Budigo Privacy Policy Introduction Welcome to the Budigo Privacy Policy! This policy explains how we collect, store, protect, and share your information. Please read this policy in conjunction with our Terms of Use when using Budigo. While using the Budigo mobile application (“App”) and our websites (“Sites”), we collect certain information about you. Additionally, you may choose to share information with other users through the App or Sites. From time to time, we may also need to share your information with third parties. Budigo is a global platform, and your information may be processed internationally, regardless of your country of residence. Please read this policy carefully to understand how we protect your personal data when it is transferred across borders. Who We Are The Budigo mobile application and website are operated by YACHTINGVERSE TECHNOLOGIES LTD (“Budigo,” “we,” or “us”). We act as the data controller responsible for processing and managing your personal information. For any questions regarding data protection, you can contact us at privacy@budigo.io by post at the following address: 284 Chase Road, A Block, Unit 653, London, United Kingdom, N14 6HF 1. INFORMATION WE COLLECT Account Registration Details When you install and sign up on Budigo, we gather specific details to create your profile, which includes: Full name; Chosen username; Email address; Contact number; Gender identity; Birth details and zodiac sign (date, time, and place); Sexual orientation; Uploaded pictures; Geographical location; and Social media credentials for accounts linked to Budigo (such as Facebook or Instagram). Once your account is active, you can update most of these details anytime via the app settings. However, your date of birth and location (if location access is granted) will update automatically based on your device’s settings. Keeping your account details current is your responsibility, including updating your phone number if it changes. We use this information to improve the app experience and authenticate users. Some details, like your name, username, and preferences, may be visible to others viewing your profile. If you are a California resident, the data collected aligns with the California Consumer Privacy Act (CCPA) and includes: A. Personal identifiers such as name and location; B. Contact details like email and phone number; C. Voluntary demographic details such as gender identity, marital status, sexual orientation, ethnicity, religion, and health conditions; D. Transaction-related records and purchase history; E. Biometric verification data; F. Internet and device usage details; G. Geolocation tracking; H. Media files such as photos and videos; I. Work-related information like employment history; J. Education records; and K. Profile-based insights generated from collected information. Profile Information We advise you to be cautious when sharing personal details on your profile. Avoid listing contact details, addresses, credit card numbers, government-issued IDs, or other sensitive data that could be misused. The level of personal information you disclose via messages or public content is at your discretion. Refer to Section 4 for details on profile visibility and content sharing on Budigo. Identity Verification (Including Biometric Data) To enhance security and prevent fake accounts, Budigo may require identity verification. This process may involve phone number confirmation and, in some cases, a photo verification step. Users may also voluntarily verify their profiles for a ‘verified’ badge. Photo verification may include facial recognition technology to compare uploaded images with profile photos, ensuring authenticity. Verification images will not appear on your public profile, but we will store them securely for fraud prevention purposes for up to three years from your last activity. Payment Information If you purchase premium features, your payment details will be securely stored for fraud prevention, tax, and audit compliance. Budigo employs automated fraud detection to monitor transactions. If a transaction appears suspicious or violates our Terms of Service, it may be automatically declined. If your account is suspended due to fraudulent activity, linked accounts on other Budigo platforms may also be restricted. Location Data If you allow Budigo access to your location, we collect real-time data from GPS, Wi-Fi signals, and other sources to optimize features like profile matching and location-based searches. To disable location access: iPhone: Settings → Privacy → Location Services → Budigo Android: Settings → Location → Budigo → Permissions Device and Image Data We collect details about your device, such as model, operating system, and unique identifiers. If permitted, Budigo may access your contacts for connection suggestions. Additionally, we analyze user engagement with profile pictures to optimize their arrangement based on attractiveness and engagement levels. Users can disable this feature in settings. Tracking Links and User Interactions Budigo tracks link interactions within the app, including third-party services, to measure engagement. Aggregated data, such as the number of clicks on a specific link, may be recorded. Surveys, Testimonials, and Promotions We occasionally conduct surveys and may invite users to participate in testimonials or promotional campaigns. Participation is voluntary, and users can opt out by contacting our support team. Customer Support Communications When you reach out to our support team, we collect your email address, IP address, and any additional details you provide. Customer interactions, including complaints, are retained for six years post-account deletion. Cookies and Tracking Technologies We use cookies and similar tracking technologies to enhance user experience and personalize features. These technologies store small data files on your device to recognize and remember you. For details on cookie usage and management options, refer to our Cookie Policy. 