This Privacy Policy (the "Policy") describes the practices of BookVitals App SRL and its affiliates, including BookVitals Inc., (hereinafter "BibleChat", "we" or "us") with respect to the Personal Information collected, stored, used, transferred, shared and otherwise processed from or of our users, visitors, business partners, and other persons ("you") in connection with the BibleChat mobile application, and the https://thebiblechat.com/ website, including all subdomains, products and services related to it (all collectively, the "App" or the "Services"). This Policy is part of our Terms and Conditions ("Terms")

"Personal Information" means, as applicable, information related to an identified or identifiable natural person as defined by Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018 ("UK Data Act"), the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), and other applicable privacy laws (the GDPR, the UK Data Act, the CCPA and any other applicable data protection laws, when and as applicable, being referred to as the "Law"), including also sensitive data, if the case ("Personal Information"). The applicable Privacy Policy provisions may vary based on your residency and will align with the applicable Law, as appropriate. For EU and UK residents, the controller is BookVitals App SRL a limited liability company incorporated under the laws of Romania, with its registered office at 22-26 Siriului Street, 3rd floor, Bucharest, District 1, Romania, identified with registration no. J2024012185403. Otherwise, the controller is BookVitals Inc., a Delaware corporation. This Policy sets forth your rights and remedies under the Law, so please read it carefully. For questions or requests regarding the Policy and the exercise of any of your rights hereunder or under the Law, please do not hesitate to contact us by e-mail at [email protected].

The Policy describes, among others:

• What Personal Information we collect from you
• The purposes for which we collect and use your Personal Information
• The grounds on which the processing is carried out
• How long we process and store Personal Information
• Your rights and how to exercise them
• To whom we may disclose your Personal Information
• The countries to which we may transfer your Personal Information

Personal Information we collect

The table below describes the Personal Information we collect:

Purpose and basis of processing

COLLECTING YOUR DATA

Where data is requested directly from you, BibleChat asks you to provide those categories of Personal Information that we require for the purposes mentioned above. If you provide BibleChat with the Personal Information of your users, employees, customers or other third parties, you undertake to inform and obtain their consent to the processing of their data in accordance with the Law before disclosing such data to BibleChat. By using the App, you warrant, represent and undertake that you have obtained the appropriate consent from each person whose data is uploaded to the App. BibleChat may obtain Personal Information from third party sources, including third-party tracking technologies.

SHARING PERSONAL INFORMATION

There are certain circumstances in which we may disclose, transfer or share your data with certain third parties with or without notifying you in advance, as you will see below:

DATA SECURITY

We have implemented at least reasonable and appropriate physical, technical and organizational measures to protect the data we collect and to prevent unauthorized access, disclosure and misuse of your Personal Information, such as encryption. Our Services may involve integrations with, or may direct you to, websites, apps, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not to BibleChat and you are subject to the third party’s privacy policy. If you access third-party services, such as social media sites or other sites linked through the Services (e.g., if you follow a link to our Instagram account), these third-party services will be able to collect Personal Information about you, including information about your activity on the Services. If we link a site or service via our Services, you should read their data usage policies or other documentation. Our linking to another site or service doesn't mean we endorse it or speak for that third party.

CHILDREN

To use our Services, you must be at least 18 years old. BibleChat may produce Output that is not appropriate for all audiences or all ages.

RETENTION PERIOD

We will store and process your Personal Information for the period of time necessary to achieve the purposes described in this Policy and in accordance with our legal and contractual obligations. For the use of the App, we store your data for the duration of such use and for up to 5 years after your termination of any use of the Services or deletion of your account (whichever occurs last), unless otherwise required by law or unless we have legitimate interests that allow us to do so for a longer term case in which data will be stored for this latter longer term. Thereafter, the data will be erased in accordance with our procedures, which may involve anonymization or destruction. If you ask us to, we will delete or anonymize your Personal Information so that it can no longer be identified, unless we are permitted or required by law to retain certain Personal Information, including in situations such as the following:

• If there is an unresolved issue related to your account, such as an outstanding claim or an unresolved complaint or dispute, we will retain the necessary Personal Information until the issue is resolved;
• Where we need to retain Personal Information for our legal, tax, audit and accounting obligations, we will retain the Personal Information required for the period required by applicable law;
• When necessary for our legitimate business interests, such as to prevent fraud or to maintain the security of our users; and/or
• To enforce our rights and those of third parties.

YOUR RIGHTS AS PER GDPR AND UK DATA ACT

You have a number of rights in relation to BibleChat, which you can exercise by sending an e-mail to [email protected].

Right to information. You have the right to know how we handle your Personal Information in an appropriate and transparent way and what rights you can exercise in this respect. In this Policy, we have explained in detail what Personal Information we collect from you and how we handle your Personal Information.

Right of access. You have the right to access your Personal Information we hold at any time. Please include your and account ID, name and e-mail address. In addition, we may ask you questions to verify your identity.

Right to rectification. You have the right to rectify the Personal Information we hold about you where it is incorrect or out of date and/or to complete such data where it is incomplete. You can do this yourself 24/7 in your App account. Please note that we cannot guarantee the factual accuracy of Outputs.

Right to withdraw. This right entitles you to object to further processing of your Personal Information under the conditions and within the limits provided by law. In particular, if you have given your consent to our use of your Personal Information, you have the right to withdraw this consent at any time.

