PRIVACY POLICY

We respect your privacy and are committed to protecting it through our

compliance with this privacy policy (“Policy”). This Policy describes the
types of information we may collect from you or that you may provide
(“Personal Information”) in the “REDZILLA Bot” mobile application (“Mobile
Application” or “Service”) and any of its related products and services
(collectively, “Services”), and our practices for collecting, using,
maintaining, protecting, and disclosing that Personal Information. It also
describes the choices available to you regarding our use of your Personal
Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or

“your”) and REDZILLA LLC (doing business as “REDZILLA”, “we”, “us” or
“our”). If you are entering into this Policy on behalf of a business or other
legal entity, you represent that you have the authority to bind such an
entity to this Policy, in which case the terms “User”, “you” or “your” shall
refer to such entity. If you do not have such authority, or if you do not
agree with the terms of this Policy, you must not accept this Policy and
may not access and use the Mobile Application and Services. By accessing
and using the Mobile Application and Services, you acknowledge that you
have read, understood, and agree to be bound by the terms of this Policy.
This Policy does not apply to the practices of companies that we do not
own or control, or to individuals that we do not employ or manage.

Collection of information

When you use the Mobile Application, our servers automatically record
information that your device sends. This data may include information
such as your device’s IP address and location, device name and version,
operating system type and version, language preferences, information you
search for in the Mobile Application, access times and dates, and other
statistics.

Information collected automatically is used only to identify potential cases

of abuse and establish statistical information regarding the usage of the
Mobile Application and Services. This statistical information is not
otherwise aggregated in such a way that would identify any particular
User of the system and we do not collect or store any personally
identifiable information.

Use and processing of collected information

We act as a data controller and a data processor when handling Personal

Information, unless we have entered into a data processing agreement
with you in which case you would be the data controller and we would be
the data processor.

Our role may also differ depending on the specific situation involving
Personal Information. We act in the capacity of a data controller when we
ask you to submit your Personal Information that is necessary to ensure
your access and use of the Mobile Application and Services. In such
instances, we are a data controller because we determine the purposes
and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit

Personal Information through the Mobile Application and Services. We do
not own, control, or make decisions about the submitted Personal
Information, and such Personal Information is processed only in
accordance with your instructions. In such instances, the User providing
Personal Information acts as a data controller.

In order to make the Mobile Application and Services available to you, or

to meet a legal obligation, we may need to collect and use certain
Personal Information. If you do not provide the information that we
request, we may not be able to provide you with the requested products
or services. Any of the information we collect from you may be used for
the following purposes:

- Improve products and services

- Enforce terms and conditions and policies

- Protect from abuse and malicious users

- Run and operate the Mobile Application and Services

Processing your Personal Information depends on how you interact with
the Mobile Application and Services, where you are located in the world
and if one of the following applies: (a) you have given your consent for
one or more specific purposes; (b) provision of information is necessary
for the performance of this Policy with you and/or for any pre-contractual
obligations thereof; (c) processing is necessary for compliance with a legal
obligation to which you are subject; (d) processing is related to a task that
is carried out in the public interest or in the exercise of official authority
vested in us; (e) processing is necessary for the purposes of the legitimate
interests pursued by us or by a third party.

We rely on user’s consent as a legal base upon which we collect and

process your Personal Information.

Note that under some legislations we may be allowed to process

information until you object to such processing by opting out, without
having to rely on consent or any other of the legal bases above. In any
case, we will be happy to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Information
is a statutory or contractual requirement, or a requirement necessary to
enter into a contract.

Disclosure of information

Depending on the requested Services or as necessary to complete any

transaction or provide any Service you have requested, we may share
your information with our contracted companies, and service providers
(collectively, “Service Providers”) we rely upon to assist in the operation of
the Mobile Application and Services available to you and whose privacy
policies are consistent with ours or who agree to abide by our policies with
respect to Personal Information. We will not share any personally
identifiable information with third parties and will not share any
information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information

except as necessary to perform services on our behalf or comply with
legal requirements. Service Providers are given the information they need
only in order to perform their designated functions, and we do not
authorize them to use or disclose any of the provided information for their
own marketing or other purposes.

Retention of information

We will retain and use your Personal Information for the period necessary
to comply with our legal obligations, to enforce our Policy, resolve
disputes, and unless a longer retention period is required or permitted by
law.

