Privacy Policy for Bozy

1. Introduction

Welcome to Bozy ("App"). This Privacy Policy governs your use of the App (including any in-app purchase features) and explains how we collect, use, store, disclose, and protect your personal information. By accessing or using the App, you confirm that you are at least 18 years of age and agree to the terms of this Privacy Policy. We comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws to safeguard your privacy rights.

This Policy applies to all users of the App, including those who contribute User-Generated Content (UGC) such as text, images, videos, comments, or other materials, and those who make in-app purchases. Please read this Policy carefully before using the App. If you do not agree with any part of this Policy, please refrain from accessing or using the App.

2. Eligibility

The App is exclusively intended for users aged 18 years or older. By registering an account, using the App, or making in-app purchases, you warrant and represent that you are 18 years of age or older and have the legal capacity to enter into this agreement and to complete financial transactions. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a user under 18 has provided personal information or made in-app purchases, we will take steps to delete such information and process a refund of any purchases promptly.

3. Collection of Personal Information

3.1 Information You Provide Voluntarily

Account Registration Information: When creating an account, you may provide personal information such as your email address, username, password, and profile picture.
User-Generated Content (UGC): Any content you post, upload, share, or submit through the App, including but not limited to text, images, videos, audio, comments, and other materials.
Communication Data: Information you provide when contacting our customer support (e.g., via help@bozyonline.com), including your queries, feedback, and communication history.
In-App Purchase Information: When making in-app purchases, you may provide or we may collect transaction-related information such as your payment method details (processed by third-party payment providers), purchase amount, purchase date and time, item purchased, and receipt information. We do not store full payment card details, as these are processed securely by authorized third-party payment processors (e.g., Apple App Store Payment Processor).

3.2 Automatically Collected Information

When you use the App (including when making in-app purchases), we may automatically collect certain information about your device and usage, including:

Device Information: Device model, operating system version, unique device identifiers (e.g., IMEI, MAC address), IP address, and mobile network information.
Usage Data: Information about how you interact with the App, such as access times, pages visited, features used, session duration, click-through rates, and in-app purchase activity (e.g., items viewed, purchase attempts, and purchase completion status).
Cookies and Similar Technologies: We use cookies and similar tracking technologies to enhance your user experience, analyze usage patterns, improve the App, and track in-app purchase preferences. You can manage your cookie preferences through your device or browser settings, but disabling certain cookies may affect the functionality of the App, including in-app purchase features.

3.3 Legal Basis for Data Collection (GDPR Compliance)

Under the GDPR, we process your personal information (including in-app purchase data) based on the following legal grounds:

Consent: Your explicit consent to process your information for specific purposes (e.g., collecting UGC, sending marketing communications about in-app purchase offers). You may withdraw your consent at any time by contacting us at help@bozyonline.com.
Performance of a Contract: Processing necessary to fulfill our obligations under the user agreement (e.g., providing access to the App, managing your account, processing and fulfilling in-app purchases).
Legitimate Interests: Processing necessary to pursue our legitimate interests, such as improving the App, ensuring security, analyzing in-app purchase trends, and enforcing our terms of service, provided that such interests do not override your privacy rights.
Legal Obligation: Processing required to comply with applicable laws, regulations, or legal processes (e.g., tax reporting for in-app purchase transactions).

4. Use of Personal Information

We use your personal information (including in-app purchase data) for the following purposes:

To provide, maintain, and improve the App and its features, including in-app purchase functionality.
To manage your account and verify your identity, including verifying in-app purchase eligibility and ownership.
To process, fulfill, and confirm in-app purchases, including issuing receipts and handling refunds or disputes related to purchases.
To moderate and manage UGC in accordance with this Policy and our Content Guidelines.
To communicate with you, including responding to your inquiries, providing updates about in-app purchases, and sending important notices (e.g., purchase confirmations, refund status).
To personalize your user experience and deliver relevant content, recommendations, and in-app purchase offers based on your usage patterns and preferences.
To monitor and analyze usage trends and patterns (including in-app purchase activity) to enhance the App's functionality and performance.
To detect, prevent, and address fraud, security issues, or other illegal activities, including unauthorized in-app purchases.
To comply with applicable laws, regulations, and legal obligations (e.g., tax compliance for in-app purchase transactions).

