Privacy Policy

This Privacy Notice for Anil Deshpande (doing business as VAELO) ("we," "us," or "our") describes how and why we might access, collect, store, use, and share your personal information when you use our services, including when you:

• Download and use our mobile application (VAELO), or any other application of ours that links to this Privacy Notice
• Use VAELO. VAELO is a personal emotional intelligence app for iOS. It helps users track and understand their emotional patterns over time through journaling, AI-generated insights, and signal metrics including tone, clarity, and energy. VAELO is a self-awareness tool and is not a medical or therapeutic service.
• 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. 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 anildeshpande.vaelo@icloud.com.

1. What Information Do We Collect?

Personal Information You Disclose 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. The personal information we collect may include:

• Names
• Email addresses
• Contact or authentication data
• Journal entries and personal reflections

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 Apple App Store. You may find their privacy notice at apple.com/legal/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing Apple ID. If you choose to register in this way, we will collect certain profile information about you from Apple, as described in the section "How Do We Handle Your Social Logins?" below.

Application Data

If you use our application, we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access to track location-based information from your mobile device to provide certain location-based services, including weather context for your entries. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access to certain features from your mobile device, including storage. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information such as your mobile device ID, model, and manufacturer, operating system, version information, device and application identification numbers, and Internet Protocol (IP) address.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. This includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
• Device Data. Information about your phone, tablet, or other device you use to access the Services, including IP address, device and application identification numbers, location, hardware model, and operating system.
• Location Data. Information about your device's location, which can be either precise or imprecise. You can opt out by refusing access or by disabling your Location setting on your device.

2. How Do We Process Your Information?

We process your personal information for the following purposes:

• To facilitate account creation and authentication and otherwise manage user accounts
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries and offer support to users
• To send administrative information to you, including details about our products and services, changes to our terms and policies
• To request feedback and to contact you about your use of our Services
• To protect our Services as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention
• To identify usage trends so we can improve our Services
• To save or protect an individual's vital interest when necessary to prevent harm

3. What Legal Bases Do We Rely On?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If You Are Located in the EU or UK

We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, including to analyze how our Services are used, to diagnose problems, and to understand how our users use our products.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• 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.

If You Are Located in Canada

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

4. When and With Whom Do We Share Your Information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. The third parties we share personal information with are:

Category	Service Provider
AI Service Providers	Anthropic
Cloud Computing Services	Supabase
Functionality and Infrastructure Optimization	Supabase
Invoice and Billing	Apple App Store In-App Purchase
User Account Registration and Authentication	Sign in with Apple and Supabase
App Testing	TestFlight
Weather Data	Apple WeatherKit

We also may need to share your personal 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 Offer AI-Based Products?

As part of our Services, 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 you with innovative solutions.

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

Our AI products are designed for the following functions:

• AI insights
• Natural language processing
• Text analysis

All personal information processed using our AI products is handled in line with this Privacy Notice and our agreement with third parties.

6. How Do We Handle Your Social Logins?

Our Services offer you the ability to register and log in using your Apple ID. Where you choose to do this, we will receive certain profile information about you from Apple. The profile information we receive may include your name and email address.

We will use the information we receive only for the purposes that are described in this Privacy Notice. We recommend that you review Apple's privacy notice to understand how they collect, use, and share your personal information.

7. Is Your Information Transferred Internationally?

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we share your personal information, including facilities in the United States.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. Our Standard Contractual Clauses can be provided upon request.

8. How Long Do We Keep Your Information?

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. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

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.

9. How Do We Keep Your Information Safe?

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.

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.

10. Do We Collect Information From Minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 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 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, please contact us at anildeshpande.vaelo@icloud.com.

11. What Are Your Privacy Rights?

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.

In some regions, 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
• Request rectification or erasure
• Restrict the processing of your personal information
• Data portability (if applicable)
• Not 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 involved, and offer a simple way to request human review of that decision.

You can make such a request by contacting us using the contact details provided in the section "How Can You Contact Us?" below.

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, you have the right to withdraw your consent at any time by contacting us using the contact details below or updating your preferences.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

If you have questions or comments about your privacy rights, you may email us at anildeshpande.vaelo@icloud.com.

12. 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.

13. Do United States Residents Have Specific Privacy Rights?

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, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect

Category	Collected
A. Identifiers (name, email, IP address, account name)	YES
B. Personal information as defined in the California Customer Records statute	YES
C. Protected classification characteristics (gender, age, race)	NO
D. Commercial information (purchase history)	NO
E. Biometric information	NO
F. Internet or other similar network activity	NO
G. Geolocation data	YES
H. Audio, electronic, sensory, or similar information	NO
I. Professional or employment-related information	NO
J. Education information	NO
K. Inferences drawn from collected personal information	YES
L. Sensitive personal information	NO

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

• Category A (Identifiers) - As long as the user has an account with us
• Category B (California Customer Records) - As long as the user has an account with us
• Category G (Geolocation data) - As long as the user has an account with us
• Category K (Inferences) - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in the section "What Information Do We Collect?" above.

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?" above.

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. 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?" above.

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

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)

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 anildeshpande.vaelo@icloud.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.

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting vaelo.me/support, by emailing us at anildeshpande.vaelo@icloud.com, 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.

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 anildeshpande.vaelo@icloud.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 Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided below.

14. Do We Make Updates to This Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" 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.

15. How Can You Contact Us?

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

16. How Can You Review, Update, or Delete Your Data?

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.

To request to review, update, or delete your personal information, please visit: vaelo.me/support.