We may use any aggregated data derived from or incorporating your

Personal Information after you update or delete it, but not in a manner
that would identify you personally. Once the retention period expires,
Personal Information shall be deleted. Therefore, the right to access, the
right to erasure, the right to rectification, and the right to data portability
cannot be enforced after the expiration of the retention period.

Transfer of information

Depending on your location, data transfers may involve transferring and

storing your information in a country other than your own. However, this
will not include countries outside the European Union and European
Economic Area. If any such transfer takes place, you can find out more by
checking the relevant sections of this Policy or inquire with us using the
information provided in the contact section. Note that we are dedicated to
ensuring the security of your personal data, adhering strictly to the
guidelines outlined in our privacy notice and conforming to the applicable
legal requirements.

Region specific notices

Out of respect for your privacy, we have implemented additional

measures to comply with the obligations and rights associated with the
collection of Personal Information as dictated by the laws governing the
regions of our users.
- Disclosures for residents of the EU/EEA and the UK

If you are a resident of the European Union (“EU”), the European

Economic Area (“EEA”), or the United Kingdom (“EEA”), you have certain
rights in relation to your Personal Information based on the the GDPR and
the UK DPA that we comply with as part of our commitment to your
privacy. Unless otherwise expressly stated, all terms in this section have
the same meaning as defined in the GDPR and the UK DPA.

(a) Right to withdraw consent: You have the right to withdraw consent
where you have previously given your consent to the processing of your
Personal Information. To the extent that the legal basis for our processing
of your Personal Information is consent, you have the right to withdraw
that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.

(b) Right to access: You have the right to learn if your Personal Information
is being processed by us, obtain disclosure regarding certain aspects of
the processing, and obtain a copy of your Personal Information undergoing
processing.

(c) Right to rectification: You have the right to verify the accuracy of your
information and ask for it to be updated or corrected. You also have the
right to request us to complete the Personal Information you believe is
incomplete.

(d) Right to object to the processing: You have the right to object to the
processing of your information if the processing is carried out on a legal
basis other than consent. Where Personal Information is processed for the
public interest, in the exercise of an official authority vested in us, or for
the purposes of the legitimate interests pursued by us, you may object to
such processing by providing a ground related to your particular situation
to justify the objection.

(e) Right to restrict to the processing: You have the right, under certain
circumstances, to restrict the processing of your Personal Information.
These circumstances include: the accuracy of your Personal Information is
contested by you and we must verify its accuracy; the processing is
unlawful, but you oppose the erasure of your Personal Information and
request the restriction of its use instead; we no longer need your Personal
Information for the purposes of processing, but you require it to establish,
exercise or defend your legal claims; you have objected to processing
pending the verification of whether our legitimate grounds override your
legitimate grounds. Where processing has been restricted, such Personal
Information will be marked accordingly and, with the exception of storage,
will be processed only with your consent or for the establishment, to
exercise or defense of legal claims, for the protection of the rights of
another natural, or legal person or for reasons of important public interest.

(f) Right to delete: You have the right, under certain circumstances, to
obtain the erasure of your Personal Information from us. These
circumstances include: the Personal Information is no longer necessary in
relation to the purposes for which it was collected or otherwise processed;
you withdraw consent to consent-based processing; you object to the
processing under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure such as where processing is necessary: for exercising the right of
freedom of expression and information; for compliance with a legal
obligation; or for the establishment, to exercise or defense of legal claims.

(g) Right to data portability: You have the right to receive your Personal
Information that you have provided to us in a structured, commonly used,
and machine-readable format and, if technically feasible, to have it
transmitted to another controller without any hindrance from us, provided
that such transmission does not adversely affect the rights and freedoms
of others.

(h) Right to complaint: You have the right to complain to a data protection
authority about our collection and use of your Personal Information. If you
are not satisfied with the outcome of your complaint directly with us, you
have the right to lodge a complaint with your local data protection
authority. For more information, please contact your local data protection
authority in the EU or the EEA. This provision is applicable provided that
your Personal Information is processed by automated means and that the
processing is based on your consent, on a contract which you are part of,
or on pre-contractual obligations thereof.

