Privacy Policy

PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE APPLICATIONS, THE WEBSITE, AND/OR SERVICES. BY USING THE APPLICATIONS, THE WEBSITE, OR SERVICES, YOU WILL BE DEEMED TO HAVE ACCEPTED THIS VITO TECHNOLOGY, INC. PRIVACY POLICY.

Last Updated July 18 , 2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY. It contains important information about how Vito Technology, Inc. (“Vito Technology” or “we”) collects, uses, and shares personal information when you use Vito Technology mobile applications (“Apps”), websites (“Websites”), products, and related services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read and understand this Privacy Policy (“Privacy Policy”) and the Vito Technology Terms of Use (“Terms of Use”). Residents of certain U.S. states may have additional privacy rights under applicable state laws, including the right to access, delete, or opt out of certain data practices. Vito Technology will comply with such rights, if and as applicable. By using the Apps, Websites and/or Services, you acknowledge that you have read and understand this Privacy Policy and the Terms of Use. Your continued use of the Services constitutes your acceptance of this Privacy Policy. Vito Technology reserves the right to modify this Privacy Policy at any time by posting such changes on this page, with an updated “Last Updated” date. Please check back regularly to review any changes. If we make material changes, we will notify you (e.g. via an in-app notice or our website). Your continued use of the Services after such changes indicates your consent to the updated Privacy Policy.

If you have any questions, concerns, or believe Vito Technology is not adhering to this Privacy Policy, please contact our Data Protection Officer (“DPO”) at privacy@vitotechnology.com. You may also contact us by mail at: Vito Technology, Inc., Attn: Data Protection Officer, 700 N Fairfax St, Suite 614, Alexandria, VA 22314, USA. We will address your inquiry promptly.

European Users

Vito Technology complies with the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council “On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC” (General Data Protection Regulation) (“GDPR”). If you are a natural person of the European Union within the meaning of the GDPR, you are afforded certain additional rights by the GDPR as further described at https://vitotechnology.com/general-data-protection-regulation.

Vito Technology complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Vito Technology has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Vito Technology has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the applicable Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

TABLE OF CONTENTS

A. CHANGES IN PRIVACY POLICY

We want you to always be aware of what personal and other data we collect, how we use that data, and under what circumstances we may disclose it. All personal data that we collect will be handled according to the Privacy Policy in effect at the time the data is collected. If the Privacy Policy changes in any significant respect in the meantime, we will not (without your permission) use your personal data in a manner that is inconsistent with the Privacy Policy in effect at the time your information was collected.

From time to time, we may find the need to make changes to this Privacy Policy. This Privacy Policy may be amended by Vito Technology upon notice given through the Apps, Websites, or via e-mail. Please check the Privacy Policy published on the Apps and/or Websites regularly to ensure that you are aware of all terms governing your use of our Services.

B. PERSONAL DATA YOU DISCLOSE TO VITO TECHNOLOGY

You never have to provide personally identifiable information to Vito Technology. Vito Technology does not sell or share personal information as those terms are defined under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). However, should you choose to withhold certain required data, Vito Technology may not be able to provide you with some or all of the Services. Some of the data we ask you to provide may be identified as mandatory or optional. If you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity or make such a purchase. Vito Technology will inform you of the mandatory or optional nature of the requested or required data.

Vito Technology may collect personal data that you voluntarily provide to it when registering on the Apps and/or the Websites to receive information about Vito Technology Services, when participating in other activities on the Apps, the Websites, or otherwise contacting Vito Technology. The personal data that Vito Technology may collect depends on the context of your interactions with the Apps, the Websites, and Services. Such data may include: geo-location (with explicit consent), first and last name, e-mail address, and any other information you voluntarily provide through our services.

Furthermore, Vito Technology may collect your personal data when you contact Vito Technology’s customer support team via email or another communication tool. The purpose of collecting such data is to help you solve any issue you have with Vito Technology Services. The legal basis of collecting this data is Vito Technology’s fulfillment of contractual or pre-contractual obligations to you or your consent thereto.

