VoyZa Privacy Policy

1. Who We Are and How to Contact Us

VoyZa is operated by Heng Kok, an individual developer (sole trader) based in Phnom Penh, Cambodia, who is the data controller for the personal information described in this policy. "VoyZa" and "Xtremon" are brand/trading names used by the operator; there is currently no separate registered company, so the responsible legal person is the individual named here.

• Controller: Heng Kok (individual / sole trader, trading as VoyZa)
• Postal address: available on request — email us and we will provide it
• Country of establishment: Cambodia
• App: VoyZa (iOS and Android)
• Website: https://voyza.xtremon.com
• Privacy policy: https://voyza.xtremon.com/privacy
• Contact email: hengsamkok76@gmail.com

"VoyZa" is a brand/trading name operated by the individual named above. If you wish to identify, contact, or bring a claim against the controller, the individual named above is the responsible legal person.

Data Protection Officer. We have assessed our processing under Article 37 GDPR / UK GDPR and have determined that we are not required to appoint a Data Protection Officer (our core activities do not consist of large-scale systematic monitoring or large-scale processing of special-category data). Privacy matters are handled directly by the controller at the contact details above.

EU and UK data subjects (Article 27). The controller is established outside the EU and the UK. We are a small independent developer and have not appointed an Article 27 representative in the EU or the UK. If you are in the EEA, the UK, or Switzerland, you can raise any privacy matter with us directly at hengsamkok76@gmail.com, and we will respond. You also retain the right to lodge a complaint with your local supervisory authority at any time (see Section 13).

If you have any questions about this policy or want to exercise your privacy rights, email us at hengsamkok76@gmail.com or write to the controller by post (ask us for the address by email).

2. What Data We Collect

We collect the categories of personal information set out below. We only collect what we need to operate the App, process your subscription, keep the service secure, and improve it.

Location fingerprints (deduplication)

When your saved places sync, we compute a one-way SHA-256 hash of each place's name plus its coordinates. This "fingerprint" is used only to detect and remove duplicate places when local data syncs to the cloud. It is a content hash of place data — it is not a device or person tracking identifier — and it is stored alongside your locations in Supabase.

Free-trial abuse prevention (device check)

When you start a free trial while signed in, the App reads a device identifier (on iOS the identifier-for-vendor; on Android the Android ID) and stores it with your user ID and the time the trial started in our trial_devices registry. We use it to detect abuse of our free and promotional offers: referral rewards claimed by referring an additional account of your own from a device you have already used, and repeated trials from one device. Whether you are eligible for an introductory offer is decided by the App Store or Google Play, not by this check. We do not use the identifier for advertising. See Sections 4 (lawful basis and balancing test), 10 (retention), and 13 (your right to object and our automated-processing statement).

3. How We Use Your Data

We use your personal information to:

• Provide the App: create and manage your account, save your trips and places, optimize multi-stop routes, show maps, autocomplete and search for places, geocode addresses, and sync your data across devices.
• Enable collaboration: let you invite others to a trip and share trip content with the collaborators you choose; if you invite someone who does not yet have a VoyZa account, we hold a pending invitation (keyed to the email you entered) so they can join that trip when they sign up (see Section 7).
• Process subscriptions: manage purchases, trials, restores, and entitlements through RevenueCat and the app stores.
• Send notifications and transactional email: deliver push notifications about trip activity and collaboration, and reminders around your trip dates (two days before a trip, on a trip day, and once it ends); and send transactional emails such as password reset, your email verification code, a trip invitation you ask us to send, and referral-reward confirmations.
• Send lifecycle / marketing email (with opt-out): send onboarding (welcome), activation-reminder, and win-back emails. These are sent on a soft opt-in / legitimate-interest basis and you can unsubscribe at any time (see Section 4).
• Operate the referral and invitation program: let you invite friends and collaborators, connect an invited person to the trip and to you when they join, grant referral rewards (promotional VoyZa Pro to an eligible referee when they sign up with a code, and to the referrer once that person starts a paid subscription), and prevent referral fraud (see Sections 4 and 7).
• Prevent abuse and secure the service: detect repeated free trials and referral fraud, detect other fraud and misuse, and protect the integrity of the App.
• Understand and improve the App: measure how features are used through analytics and monitor performance and stability (subject to consent where required — see Section 6).
• Measure and improve our advertising: learn which of our ads led to an install, a trial or a subscription, and let the advertising platforms we use show our ads to people more likely to be interested and stop showing install ads to people who already have the App (see Section 6).
• Request feedback: occasionally show the native in-app rating prompt after you complete an action such as optimizing a route. This prompt is handled entirely by Apple or Google; we do not receive any personal data from it.
• Comply with law: meet our legal obligations and respond to lawful requests.

