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Privacy Policy

Last Updated: February 2, 2026

Welcome to Giftlyy, operated by Fasa Smartech. Your privacy is critically important to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

1. Information We Collect

1.1 Information You Provide Directly

• Account Information: Full name, username, email address, phone number, date of birth, and profile picture
• Authentication Data: Login credentials, authentication tokens
• Payment Information: Payment card details are processed securely by our payment processor (iVeri). We store only transaction references and payment status
• Contact Information: Names, phone numbers, and email addresses of gift recipients you choose to send gifts to
• Gift Messages: Personalized messages, photos, videos, or audio recordings you attach to gifts
• Calendar Events: Special dates (birthdays, anniversaries) you choose to save for reminders
• Communications: Support requests, feedback, and correspondence with us

1.2 Information Collected Automatically

• Device Information: Device type, operating system version, unique device identifiers (IDFA/Android Advertising ID), mobile network information
• Usage Data: App features used, screens viewed, time spent in app, interaction patterns
• Location Data: Approximate location based on IP address (we do not collect precise GPS location)
• Log Data: IP address, access times, app crashes, performance data
• Push Notification Tokens: FCM tokens to send you notifications

1.3 Information from Third Parties

• Social Login: If you sign in using social media accounts, we receive basic profile information (name, email, profile picture) as permitted by that service
• Contacts: With your explicit permission, we may access your device contacts to help you find friends on Giftlyy
• Photos/Camera: With your permission, to upload profile pictures or attach media to gifts
• Microphone/Audio: With your permission, to record and attach voice messages to gifts
• Storage/Files: With your permission, to select and upload photos, videos, or audio files

1.4 Reports and Safety Data

• Reports: Details you submit when reporting content or behavior (reason, description)
• Content References: IDs or references to the gift, message, or media being reported
• Safety Logs: Timestamps, account IDs, and basic device information to investigate abuse and enforce our Terms

2. How We Use Your Information

We use the collected information for the following purposes:

2.1 Service Delivery

• Create and manage your account
• Process gift purchases and redemptions
• Facilitate gift delivery to recipients
• Enable communication features (friend requests, gift messages)
• Provide customer support

2.2 Service Improvement

• Analyze usage patterns to improve app functionality
• Develop new features and services
• Test and troubleshoot technical issues
• Conduct research and analytics

2.3 Communications

• Send transactional notifications (gift received, payment confirmations)
• Send reminder notifications for special occasions you've saved
• Notify you about friend activity (with your consent)
• Send service announcements and updates
• Respond to your inquiries and support requests

2.4 Safety and Security

• Detect, investigate, and prevent fraudulent transactions
• Monitor for security threats and abuse
• Enforce our Terms of Service
• Comply with legal obligations
• Protect the rights and safety of our users
• Review and respond to reports of inappropriate content or behavior

2.5 Reporting and Moderation

• Investigate reports of spam, harassment, or inappropriate content
• Take enforcement actions such as content removal, warnings, or account suspension
• Maintain records of reports and actions for safety, audit, and compliance

3. How We Share Your Information

We may share your information in the following limited circumstances:

3.1 With Your Consent

• Gift Recipients: When you send a gift, we share your name with the recipient
• Vendors: When a gift is redeemed, we share the recipient's name and redemption code with the vendor
• Friends: Profile information you choose to share with friends on the platform

3.2 Service Providers

• Firebase/Google Cloud: Authentication, database, cloud storage, push notifications, and analytics
• iVeri Payment Gateway: Secure payment processing (they receive only necessary payment information)
• Twilio: SMS notifications for non-registered recipients (only phone numbers and message content)
• Cloud Infrastructure: Hosting and data storage providers

3.3 Business Transfers

If Fasa Smartech is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

3.4 Legal Requirements

We may disclose your information if required by law or in response to valid legal requests, such as:

• Compliance with court orders or subpoenas
• Protection against legal liability
• Investigation of fraud or security issues
• Protection of rights, property, or safety of Giftlyy, our users, or the public

4. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL
• Data at Rest: Sensitive data is encrypted in our databases
• Secure Authentication: Firebase Authentication with secure token management
• Access Controls: Limited employee access to personal data on a need-to-know basis
• Payment Security: PCI-DSS compliant payment processing (we don't store card details)
• Regular Audits: Periodic security assessments and vulnerability testing
• Secure Storage: Data stored in Google Cloud Platform with enterprise-grade security

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Data Retention

We retain your information for different periods based on the type of data:

• Account Data: Retained while your account is active
• Transaction Records: Retained for 7 years for tax and legal compliance
• Support Communications: Retained for 2 years
• Analytics Data: Anonymized after 26 months
• Deleted Account Data: Most data deleted within 30 days; some retained for legal/fraud prevention (anonymized where possible)

6. Your Rights and Choices

6.1 Access and Correction

You can access and update your account information directly in the app under Profile Settings.

