FeelType Privacy Policy

Effective: 17th April, 2025

As your Service provider, Luvento Limited, its related corporations and affiliates, ("we", "our" or "us") respects your legal rights of privacy when collecting, storing, using and transmitting Personal Information (as defined below) and this Privacy Policy explains our privacy practices. It is our policy and obligation to comply with the requirements of the laws of the United State.

Please read the following carefully to understand our policy and practices regarding how your Personal Information will be treated. This Privacy Policy applies to all registered and unregistered Users of FeelType (hereinafter referred to as the "App") and may from time to time be revised, or otherwise changed where necessary.

By being one of our Users you agree to be bound by all the terms and conditions set out in this Privacy Policy and THAT YOU GIVE US YOUR CONSENT to collect, use and disclose such Personal Information. If you do not accept the terms of this Privacy Policy or disagree with any subsequent amendments, changes, or updates we made, you MUST NOT access the FeelType and not use any Service provided by us. You hereby agree your only recourse in this case is to cease and desist from further use of the Service.

Please note that our Privacy Policy has also been updated to comply with the requirements under the EU General Data Protection Regulation (the "GDPR"), the California Consumer Privacy Act (the "CCPA"), and other personal data protection regulations.

THIS DOCUMENT CONTAINS IMPORTANT TERMS AND CONDITIONS WHICH AFFECT YOUR RIGHT TO PRIVACY AND YOUR EXPECTATIONS AS TO YOUR PRIVACY. USING THE APP CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY POLICY.

The terms "you", "your", and "yours" refer to all users, and/or any user of the App. The terms "its", "we", "us", "our", "FeelType" and "App" refer wholly or in part to Luvento Limited, its related subsidiaries and affiliates (collectively, the "Company" or "FeelType"). Your privacy is an important factor that we considered in the development of our Services. As such, we are committed to being transparent and open. This Privacy Policy explains generally how we collect, store and process the information, which may include personally identifiable data ("Personal Data"). The Privacy Policy applies to all Personal Data processed by us, including Personal Data collected or submitted through our App. The "FeelType Privacy Policy" shall be referred to as the "Privacy Policy" hereinafter.

BY USING OUR APP, OR DOWNLOADING OR ACCESSING OUR APP, YOU ARE CONSENTING TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR COLLECTION AND USE OF PERSONAL INFORMATION AS OUTLINED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

1. INFORMATION THAT WE MAY COLLECT

We may collect different types of personal and other identifiable information based on your use of the Services. Wherever the Company collects Personal Data we make an effort to provide a link to this Privacy Policy. When you use our app, and otherwise use our Services including when you use some of the functions of our software applications offline, we may collect the following types of Personal Data related to the Services from our users:

Identifiers such as alias, postal address, internet protocol address, email address, account name, usage data or other similar identifiers. We will collect your contact information if you reach out to us with questions about customer service.

Internet or other electronic network activity information, including but not limited to, user content, information regarding a consumer's interaction with an internet website, application, or advertisement.

Login information and passwords in other sites, to help you fill out forms or sign in to sites you visit. You can manage or delete stored browsing data or history information from the Cookies.

Data collected by the App includes information gathered in accordance with the contracts you are involved in or obligations before the contract's formation, compliance with our legal obligations, or our legitimate interests in marketing and other business activities.

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

To enhance app functionality and analytics, we require access to web browsing history, including information about the websites users have visited. We collect personal data related to web browsing history.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Company, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of the Company and the authorized third parties referred to herein.

We may also collect:

  1. (i) Non-Identifiable Data. When you interact with the Company through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. The Company may store such information itself or such information may be included in databases owned and maintained by the Company, affiliates, agents or service providers. The Services may use such information and pool it with other information to track. It is important to note that no Personal Data is available or used in this process.
  2. (ii) Aggregated Personal Data. In an ongoing effort to better understand and serve the users of the Services, the Company may conduct research on its customer demographics, interests, and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and the Company may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. The Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.
  3. (iii) A cookie is a text file placed on the hard disk of your computer by a Web page server. Please rest assured that the Cookies cannot be used to run programs or bring viruses to your device. Cookies are uniquely assigned to your computer, and can only be read by the web server in the domain which issued to you the cookies. The purposes of a cookie are to enable the Web server to recognize your return to a specific page, and to provide you convenience to save you time. You are provided with the option to accept or decline cookies. Most Web browsers will automatically accept cookies, and you can modify your browser setting to decline cookies. When you choose to decline cookies, your experience of interaction with the FeelType services can be compromised. The APP use cookies to better your interactions with the APP. Our servers will send to your device a cookie while you visit our APP. The cookies, however, cannot be used to personally identify you. We will not be able to know your identity unless you choose to identify yourself to us by, for instance, responding to our marketing questionnaire. The types of Cookies include persistent-based Cookies. Persistent cookies will be kept on your computer after you turn off your computer. The APP uses persistent cookies that only the Company will be able to read and use to identify your previous visit. Whenever you access the APP, a unique identifier is assigned to you through the server. This unique identifier is associated with a persistent cookie. The security and confidentiality of the information stored in persistent cookies shall be especially taken care of by the Company.
  4. (iv) Data Related to the Use of our Products or Services. This data includes, but is not limited to, activation dates and times, device details (like model and OS version), and usage statistics (such as feature usage frequency and error logs). We collect this information to ensure smooth operation and improve user experience.
  5. (v) User Generated Content. We offer you the ability to post content that other users can read. Anyone can read, collect and use any personal information that you post. Read our Terms and Conditions on posting for more information. We do not have to publish any of your content. If the law requires us to take down, remove or edit your personal information, we will comply to the required extent.

2. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION

The Company uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. FeelType may use your data (including data concerning your activity with a FeelType product or software) across all other FeelType products and software to deliver FeelType products, functionality, or features. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem.

Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. The Company may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services to better understand our users and to improve the Services.

The Company may use this information to contact you in the future to tell you about Services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt out" of receiving future marketing communications.

In addition, if at any time you wish not to receive any future marketing communications, or you wish to have your name deleted from our mailing lists, please contact us at [email protected]. If the Company intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, the Company would inform you of such anticipated use prior to or at the time at which the Personal Data is collected.

3. WE MAY SHARE YOUR PERSONAL DATA AND OTHER INFORMATION WITH THIRD PARTIES

Our Company is not in the business of selling your Personal Data. Maintaining the privacy of your Personal Data is a vital part of our relationship with you and an important aspect of the Services that we provide. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers. As we develop our business, we might sell or buy businesses or assets, including Personal Data. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Agents, Consultants, and Third Parties. The Company, like many businesses, sometimes contracts other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and customer service. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Additionally, we reserve the right to use third party analytics service providers and advertising partners to collect personally identifiable information about your online activities over time and across different websites when you use our Services, including details as described in this Privacy Policy. Furthermore, we partner with third parties to provide certain support services to our users. We try to limit how these third parties can use the information they gather from you or that we provide. The processing and storage of any and all information you may provide to any of such third parties, including information they may collect from you, is not governed by this Privacy Policy. You will need to review the Privacy and Cookie Policy of such third party on their websites and accept separately if necessary.

With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

Legal Requirements. The Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

4. HOW LONG WE KEEP YOUR CONTENT

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action. The storage periods are determined on a case-by-case basis that depends on factors like the nature of the information, why it is collected and processed, relevant legal or operational retention needs, and legal obligations.

If you wish to delete your personal information you have provided to us, please contact us by email at [email protected].

* Please be noted that any Content that you send to the recipient as aforementioned does not fall within the scope of personal information which we will collect under Article 1 of the Privacy Policy. The Company hereby disclaims any obligation or liability for acquisition, storage and use of the Content by any third party, including the recipient, to whom the Content is sent by the User.

5. CHILDREN SHOULD NOT SUBMIT PERSONAL DATA

The Company does not knowingly collect Personal Data from individuals under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children under the age of 18 never to provide Personal Data to the Services. If you have reason to believe that someone under the age of 18 has provided Personal Data to the Company through the Services, please contact us at [email protected], and we will endeavor to delete that information from our databases.

6. HOW WE SECURE YOUR INFORMATION AND CONTENT

The Company takes commercially reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The Company uses security measures for any personal and account data that we store (emails, phone numbers, etc.). Account-identifiable or user-identifiable data collected through the Services may be encrypted and stored on our internal databases. The Company will not sell or transfer account-identifiable data to third parties. Any accessible data associated with your account or your profile can be retrieved only if you provide us with your account identifier. Please be reminded, however, that no internet or email transmission or data storage is ever fully secure or error free and that information on the Services may be accessed, disclosed or altered. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to Company via the Internet.

Please note that all payments for products and services are processed by third-parties. The Company makes good-faith efforts to use third-party companies which employ proper protections for private information. However, we have no control over said companies; therefore, the Company exclusively disclaims any obligation or liability for said third-parties' processes and security measures.

7. YOUR ABILITY TO MODIFY OUR USE OF YOUR PERSONAL DATA UNDER GDPR

Under the GDPR, you have the following rights related to the Company's use of your Personal Data:

  1. a. Right to withdraw consent. You have the right to notify the Company that you no longer want us to process or use your Personal Data. You can do that by contacting the Company at [email protected]. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
  2. b. Right to data portability. You have the right to obtain a copy of your Personal Data stored and processed by the Company and direct the Company to transfer your Personal Data to another controller via a structured, commonly used and machine-readable format. You can do that by contacting the Company at [email protected].
  3. c. Right to erasure/ Right to be forgotten. You have the right to request that any of your Personal Data being stored or processed by the Company is deleted from our records. However, while we can delete your Personal Data from our current records, copies of your data may be stored in the Company's inactive and archived records and will be deleted in accordance with the Company's then-current document management policy. In some cases, your Personal Data may be continued to be stored in archived records of transactions or activities where we are required by law to retain such records.
  4. d. Right to restriction of processing. You may request that the Company restrict the processing of your Personal Data. In such case, this may affect your ability to navigate or use the Services.
  5. e. Request correction of the Personal Data that we hold about you. you have the right to have any incomplete or inaccurate information we hold about you corrected.
  6. f. Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where We are processing your Personal Data for direct marketing purposes.
  7. g. To exercise any of your rights above, please contact the Company at [email protected]. If you choose to exercise any of your rights listed above, it may affect your ability to use the Services, as the operation and functionalities provided on the Services may require the use of your Personal Data.
  8. h. Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data, as well as other supplementary information. You can do that by contacting us using the contact details abovementioned.
  9. i. Right not to be subject to discrimination: We will not provide a different level of quality of goods or services.