5. Disclosure of Personal Information

We will not sell, rent, or lease your personal information (including in-app purchase data) to third parties without your consent, except as follows:

Service Providers: We may share your information with trusted third-party service providers who assist us in operating the App, providing services, or performing business functions (e.g., cloud storage, payment processing for in-app purchases, customer support, fraud detection). These service providers are bound by confidentiality obligations and may only use your information to perform the services we request.
Payment Processors: We share transaction-related information (e.g., purchase amount, item purchased) with authorized third-party payment processors (e.g., Apple App Store Payment Processor) to process in-app purchases. These processors are required to comply with applicable data protection laws and only use your payment information to complete the transaction.
Legal Compliance: We may disclose your information if required by law, regulation, legal process, or governmental request (e.g., subpoena, court order), including disclosing in-app purchase data to comply with tax or financial regulations.
Protection of Rights: We may disclose your information to protect our rights, property, or safety, or the rights, property, or safety of other users or third parties. This includes investigating and addressing violations of this Policy or our Content Guidelines, unauthorized in-app purchases, or responding to emergency situations.
Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information (including in-app purchase history) may be transferred as part of the business transaction. We will notify you of any such transfer and ensure that the receiving party complies with this Policy.
With Your Consent: We may disclose your information with your explicit consent for other purposes not listed above (e.g., sharing in-app purchase preferences with a third-party partner for personalized offers).

6. User-Generated Content (UGC) Guidelines and Policies

6.1 UGC Definition

UGC refers to any content created, uploaded, shared, or submitted by users through the App, including but not limited to text, images, videos, audio, comments, reviews, and other materials. By submitting UGC, you grant us a non-exclusive, worldwide, royalty-free, perpetual, irrevocable license to use, reproduce, modify, adapt, publish, distribute, and display such content for the purpose of operating and promoting the App (including in connection with in-app purchase features).

6.2 Prohibited UGC Content

You agree not to create, upload, share, or submit any UGC that:

Contains pornographic, sexual, or explicit content, including but not limited to nudity, sexual acts, or sexually suggestive material.
Is violent, graphic, or causes discomfort, including but not limited to depictions of physical harm, torture, mutilation, or death.
Promotes or facilitates gambling, betting, or any form of illegal gaming activity.
Involves or promotes drugs, narcotics, controlled substances, or illegal drug use.
Relates to politics, political figures, political parties, or political activities, including but not limited to political propaganda, lobbying, or partisan content.
Contains discriminatory, hateful, or offensive content based on race, ethnicity, nationality, religion, gender, sexual orientation, age, disability, or any other protected characteristic.
Is defamatory, libelous, slanderous, or infringes upon the privacy, reputation, or intellectual property rights of others.
Incites hatred, violence, discrimination, or harassment against any individual or group.
Violates any applicable laws, regulations, or third-party rights.
Is spam, unsolicited advertising, or promotional content (including unauthorized promotion of in-app purchase items).
Contains malware, viruses, or other harmful code.

6.3 UGC Moderation

We reserve the right to moderate, review, and remove any UGC that violates this Policy or our Content Guidelines. We use a combination of automated tools and human moderators to monitor UGC. However, we cannot review all UGC in real-time, and we do not guarantee that all prohibited content will be detected and removed immediately. We may take action against users who violate these guidelines, including but not limited to:

Removing the prohibited UGC.
Issuing a warning to the user.
Restricting or suspending the user's account privileges (including access to in-app purchase features).
Terminating the user's account permanently (including revocation of access to purchased in-app items, where permitted by law).
Reporting the user to relevant authorities if the content constitutes a criminal offense.

6.4 UGC Reporting Mechanism

We encourage users to report any UGC that violates this Policy or our Content Guidelines. To report prohibited content:

Locate the UGC you wish to report (e.g., comment, post, video).
Click on the "Report" button or icon associated with the content.
Select the appropriate reason for reporting (e.g., pornographic content, hate speech, gambling, unauthorized in-app purchase promotion).
Provide any additional details or evidence to support your report (optional but recommended).
Submit the report.

Upon receiving a report, we will review the content promptly (within a reasonable time frame) and take appropriate action in accordance with this Policy. We will notify the reporting user of the outcome of the review if possible, but we reserve the right to keep certain details confidential to protect the privacy of other users.

7. In-App Purchase Specific Terms

7.1 Purchase Authorization

By making an in-app purchase, you authorize us (and our third-party payment processors) to charge your selected payment method for the total amount of the purchase (including any applicable taxes). All in-app purchases are subject to the terms and conditions of the Apple App Store, in addition to this Privacy Policy.