- Disclosures for residents of the USA

If you are a resident of USA, you have certain rights and we aim to take
reasonable steps to allow you to correct, amend, delete, or limit the use of
your Personal Information. This supplemental section, together with other
relevant sections of the Policy, provides information about your rights and
how to exercise them under the California Consumer Privacy Act and the
California Privacy Rights Act (collectively, “CCPA”), the Colorado Privacy
Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Delaware
Online Privacy and Protection Act (“DOPPA”), the Iowa Consumer Data
Protection Act (“ICDPA”), the Maryland Personal Information Protection Act
(“PIPA”), the Utah Consumer Privacy Act (“UCPA”), the Virginia Consumer
Data Protection Act (“VCDPA”), and and any and all regulations arising
therefrom. Unless otherwise expressly stated, all terms in this section
have the same meaning as defined in the related state laws.

In addition to the rights as explained in this Policy, if you provide Personal

Information as defined in the statute to obtain Services for personal,
family, or household use, you have the right to submit requests related to
your Personal Information once a calendar year. Note that there are
circumstances when we may not be able to comply with your request such
as when we are not be able to verify your request or we may find that
providing a full response conflicts with other legal obligations or
regulatory requirements. You will be notified if it’s the case.

(a) Right to know and right to access: You have the right to request certain
information we have collected about you. Once we receive and confirm a
verifiable request from you, we will disclose to you, to the extent
permitted by law:

- The specific pieces of Personal Information we hold about you.

- The categories of sources from which Information about you is collected.

- The purposes for collecting, selling, or sharing your Personal Information.

 You have the right to request that the Personal Information to be
delivered in a format that is both portable and easily usable, as long as it
is technically possible to do so.

(b) Right to correct: You have the right to request that we correct your
inaccurate Personal Information taking into account the nature of the
Personal Information and the purposes of the processing of the Personal
Information.

(c) Right to delete: You have the right to request deletion of your Personal
Information.

(d) Right to opt-out of the sale and sharing: You have the right to opt-out
of the sale of your Personal Information which may include selling,
disclosing, or transferring Personal Information to another business or a
third party for monetary or other valuable consideration.

(e) Right to consent to or limit the use of your sensitive personal

information: You have the right to consent to the use of your Sensitive
Personal information and to direct us to restrict its use and disclosure
solely to what is essential for carrying out or delivering the Services in a
manner reasonably anticipated by an average user, or for certain business
objectives as specified by law. However, we do not use Sensitive Personal
Information for any purposes other than those legally permitted or beyond
the scope of your consent.

(f) Right to non-discrimination: You have the right to not be discriminated

against in the Services or quality of Services you receive from us for
exercising your rights. We may not, and will not, treat you differently
because of your data subject request activity, and we may not and will not
deny goods or Services to you, charge different rates for goods or
Services, provide a different level quality of goods or Services, or suggest
that we would treat you differently because of your data subject request
activity.
To exercise any of your rights, simply contact us using the details below.
After we receive and verify your request, we will process it to the extent
possible within our capabilities.

How to exercise your rights

Any requests to exercise your rights can be directed to us through the

contact details provided in this document. Please note that we may ask
you to verify your identity before responding to such requests. Your
request must provide sufficient information that allows us to verify that
you are the person you are claiming to be or that you are the authorized
representative of such person. If we receive your request from an
authorized representative, we may request evidence that you have
provided such an authorized representative with power of attorney or that
the authorized representative otherwise has valid written authority to
submit requests on your behalf.

You must include sufficient details to allow us to properly understand the

request and respond to it. We cannot respond to your request or provide
you with Personal Information unless we first verify your identity or
authority to make such a request and confirm that the Personal
Information relates to you.

Data analytics

Our Mobile Application and Services may use third-party analytics tools
that use cookies, web beacons, or other similar information-gathering
technologies to collect standard internet activity and usage information.
The information gathered is used to compile statistical reports on User
activity such as how often Users visit our Mobile Application and Services,
what pages they visit and for how long, etc. We use the information
obtained from these analytics tools to monitor the performance and
improve our Mobile Application and Services. We do not use third-party
analytics tools to track or to collect any personally identifiable information
of our Users and we will not associate any information gathered from the
statistical reports with any individual User.
Privacy of children

We do not knowingly collect any Personal Information from children under

the age of 18. If you are under the age of 18, please do not submit any
Personal Information through the Mobile Application and Services. If you
have reason to believe that a child under the age of 18 has provided
Personal Information to us through the Mobile Application and Services,
please contact us to request that we delete that child’s Personal
Information from our Services.

