Privacy Information Statement

1. Your Privacy Rights and Controls

Depending on your location (GDPR, CCPA, VCDPA, and similar frameworks), you may have the right to:

• Access — receive a copy of personal data we hold about you
• Correction — update inaccurate or incomplete records
• Deletion — request erasure, subject to lawful exceptions
• Portability — obtain data in a structured, machine-readable format
• Objection — object to certain processing, including direct marketing
• Withdraw consent — revoke consent where processing relies on it
• Right to know about data sharing — learn whether data is shared, with whom, and for what purpose
• Opt-out of data sale / targeted ads — refuse sharing or selling for behavioral advertising

Submit requests to lardinpoellabauerib460@gmail.com. We respond within 30 days or as required by applicable law.

2. Data Controller & Data Protection Officer

Cutely has appointed a Data Protection Officer (DPO) to oversee privacy compliance.

• DPO Name: Lardin Poellabauer
• DPO Email: lardinpoellabauerib460@gmail.com
• Role: Monitors data processing, handles privacy requests, supports user rights, and coordinates with regulators under GDPR and comparable laws

3. Right to Know About Data Sharing

You have the right to know whether your personal data is shared. You may ask whether Cutely discloses your information to third parties, including categories, recipients, purposes, and duration.

3.1 What Sharing Means

Data is "shared" when disclosed to a third party for a business purpose — including service providers, analytics vendors, payment processors, advertising partners, or authorities under lawful request.

3.2 Categories That May Be Shared

• Identifiers: name, email, username, user ID — with consent or as law requires
• Device identifiers: advertising ID, device model, OS — with operational vendors
• Usage data: feature usage, sessions — with analytics partners (anonymized when feasible)
• Payment metadata: shared with payment processors only
• Location: only when you enable location-based features

3.3 How to Request a Sharing Report

• Email lardinpoellabauerib460@gmail.com with subject "Right to Know About Data Sharing"
• Use Settings > Privacy & Security > Data Sharing Request in Cutely

After identity verification, we respond within 15 business days at no charge.

4. How to Opt-Out of Data Sale/Target Ads (Full Details)

How users opt out of the sharing or selling of their data is set out in the callout at the top of this Statement. Three methods are available: in-app settings, device-level controls, and email request. Opt-out is free and does not disable core Cutely features.

5. Right to Opt-Out of Data Sale

Cutely does not sell your personal information. We do not sell, rent, or trade personal data for money or other valuable consideration under CCPA, VCDPA, or similar laws.

6. Information We Collect

6.1 Information You Provide

• Account details: name, email, date of birth, username, profile photo
• Phone number for verification or recovery when added
• Billing data handled by payment partners (we do not store full card numbers)
• Messages, chat threads, and support correspondence
• Photos, videos, and content you share on Cutely

6.2 Information Collected Automatically

• Device info: model, OS, unique identifiers, advertising ID
• Usage patterns: features used, session length, in-app behavior
• Location data only with your permission
• Technical logs: IP address, timestamps, crash reports
• De-identified analytics for stability and performance

7. How We Use Your Information

• Register, maintain, and secure your Cutely account
• Enable chat, social features, and real-time connections
• Process virtual goods, subscriptions, and premium purchases
• Handle support, privacy, and deletion requests
• Detect fraud, spam, and policy violations
• Improve recommendations and the Cutely experience
• Meet safety, legal, and regulatory obligations

8. Data Retention

Data Retention Practices. We retain personal data only as long as needed for the purposes described here, unless law requires longer storage.

8.1 Retention Periods by Data Type

• Account and profile data — while active; deleted within 30 days after confirmed deletion
• Messages and user content — while active; deleted on account deletion, subject to legal holds
• Payment records — up to 7 years for tax and financial compliance
• Security and compliance logs — up to 3 years from collection
• Support and privacy request records — up to 2 years after closure
• Advertising preference records — until opt-out or deletion, then removed within 30 days
• Anonymized analytics — may be kept indefinitely when no longer identifiable

8.2 When Data Is Deleted

When retention periods end, we delete or anonymize data securely. Request early deletion via lardinpoellabauerib460@gmail.com or Settings > Account > Delete Account.

9. Data Security

• SSL/TLS encryption in transit and encryption at rest for sensitive fields
• Role-based access controls for authorized personnel
• Secure storage for credentials and payment metadata
• Regular security assessments, patching, and monitoring
• Documented breach response procedures

10. Account & Data Deletion

Delete via Settings > Account > Delete Account or our Cutely-AccountClosureInstructions page. Removes profile, chat history, activity logs, and media except where law requires retention. Contact lardinpoellabauerib460@gmail.com for assistance.

11. Children's Privacy

Cutely is not directed at children under 13. Registration requires users to be at least 13; users under 18 may need guardian consent. Paid and mature features require users to be 18+. Contact lardinpoellabauerib460@gmail.com if a child under 13 has registered. See Cutely-KidsProtectionGuidelines for additional protections.

12. International Data Transfers

Your information may be processed outside your home country. Cross-border transfers use Standard Contractual Clauses or equivalent safeguards.

13. Policy Updates & Contact

We may revise this Statement as Cutely develops. Material updates will be posted with a revised Last Updated date.

• Data Controller: Lardin Poellabauer
• Privacy Contact: lardinpoellabauerib460@gmail.com
• Application: Cutely - Social Connect (com.cutely.socialhaven)

14. Data Protection Officer

Contact the DPO at lardinpoellabauerib460@gmail.com for questions about how your personal data is collected, used, shared, retained, or protected.