4. Legal Bases for Processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the legal bases mapped purpose-by-purpose in the table below.

Device-check balancing test (legitimate-interest assessment, Art. 6(1)(f) + ePrivacy/PECR). We rely on legitimate interests to read and store a device identifier to detect abuse of our free and promotional offers — repeated free trials from one device and referral-reward abuse (such as referring an additional account of your own from a device you have already used). We conducted a balancing test and concluded that: (a) the interest (preventing repeat-trial and referral-reward abuse of a paid service) is legitimate and necessary; (b) the processing is limited to a single identifier tied to your account and the trial date, is never used for advertising or cross-app tracking, and is retained for a limited period (see Section 10); and (c) the limited impact on you does not override our interest, particularly given your right to object below. Because reading an identifier from the device can engage ePrivacy/PECR, for EEA/UK/CH users this access occurs only in connection with a trial you actively start (a service you request) and is not used for any non-essential analytics or advertising purpose. You can object to this processing at any time (see Section 13); we will assess any objection and, where it succeeds, cease the processing.

Marketing email — soft opt-in. Lifecycle/marketing emails (welcome, activation reminder, win-back) are treated as direct marketing. We send them on a soft opt-in / consent basis to people who have an account, and you can unsubscribe at any time by emailing hengsamkok76@gmail.com; we will promptly stop sending them. Transactional and authentication emails (e.g., password reset) are separate and necessary to provide the service.

Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal (see Sections 6 and 13 for how).

5. Push Notifications and Device Permissions

The App requests the following device permissions:

• Location (while-in-use): to show your position on the map, bias place searches to your area, detect your country, and calculate distances. We do not request background or "always" location.
• Notifications: to deliver push notifications about trip activity and collaboration. You can disable notifications at any time in your device settings.
• Network / Internet: required for the App to function.
• Advertising ID (Android): used for analytics and ads measurement, subject to the choices in Section 6 (for EEA/UK/CH users it is not collected before opt-in consent).
• Tracking (iOS): the App asks, through Apple's "Allow … to track" prompt, whether it may use your device's advertising identifier to measure our advertising. If you choose "Ask App Not to Track", the App does not read that identifier. You can change this at any time in iOS Settings → Privacy & Security → Tracking.

When you choose Save on a share card you created, the App asks for permission to add that image to your photo library (on Android 10 and below, storage permission); it never reads or browses your photos. The App does not request access to your camera, microphone, contacts, calendar, or Bluetooth.

6. Advertising and Analytics

We advertise VoyZa on other companies' platforms and measure whether that advertising works. We do not show third-party advertising inside the App. This section says exactly what we do, who receives what, and how to switch it off.

Two separate choices

• Usage analytics — how the App is used, so we can improve it (Firebase Analytics / Google Analytics 4).
• Ads measurement — telling the advertising platforms we use (Google and Meta) when one of our ads led to an install, a trial or a subscription. For Google, this choice sets the Google Consent Mode advertising signals (ad_storage, ad_user_data, and ad_personalization); for Meta, it decides whether Meta's SDK runs at all.

Each has its own switch in the App at Settings → Preferences — Usage analytics and Ads measurement — and you can change either at any time. Versions of the App released before this change have a single analytics switch in the same place, covering usage analytics and the Google signals; those versions do not contain Meta's SDK and send nothing to Meta.

Consent before anything non-essential (EEA, UK, Switzerland)

For users in the EEA, the UK, and Switzerland, no non-essential SDK reads from or writes to your device, and no analytics or advertising signal fires, before you give opt-in consent to the relevant choice above. This includes Firebase Analytics / Google Analytics 4, Firebase Performance Monitoring, Google Ads conversion measurement, Apple Search Ads attribution, Meta's SDK, the Android Advertising ID, the iOS advertising identifier, and any conversion or measurement signal. Only essential, service-providing processing that you actively request runs without this consent. This reflects the prior-consent requirement under ePrivacy / PECR for storing or accessing information on your device, which applies independently of any GDPR legal basis.