C. INFORMATION AUTOMATICALLY COLLECTED

Vito Technology only collects precise location data (e.g., GPS) with the user’s explicit consent, which can be withdrawn at any time, and solely to provide core app functions such as rendering a star map or fetching localized weather. This data is used in real-time, is not stored after use, is not combined with identifiers, and is not shared or sold to any third party. Users can disable location services at any time through their device settings without losing access to other app features.

Vito Technology automatically collects certain data to facilitate the end users’ requested service. This includes technical information such as the end users’ Internet Protocol (IP) address, device information, operating system and browser information (where applicable), time zone setting, and information about end users’ interaction with our Apps and/or Websites. For Websites, this may include full Uniform Resource Locators (URLs), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. For Apps, this may include information about features used, screens viewed, in-app events, session length, and interactions with in-app elements. We also collect device identification information (e.g., unique device ID, advertising ID). We collect this data in order to make our Apps and Websites function correctly and provide you the functionality that you see on the Apps and/or the Websites, as our servers use this data to deliver the pages to you through the Apps and/or the Websites. We also use this data to better understand how visitors use our Apps and/or Websites and how we can better tune our Services , their contents, and functionality to meet your needs. However, this data is not associated with any personally identifiable information of persons browsing the Apps and/or Websites.

When you use the Apps and/or Websites, Vito Technology or trusted third parties authorized by Vito Technology may also collect certain technical and routing information about your computer (also known as environmental variables) to facilitate your use of the Apps, Websites, and the Services enabled thereby. When you browse the Internet, your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Edge) automatically transmits some data to Vito Technology every time you access content on one of our internet domains. Examples of such data include the URL of the particular webpage you visited, the IP (Internet Protocol) address of the computer you are using, or the browser version that you are using to access the Website. All of this data may be collected by Vito Technology and used to help improve our offerings to you.

We may collect, use, and share aggregated data (statistical or demographic data) for any purpose. Although this data is derived from end-users’ personal data, it cannot directly or indirectly lead to an end-user’s identity in aggregated form, and is therefore not “personal data” for purposes of this Privacy Policy. If the aggregated data is connected to end-users’ personal data such that end-users can be identified, we will treat that data as personal data for purposes of this Privacy Policy.

If data collection is required by law or under the terms of a contract with end-users, and end-users fail to provide that data when requested, we may not be able to perform the contract. This may require cancellation of a product or service with the end-user. We will notify end-users in this is the case at the appropriate time.

Vito Technology does not collect special categories of personal data including end-users’ race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about end-users’ health, genetic and biometric data, and criminal convictions and offences.

D. DATA COLLECTED FROM OTHER SOURCES; THIRD-PARTY PAYMENT PROCESSORS

Vito Technology may collect personal data from third-party sources in certain circumstances. This may include data obtained from public databases, social media platforms, marketing partners, and other third parties we work with. The types of personal data collected from these sources may include contact information, professional details, and user preferences. We ensure that any third-party data collection complies with applicable data protection laws and this Privacy Policy.

Vito Technology may receive information from third-parties including business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, and search information providers.

Vito Technology permits trusted partners to place advertisements within the Apps and/or the Websites and to conduct related analytics using their own technologies and systems. The following is a non-exhaustive list of Vito Technology’s current trusted partners:

  • Firebase - Analytics, Push Notifications, Dynamic Links, Crashlytics
  • Google AdMob – Ads
  • Facebook – Analytics
  • Meta Audience Network – Ads
  • OneSignal - Push Notifications
  • AppLovin – Ads
  • Unity Analytics - Analytics, Crashlytics
  • Unity Ads - Ads

Each of their privacy and cookie policies can be found on their respective websites.

