Privacy Policy

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include:

• Names (business owner, consumer, referral participant names)
• Phone numbers
• Email addresses
• Dates of birth
• ZIP codes
• Business names and addresses
• Referral activity and rewards history (referral links shared, rewards earned, points balances)
• Consumer preferences and interests
• Usernames and passwords
• Contact preferences
• Billing addresses and subscription plan information

Sensitive Information. We do not process sensitive information.

Information automatically collected

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting.

• Log and Usage Data. Service-related diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. Information about your device's location, which can be either precise or imprecise depending on your device settings. We may use this data to show you nearby participating businesses.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

• To facilitate account creation and authentication so you can create and log in to your Dealsby Referrals account as a consumer or business owner.
• To deliver and facilitate delivery of services, including referral campaign management, rewards tracking, points programs, leaderboards, and customer engagement features.
• To send transactional communications such as referral notifications, reward confirmations, and promotional alerts via SMS (Twilio) and email (SendGrid) on behalf of our business subscribers.
• To respond to user inquiries and offer support to resolve any potential issues with the requested service.
• To send administrative information about our products and services, changes to our terms and policies.
• To fulfill and manage your orders, including subscription payments, plan upgrades, and SMS/email credit pack purchases.
• To personalize your experience by showing you nearby participating businesses, relevant deals, and tailored recommendations based on your location and preferences.
• To request feedback and to contact you about your use of our Services.
• To protect our Services including fraud monitoring and prevention.
• To identify usage trends so we can improve how our Services work.
• To save or protect an individual's vital interest, such as to prevent harm.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, we may rely on the following legal bases:

• Consent. You may withdraw your consent at any time.
• Performance of a Contract. To fulfill our contractual obligations to you, including providing our Services.
• Legitimate Interests. To achieve our legitimate business interests where they do not outweigh your rights and freedoms.
• Legal Obligations. For compliance with our legal obligations.
• Vital Interests. To protect your vital interests or the vital interests of a third party.

If you are located in Canada, we may process your information with your express consent, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In Short: We may share information with specific third-party service providers who perform services on our behalf.

We have contracts in place with our third parties designed to help safeguard your personal information. The categories of third parties we may share personal information with include:

• Cloud Computing Services (Google Firebase / Google Cloud Platform)
• Payment Processors (Stripe)
• Communication Services — SMS (Twilio)
• Communication Services — Email (SendGrid / Twilio)
• Data Storage Service Providers (Google Firestore)
• Performance Monitoring Tools
• Website Hosting Service Providers

We also may need to share your personal information in these situations:

• Business Transfers. In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• Affiliates. We will require affiliates to honor this privacy notice.
• Referral Program Participants. When you participate in a referral program, the referring business may receive limited information about referral activity (e.g., whether a referral was completed) to facilitate the rewards program. Businesses do not receive your full personal information without your consent.

In Short: We are not responsible for the safety of any information that you share with unaffiliated third parties.

The Services may link to third-party websites, online services, or mobile applications that are not affiliated with us, including participating business websites. We do not make any guarantee regarding any such third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices of any third parties. You should review the policies of such third parties and contact them directly.

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies to access or store information. The Dealsby Referrals application uses browser localStorage to persist your application state, session data, and preferences locally on your device. This data remains on your device and is not transmitted to external servers except as required to operate the Services (e.g., syncing with Firebase for data persistence).

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, your information may be transferred to, stored, and processed by us in the United States. If you are a resident in the EEA or UK, these countries may not have data protection laws as comprehensive as those in your country. We will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or securely store it and isolate it from further processing until deletion is possible.

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable security measures, including:

• Firebase Authentication with secure session management
• Role-based access control with granular permissions
• Stripe PCI-compliant payment processing — we never store card numbers directly
• HTTPS encryption for all data in transit
• Firestore security rules restricting data access to authorized users
• Unique referral link generation with fraud detection safeguards

However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk.You should only access the Services within a secure environment.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to the minor's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under age 18, please contact us at support@dealsby.io.

In Short: In some regions you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws, including the right to request access, rectification or erasure, to restrict processing, and to data portability.

Withdrawing your consent: You can withdraw your consent at any time by contacting us at support@dealsby.io.

Account Information

If you would like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account
• Contact us at support@dealsby.io

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information in our files to prevent fraud, troubleshoot problems, enforce our legal terms and/or comply with applicable legal requirements. Points balances and referral history will be forfeited upon account termination.

Opting out of marketing communications: Unsubscribe via the link in our emails, reply "STOP" or "UNSUBSCRIBE" to our SMS messages, or contact us at support@dealsby.io. We may still send you service-related messages necessary for the administration of your account.

Most web browsers include a Do-Not-Track ("DNT") feature or setting. No uniform technology standard for DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. If a standard for online tracking is adopted that we must follow in the future, we will inform you in a revised version of this privacy notice.

In Short: If you are a California resident, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83 ("Shine The Light") permits California residents to request information about personal information disclosed to third parties for direct marketing purposes once per year, free of charge.

CCPA Privacy Notice

We have collected the following categories of personal information in the past twelve (12) months:

Your rights as a California resident

• Right to request deletion of your personal information
• Right to be informed about whether we collect and use your personal information
• Right to non-discrimination for exercising your privacy rights
• Right to limit use and disclosure of sensitive personal information

Contact us by email at support@dealsby.io, by phone at (888) 487-1873, or by post at the address below.

In Short: Virginia residents may be granted specific rights regarding access to and use of their personal information.

Under the Virginia Consumer Data Protection Act (CDPA), you have the following rights:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of targeted advertising, sale of personal data, or profiling

Virely LLC has not sold any personal data to third parties for business or commercial purposes. Virely LLC will not sell personal data in the future belonging to website visitors, users, and other consumers.

If we decline to take action regarding your request, we will inform you of our decision and reasoning. If you wish to appeal, please email us at support@dealsby.io. Within sixty (60) days of receipt, we will inform you in writing of any action taken or not taken. If your appeal is denied, you may contact the Attorney General to submit a complaint.

In Short: We will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and will be effective as soon as it is accessible. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently.

If you have questions or comments about this notice, you may contact us:

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at support@dealsby.io.