2. HOW WE USE YOUR INFORMATION Our primary objective is to enhance your experience on Budigo and ensure it is both enjoyable and safe. To achieve this, we may use the data you provide us for the following purposes: Delivering our services and app features tailored to your needs; Sending you notifications about updates, new functionalities, and general app-related communications; Customizing your experience by personalizing content and recommendations; Analyzing usage data to better understand how you interact with the app and improve its functionality; Testing new technologies and optimizing platform performance; Addressing technical issues, resolving disputes, and ensuring compliance with our Terms of Service; Detecting and preventing fraud while protecting our legal rights; Sending promotional offers and marketing materials (only if you have opted in to receive them); Ensuring user safety and protecting the Budigo community. Our Matching Algorithms Budigo is designed to help users connect with people they are most compatible with. Our algorithms analyze various factors from your profile and app interactions, such as your swiping behavior, engagement patterns, and stated preferences, to suggest matches that align with your interests. We also consider geographical proximity to show potential connections within your vicinity. Additionally, Budigo incorporates zodiac compatibility into its matchmaking process, analyzing users’ birth details and current astronomical events to enhance match recommendations. Our recommendation system leverages machine learning to continuously refine matches and improve your overall experience. We do not process or store sensitive personal data such as beliefs or other explicitly personal identifiers in our matchmaking algorithms. The processing of your data for matchmaking purposes falls under contractual necessity as per Article 6(1)(b) of the GDPR. Moderation and Content Review To maintain a safe and positive environment, Budigo employs a combination of automated moderation tools and human review processes. Our moderation team monitors user-generated content, including profiles, images, and messages, to ensure compliance with our Terms of Service. Accounts found in violation may be subject to warnings, restrictions, or permanent suspension. Users who believe their account has been wrongfully restricted can appeal the decision through our support team. Budigo reserves the right to suspend or terminate accounts that violate our guidelines or pose risks to our community. Legal Grounds for Data Processing Under EU and UK data protection regulations, we are required to outline the legal basis for processing your data. Below is a breakdown of the purposes and corresponding legal justifications: Purpose Data Used Source Legal Basis To provide access to Budigo and its features Name, email, birthdate, location Provided by the user Contractual necessity To enable social networking on Budigo Profile details, sexual orientation, gender identity, interests Provided by the user Contractual necessity & legitimate interests To verify identity and prevent fraud Phone number, profile photo, government-issued ID (where required), location, device info Provided by the user, location from device Legitimate interests Processing payments for premium features Payment details Provided by the user Contractual necessity Sending marketing promotions Name, email, social media handle, phone number Provided by the user Consent or legitimate interests Conducting research and improving Budigo Log data, app usage patterns, device info Collected from app usage Legitimate interests Responding to user queries Email, IP address, social media username Provided by the user Legitimate interests Investigating policy violations User profile, messages, photos, IP session info Provided by the user, collected from device Legitimate interests Enhancing user experience Engagement metrics from profile interactions Collected from app usage Legitimate interests Enabling third-party login options Data from connected accounts (e.g., Facebook) Collected via third-party login Legitimate interests Preventing fraudulent payments Name, IP, email, transaction history Provided by the user, collected from device Legitimate interests Serving relevant ads on Budigo Age, gender, location, profile preferences Provided by the user, collected from device Legitimate interests Running targeted ads on external platforms Site visit data, IP, age, gender, device ID Collected via app interactions Consent (if opted-in) Conducting surveys and obtaining feedback Email, phone number Provided by the user Legitimate interests Enabling in-app video/audio features Call logs, images, videos Collected from app usage Legitimate interests Protecting legal rights and ensuring safety Any relevant user data Provided by the user, collected as needed Legitimate interests Student-Focused Enhancements Budigo may analyze historical location data to determine whether users are in college or university areas. This helps us tailor student-centric offers and events. However, we do not track real-time movements or store precise location details. We only keep a “campus yes/no” indicator and delete the data after processing. This process applies to Budigo users in the U.S. and Canada (excluding Quebec) aged 18 to 24. The legal basis for this activity is our legitimate interest in optimizing the student user experience. For more details on data usage, privacy controls, or opting out of specific processing activities, please refer to your Budigo app settings. 