Vito Technology integrates third-party SDKs (e.g., Google AdMob, Unity Ads, AppLovin, Firebase Analytics) that may collect device-level information (e.g., Advertising ID, IP address) to deliver ads or perform analytics. Vito Technology does not link device identifiers (including but not limited to IDFA/GAID) to a user’s name, email, or any other personal identifiers that could directly identify an individual. These identifiers are randomly generated by operating systems and do not, in Vito Technology’s systems, identify any particular person. Any approximate location data inferred by these SDKs (e.g., from IP address) is done independently and is not directed by or accessible to Vito Technology.

We use third-party payment processors for all payments. When you pay for your purchase, you provide your personal information needed to perform the transaction directly to the third-party payment processor. In such cases, its privacy policy and security practices will apply to your personal information. We strongly encourage you to review that privacy policy before providing your personal information.

E. HOW VITO TECHNOLOGY USES YOUR INFORMATION

We may disclose your personally identifiable information without your permission only in limited circumstances as required or permitted by law. We will only do so if we have a good-faith belief that disclosure is reasonably necessary to (1) comply with laws, regulations, or government requests, or (2) to investigate or protect against harmful activities to our users, visitors, or property (including the Apps, Websites, or Services), or to others. Such disclosures do not constitute a sale or sharing of personal information as defined under the California Consumer Privacy Act (CCPA) or California Privacy Rights Act (CPRA). If we are required by law enforcement or judicial authorities to provide your personally identifiable information, we will only do so upon receipt of appropriate documentation. We may also disclose your information to investigate violation of and enforce our Terms of Use. Please know that we do not take this responsibility lightly. Your privacy is of paramount importance to us.

We will obtain end-users’ express opt-in consent before collecting and using their personal data. This consent will be obtained through a clear affirmative action, such as ticking a box or clicking a button, after being presented with clear and comprehensive information about how their data will be used. We will get end-users’ express opt-in consent before sharing end-users’ personal data with any company outside Vito Technology for marketing purposes.

We will only use your personal data for the purpose for which we collected it. We may use your personal data for a different purpose only if we reasonably believe that it is necessary for that purpose and that purpose is compatible with the original purpose. End-users may request an explanation for the compatibility between an original and new purpose by contacting us.

If we need to use end-users’ personal data for a purpose unrelated to the purpose for which it was collected, we will notify end-users and provide an explanation of the legal basis which allows us to do this.

Vito Technology may also use your personal data for a variety of business purposes, as described in detail below. Vito Technology may process your personal data for such purposes in reliance on its legitimate business interests in order to enter into or perform a contract with your consent. The following indicates the specific processing grounds on which Vito Technology relies, if and when it processes any personal data.

As a non-exclusive list of examples, Vito Technology may use your personal data:

  • to authenticate end-users in Vito Technology products and enable the sending of alerts, scrolling tickers, surveys, and other content;
  • to carry out our obligations arising from any contracts entered into between end-users and us or to take steps at end-users’ request before entering into any contracts, including the registration of new customers and notifying end-users of changes to this Privacy Policy or Terms of Use;
  • to comply with any legal obligations to which we are subject;
  • where it is necessary to carry out our or a third party’s legitimate interests except where end-users’ interests or fundamental rights and freedoms override these interests;
  • to send marketing communications to end-users regarding requested information, purchased services, and promotions in which the end-user has participated, unless they have opted out of receiving such communications. While end-users may opt out of marketing messages, they will continue to receive necessary service-related communications regarding their purchases, product experiences, or other transactions;
  • to deliver relevant App and/or Website content and advertisements to end-users and measure or understand the effectiveness of this advertising;
  • to respond to legal requests and prevent harm. For example, if Vito Technology receives a subpoena or other legal request, Vito Technology may need to inspect the personal data it holds in order to determine if and how to respond; and
  • to administer, protect, and improve the Apps and Websites through data analysis, testing, system maintenance, troubleshooting, reporting and hosting.

