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Draft for review. Fill in every highlighted item and have a lawyer review this policy before launch. Check sections 5 and 6 against the services you actually use at launch (hosting, email sender, payment provider). Delete this box when you're done.

Privacy Policy

Effective date: [DATE]

This policy explains what information Resonzo (the "Service") collects, how we use and share it, how long we keep it, and the choices and rights you have. It applies to everyone who uses the Service, wherever you live.

The short version: we collect your email address and the profiles you choose to create. We use them only to run the Service. We don't sell your information, we don't show ads, and we don't use tracking cookies. You can download or delete your data at any time from Account in the app.

1. Who we are

The Service is operated by [RESONZO LLC — exact legal name once formed], a New York limited liability company located in Buffalo, New York, USA ("we", "us", "our"). For the purposes of European and UK data protection law, we are the "controller" of the personal information described in this policy, except where we say otherwise.

Contact: [email protected] · [MAILING ADDRESS, Buffalo, NY]

2. Information we collect

Information you give us

Information created when you use the Service

Information stored on your device

The Service stores a small amount of information in your browser's local storage: your sign-in session, so you stay signed in, and display preferences such as your last-opened tab and score weights. This is strictly necessary to provide the features you use. We don't use advertising or analytics cookies or similar tracking technologies. If we ever add analytics, we will update this policy first and, where the law requires it, ask for your consent.

Payment information

If you subscribe to Premium, your payment is handled by our payment provider (see section 5). We never receive or store your full card number or bank details.

3. Information about other people

The Service lets you create profiles about people you know. Those people have not necessarily agreed to be in your profiles, so please be thoughtful:

Profiles are private to the account that created them. Other users can't see them. If someone believes they appear in another user's profile and wants it removed, they can contact us at [email protected]. We can't always identify which account holds information about a particular person, but we will take reasonable steps to help.

4. How we use information

We don't sell your personal information, we don't share it for cross-context behavioral advertising, and we don't use it to make decisions that have legal or similarly significant effects on you.

Legal bases (European Economic Area and UK users). We process your information because it's necessary to perform our contract with you (providing the Service you signed up for); for our legitimate interests in keeping the Service secure, preventing abuse and improving it, balanced against your rights; to comply with legal obligations; and, where we ask for it, with your consent, which you can withdraw at any time.

5. Who we share information with

We share information only with service providers that help us run the Service, under contracts that limit what they can do with it, and as described below:

We may also disclose information if the law requires it, to protect the rights, safety or property of our users, the public or us, or as part of a merger, acquisition or sale of assets. If that happens, this policy will continue to apply to your information, or we'll give you notice.

6. International transfers

We're based in the United States, and our service providers process information in the United States. If you use the Service from outside the US, your information will be transferred to the US, where data protection laws may differ from those in your country. Where European or UK law requires it, we rely on safeguards such as the European Commission's Standard Contractual Clauses (and the UK equivalent) or a provider's certification under the EU-U.S. Data Privacy Framework.

7. How long we keep information

8. Security

We use reasonable administrative, technical and physical safeguards, consistent with the New York SHIELD Act, to protect your information. These include encrypted connections (HTTPS), encryption of stored data by our providers, database rules that let each account access only its own profiles, sign-in without passwords, and restricted access to administrative credentials. No system is perfectly secure. If a breach affects your personal information, we'll notify you and the authorities as the law requires.

9. Your choices and rights

Everyone, wherever you live, can:

US state privacy rights. Depending on where you live (for example California, Colorado, Connecticut, Virginia, Texas and other states), you may have the right to know what personal information we collect and how we use it, to access, correct, delete or get a copy of it, and to opt out of its sale, sharing for targeted advertising, or profiling. We don't sell or share personal information for targeted advertising, and we don't profile people in ways that produce legal or similarly significant effects. We won't discriminate against you for exercising your rights. You may use an authorized agent; we may need to verify your identity, and the agent's authority, before acting on a request. If we deny your request, you can appeal by replying to our decision.

European Economic Area, UK and Swiss users also have the right to restrict or object to our processing, to data portability, to withdraw consent at any time, and to lodge a complaint with your local data protection authority. [If required: our EU representative is ___ and our UK representative is ___. Ask your lawyer whether you need them.]

10. Children

The Service is not directed to children under 13, and you must be at least 13 to create an account (or older where local law sets a higher age for consent to data processing, such as 16 in some EU countries). We don't knowingly collect personal information from children under 13. If you believe a child has given us personal information, contact us and we'll delete it.

11. Changes to this policy

We may update this policy. If we make material changes, we'll notify you by email or in the Service before they take effect. The effective date at the top shows when it was last changed.

12. Contact

[RESONZO LLC]
[MAILING ADDRESS], Buffalo, NY, USA
[email protected]