YouTube content through this public monitoring feature. A creator may request that Vavvy stop monitoring a designated channel. When monitoring ends, we may unsubscribe from future updates and delete or de-identify the applicable channel association and cached public metadata, subject to the retention exceptions described in this Privacy Policy. Use of information obtained from TikTok, Instagram, and YouTube is also subject to the applicable third-party platform’s terms, policies, permissions, and technical limitations. Vavvy does not sell connected-platform information or use it for cross-context behavioral advertising. We may disclose such information to service providers that process data on our behalf as necessary to host, secure, maintain, troubleshoot, and provide the Vavvy service.

15. SERVICE USAGE, CREATOR ANALYTICS, AND PUBLIC PROFILES
When creators and fans use Vavvy, we may collect or generate information about their use of and interactions with the Service, including information associated with creator communities, memberships, Wallet passes, links, referrals, content interactions, loyalty features, leaderboards, and related device or technical activity. We use this information to provide, maintain, personalize, secure, and troubleshoot the Service; operate Wallet, engagement, loyalty, leaderboard, and referral features; prevent fraud or misuse; and provide creators with information about the performance and participation of their communities. Creator-facing analytics may include aggregated or summarized engagement, platform, referral, loyalty-participation, and general regional information. Certain fan-provided or service-generated profile and participation information may be displayed individually to creators, other members of a creator community, or the public through leaderboards and related social or loyalty features. When a fan joins a Creator’s community or adds that Creator’s Vavvy pass, this information may be displayed automatically and may include the fan’s display name, username, leaderboard position, XP or other loyalty progress, tier, level, streak, status, badges, or similar profile and participation information. If Vavvy allows fans to provide avatars or profile images, those images may also be displayed through these features. We do not provide creators with fans’ account credentials, Wallet authentication or push tokens, private device-registration information, full account records, or email addresses merely because a fan joins a creator’s community. We do not sell this information to advertisers or use it for cross-context behavioral advertising. We retain and delete this information as described elsewhere in this Privacy Policy.

16. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at privacy@vavvy.app or contact us by post at:

Divpreet Dhingra

San Jose, CA

United States

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://vavvy.app/contact.

This Privacy Policy was created using Termly's Privacy Policy Generator