F. HOW VITO TECHNOLOGY SHARES YOUR DATA

We only share personal data with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. As a non-exclusive list of examples, Vito Technology only shares and discloses your personal data in the following situations:

  • Compliance with Laws. Vito Technology may disclose your personal data where it is legally required to do so in order to comply with applicable law, governmental requests, or a judicial proceeding, court order, or legal process such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements);

  • Vital Interests and Legal Rights. Vito Technology may disclose your personal data where it believes it is necessary to investigate, prevent, or take action regarding potential violations of Vito Technology policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or in the event of litigation;

  • Vendors, Consultants and Other Third-Party Service Providers. Vito Technology may share your personal data with third party vendors, service providers, contractors or agents (“Third-Party Processors”) who perform services on its behalf and require access to such information. For example, Vito Technology may use third parties for technical and customer support, payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. These Third-Party Processors may be located within the U.S., EU, or another country. For transfers of personal data received pursuant to the EU-U.S. DPF, Vito Technology remains liable under the DPF Principles if its Third-Party Processors processes personal data in a manner inconsistent with the DPF Principles, unless Vito Technology proves that it is not responsible for the event giving rise to the damage. Vito Technology requires all Third-Party Processors to provide at least the same level of privacy protection as required by the DPF Principles through written contracts that include specific safeguards and ongoing oversight;

  • Tracking Technology. Vito Technology also may allow select third parties to use tracking technology on the Apps and/or the Websites, which will enable the collection of data about how you interact with the Apps and/or the Websites over time. This data may be used to, among other things, analyze and track data, determine the popularity of certain content or pages, and better understand user activity in order for Vito Technology to improve its Services. Vito Technology does not share, sell, rent or trade your Personal data with third parties for their independent promotional purposes, except as explicitly described in this Privacy Policy;

  • Business Transfers. Vito Technology may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of its business to another company;

  • Business Partners. Vito Technology may share your personal data with its business partners to offer you certain products, Services or promotions, and/or to facilitate provision of Vito Technology products and Services to you, as well as with other Vito Technology entities; and

  • With your Consent. Vito Technology may disclose your personal data for any other purpose in accordance with your consent.

Do Not Sell My Personal Information

Residents of certain states, including California, have the right under their respective state laws (e.g., the California Consumer Privacy Act (CCPA)), to opt out of the sale of their personal data. While Vito Technology does not sell or share personal information as those terms are defined under the CCPA and CPRA (see below), we provide a “Do Not Sell My Personal Information” page at https://vitotechnology.com/data-subject-request in the interest of transparency and to honor global privacy control signals, where applicable.

If you are located outside one of such applicable states or are using a VPN that makes it appear you are accessing our site from one of the applicable states, you are also welcome to submit a request through the same page. We will review and process your request based on the information provided and applicable legal requirements.

Vito Technology does not sell or share personal information, including geolocation data, as those terms are defined under the CCPA and California Privacy Rights Act (CPRA). This means we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your personal information to a third party for monetary or other valuable consideration, or for cross-context behavioral advertising purposes. Vito does not provide any personal information to third parties for cross-context behavioral advertising or data brokerage purposes. Any sharing of personal information with service providers is strictly limited to business purposes as permitted under applicable law and subject to written contracts that prohibit the service provider from selling or sharing the personal information.

For more information about your rights under applicable data privacy laws, please review the relevant sections of this Privacy Policy or contact us at privacy@vitotechnology.com.

G. COOKIES

Vito Technology may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Cookies and similar tracking technologies are short pieces of data or code generated by a web server or mobile application that a service stores on a user’s device to collect and track information. The Apps and the Websites may require the use of a cookie and similar tracking technologies for purposes of keeping information you enter on multiple pages together. Cookies and similar tracking technologies also enable Vito Technology to customize the Apps, the Websites, and offerings to your needs and provide you with a better online experience. Beacons are used in combination with cookies to help the website and mobile application operators understand how visitors interact with their online services.