7.2 Refund Policy for In-App Purchases

Refunds for in-app purchases are governed by Apple App Store refund policies and applicable laws. If you wish to request a refund for an in-app purchase, you may do so through the Apple App Store or by contacting us at help@bozyonline.com. We may collect and process your refund request information (e.g., purchase receipt, reason for refund) to assist with the refund process, in compliance with GDPR and Apple's requirements.

7.3 Purchase History and Data

We retain your in-app purchase history for the period required to fulfill the purposes outlined in Section 8 (Data Retention), including tax compliance, refund processing, and providing purchase support. You may request access to your purchase history at any time by contacting us at help@bozyonline.com, in accordance with your GDPR data access rights.

7.4 Restrictions on In-App Purchases

We reserve the right to restrict or suspend access to in-app purchase features if we suspect fraudulent activity, violation of this Policy, or non-compliance with Apple App Store terms. We may collect and use device and transaction data to detect and prevent fraudulent in-app purchases, in accordance with our legitimate interests under GDPR.

8. Data Security and Protection

We implement appropriate technical and organizational measures to protect your personal information (including in-app purchase data) from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

Encryption of data in transit (e.g., using SSL/TLS) and at rest (e.g., encrypted databases), including encryption of in-app purchase transaction data.
Access controls to limit access to personal information (including payment and purchase data) to authorized personnel only.
Regular security audits and assessments to identify and address potential vulnerabilities, including those related to in-app purchase processing.
Training and awareness programs for employees on data protection and security best practices, including handling of in-app purchase data.
Implementation of firewalls, antivirus software, and other security tools to prevent unauthorized access to the App and in-app purchase systems.

However, no method of data transmission or storage is 100% secure. We cannot guarantee the absolute security of your personal information (including in-app purchase data), and you acknowledge and accept the inherent risks associated with using the App and making in-app purchases. You are responsible for maintaining the confidentiality of your account credentials (e.g., username, password) and not sharing them with others. If you suspect any unauthorized access to your account or unauthorized in-app purchases, please contact us immediately at help@bozyonline.com.

9. Data Retention

We will retain your personal information (including in-app purchase data) for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The retention period will be determined based on the following factors:

The purpose of the data processing (e.g., to maintain your account, provide services, process in-app purchases, comply with legal obligations such as tax reporting).
The type of personal information collected (e.g., in-app purchase history may be retained for tax compliance purposes for the period required by law).
Applicable legal requirements (e.g., statutory retention periods for financial and transaction data).

Once the retention period expires, we will delete or anonymize your personal information (including in-app purchase data) to ensure it can no longer be associated with you. If you wish to request the deletion of your personal information (including purchase history, where permitted by law), please contact us at help@bozyonline.com.

10. Your Data Protection Rights (GDPR)

Under the GDPR, you have the following rights with respect to your personal information (including in-app purchase data):

Right to Access: You have the right to request access to the personal information we hold about you, including in-app purchase history, transaction data, and details of how we process this information.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information, including incorrect in-app purchase records.
Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal information, subject to certain exceptions (e.g., legal obligations to retain in-app purchase data for tax purposes).
Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances (e.g., if you contest the accuracy of your in-app purchase data).
Right to Data Portability: You have the right to receive your personal information (including in-app purchase history) in a structured, commonly used, and machine-readable format, or to request that we transfer it to another data controller.
Right to Object: You have the right to object to the processing of your personal information for certain purposes (e.g., using your purchase history to send marketing offers, processing based on legitimate interests).
Right to Withdraw Consent: If we process your information based on your consent (e.g., using your purchase data for personalized marketing), you have the right to withdraw your consent at any time.

To exercise any of these rights (including rights related to in-app purchase data), please contact us at help@bozyonline.com. We will respond to your request within one month of receipt, and we may ask for additional information to verify your identity (e.g., purchase receipt details). We will not charge you for exercising your rights, unless your request is excessive, repetitive, or unfounded.

11. Third-Party Links and Services

The App may contain links to third-party websites, applications, or services (including third-party payment processors for in-app purchases). This Privacy Policy does not apply to such third-party platforms, and we are not responsible for their privacy practices or content. We encourage you to review the privacy policies of any third-party platforms you access through the App, including Apple's privacy policy for App Store payments.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the App's functionality (including changes to in-app purchase features). We will notify you of any material changes by posting the updated Policy on the App, sending you a notification, or contacting you via email. The updated Policy will take effect on the effective date stated at the top of the Policy.

We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect your personal information (including in-app purchase data). Your continued use of the App (including making in-app purchases) after the effective date of the updated Policy constitutes your acceptance of the changes.