We decide whether the opt-in requirement applies from your device's region setting and the country your network connection indicates. A choice you have made yourself always stands, wherever you are. Otherwise, if either signal indicates the EEA, the UK, or Switzerland, both choices stay off until you opt in; and if we cannot yet tell where your connection comes from, both stay off until we can. To make this check, the App asks our own server, each time it starts, which country your connection appears to come from. The server answers with a country code and stores nothing — we do not store your IP address for this purpose — and the App keeps only that country code on your device.

Everywhere else

Outside the EEA, the UK, and Switzerland, both choices are on by default. Before Meta's SDK is used for the first time on your device, the App shows a notice explaining the change, with a button to turn ads measurement off there and then.

On iOS

• The App shows Apple's App Tracking Transparency prompt — only where ads measurement is on, and not before you have created your first trip. If you tap Allow, the App may read your device's advertising identifier (IDFA) and share it with Meta together with the events listed below, which lets Meta match an install or purchase to an ad you saw in another company's app or website. This is "tracking" as Apple defines it.
• Until you answer, and if you choose Ask App Not to Track, the App does not read the IDFA, and iOS blocks the App's connections to the tracking domain we declare. Where ads measurement is on, the App still sends the events below to Meta marked as not-for-tracking; Meta has committed to use events marked this way only for aggregated, delayed measurement that is not linked to you across other companies' apps and websites.
• We register with Apple's SKAdNetwork. When an ad leads to an install, Apple — not VoyZa — tells the ad network that an install occurred, without identifying you or your device.
• We use the Apple Search Ads (AdServices) attribution token for aggregate, campaign-level measurement of our Apple Search Ads (collected via RevenueCat).
• Our iOS privacy declaration is NSPrivacyTracking = true, with Meta's tracking domain (ep1.facebook.com) declared.

On Android

• Where ads measurement is on, we share the Advertising ID with Google and Meta to attribute installs and subscriptions to our campaigns — and, for EEA/UK/CH users, only after opt-in consent.
• Where your device supports it, Meta's SDK may also use Android's own attribution reporting, in which Android — rather than VoyZa — reports to the ad network that an ad led to an install or a purchase. We have removed the SDK's access to Android's on-device ad-audience and interest-topic features.
• You can reset or delete your Advertising ID, or opt out of ad personalization, at any time in your device's system settings (Settings → Google → Ads). When you do so at the OS level, we respect that choice.

What Meta receives, and what it never receives

Where ads measurement is on, Meta's SDK inside the App sends Meta:

• that the App was installed and opened, and how long each session lasted;
• that you signed up (and that you did so by email — never the address itself) and created a trip;
• that you optimized a route — reported once per installation, the first time it happens while ads measurement is on, and only the fact that it happened: never the route itself, its places or the number of stops;
• an install-level identifier created by Meta's SDK, and your device's advertising identifier where the conditions above are met;
• on iOS, if you open the App from one of our Meta ads, the link from that ad, so that Meta can credit the ad — never a trip link or any other link the App is opened with;
• basic device and app information (such as device model, operating-system version, App version, language, time zone, mobile carrier, screen size and storage capacity) and, as with any internet request, your IP address.

Where ads measurement is on, our subscription provider RevenueCat also reports to Meta, directly from its servers and including when the App is closed, that you started a trial, that a trial converted to a paid plan, that you made a purchase, and each renewal — with the plan, price and currency. With those events RevenueCat forwards Meta's install identifier, your device's advertising identifier (under the same conditions as above) and the IP address recorded with the purchase, so that Meta can match the purchase to an ad. RevenueCat holds no email address or phone number for you, so none is forwarded.

We never send Meta your name, email address, phone number, VoyZa account ID, trips, saved places, routes, or location. We do not upload contact lists to Meta.

What Meta does with it

We use Meta's reports to see which of our ads work. Meta uses the events to deliver our campaigns: to show VoyZa ads to people more likely to be interested, and to stop showing install ads to people who already have the App. Meta may also combine these events with other information it holds about you to personalise the ads and content you see on Meta's services and to improve its systems, as described in Meta's Privacy Policy. For this processing Meta acts as a controller in its own right (see Section 8). If you have a Meta account, you can review and disconnect this activity in Meta's settings under "Your activity off Meta technologies."