Cookies and similar technologies. Most web browsers and mobile devices allow you to manage cookies and similar tracking technologies by default. If you prefer, you can usually choose to adjust these settings to remove or reject such technologies. If you choose to remove or reject these technologies, this could affect certain features or services of our Apps and Websites.

Vito Technology is committed to complying with all applicable data protection laws and regulations regarding cookie usage, including GDPR, CCPA and local data protection regulations. We ensure transparent cookie practices, obtain necessary consents, and provide clear information about our cookie usage in alignment with these legal requirements.

H. TRANSFER OF INFORMATION

Vito Technology primarily stores and processes your personal data on servers located in the United States, though we may also transfer, store, and process your data in other countries, subject to appropriate safeguards and data transfer mechanisms as required by applicable data protection laws.

Please be aware that your personal data may be transferred to, stored, or processed by Vito Technology in its facilities, with Vito Technology entities, or by those third parties with whom Vito Technology has formed trusted contracts within the U.S. or other countries, as the case may be, for business operations (e.g., marketing, analytics, payment processing). A list of representative affiliates is available upon request.

If you are a resident in the EU, please note that the United States may not have data protection laws as comprehensive as those in your country. For transfers of personal data to the United States, Vito Technology complies with the EU-U.S. Data Privacy Framework (DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States. Vito Technology has certified to the Department of Commerce that it adheres to the DPF Principles. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/. If a transfer to a non-DPF country is necessary, Vito Technology will conduct a thorough data transfer assessment and implement safeguards, such as signing a Data Processing Agreement (DPA), as required. Vito Technology remains committed to taking all necessary measures to protect your personal data in accordance with this Privacy Policy and applicable laws.

International transfers

If end-users are located in the EU, the UK (and Gibraltar), or Switzerland, some of our external third parties may be based outside the EU, the UK (and Gibraltar), and Switzerland, so their processing of end-users’ personal data will involve a transfer of data outside the EU, the UK (and Gibraltar), and Switzerland.

Whenever we transfer end-users’ personal data out of the EU, the UK (and Gibraltar), or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We may transfer end-users’ personal data to a country where it has been deemed to provide an adequate level of protection for personal data by the European Commission; or

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU, the UK, and Switzerland; or

Where we use providers based in the US, we may transfer data to them if they are part of the Data Privacy Framework which requires them to provide similar protection to personal data shared between the EU, the UK, Switzerland and the US.

Vito Technology hosts its cloud instances on the AWS cloud. Security and compliance are shared responsibilities between AWS and Vito Technology regarding AWS cloud instances. Please visit the AWS Shared Responsibility Model website (https://aws.amazon.com/compliance/shared-responsibility-model/) to learn more.

If, in the future, Vito Technology does transfer personal data to a third party acting as an agent on its behalf, Vito Technology remains liable under the DPF Principles if its agent processes such personal data in a manner inconsistent with the DPF Principles, unless Vito Technology proves that it is not responsible for the event giving rise to the damage.

Please contact us if end-users want further information on the specific mechanism used by us when transferring end-users’ personal data out of the EU, UK and/or Switzerland at privacy@vitotechnology.com.

I. HOW LONG VITO TECHNOLOGY STORES YOUR DATA

Vito Technology keeps your personal data for as long as necessary to fulfill the purposes outlined in the Privacy Policy, unless otherwise required by law. Vito Technology undertakes not to store your information for longer than is required, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When Vito Technology no longer has a legitimate business need to process your personal data, it will either delete or anonymize such information. However, if this is not possible (for example, because your personal data has been stored in backup archives), then Vito Technology will securely store your personal data and isolate it from any further processing until deletion is possible.

We determine the appropriate retention period for personal data based on the amount, nature, and sensitivity of the personal data, potential risk of harm from unauthorized disclosure or use, the purpose for which we processed the data, whether we can achieve that purpose through other means, and any applicable legal requirements. Vito Technology regularly reviews these retention periods to ensure they remain appropriate and compliant with evolving data protection standards and regulations.