We encourage parents and legal guardians to monitor their children’s

Internet usage and to help enforce this Policy by instructing their children
never to provide Personal Information through the Mobile Application and
Services without their permission. We also ask that all parents and legal
guardians overseeing the care of children take the necessary precautions
to ensure that their children are instructed to never give out Personal
Information when online without their permission.

Do not sell my personal information

You have the right to choose not to have your Personal Information sold or
dislcosed by contacting us. Upon receiving and verifying your request, we
will cease the sale and disclosure of your Personal Information. Be aware,
however, that opting out of data transfers to our third parties might affect
our ability to provide certain Services you have signed up for. We reserve
the right to reject opt-out requests in certain situations as permitted by
the CCPA, such as when the sale of Personal Information is required for us
to fulfill legal or contractual duties.

Social media features

Our Mobile Application and Services may include social media features,
such as the Facebook and Twitter buttons, Share This buttons, etc
(collectively, “Social Media Features”). These Social Media Features may
collect your IP address, what page you are visiting on our Mobile
Application and Services, and may set a cookie to enable Social Media
Features to function properly. Social Media Features are hosted either by
their respective providers or directly on our Mobile Application and
Services. Your interactions with these Social Media Features are governed
by the privacy policy of their respective providers.

Push notifications

We offer push notifications to which you may voluntarily subscribe at any

time. To make sure push notifications reach the correct devices, we rely on
a device token unique to your device which is issued by the operating
system of your device. While it is possible to access a list of device tokens,
they will not reveal your identity, your unique device ID, or your contact
information to us. We will maintain the information sent via e-mail in
accordance with applicable laws and regulations. If, at any time, you wish
to stop receiving push notifications, simply adjust your device settings
accordingly.

Links to other resources

The Mobile Application and Services contain links to other resources that
are not owned or controlled by us. Please be aware that we are not
responsible for the privacy practices of such other resources or third
parties. We encourage you to be aware when you leave the Mobile
Application and Services and to read the privacy statements of each and
every resource that may collect Personal Information.

Information security

No data transmission over the Internet or wireless network can be

guaranteed. Therefore, while we strive to protect your Personal
Information, you acknowledge that (a) there are security and privacy
limitations of the Internet which are beyond our control; (b) the security,
integrity, and privacy of any and all information and data exchanged
between you and the Mobile Application and Services cannot be
guaranteed; and (c) any such information and data may be viewed or
tampered with in transit by a third party, despite best efforts.
Data breach

In the event we become aware that the security of the Mobile Application
and Services has been compromised or Users’ Personal Information has
been disclosed to unrelated third parties as a result of external activity,
including, but not limited to, security attacks or fraud, we reserve the right
to take reasonably appropriate measures, including, but not limited to,
investigation and reporting, as well as notification to and cooperation with
law enforcement authorities. In the event of a data breach, we will make
reasonable efforts to notify affected individuals if we believe that there is
a reasonable risk of harm to the User as a result of the breach or if notice
is otherwise required by law. When we do, we will post a notice in the
Mobile Application.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Mobile
Application and Services at any time at our discretion. When we do, we
will revise the updated date at the bottom of this page, post a notification
in the Mobile Application. We may also provide notice to you in other ways
at our discretion, such as through the contact information you have
provided.

An updated version of this Policy will be effective immediately upon the

posting of the revised Policy unless otherwise specified. Your continued
use of the Mobile Application and Services after the effective date of the
revised Policy (or such other act specified at that time) will constitute your
consent to those changes. However, we will not, without your consent, use
your Personal Information in a manner materially different than what was
stated at the time your Personal Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms
and conditions. By accessing and using the Mobile Application and
Services and submitting your information you agree to be bound by this
Policy. If you do not agree to abide by the terms of this Policy, you are not
authorized to access or use the Mobile Application and Services.

Contacting us

If you have any other questions, concerns, or complaints regarding this

Policy, we encourage you to contact us using the details below:

Contact Us support@[Link]

We will attempt to resolve complaints and disputes and make every

reasonable effort to honour your wish to exercise your rights as quickly as
possible and in any event, within the timescales provided by applicable
data protection laws.

This document was last updated on July 24, 2024