United States — Limited Data Use

We send every event to Meta with Meta's Limited Data Use setting enabled. For people Meta locates in California and the other US states covered by that setting, Meta processes the events as our service provider or processor, for our measurement only, and does not use them for cross-context behavioral advertising or targeted advertising (see Section 13).

Our advertising and measurement partners

• Google Ads, for app-install campaign delivery and conversion measurement, through the RevenueCat → Firebase → Google Analytics 4 conversion pipeline.
• Meta (Facebook and Instagram), for app-install campaign delivery and conversion measurement, through Meta's SDK as described above.
• Apple Search Ads (AdServices) attribution token on iOS.

For ad measurement, Google and Meta act as independent or joint controllers for the device and event signals involved, not merely as our processors; their handling is governed by their own controller terms (linked in Section 8). Any device or event data sent to them for EEA/UK/CH users is covered by the opt-in consent described above.

What we do not do

We do not show third-party ads in the App, use the Meta Audience Network, use AppsFlyer, Adjust or any other attribution vendor, send contact details to advertising platforms, or sell your personal information. If any of that changes, we will update this policy and ask again where consent is required (see Section 16) before it starts.

7. Trip Collaboration and Sharing Between Users

Collaboration is a core feature of VoyZa, and it is the most important sharing surface to understand.

• Inviting collaborators: You invite someone to a trip by entering their email address. If that email belongs to an existing VoyZa account, our backend (Supabase) links them to the trip. If it does not yet belong to a VoyZa account, we store a pending invitation — the email address you entered, the trip, your user ID, and your referral code — so that when that person signs up with the same email they are automatically added to the trip and both of you may receive a referral reward. A pending invitation is deleted when it is claimed or when it expires (30 days). If the person is not yet a user we also email them the invitation (through Resend): it shows your first name — or the first part of your email address if you have not added a name — the trip's name and your referral code. We keep a log of the invitation emails we sent (your user ID, the address and the time) to enforce sending limits, for as long as your account exists. Only invite people who are happy to be contacted and added.
• Referral program: When you share a referral link or code and someone signs up through it — or when you invite a non-user as described above — we record a referral connecting you (the referrer) to that person (the referee) so we can grant the reward. The referee may receive promotional VoyZa Pro when they sign up with your code; your reward is granted only once they go on to start a paid subscription (after any free trial). If you already have an active paid subscription when a reward is earned, we record it and apply it when your current paid period ends, so the reward is not lost. Referral rewards are subject to anti-fraud checks and the limits described in the app's Terms; see Sections 3 and 4.
• What collaborators can see: Once added, a collaborator with read or write access can see the entire trip's contents — all saved places (names, precise coordinates, photos, scheduled dates, durations, tags and who added each one) and the trip name, description, dates and arrival and departure times. Edits stream between collaborators in real time.
• Collaborator emails are visible to the group: Every member of a shared trip can see the email address of every other member, and who invited whom. Members also see the trip owner's name (or email) and, in notifications, the name — or the first part of the email address — of whoever added a place or invited them, together with the place and trip names.
• Public trip links and codes: when you make a trip public (the Share button), the App creates a link (voyza.xtremon.com/c/CODE) and a code. Anyone who has them and is signed in to VoyZa can preview the trip — its name, description, dates, country and every place with its coordinates, scheduled day, stay duration, accommodation flag, photo and opening hours — and copy it into their own account as a private trip (the places with their days, stay durations, tags, photos and opening hours; not your arrival and departure times). Neither the preview nor the copy shows your name or email address. When you share a route card while signed in, the share text also carries a link (voyza.xtremon.com/t/…) to a web page that anyone can open without an account: it shows the trip's name, the number of stops, the stop names grouped by day and a map image of the stops served by Google. You can make the trip private again at any time: the code stops working and the route-card page links are withdrawn; copies already made stay with the people who made them, and we count how many times a trip was copied. Deleting the trip removes all of its links.
• CSV / PDF export, share cards and the OS share sheet: When you export a trip to CSV or PDF, save or share a route card or QR card, or use your device's share sheet, the itinerary (place names, addresses, scheduled dates, durations, travel times — and, on a QR card, the trip's share link) leaves the App and is sent to whatever app or person you choose. Once you share it, that data is outside our control.
• In-app notifications: when someone invites you to a trip or collaborates with you, we store an in-app notification on our servers (including the inviter's name and the trip name) so you can see your notification history in the App. These are protected by row-level security, retained while your account is active, and deleted when you delete your account.