3. DISCLOSURE OF INFORMATION At Budigo, we are committed to protecting your personal data and do not share your Registration Information or personal details except in the specific situations outlined below: Circumstances where data may be disclosed Disclosed Data Service Providers – We collaborate with trusted third-party partners who assist us in delivering services such as hosting, customer support, analytics, and security operations. These entities may access certain personal data, but only to perform their designated functions. This may include all categories of personal data necessary for providing these services. Moderation Team – Our moderation team reviews content and monitors activity on Budigo to ensure compliance with our policies. User registration details, profile information, images, and message content. Payment Processors and Telecom Providers – To securely process payments for premium features. Cardholder details, payment history, billing address, and transaction timestamps. Legal Compliance & Safety Measures – We may disclose personal data in good faith if required to do so by law, legal proceedings, or regulatory authorities. This includes responding to valid legal requests, preventing fraudulent activity, protecting user safety, and enforcing our Terms of Service. Any relevant personal data necessary to comply with legal and security obligations. Business Transfers – In case of a merger, acquisition, reorganization, or sale of Budigo’s assets, user data may be transferred as part of the transaction. All user-related data stored by Budigo may be included in such transfers. Marketing & Advertising Partners – To assist with delivering personalized advertising and measuring the effectiveness of promotional campaigns on third-party platforms. Device ID, approximate location, age, gender, browsing behavior on Budigo, and hashed email addresses for targeted advertising. Fraud Prevention & Security Measures – To protect users from spam, fraudulent transactions, and unauthorized activities, we may share information within our internal security systems and affiliated platforms. Email address, phone number, IP details, device identifiers, and payment transaction data. Aggregated Insights – We may provide anonymized and aggregated data to partners for research, industry analysis, and improving user experience. This data does not directly identify individuals. Statistical insights derived from user behavior and demographics. We ensure that all disclosed information is shared securely and in compliance with applicable laws. If you have any questions regarding how your data is handled, please review Budigo’s Privacy Policy or reach out to our support team. MORE INFORMATION ABOUT DISCLOSURES Service Providers We collaborate with reliable third-party service providers to enhance Budigo’s functionality and user experience. The specific providers we work with depend on the features and services you use. Some of the key service providers we partner with include: Billing services – To enable secure payments for premium features (e.g., Google Play, Apple Pay). Authentication services – To verify accounts and enhance security (e.g., Twilio for phone number verification). Social media platforms – To allow users to connect their Budigo accounts with external platforms (e.g., Facebook, Instagram, or Spotify). Product improvement and market research – We work with research firms and survey platforms (e.g., Typeform, Kantar) to refine our services based on user feedback. IT and customer support services – External providers help process customer inquiries, security monitoring, and technical operations (e.g., cloud storage, customer support systems). All service providers undergo strict security assessments to ensure they handle your personal data responsibly. We limit the data shared with them to only what is necessary for their respective functions. We also require these providers to adhere to stringent contractual obligations, including data protection policies and retention limits. Marketing Service Providers We collaborate with marketing and advertising platforms to promote Budigo and analyze the effectiveness of our campaigns. These providers help us deliver tailored advertisements and measure user engagement. For example, we may use: Exclusion targeting – Ensuring existing Budigo users do not receive ads meant for new users. Retargeting campaigns – Displaying Budigo ads to individuals who have interacted with our app but have not yet registered. Lookalike Audiences – Identifying potential users with similar traits to existing Budigo members based on marketing provider data. Custom Audiences – Showing promotional content to users most likely to be interested in Budigo based on their past engagement. We share limited data with marketing providers, including: Device advertising identifiers (randomly generated unique IDs used to track ad engagement); Approximate location data (derived from IP addresses); Age and gender (if provided in your profile); App interaction details (such as registrations, purchases, and engagement metrics); A hashed* version of your email address for audience targeting. *Hashing converts your email into a secure, encrypted format before sharing it with marketing providers. This ensures that the data remains protected while enabling audience matching. For details on how we use cookies and tracking technologies, including how you can manage preferences, please refer to our Cookie Policy. Advertising and Third-Party Data Usage In some cases, marketing providers may use collected data for their own analytics and services. For instance, they might combine your interaction data with other user insights to refine their advertising strategies across multiple clients. Facebook Marketing Integration When we share data with Facebook (including via the Facebook “Like” feature), Budigo and Facebook Ireland are considered joint data controllers. This means that while Budigo provides this notice, you should contact Facebook directly for inquiries regarding your data protection rights. You can find further details in Facebook Ireland’s Data Policy. The information shared with Facebook may include user interactions with Budigo’s platform, as well as data collected through cookies and tracking tools like the