Phictly Privacy Policy

Privacy Policy

Effective Date: 01/01/2025

1. Introduction
At Phictly, we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and disclose information about you. It applies to our website phictly.com and our mobile application.
2. Information We Collect
2.1 Personal Information
We may collect personal information from you directly, such as your name, email address, phone number, and billing information, when you:
– Register for an account
– Purchase our products or services
– Subscribe to our newsletter
– Contact customer support
2.2 Usage Data
We may automatically collect information about your usage of our website, including:
– IP address
– Browser type
– Device information
– Pages visited
– Time and date of each visit
3. How We Use Your Information
We use the information we collect for the following purposes:
– To provide and maintain our services
– To manage your account
– To improve our website and services
– To send you promotional communications that you have subscribed to
– To comply with legal obligations and protect against fraud
4. Legal Basis for Processing
Under the GDPR, we process your personal information based on:
– Your consent
– The necessity of fulfilling a contract with you
– Compliance with a legal obligation
– Our legitimate interests, such as improving our services and products

5. Data Sharing and Disclosure
We do not sell your personal information. We may share your information with:
– Third-party service providers who assist in our operations
– Legal authorities, if required by law
– Affiliates and partners with your consent
6. International Data Transfers
Your personal data may be transferred to, stored, and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place to protect your data under GDPR.
7. Data Retention
We retain your personal information only as long as necessary for the purposes outlined in this policy or as required by law.
8. Your Rights
You have the following rights under the GDPR:
– The right to access your data
– The right to rectify inaccurate data
– The right to erase your data (‘right to be forgotten’)
– The right to restrict processing
– The right to data portability
– The right to object to processing
– The right to withdraw consent
9. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to improve user experience and analyze website traffic. You can manage your cookie preferences through your browser settings.
10. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the effective date.
11. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
info@phictly.com

Privacy Notice (GDPR/UK GDPR)

Effective: 09/06/2025

Controller: Phictly Inc., 5000 Thayer Center STE C, Oakland, MD 21550, info@phictly.com. EU/UK Rep Nyla Roberts.

Personal Data We Process

Account/profile details; content you post and related metadata; device/usage/diagnostics; cookies/SDKs; communications and reports/flags; settings; transactions (if any). Aggregated/de‑identified data is not personal data.

Sources

From you, your devices, and third parties you connect (e.g., sign‑in providers).

How We Use AI (and don’t)

Use: automation (e.g., recommendations/notifications), analytics on aggregated/de‑identified metrics, and optional discussion prompts.
Don’t: train AI on copyrighted books or your club/DM conversations; no AI monitoring of conversations.
Providers act as processors under contract; they may not use our data to train their foundation models.

Purposes & Legal Bases

Provide, maintain, and secure the service (contract; legitimate interests for safety/fraud prevention).
Optional AI prompts: EEA/UK—consent (withdraw anytime). Outside EEA/UK—legitimate interests with easy opt‑out.
Marketing: EEA/UK—opt‑in consent; outside EEA/UK—sign‑up consent with opt‑out.
Legal compliance (legal obligation).
Analytics on aggregated/de‑identified data (not personal data).

Sharing

With processors (hosting, email, analytics, AI infrastructure, etc.), for legal/safety reasons, or in corporate transactions. We do not sell personal data.

Automated Decision‑Making

We do not make decisions with legal or similarly significant effects solely by automated means.

International Transfers

Where required, protected by appropriate safeguards (e.g., EU SCCs/UK IDTA and supplementary measures).

Cookies & Similar Technologies

Necessary cookies/SDKs to run the service.
EEA/UK: analytics/marketing/personalization (AI prompts) only with consent via a CMP; manage preferences anytime in settings/CMP.

Retention

Kept only as long as needed for the purposes above or as required by law; then deleted or irreversibly anonymized. Backups delete on a rolling schedule.

Security

Appropriate technical and organizational measures (e.g., encryption in transit/at rest where applicable, access controls, least privilege, incident response). No method is 100% secure.

Your Rights (GDPR/UK GDPR)

Access, rectification, erasure, restriction, portability, and objection (including to processing based on legitimate interests and to direct marketing).
Withdraw consent at any time without affecting prior processing.
Contact: info@phictly.com. We may verify your identity and will respond within one month (extendable for complexity).
You can lodge a complaint with your Supervisory Authority (e.g., your local DPA; UK ICO).

Children

Not for users under 16 in the EEA/UK (or local digital‑consent age where permitted). We don’t knowingly collect data from children; if we learn we have, we’ll delete it.

Updates

We’ll post changes here and update the Effective date. Material changes will be notified by email or in‑app.

Contact

Controller: Phictly Inc., 5000 Thayer Center STE C, Oakland, MD 21550 info@phictly.com. EU/UK Rep Nyla Roberts.