Only add content and invite people if you are comfortable with this visibility.

8. Sharing and Disclosure

We do not sell your personal information. Where ads measurement is on, we disclose the device and event data described in Section 6 to Google and Meta so that our own advertising can be measured and delivered; outside the US states covered by Meta's Limited Data Use setting, and where the law of your region treats that as "sharing" for advertising, you can stop it with the Ads measurement switch (Section 13). We disclose data only as described below.

Most providers below act as our processors (acting only on our instructions). However, our advertising and measurement partners (Google and Meta) act as independent or joint controllers for the device and event signals involved; their processing is governed by their own controller terms, linked below, and is subject to the consent described in Section 6 for EEA/UK/CH users.

Service providers and partners

Other disclosures

• Other users: trip content you share with collaborators, as described in Section 7.
• Legal and safety: we may disclose information where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of VoyZa, our users, or others.
• Business transfers: if VoyZa is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your personal information.

9. International Data Transfers

VoyZa is operated with the help of service providers located in the United States and other countries. When you use the App, your personal information may be transferred to, stored, and processed in countries other than your own, including the United States, where data-protection laws may differ from those in your jurisdiction.

Where we transfer personal information out of the EEA, UK, or Switzerland, we rely on the specific safeguards below. We confirm that the EU Standard Contractual Clauses (with the UK International Data Transfer Addendum and the Swiss addendum where applicable) are in place with each US processor we engage, that we have carried out a transfer risk assessment for these transfers, and that, where a provider is certified under the EU-US Data Privacy Framework (and its UK Extension and Swiss-US framework), we additionally rely on that certification.

You have the right to obtain a copy of the relevant safeguards (e.g., the executed SCCs, with commercially confidential terms redacted). To request a copy, email hengsamkok76@gmail.com with the subject "Transfer safeguards request," and we will provide it.

10. Data Retention

We keep your personal information only for as long as we need it. Concrete periods and criteria are set out below:

• Account and profile data, trips, and saved places: retained while your account is active. When you delete your account, this data is deleted as described in Section 12.
• Subscription and purchase records: retained for the life of the subscription relationship and then for up to 7 years to meet legal, tax, and accounting obligations.
• Subscription event history (user_subscription_history): a per-event audit log retained to support billing accuracy and reconciliation. Events recorded before you sign up are keyed only to an anonymous store identifier (no account link); a signed-up user's history is deleted when you delete your account.
• Push tokens: an inactive token is retained to suppress stale deliveries; all push tokens are deleted when you delete your account.
• Referrals and invitations: your referral code and referral records (who referred whom, and reward status) are retained while your account is active and deleted when you delete your account. A pending invitation to a person who is not yet a user (their email, the trip, and your referral code) is deleted as soon as it is claimed or after it expires (30 days), whichever comes first. The log of invitation emails you sent is kept while your account exists.
• Public trip links: a trip's share code and copy count are kept while the trip exists; making the trip private revokes the link and code at once.
• Email verification codes: stored only as one-way hashes and expire after 10 minutes; the record that a code was sent is kept while your account exists.
• Abuse-prevention device IDs (trial_devices): retained for as long as necessary to enforce the one-free-trial-per-device limit, and de-linked from your account (the account reference is cleared) when you delete your account, consistent with storage limitation (Art. 5(1)(e)).
• Analytics and advertising data (GA4): user-level data is retained in Google Analytics 4 for the configured 14-month user-data retention window and then automatically deleted; aggregated reporting may persist longer in de-identified form.
• Ads measurement data sent to Meta: held by Meta under its own retention rules as a controller (see Meta's Privacy Policy). We keep no copy beyond the aggregated campaign reports Meta shows us. Turning ads measurement off stops new events at once; data Meta already holds is managed through Meta's own tools, or by contacting Meta.
• Performance / stability data (Firebase Performance): retained for Firebase's standard performance retention window (up to approximately 90 days for detailed traces).
• Support and email records: retained for as long as needed to handle your request and keep reasonable business records (typically up to 24 months).

When data is no longer needed, we delete or anonymize it.