Facebook Pixel. This helps us improve marketing effectiveness, optimize ad delivery, and present more relevant promotions to users on Facebook and similar social platforms. For any questions regarding Budigo’s data-sharing practices or your privacy rights, please contact our support team. 4. WHAT OTHERS MAY SEE ABOUT YOU At Budigo, we believe our users are amazing, and we want to make it easy for you to showcase your personality and connect with others. Our platform is designed to facilitate interactions between users, helping you discover meaningful connections. When using Budigo, keep in mind that any content you share—whether on your profile or through public interactions—may be visible to other users. This includes not only people actively using Budigo but also, in some cases, individuals outside of the platform. Therefore, we encourage you to be mindful of the information you choose to share publicly. We advise against posting sensitive personal details on your profile, such as medical information or any personally identifiable data that you wouldn’t want widely accessible. Budigo does not require users to disclose personal beliefs, political views, or religious affiliations. However, if you choose to include such details in your profile, please be aware that this information will be visible to other users. Additionally, images you upload to Budigo may reveal personal details about you. Other users may view and share the content you post, including by taking screenshots of your profile or sharing your public details with others. Keep this in mind when choosing what to display on your profile. Some users may log into Budigo using third-party accounts such as Facebook or Instagram. If you connect your Budigo profile with external platforms, certain information from those accounts may be visible within Budigo. Be sure to review and manage your privacy settings accordingly. If you are accessing Budigo on a shared device or through a third-party login, we strongly recommend logging out when you are finished to prevent unauthorized access to your account. Your privacy and security are important to us, and we encourage all users to be thoughtful about the information they share on Budigo. If you have any concerns, you can adjust your privacy settings within the app or reach out to our support team for assistance. 5. AGE REQUIREMENTS While we want as many people as possible to enjoy Budigo, our platform is strictly for users who are 18 years of age or older. Budigo does not knowingly collect data from, provide services to, or target individuals under the age of 18. If we discover that an underage individual has created an account and shared personal information, we will promptly take action to remove the account and delete any associated data. 6. SECURITY MEASURES At Budigo, we take security seriously and implement robust measures to safeguard your personal information from unauthorized access, misuse, or loss. Our platform employs advanced security protocols, including secure servers and firewalls, to help protect your data. While we strive to provide a secure experience, no online platform can guarantee absolute protection against cyber threats. To help enhance your security, consider the following best practices: Always log out of your account after using Budigo, especially on shared or public devices. Keep your login credentials confidential and avoid sharing your password with anyone. Update your password regularly to strengthen your account security. If you suspect that someone has accessed your account without permission, take immediate steps to reset your password and secure your profile. While we employ rigorous security measures, we cannot fully ensure the security of data during transmission over the internet. Users should exercise caution when sharing sensitive information online. 7. LINKING OTHER ACCOUNTS TO BUDIGO Signing in with Social Media Accounts Budigo allows users to sign in using their social media accounts for a seamless registration process. If you choose to sign in using Facebook, you authorize Facebook to share certain information with us, such as your name and profile picture. By default, Facebook may also share your email address (if linked to your Facebook account), date of birth, profile photos, gender, liked pages, and current city unless you opt out of sharing specific details. If you sign in using your Apple ID, Apple will share a login identifier, a name (which you can edit), and an email address with Budigo. Apple also provides an option to hide your actual email by creating a unique, randomized email address linked to your Budigo account. This ensures that your personal email remains private. We use this shared data to set up and personalize your Budigo account. If you later decide to unlink Budigo from your Facebook or Apple ID, we will no longer receive updated information from these platforms. However, any data previously shared during the initial account creation will remain in our system unless you delete your Budigo account entirely. Connecting Social Media Accounts to Your Budigo Profile Users can link their Budigo profile with other social media accounts such as Instagram, Facebook, or Spotify. This feature enables you to display select content from those platforms on your Budigo profile, such as Instagram photos or top artists from Spotify. Budigo only receives the limited data that these platforms allow for transfer, as outlined in their respective policies and agreed upon by you at the time of linking your accounts. If you decide to unlink any of these accounts from Budigo, you can do so by adjusting the settings within Instagram, Facebook, or Spotify. Please note that disconnecting an account will stop further data sharing, but any previously transferred content will remain visible on your Budigo profile until you manually remove it. 8. CALIFORNIA PRIVACY RIGHTS For users residing in California, you are entitled to specific rights under the California Consumer Privacy Act (CCPA), in addition to those outlined in Section 10. We are committed to ensuring that your rights under this law are protected, and you will not be discriminated against for exercising them. Your rights include: The right to request details about how we collect, use, and share your personal data over the past 12 months. The right to request the deletion of personal data that we have collected from you, subject to certain legal exceptions. Under California’s “Shine the Light” law (Civil Code section 1798.83), you may request information regarding our disclosure of personal data to third parties for direct marketing purposes. You can submit such a request by contacting us at privacy@budigo.io. From time to time, as part of special promotions in partnership with third parties, we may share your contact details with them so they can offer their services to you. If participation in such promotions requires sharing your details, we will always notify you beforehand and provide an option to opt out. California law also requires online service providers to disclose whether they respond to “Do Not Track” signals or similar mechanisms that allow users to opt out of data collection across different websites. At this time, Budigo does not track users’ personal information over time across third-party online services, nor do we knowingly permit third parties to collect personal data about users’ activities beyond Budigo’s platform. 9. YOUR RIGHTS Depending on the privacy laws in your country, you may be entitled to the following rights regarding your personal data: Right to be informed: You have the right to know what personal data we collect and why we collect it (as outlined in this Privacy Policy). Right of access: You may request a copy of the personal data we hold about you. Right to rectification: If any information we hold about you is inaccurate, you have the right to have it corrected. Right to erasure: You may request the deletion of your personal data in certain situations. Right to restrict processing: Under specific conditions, you can request that we limit how we process your data while retaining it. Right to data portability: You may request that we provide certain personal data in a machine-readable format that can be transferred to another service provider. Right to object: You can object to certain types of data processing, including processing based on legitimate interests or for direct marketing purposes. Rights related to automated decision-making and profiling: If we make decisions about you based solely on automated processing that significantly affects you, you have the right to request human intervention in the decision-making process. Your specific rights may vary depending on the privacy regulations in your country. We encourage you to familiarize yourself with the privacy laws applicable in your region. To exercise any of your rights, please visit our Support Center or email at privacy@budigo.io. You may also reach out to us by mail at the following address: 284 Chase Road A Block Unit 653, 2nd Floor, London, United Kingdom, N14 6HF. To protect your data, we may require verification of your identity before processing your request. If you have concerns about how we handle your personal data, we encourage you to contact us directly for resolution. If you feel that your concerns have not been adequately addressed, you may file a complaint with your country’s data protection authority. EU Representative In accordance with Article 27 of the General Data Protection Regulation (GDPR), Budigo has appointed DataProtect Ltd as its GDPR representative in the EU. If you reside in an EU Member State, you can contact DataProtect Ltd regarding GDPR matters via: Online request: privacy@budigo.io Postal address: 284 Chase Road A Block Unit 653, 2nd Floor, London, United Kingdom, N14 6HF For further information or assistance regarding your privacy rights, feel free to reach out to our support team. 10. DATA RETENTION AND DELETION We retain your personal information only for as long as necessary based on the legal grounds outlined in Section 2 and in compliance with applicable laws. Please refer to “Profile Verification Information” in Section 1 for details on how we manage biometric data retention. When you delete your Budigo account, it is immediately removed from public view within the app. However, for up to 28 days, your account can be restored if it was deleted by mistake. After this period, we begin permanently erasing your personal data from our systems, except in cases where: We are legally required to retain certain information (for example, transaction details for tax or regulatory compliance). We need to store data to demonstrate compliance with legal requirements (such as retaining records of blocked accounts for security and policy enforcement). There is an ongoing dispute, claim, or issue that requires us to keep relevant data until resolution. Retaining the information serves our legitimate business interests, such as fraud prevention and maintaining user safety. For instance, if a user is banned due to safety concerns, we may retain related records to prevent them from creating new accounts. Important Note: Even after removing data from your profile or deleting your account, copies of certain information may still exist if they were shared with others or stored by third parties. We have no control over how third-party services retain such information under their respective terms and policies. 11. CHANGES TO THIS POLICY As Budigo evolves, we may periodically update this Privacy Policy to reflect changes in our practices. The latest version of the policy will always be available at [Budigo’s Privacy Page]. If we make any significant modifications, we will notify you, either via email associated with your account or through an in-app notification. Effective Date This Privacy Policy was last updated on: 11th February 2025