Privacy Policy

1. What Information Do We Collect?

Personal information you disclose to us

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

The personal information we collect may include:

• Names
• Phone numbers
• Email addresses
• Job titles
• Usernames
• Passwords

You must ensure that all personal information you provide to us is true, complete, and accurate, and you must notify us of any changes.

Payment data

We may collect data necessary to process your payment if you choose to make purchases, such as payment instrument details and security code. All payment data is handled and stored by Stripe. You can review Stripe's privacy notice at https://stripe.com/privacy .

Social media login data

We may offer registration through social media accounts, such as Facebook, X, or other social media accounts. If you choose this option, we collect certain profile information from the social media provider as described in the social logins section below.

Application data

If you use our application, we may request access to the following:

• Geolocation information, either continuously or while you use the application, to provide location-based services.
• Mobile device features, including camera, microphone, storage, and other features.
• Push notifications regarding your account or certain features of the application.

You can change application permissions in your device settings. This information is primarily needed to maintain security and operation, troubleshoot issues, and support internal analytics and reporting.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity, but it may include device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Services, and other technical information.

This information is primarily needed to maintain security and operation of the Services and for internal analytics and reporting.

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 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 enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• 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.

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, or 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 Canada, this section applies to you.

We may process your information if you have given us specific permission, or express consent, to use your personal information for a specific purpose, or in situations where your permission can be inferred, or 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 third parties.

We 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.
• Other Users. When you share personal information, for example by posting comments, contributions, or other content to the Services, or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network, such as Facebook, your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

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 technologies, such as web beacons and pixels, to collect and store information when you interact with the Services. These technologies help us maintain account security, prevent crashes, fix bugs, save preferences, and support basic site functions.

We may permit third parties and service providers to use online tracking technologies for analytics and advertising, including to manage and display ads, tailor ads to your interests, or send abandoned shopping cart reminders depending on your communication preferences.

To the extent these online tracking technologies are deemed to be a "sale" or "sharing" under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under 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 Policy .

Google Analytics

We may share information with Google Analytics to track and analyze use of the Services. Google Analytics Advertising Features we may use include Google Display Network Impressions Reporting. You can opt out at https://tools.google.com/dlpage/gaoptout . You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice . For more information on the privacy practices of Google, please visit the Google Privacy & Terms page .

6. Do We Offer Artificial Intelligence-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. These tools are designed to enhance your experience and provide innovative solutions.

We provide AI Products through third-party service providers, including Runpod. Your input, output, and personal information may be shared with and processed by these AI Service Providers to enable your use of AI Products. You must not use AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI automation

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.

7. 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.

If you register or log in using a third-party social media account, we may receive profile information from that provider. This may include your name, email address, friends list, profile picture, and other information you make public on that platform.

We use this information only for purposes described in this Privacy Notice or otherwise made clear to you. We do not control how your social media provider uses your personal information, so you should review that provider's privacy notice.

8. SMS Communications

When you provide your mobile phone number to Qrylo for phone verification, Qrylo may send you an SMS verification code to verify ownership of that number.

Your mobile information will not be sold or shared with third parties for promotional or marketing purposes.

We will not share your SMS opt-in data or consent with third parties for purposes unrelated to providing the messaging service. We may share information with service providers, telecommunications carriers, and messaging platform providers only as necessary to deliver SMS messages and operate the service.

Message and data rates may apply. Message frequency may vary. You may reply STOP to opt out or HELP for assistance.

9. 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 keep personal information for as long as necessary to fulfill the purposes described 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 to keep your personal information for longer than twelve (12) months after termination of your account. When we have no ongoing legitimate business need to process your information, we will delete or anonymize it. If deletion is not immediately possible, such as with backup archives, we will securely store it and isolate it from further processing until deletion is possible.

10. 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.

11. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction, or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at support@qrylo.com .

12. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as 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 Canada, you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict the processing of your personal information, if applicable, to data portability, and 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 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.

Withdrawing your consent: You may withdraw consent where we rely on consent. You may opt out of marketing and promotional communications at any time by using unsubscribe links or contacting us. Service-related messages may still be sent where necessary for account administration or support.

Account information

You can review or change account information by logging in to account settings or contacting us. If you request account termination, we will deactivate or delete your account and information from active databases, but may retain some information to prevent fraud, troubleshoot problems, assist investigations, enforce legal terms, or comply with legal requirements.

13. 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.

We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat it as a valid request to opt out of sale or sharing of personal information for targeted advertising purposes under applicable state privacy laws, including the California Consumer Privacy Act (CCPA). When we detect a GPC signal from your browser, we will automatically apply your opt-out preference without requiring you to take any additional action. For more information about GPC and how to enable it, visit globalprivacycontrol.org .

14. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, 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.

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?

Categories of personal information collected in the past 12 months

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.
• 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 - 1 year.
• Category B - 1 year.
• Category I - 1 year.

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 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 disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

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, or sharing as defined under California's privacy law, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed, as permitted by applicable law, including the privacy law in Minnesota.
• Right to obtain a list of the categories of third parties to which we have disclosed personal data, as permitted by applicable law, including the privacy law in California, Delaware, and Maryland.
• Right to obtain a list of specific third parties to which we have disclosed personal data, as permitted by applicable law, including the privacy law in Minnesota and Oregon.
• Right to obtain a list of third parties to which we have sold personal data, as permitted by applicable law, including the privacy law in Connecticut.
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled, as permitted by applicable law, including the privacy law in Connecticut and Minnesota.
• Right to limit use and disclosure of sensitive personal data, as permitted by applicable law, including the privacy law in California.
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature, as permitted by applicable law, including the privacy law in Florida.

How to exercise your rights

To exercise these rights, you can contact us by visiting https://qrylo.com/ , by emailing us at support@qrylo.com , or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

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.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@qrylo.com . We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California residents may request information about categories of personal information, if any, disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section How Can You Contact Us About This Notice?

15. 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.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at support@qrylo.com or contact us by post at:

17. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or US state of residence, you may have the right to request access to personal information we collect from you, details about how we processed it, correction of inaccuracies, deletion, or withdrawal of consent where applicable. These rights may be limited by law.

To request to review, update, or delete your personal information, please visit: https://qrylo.com/ .