11. Security

We take reasonable technical and organizational measures to protect your personal information. These include encrypted connections (HTTPS/TLS) for data in transit, authentication and access controls, database row-level security to enforce access rules, and platform-level protections that disable plaintext network traffic and exclude app data from device backups.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. You are responsible for keeping your account password confidential.

12. Account and Data Deletion

You can delete your VoyZa account at any time from within the App (Settings → Delete Account). When you delete your account, we:

• delete your profile, trips, and saved locations from our servers;
• cascade-delete your trip collaborations, your referral code and referral records, any pending invitations you created, associated subscription records, and your stored push tokens (device_tokens); and
• hand over to the trip owner any places you added to someone else's trip (they stay in that trip, marked as handed over from a deleted account), while places other people added to your trips stay with those people; and
• clear VoyZa data stored locally on your device.

Retained after deletion: To enforce our one-free-trial-per-device limit and prevent referral-reward abuse, the device identifier in our abuse-prevention registry (trial_devices) is retained after account deletion — de-linked from your account — for the period stated in Section 10. See Sections 2 and 10. Some other information may be retained where we are legally required to keep it (for example, transaction records for tax purposes) or in backups for a limited period before being overwritten. Content you previously shared with collaborators, copied by others from a public trip, or exported (for example, via CSV or PDF) may remain with those recipients. Rate-limit and send logs that reference only your former user ID, never your email, may remain. RevenueCat keeps its own customer record (app user ID and name, plus the email address if a version of the App before October 2026 stored it) and the stores keep their transaction records; deleting your VoyZa account does not cancel a store subscription — cancel it in your App Store or Google Play account.

Deleting without the App. If you cannot access the App, you can request account and data deletion via our web route at https://voyza.xtremon.com/#how-can-i-delete-my-voyza-account, or by emailing hengsamkok76@gmail.com. This web route is also referenced in our Google Play and App Store data-handling declarations.

13. Your Privacy Rights

How to exercise your rights (all regions)

You can exercise your rights by: (a) using the in-app controls described below; or (b) emailing hengsamkok76@gmail.com; or (c) writing to the controller by post (ask us for the address by email); or (d) for deletion, using https://voyza.xtremon.com/#how-can-i-delete-my-voyza-account.

• Withdraw consent to, or switch off, usage analytics or ads measurement: in the App at Settings → Preferences, using the two switches. On iOS you can also withdraw tracking permission in iOS Settings → Privacy & Security → Tracking; on Android you can reset or delete your Advertising ID in Settings → Google → Ads.
• Object to legitimate-interest processing (e.g., the free-trial abuse device check or fraud/security analytics): email hengsamkok76@gmail.com with the subject "Objection," identifying the processing; we will assess it and stop where required.
• Unsubscribe from lifecycle/marketing email: email hengsamkok76@gmail.com and we will stop promptly (these emails do not currently carry an unsubscribe link).
• Delete your account/data: in-app (Settings → Delete Account) or via https://voyza.xtremon.com/#how-can-i-delete-my-voyza-account.

We respond to rights requests free of charge and within one month of receipt (extendable by two further months for complex or numerous requests, in which case we will tell you within the first month). We may need to verify your identity before responding.

GDPR / UK GDPR (EEA, UK, Switzerland)

If you are in the EEA, the UK, or Switzerland, you have the right to:

• Access the personal information we hold about you;
• Rectify inaccurate or incomplete information;
• Erase your information ("right to be forgotten");
• Restrict processing in certain circumstances;
• Object to processing based on legitimate interests, and to direct marketing;
• Data portability — receive your data in a structured, commonly used, machine-readable format;
• Withdraw consent at any time where we rely on consent; and
• Lodge a complaint with a supervisory authority.

Automated decision-making / profiling. We do not carry out automated decision-making that produces legal or similarly significant effects about you under Article 22. The free-trial abuse device check is a simple rule-based duplicate-device check (it does not profile you or make significant automated decisions about you), and you may object to it as described above.

Supervisory authorities and complaints. You can lodge a complaint with your local supervisory authority. You can find your EEA authority via the European Data Protection Board's list at edpb.europa.eu. In the UK, you can contact the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint. In Switzerland, you can contact the Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch. We would, however, appreciate the chance to address your concerns first.

California (CCPA / CPRA)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose;
• Access and obtain a copy of your personal information;
• Delete your personal information;
• Correct inaccurate personal information; and
• Not be discriminated against for exercising your rights.