We may anonymize personal data for research or statistical purposes. In this case, we will use this data indefinitely without further notice to end-users.

J. HOW VITO TECHNOLOGY PROTECTS YOUR INFORMATION

Vito Technology implements and maintains appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to, encryption, access controls, secure data storage, regular security assessments, and employee training on data protection.

Vito Technology has implemented appropriate technical and organizational security measures designed to protect the security of any personal data it processes. However, please also remember that Vito Technology cannot guarantee that the internet itself is 100% secure. Although Vito Technology will do its best to protect your personal data, transmission of personal data to and from the Apps and/or the Websites is at your own risk. You should only access the Apps, the Websites, and Services within a secure environment. We have implemented procedures to deal with any suspected personal data breach and will notify end-users and any applicable regulator of a breach where we are legally required to do so.

K. MINORS

Vito Technology strictly prohibits and does not knowingly collect personal data from or market to children under 18 years of age (or the applicable age of digital consent in your jurisdiction, if different, e.g., 16 years of age under the GDPR in the European Union). By using the Apps and/or the Websites, you represent that you are at least 18 or that you are the parent or legal guardian of such a minor and consent to such minor dependent’s use of the Apps and the Websites. If Vito Technology learns that personal data from users less than 18 years of age has been collected, it will deactivate the account and take reasonable measures to promptly delete such data from Vito Technology’s records. If you become aware of any data Vito Technology may have collected from children under age 18, please contact privacy@vitotechnology.com, or as outlined in Section L below.

The Children’s Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children’s privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission (FTC) Website. The Apps, the Websites, and Services are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, we recognize that children under the age of 13 may potentially access the Apps, the Websites, and Services. The collection of information is covered above. Parents and Legal Guardians may request from us to review, delete or stop the collection of the personally identifiable information of their child. You may do so by contacting us by email at privacy@vitotechnology.com.

L. EMAIL AND CONTACT BY VITO TECHNOLOGY

You can unsubscribe from Vito Technology’s marketing email list at any time by clicking on the unsubscribe link in the emails received, adjusting your preferences in our Apps’ settings, or by contacting Vito Technology by e-mail at privacy@vitotechnology.com. Upon notifying Vito Technology, you will then be removed from the marketing email list; however, Vito Technology will still need to send you service-related emails that are necessary for the administration and use of your account.

We reserve the right to send a one-time registration confirmation email, and infrequent service alert messages to users to inform you of specific changes that may impact your ability to use a service that you have previously signed up for, regardless of email contact opt-in status. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty, or purchase agreements.

Vito Technology is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing Service if you have asked us not to do so, and issuance of these types of communications is rare.

M. CHANGE OF CONTROL

In the event that all or substantially all of Vito Technology’s stock and/or all or substantially all assets are transferred or sold to another entity, Vito Technology may transfer personally identifiable data to the acquiring entity, provided such transfer complies with all applicable data protection laws and the acquiring entity maintains at least the same level of data protection standards, subject to applicable data protection laws and regulations. If, as a result of such a business transition, your personally identifiable data will be used in a materially different manner, you will be given notice and the opportunity to give consent pursuant to our policy regarding notification of changes.

European Union (EU) residents may withdraw their consent for the processing of personal data at any time. Similarly, residents of certain states, including California, have the right to opt-out of data sales under their state’s privacy laws. To exercise these rights, you may:

In accordance with Article 77 of the GDPR, if you are a resident of the European Union and believe that the processing of your personal data infringes applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement. A list of EU supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

UK and Swiss Resident Rights

If you are a resident of the United Kingdom or Switzerland, you have the right to:

  • Access, correct, or delete your personal data.
  • Object to the processing of your data.
  • Withdraw consent for data collection and processing at any time.
  • Lodge a complaint with the UK Information Commissioner’s Office (ICO) or the Swiss Federal Data Protection and Information Commissioner (FDPIC).

To exercise these rights, please contact us at privacy@vitotechnology.com or submit a request through our Data Subject Request at https://vitotechnology.com/data-subject-request.

O. DISPUTE RESOLUTION

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Vito Technology commits to resolve DPF Principles-related complaints about our collection and use of your personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Vito Technology at privacy@vitotechnology.com.

Vito Technology will respond without undue delay and at the latest within one month (30 calendar days) of receipt of the request. This period may be extended by two further months where necessary, taking into account the complexity and number of requests, in accordance with applicable law.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Vito Technology commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR-AAA), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction within the 30-day period, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of the ICDR-AAA DPF IRM are provided at no cost to you.

Please note, an individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. Please, refer to Annex I of the DPF for additional information: ANNEX-I-introduction.

The Federal Trade Commission has jurisdiction over Vito Technology’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

P. END-USERS RIGHTS

U.S. residents of certain states may be entitled to rights under state privacy laws. Vito Technology will comply with such rights, if and as applicable. If end-users are an EEA citizen and/or located in the EU, the UK (and Gibraltar), or Switzerland, then under the Data Protection Legislation and the DPF Principles end-users may be entitled to the following rights:

  • Where end-users have provided their consent to the processing of end-users’ personal data for any purpose, including geolocation data which is solely associated with the device identifier and not linked to any personally identifiable information (such as name, email, or other personal data), end-users have the right to withdraw such consent at any time by contacting us at Vito Technology (address by email to privacy@vitotechnology.com). Please note that withdrawing consent may result in the loss of access to certain services or features that require the processing of your personal data, but will not affect the lawfulness of processing based on consent before its withdrawal. However, we will inform you of any such consequences before you withdraw your consent. Vito Technology keeps records of all user consents, including the time and date when consent was given, to ensure transparency and compliance with data protection regulations. As noted above, any geolocation data collected upon consent is solely associated with the device identifier and not linked to personally identifiable information such as name or email address.
  • End-users can ask us to rectify any inaccuracies in the personal data that we hold about end-users.
  • To request the erasure of personal data that we hold about end-users where there is no legitimate business purpose for us to continue processing it, where end-users have successfully exercised their right to object to processing, where we may have processed end-users’ data unlawfully or where we are required to erase end-users’ personal data to comply with local law.
  • To object to our processing of end-users’ personal data where we are relying on a legitimate interest (or that of a third party) and there is something about end-users’ particular situation which makes end-users want to object to processing on this ground as end-users feel it impacts on end-users’ fundamental rights and freedoms. End-users also have the right to object where we are processing end-users’ personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process end-users’ data which override end-users rights and freedoms.
  • To restrict our processing of end-users’ personal data (a) if end-users want us to establish the data's accuracy; (b) where our use of the data is unlawful but end-users do not want us to erase it; (c) where end-users need us to hold the data even if we no longer require it as end-users need it to establish, exercise or defend legal claims; or (d) end-users have objected to our use of end-users data but we need to verify whether we have overriding legitimate grounds to use it.
  • To request a copy of end-users’ personal data from us in a commonly used and machine-readable format or that we transmit end-users’ personal data to another data controller.
  • Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on end-users.
  • To access information held about end-users. End-users will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if the request is manifestly unfounded, excessive, or repetitive, or we may refuse to act on the request, in accordance with applicable data protection laws.

End-users will receive a notification of our decision within 30 calendar days of their request, with a possible extension of two months where necessary, taking into account the complexity and number of requests. We may refuse to comply with end-users’ requests where permitted by applicable law. If you are unsatisfied with Vito Technology’s decision regarding your request, you may appeal the decision within 30 calendar days of the decision by sending an email to privacy@vitotechnology.com with the request number and “Notice of Appeal” in the subject line.

Any data subject, regardless of location (including those located outside of the EEA) may exercise any of the above rights at any time by contacting our Data Protection Officer at Vito Technology via email at privacy@vitotechnology.com. We will process such requests in accordance with applicable local laws and our internal policies.

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