8. ABILITY TO REVIEW AND EDIT YOUR INFORMATION

You may review and approve the Information about you that was stored in our database and obtained through your use of the Services. Upon your written request, we will remove that information from our database or change or correct Personal Data that you state is erroneous within applicable regulatory or other legal requirements. You should understand, however, that information about you in our database might come from a number of sources, so any inaccuracy is not necessarily the fault of the Company.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This supplemental privacy policy shall apply only to residents of California, according to the regulation of CCPA, and may be subject to change. The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. Any term used in this supplemental privacy policy shall have the same meaning as in the general privacy policy.

9.1 The CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail above, the categories of personal information that we have collected, as described by the CCPA, are:

Identifiers, demographics, commercial information, internet activity, web browsing history, and inferences(for more details, please refer to Article 1 of this Privacy Policy).

9.2 We collect and use these categories of personal information for our business and commercial purposes that are previously described, including providing and improving our services, maintaining the safety and security of our services, processing purchase and sale transactions, and for advertising and marketing services. We share personal data as described above under Article 3.

9.3 For the purposes of the CCPA, FeelType does not sell personal information, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age. California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the direct marketing purposes of third parties. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us, in writing by email at [email protected].

Under CCPA, personal information does not include:

9.4 Your Rights under the CCPA.

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, you have the following rights: the right to notice, request, say no to the sale of Personal Data (opt-out), delete Personal Data and not to be discriminated against .

9.5 In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us at [email protected].

Your request to us must provide sufficient information. We cannot respond to your request or provide you with the required information if we cannot v erify your identity or authority to make the request. And confirm that the personal information relates to you. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

9.6 Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

10. Other Information Collected:

App Extension Keyboard Information

The Company may track or otherwise keep record of keystrokes for statistical purposes and will do so in an anonymized and non-identifiable manner. The Company may also share such statistical data with third parties or persons or make it available for the general public on its website or in any other form.

Social Media Connections

The Company may allow you to "register" with the Company by using Apple, Google, Facebook Connect or other Social Networking Site ("SNS") authentication options to create an account within the Websites and Apps. The Company may also provide a more typical registration flow where you may be required to provide certain information such as your first and last names; your email address; a password and other information that helps the Company confirm that it is you accessing your account. If you use your login credentials from any SNS, you do so at your own risk and the Company is not liable for you doing so.

At this time, but subject to change without any notice and at any time, you can connect your Company account to your accounts on third party services like Apple, Google, Facebook, in which case the Company may collect, use, disclose, transfer and/or store information relating to your account with such third-party services in accordance with this Privacy Policy. For example, if you connect with Apple, Google, Facebook, the Company may store, among other things, your Apple ID, Google ID, Facebook ID, first name, last name and/or email address and use any or all of them to connect with your Apple, Google, Facebook account to provide certain other information, such as your request history. The Apps allow you to share and/or disclose information on TikTok, X, Apple, Google, Instagram and/or Facebook, such as sharing and/or disclosure is governed by the practices and policies of those apps.

Use of third-party social networking apps, such as TikTok, X, Apple, Google, Instagram and Facebook, are governed by the privacy practices and policies of those apps, which may include, among other things, your ability to opt out of certain settings. Also, if and when you share or recommend links to content on a third-party platform (TikTok, X, Apple, Google, Instagram and Facebook), that action and any information you share will be covered by their respective privacy policies.

Additionally, the Company may use a variety of new technologies and social media options to communicate and interact with you. These mobile applications include popular social networking and media sites, such as TikTok, X, Apple, Google, Instagram and Facebook. The Company does not capture or store your login password for TikTok, X, Apple, Google, Instagram and Facebook and other social networks; however, session information or cookies may be stored on your phone, by their apps. Web-enabled mobile applications may, among other things, use cookies or web beacons and other methods to customize your browsing experience.

11. CHANGES TO THE PRIVACY POLICY

The Company hereby reserves the right to modify/amend or otherwise change this Privacy Policy, as it deems necessary or appropriate because of legal compliance requirements or changes in Company's business practices. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email, and update the date at the top of this Privacy Policy. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy. If you do not agree with our updated Privacy Policy, please do not use our Services.

12. CONTACT US

If you have any further questions about this Policy, please contact us by email at [email protected].