Categories and recipients. For the categories of personal information we collect, see Section 2; for the categories of recipients (service providers/processors and our ad-measurement controllers) and what we disclose to each for a business purpose, see Section 8. In the preceding 12 months we disclosed personal information (identifiers, account/contact data, commercial/purchase information, internet/usage activity, approximate and precise geolocation, and inferences) to service providers for business purposes, and device and event signals to our advertising-measurement partners (Google, and Meta from the first version of the App that includes Meta's SDK) for ad attribution. We do not disclose personal information to third parties for monetary consideration.

No sale. Sharing limited by design. We do not sell your personal information. Events we send to Meta carry Meta's Limited Data Use setting, under which Meta acts as our service provider for California residents and does not use that data for cross-context behavioral advertising. On that basis we do not "share" your personal information as the CCPA/CPRA defines the term. You can in any case stop all disclosure to advertising platforms with the Ads measurement switch at Settings → Preferences, which we treat as an opt-out of sale, sharing and targeted advertising for every US state that provides one.

Response times. We confirm receipt of verifiable consumer requests within 10 business days and respond within 45 days (extendable by a further 45 days with notice). Requests are free of charge.

To exercise your California rights, email hengsamkok76@gmail.com or write to the controller by post (ask us for the address by email). You may use an authorized agent, and we will verify requests as required by law.

Notice of Financial Incentive. Our free trial and any trial-recap/win-back messaging are standard product features and are not financial-incentive programs that are conditioned on, or that pay you for, your personal information; we do not currently offer any CPRA "financial incentive" or price/service difference in exchange for personal information. If we introduce one, we will add the required Notice of Financial Incentive here first.

Do Not Track / Global Privacy Control

Global Privacy Control (GPC) and "Do Not Track" are browser-based signals that are not transmitted to native mobile apps; the App has no mechanism to receive them. In the App, the equivalent controls are the Ads measurement switch, Apple's tracking permission and Android's advertising-ID settings, described in Section 6. If our website at voyza.xtremon.com begins to use advertising or analytics technologies that GPC applies to, we will honor GPC there.

14. Children's Privacy

VoyZa is a general-audience trip-planning app and is not directed to children. The minimum age to use the App is:

• 16 in the EEA, the UK, and Switzerland, except where a Member State has set a lower age of digital consent under Article 8 GDPR (which may be 13, 14, 15, or 16), in which case that national age applies; and
• 13 in the United States and elsewhere.

We do not knowingly collect personal information from anyone below the applicable minimum age. Most processing for account holders relies on contract rather than consent; where national law sets a minimum age for entering into the relevant contract or for valid consent, that minimum-age rule applies, and a user below it should not use the App or should do so only with verifiable parental/guardian consent. Where processing relies on consent (analytics and ads measurement for EEA/UK/CH users), the consent prompt asks you to confirm that you are old enough to give that consent in your country; if you are not, please choose "Don't allow". We do not otherwise ask for or verify your age or date of birth, and we do not knowingly proceed with consent-based processing for a user below the applicable age.

If we learn that we have collected personal information from a child below the applicable minimum age without the required parental/guardian consent, we will delete the account and associated personal information and remove any related abuse-prevention identifier from active use. If you believe a child has provided us personal information, contact us at hengsamkok76@gmail.com and we will act promptly.

15. Third-Party Links and Services

The App may link to or open third-party apps and services — for example, opening Google Maps or a ride-hailing app for directions, or the Apple App Store / Google Play for subscriptions. These third parties have their own privacy policies, and we are not responsible for their practices. We encourage you to review the privacy policy of any third-party service you use.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. For material changes — a new purpose, a new category of data, or a new recipient — we will also tell you in the App before the change takes effect.

Where a change involves processing that needs your consent — any new analytics, advertising or measurement processing for users in the EEA, the UK and Switzerland, and any processing for which the law of your region or Apple's or Google's platform rules require consent — we will ask for fresh, affirmative opt-in consent before that processing begins. Continued use of the App is never treated as consent to it.

Where a change does not need consent, the in-app notice will say what is changing and how to switch it off, and the change takes effect after the notice has been shown.

17. Contact Us

If you have any questions, requests, or complaints about this Privacy Policy or how we handle your personal information, contact us at: