DATA USAGE MANAGER - PRIVACY POLICY

]Last Updated: August 5, 2025[

INTRODUCTION

This privacy policy ("Privacy Policy") governs the data collection practices used by Flavr Technology LP

(“Company”, “we” or “us”) in relation to your (“you” or “user”) use of our Data Usage Manager mobile app,

which analyzes and keeps track of how much data the various apps installed on your device use, or our

website (collectively, the "Mobile App”). The services that we provide within the Mobile App shall be

referred to herein as the “Services”.

THIS PRIVACY POLICY. IF YOU OBJECT TO THE TERMS HEREIN, PLEASE DO NOT ACCESS, DOWNLOAD OR USE

THE MOBILE APP OR SERVICES.

AGE LIMITATION

You represent and warrant that you are at least 18 years of age (or at least above the age that would be

considered a minor or child in your country or state of residence) and of legal competence to enter into

these terms. If we become aware that a user under the age of 18 has shared any information with us, we

will discard such information. If you have any reason to believe that a child under the age of 18 has shared

any information with us, please contact our Data Protection Officer at: dpo@flavrtech.co.

Non-Personal Information which we collect may include your aggregated usage information and technical

information transmitted by your device, including: (i) certain software and hardware information, such as:

type of device and operating system; and (ii) Mobile App session ID, the time and date you access the

Mobile App.

The second type of information we may collect when you install or otherwise use the Mobile App is

individually identifiable information, namely information that identifies an individual or may with

reasonable effort identify an individual (“Personal Information”).

Directly Collected Personal Information: This information may include contact information, such as your

name, telephone number, address, email, etc., which you might provide us if you voluntarily contact us.

Additionally, you may be able to subscribe for certain services, as further explained via the Mobile App in which

reflecting usage patterns or performance, details about your search behavior within these applications,

records of online shopping activity, advertisements that are displayed, and certain communications sent

through messaging platforms that you use; (iii) Mobile Web Data - this includes information about your

activity across mobile websites that you visit while using our Services including the URLs you visit, time you

spent there and your interactions there; (iv) AI Prompts and Outputs - we may collect and process the

users, and which we irreversibly encrypt so that it would be very difficult to be used to identify you.

In order to provide our Services, we may request access to certain Android permissions (“Permissions”),

such as: (i) App Usage and Storage; (ii) Query Intent; and (iii) Accessibility. We use the information obtained

through the Permissions for the purpose of providing our Services. Specifically we use the App Usage and

Storage Permission to monitor your mobile data usage and display the analysis on your home screen and

within the Mobile App. The Query Intent Permission is used to provide our Services and the Accessibility

Permission is used to enable the Smart Warnings and app details features even when the Mobile App is not in

use.

To access these Permissions, you will need to actively enable them through your mobile device

HOW DO WE USE YOUR INFORMATION? WHAT IS OUR LEGAL BASIS?

● Contact Information and Social Network Registration - we will use this information solely to

respond to your requests and support your needs. Our legal basis for the use of such information is

to fulfill our contract with you, by providing you with the Services that you requested.

● Installed Applications Data - we will process this data to provide you with the Services and fulfill

our contract with you. We may also process this data, based on your consent, if we need to obtain it

in order to do so. Our affiliates, who support us in operating the Services, typically process this

information and filter or aggregate this information so that it cannot reasonably be used to identify

you or your device. In limited circumstances, our affiliates may share such information with their

customers for purposes such as market analysis or research into consumer trends. Any such sharing

where the customer has agreed by contract not to attempt to identify you. We may also process

this data based on your consent, if we need to obtain it under applicable law, in order to do so.

● Mobile Web Data - we will process this data to provide you with the Services and fulfill our contract

with you. We may also process this data, based on your consent, if we need to obtain it in order to

do so. Our affiliates, who support us in operating the Services, typically process this information and

contract with you. We may also process this data, based on your consent, if we need to obtain it in

order to do so. If any sensitive personal data is unintentionally included in the AI inputs or outputs,

it will be handled based on your explicit consent when such consent is required under applicable

laws. You may revoke this consent at any time by using the opt-out methods described below. To

stop the collection of AI inputs and outputs, please refer to the instructions provided in the “How to

Delete Your Data and Exercise Your Rights” section. Our affiliates, who support us in operating the

Services, typically process this information and filter or aggregate this information so that it cannot

reasonably be used to identify you or your device. In limited circumstances, our affiliates may share

such information with their customers for purposes such as market analysis or research into

consumer trends. Any such sharing occurs only where the customer has agreed by contract not to

We may share your Personal Information with third parties for the purposes described in this Privacy Policy,

including:

● Legal, Regulatory, and Safety Disclosures: We may disclose Personal Information as required by law

or when we believe it is necessary to protect our rights or the safety of others. This includes sharing

information with law enforcement, regulatory authorities, and other government entities, as well as

in situations involving potential threats, fraud, or legal disputes.

