VICINY PRIVACY POLICY

Effective Date: July 19, 2026 | Last Updated: July 24, 2026

Viciny (“Viciny,

” “we,

” “us,

” or “our”) values your privacy. This Privacy Policy explains how we collect,

use, disclose, and protect information when you use our apps, websites, APIs, and related services

(collectively, the “Services”).

1. Scope

This Privacy Policy applies to information processed by Viciny through viciny.com, mobile applications,

and customer support channels.

2. Information We Collect

2.1 Information You Provide. Account details, profile information, user content (posts, messages),

payment details, and communications with support.

2.2 Information Collected Automatically. We collect the following categories of information

automatically or with your permission:

Camera access (photos and video): The app requests camera access as needed for creating

and posting content within the app, such as capturing photos or video, including content used for

account verification.

Microphone access (live streaming and audio): The app requests microphone access as

needed for creating and posting content within the app, such as capturing audio during live

streams, voice messages, or other audio features.

Photo library access: The app requests photo library access as needed so you can select and

upload existing photos or videos when creating and posting content within the app.

Device data: Device identifiers, operating system, browser type, and app version.

IP addresses and log information: Including access times, pages viewed, and app crashes or

system activity.

Location information: Approximate (e.g., derived from IP address) or precise (e.g., GPS) location,

collected only with your permission.

All of the device permissions above are requested only as needed to let you create and post content

within the app, and only with your permission where required by your device’s operating system.

2.3 Data Types Disclosed for App Store Privacy Labels. For transparency and in connection with

Apple’s Privacy Nutrition Label and Google Play’s Data Safety disclosures, the following is an itemized

list of data types we may collect through the Services:

Precise location

Photos and videos

Audio recordings from live streams

Contacts (only if you choose to use a friend-finding feature that accesses your contacts)

Phone number

Email address

This list is maintained to be consistent with the data types Viciny discloses in the Apple App Store

Privacy Nutrition Label and the Google Play Data Safety section. If Viciny’s actual data collection

practices change, this list and the corresponding app store disclosures will be updated together.

3. How We Use Information

To provide and improve services, personalize content, ensure community safety, process transactions,

and communicate updates.

4. How We Share Information

We do not sell personal information. We share information with the following categories of recipients:

Service providers who perform functions on our behalf, such as cloud hosting, customer support

tooling, and payment processing.Business partners, where necessary to operate features you use.

Legal, safety, or regulatory authorities, where required to comply with law, enforce our Terms, or

protect the safety of our community.

Successors in the event of a merger, acquisition, financing, or sale of business assets.

5. Cookies and Similar Technologies; Third-Party SDKs

The Services do not currently integrate any third-party analytics or advertising SDKs (such as Google

Firebase Analytics, Google AdMob, Meta Audience Network, or similar tools). We may use limited first-

party cookies or similar technologies for authentication and preferences.

If Viciny adds any third-party analytics or advertising SDK in the future, this section will be updated to

identify the specific SDK(s) integrated into the Services, consistent with Apple App Store and Google

Play disclosure requirements.

6. Personalized Ads and FTC Disclosures

Viciny does not currently deliver personalized advertising through third-party advertising SDKs, as

described in Section 5. In accordance with FTC guidelines, users and partners who post “sponsored” or

“commercial” content must clearly disclose their relationship with the brand (e.g., using #ad or

#sponsored). Viciny may collect data regarding these disclosures to ensure transparency for our

community.

7. Data Retention

We retain data as long as necessary for service provision, legal compliance, and safety, subject to the

following account deletion process:

30-day grace period: When you delete your account, it enters a 30-day grace period during

which the account is deactivated but not yet permanently deleted.

User content during the grace period: Your posts, messages, photos, videos, and other user

content are hidden from other users but retained by Viciny so that the deletion can be reversed if

you reactivate your account within the 30-day window.

Live stream recordings during the grace period: Recordings of your past live streams are

similarly hidden from public view and retained during the grace period.

After the grace period: If the account is not reactivated within 30 days, your account and all

associated content — including photos, videos, and live stream recordings — are permanently

deleted from our production systems, except where retention is required for legal, security, fraud-

prevention, or technical reasons (for example, residual copies in encrypted backups, which are

purged on a rolling schedule).

8. In-App Account Deletion

You can delete your account directly within the Viciny app, without needing to contact customer

support. To delete your account:

Go to Settings within the app.

Select Account, then Delete Account.

Confirm your choice to begin the 30-day grace period described in Section 7.

You may also contact us at support@viciny.com if you need assistance, but doing so is not

required to delete your account.

9. Data Security

We use reasonable safeguards to protect your information, though no system is 100% secure.

10. Children’s Privacy

Viciny is not for children under 13 (or the applicable minimum age in your country). We use the

following age-gating mechanism to help prevent underage use:

Date of birth entry at signup: During account creation, users must enter their date of birth as a

required field before an account can be created.

Blocked signups: If the date of birth entered indicates the user is under 13 (or under theapplicable minimum age in their country), the app displays an on-screen error indicating the user is

underage and blocks the user from completing account creation. The user cannot proceed past this

point using that date of birth.

Reactive removal: If we later learn that a user under the applicable minimum age has provided

personal information despite these controls (for example, by entering an inaccurate date of birth),

we will delete that account and associated data.

11. Copyright and DMCA Safe Harbor

Viciny respects intellectual property rights and complies with the Digital Millennium Copyright Act

(DMCA). If you believe your work has been infringed, please provide our Designated Copyright Agent

with:

A physical or electronic signature of the owner/authorized agent.

Identification of the copyrighted work claimed to have been infringed.

Contact information (address, phone, and email).

A statement of “good faith belief” that the use is unauthorized.

A statement that the information provided is accurate under penalty of perjury.

Send notices to: support@viciny.com.

12. Your Privacy Rights

Depending on location, you may have rights to access, correct, delete, or port your data. Contact us to

exercise these rights.

13. International Data Transfers

Viciny is based in the United States. User data is stored in the United States region, and the servers

that host the Services are located in the United States. If you access the Services from outside the

United States, including from the European Economic Area, the United Kingdom, or Switzerland, your

information will be transferred to and processed in the United States.

Where we transfer personal data outside of your country, including to the United States, we rely on

appropriate safeguards recognized under applicable law, such as the European Commission’s

Standard Contractual Clauses, the UK International Data Transfer Addendum, or other legally

recognized equivalent mechanisms, to help ensure your information receives an adequate level of

protection.

This section is relevant for EU/UK users accessing Viciny through Google Play and the Apple App Store,

both of which require disclosure of international data transfer practices and safeguards.

14. Legal Bases for Processing

We process data based on contract performance, legitimate interests, legal obligations, or consent.

15. Changes to This Policy

Material changes will be notified via the Services or email.

16. Contact Information

Viciny Support

Email: support@viciny.com