6.2 Data Portability

You have the right to request a copy of your data in a machine-readable format. Contact us at info@fasasmartech.com.

6.3 Account Deletion

You can delete your account at any time through the app (Profile → Settings → Delete Account). This will:

• Immediately disable your account
• Delete most personal information within 30 days
• Retain transaction records as required by law (anonymized where possible)
• Remove you from marketing communications

6.4 Marketing Communications

You can opt-out of promotional emails by clicking "Unsubscribe" in any marketing email or adjusting settings in the app.

6.5 Push Notifications

You can manage push notification preferences in your device settings or within the app.

6.6 Cookie Preferences

Our app uses minimal cookies/local storage. You can clear app data through your device settings.

6.7 Withdraw Consent

Where we rely on consent, you can withdraw it at any time through app settings or by contacting us.

7. Children's Privacy

Giftlyy is not intended for children under 13 years of age (or 16 in certain jurisdictions). We do not knowingly collect personal information from children under these ages.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at info@fasasmartech.com. We will promptly delete such information from our systems.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States where our servers are located (Google Cloud Platform).

These countries may have data protection laws different from your country. We ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant authorities
• Compliance with applicable data protection regulations
• Use of service providers with strong privacy practices

9. California Privacy Rights (CCPA)

If you are a California resident, you have specific rights regarding your personal information:

• Right to Know: What personal information we collect, use, and share
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: We don't sell personal information, so this doesn't apply
• Right to Non-Discrimination: We won't discriminate against you for exercising your rights

To exercise these rights, email info@fasasmartech.com with "CCPA Request" in the subject line.

10. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have additional rights under GDPR:

• Right of Access: Obtain confirmation of processing and a copy of your data
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion ("right to be forgotten")
• Right to Restriction: Limit processing in certain circumstances
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with your supervisory authority

11. Push Notifications

With your explicit consent, we send push notifications for:

• Gifts you receive
• Gift status updates (revealed, redeemed)
• Friend requests and acceptances
• Special occasion reminders you've set
• Payment confirmations

You can disable notifications at any time in your device settings: Settings → Notifications → Giftlyy.

12. Third-Party Services and Links

Our app integrates with third-party services that have their own privacy policies:

12.1 Firebase (Google)

• Authentication, Firestore database, Cloud Storage, Cloud Messaging
• Privacy Policy: https://firebase.google.com/support/privacy

12.2 iVeri Payment Gateway

• Payment processing (PCI-DSS compliant)
• We don't store full card details; iVeri handles all payment data securely

12.3 Twilio

• SMS notifications
• Privacy Policy: https://www.twilio.com/legal/privacy

We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

13. Data Breach Notification

In the event of a data breach that affects your personal information, we will:

• Notify affected users within 72 hours of discovery
• Notify relevant supervisory authorities as required by law
• Provide information about the breach and steps we're taking
• Advise you on protective measures you can take

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes:

• We will update the "Last Updated" date at the top
• We will notify you via email or push notification
• For significant changes, we may require you to review and accept the new policy

Your continued use of Giftlyy after changes take effect constitutes acceptance of the updated policy.

15. Apple App Store Requirements

15.1 App Tracking Transparency (ATT)

We respect Apple's App Tracking Transparency framework. We do not track you across apps or websites owned by other companies for advertising purposes. Any data collection is limited to what's necessary for our services.

15.2 Data Collection Disclosure

In compliance with Apple's privacy requirements, here's how we use collected data:

• Contact Info (name, email, phone): Account creation, gift delivery
• Contacts: To help find friends (optional, with permission)
• User Content: Gift messages, photos, videos attached to gifts
• Identifiers: Device ID for authentication and push notifications
• Usage Data: To improve app performance (not linked to identity)
• Diagnostics: Crash logs and performance data (anonymized)

15.3 Data Linked to You

• Account information (name, email, phone)
• Transaction history
• Gift messages and media you send
• Friend connections

15.4 Data Not Linked to You

• Anonymized usage analytics
• Crash reports (anonymized)

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