● Business Transactions: If we or our affiliates undergo a merger, acquisition, investment,

reorganization, or asset sale, your Personal Information may be shared or transferred as part of the

process. This can include disclosures during due diligence to attorneys, auditors, lenders, and

● Affiliates: We may share Personal Information with our affiliated companies. These entities may use

the information for analytics, market research, and other uses consistent with this Privacy Policy.

Our affiliates may also disclose some of this information to their customers as part of their market

intelligence services however, only under terms that do not allow its customers to identify any one

individual (including you) by way of the information.

● Marketing and Advertising Partners: To support our promotional and advertising efforts, we may

share Personal Information with third-party platforms, networks, and partners involved in managing

and optimizing campaigns.

● Objection to Processing: You may object to the processing of your Personal Information when we

In order to assert any of these rights, please contact our data protection officer at: dpo@flavrtech.co.

● Conducting internal analysis and improving performance

● Marketing and ad campaign management

● Ensuring the safety, integrity, and legal compliance of our Services

● Responding to legal obligations or regulatory requests

● Supporting corporate events, such as mergers or business reorganizations

cross-context behavioral advertising.

We may engage in “selling” or “sharing” certain categories of Personal Information—such as identifiers and

browsing behavior (including Mobile Web Data, App Activity Data, Installed Applications Data and AI

Prompts and Outputs)—to business clients for marketing analytics. Some of the information involved may

qualify as sensitive under state privacy laws.

Data Retention Practices

We retain Personal Information only for as long as necessary to fulfill the purposes for which it was

collected, or as otherwise disclosed at the time of collection. When determining how long to keep

information, we take into account our legal responsibilities, the nature of the data, and whether we have a

valid reason to preserve it (such as in connection with legal holds).

we’ve collected, where it came from, the purposes behind its collection, and who it’s been shared

with over the past 12 months.

● Right to Know (Sale/Disclosure): You may also inquire about how we’ve disclosed or sold your data

during the same timeframe, including what types of information were involved and which third

parties received it.

● Right to Access (Copy): You can request a copy of the specific pieces of Personal Information we’ve

gathered about you.

● Right to Data Portability: Where applicable, you can request that your data be provided in a

portable, machine-readable format.

Only you or a representative authorized and registered with the California Secretary of State to act on your

behalf may make a CCPA request. Requests must be sent by e-mail to dpo@flavrtech.co.

We must verify your identity and that you have the authority to make the request before we can respond,

beginning with matching the information in the request with information in our files. As a result, while we

will attempt to limit the additional information required in a CCPA request, we need sufficient personal

Residents of certain other U.S. states may have additional rights under applicable privacy laws and be entitled to

additional disclosures as follows:.

Sale of Personal Data: We may sell the following categories of Personal Data: Identifiers, commercial

information, internet and electronic network activity information, profiles and inferences, and “sensitive data,”

as that term is defined under applicable U.S. privacy laws. We sell such categories of Personal Data to our

business customers so that they may conduct their own analysis on consumer behaviors and analyze and

improve their marketing and advertising campaigns.

To exercise your privacy rights under applicable U.S. state laws, you can submit a request by contacting us

via email at dpo@flavrtech.co. Upon receiving your request, we will take reasonable steps to verify both

your identity and the nature of the request by comparing the details you provide with information already

at dpo@flavrtech.co. In such cases, you will need to provide valid proof of your authority to act on the

and your authorization to act on their behalf.

We employ industry standard procedures and policies to ensure the safety of our users’ information, and

Mobile App, and we make no warranty, express, implied or otherwise, that we will prevent such access. We

may adopt what we believe is appropriate data collection, storage and processing practices and security

measures to protect against unauthorized access to such data.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to

abuse our Mobile App or acted in an inappropriate manner, please contact our Data Protection Officer

directly at dpo@flavrtech.co.

revised privacy policy constitutes your acknowledgement of such amendments to the Privacy Policy and,

where the processing of personal data is based on consent, your agreement to be bound by the terms

therein. In the event of a material change that will substantially affect your use of the Mobile App or service

or the data collection by us, we will endeavor to provide you with notifications through the Mobile App or

by email.

If you have any general questions about the Mobile App or the information that we collect about you and

how we use it, please contact us at: dpo@flavrtech.co.