Right to object to direct marketing. If Personal Information is processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your Personal Information for direct marketing purposes by clicking on the "Unsubscribe" box when you receive such an email. If you object to processing for direct marketing purposes, your Personal Information will no longer be processed for such purposes. However, these opt-outs do not apply to communications that relate to order fulfillment, agreements, support, warnings about the safety of our products, or other administrative and transactional notices, where the primary purpose of such communications is not promotional.

Right to data portability. You have the right to receive the Personal Information you have provided to us, in the context of the agreement you have entered into with us, to store this Personal Information in a database of your own or a third party. Please include your and account ID, name and e-mail address. In addition, we may ask you questions to verify your identity.

Right to restriction of processing. You have the right to obtain restriction of the processing of your Personal Information in certain cases (for example, where you contest the accuracy of your Personal Information, for a period of time, to allow us to verify the accuracy).

Right to have your account forgotten/deleted. In some cases, you have the right to be forgotten. In this case, we will assess whether we can delete your data or whether we need to retain certain data to comply with a legal obligation. You can ask us to delete (part of) your Personal Information.

Right to complain. If you disagree with the way we handle your Personal Information, you have the right to lodge a complaint. If you have a complaint, we would like to resolve it with you first. Please include your name, e-mail address and account ID when contacting us.

At the same time, you have the right to lodge a complaint directly to the National Supervisory Authority for Personal Information Processing (ANSPDP), with headquarters in Bulevardul Gheorghe Magheru nr. 28 - 30, sector 1, Bucharest (postal code: 010336; phone no: 0040 318.059.211).

Please note that under many countries' laws, you have the right to lodge a complaint with the supervisory authority in the place in which you live or work. A full list of EU supervisory authorities' contact details is available here. In the UK, you have the right to lodge a complaint with the UK Information Commissioner's Office.

You also have the right to lodge a complaint with the competent court of law against us if you believe that your rights under the GDPR have been violated as a result of our processing your Personal Information, as well as against a legally binding decision of the ANSPDP relating to you and your Personal Information.

There is usually no fee for exercising the above rights.

You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

YOUR RIGHTS UNDER US PRIVACY LAWS (INCLUDING CCPA AND VCDPA) FOR US RESIDENTS

You have certain rights in relation to BibleChat, which you can exercise by sending an e-mail to [email protected]. You can invoke the consumer rights authorized at any time by submitting a request to BibleChat specifying the consumer rights you are invoking.

Rights you have as a consumer:
• To confirm whether or not BibleChat is processing your Personal Information and to access such Personal Information
• To access your Personal Information
• To correct inaccuracies in your Personal Information
• To delete Personal Information provided by or obtained about yourself
• To obtain a copy of your Personal Information that the consumer previously provided to BibleChat
• To opt out (at [email protected]) of the processing of the Personal Information for purposes of:
    (i) sale
    (ii) targeted advertising,
    (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer
• To appeal a decision regarding a specific request

Some of these rights are further detailed below:

Request to opt out/Do Not Track
You have the right to opt out of sharing your personal information with our analytics and advertising partners and from selling your data.

Right to Limit the Use of Sensitive Personal Information
Under certain U.S state laws, you may have the right to limit the use or disclosure of your sensitive data to certain purposes such as to a) conduct internal research to improve, repair, or develop products, services, or technology, b) provide a product or service specifically requested by a consumer or the parent or guardian of a child, perform a contract to which the consumer is a party, or take steps at the request of the consumer prior to entering into a contract; c) maintain the security and integrity of our Services, systems, and data, prevent fraud or illegal activities, and protect individuals' physical safety, and d) any other purposes allowed by future regulations under applicable U.S. state data privacy laws.

Right to complain
BibleChat shall respond to you without undue delay, but in all cases within 45 days of receipt of the request. The response period may be extended once by 45 additional days when reasonably necessary, considering the complexity and number of the consumer's requests, but we shall inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

If BibleChat declines to take action regarding your request, we shall inform the consumer without undue delay, but in all cases and at the latest within 45 days of receipt of the request, of the justification for declining to take action and also BibleChat shall provide instructions for how to appeal the declined decision.

In the unlikely case of having your request declined by BibleChat, you can appeal by sending a sufficiently substantiated notice at [email protected].

Within 60 days of receipt of an appeal, BibleChat will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decision.

If the appeal is denied, BibleChat will provide you a method through which you can contact the Attorney General to submit a complaint.

Non-Discrimination
Under U.S. state privacy laws, businesses are prohibited from discriminating against you for exercising your rights under the law. This includes actions such as denying you a product or service, offering a lower quality or different level of service, or charging you higher prices. However, the California Consumer Privacy Act (CCPA) allows businesses to offer different levels or qualities of service or charge different prices, provided the business can demonstrate that these differences are reasonably tied to the value the consumer's personal information brings to the business. This ensures that businesses can adjust their offerings in a way that reflects the value of the Personal Information they collect, without unfairly penalizing consumers for exercising their privacy rights

TRANSFERS TO OTHER COUNTRIES

Transfers from and outside of the EU or the UK

BookVitals App SRL is based in Romania. Personal Information we collect may be transferred to and processed in the United States (“US”), including by our affiliate BookVitals Inc. Also, some of our third-party providers may be based outside the European Union or the UK. Their processing of your Personal Information will involve a transfer of data outside these territories Whenever we transfer your Personal Information outside the EU or the UK, we endeavor to ensure that one of the following safeguards is in place:

• we only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection of Personal Information. For more details in the EU, please see European Commission: Adequacy Decisions;
• where we use certain service providers, we may use specific contracts, which provide the same protection for Personal Information as in the EU or the UK;
• where such data cannot be afforded one of the above protections, we will only transfer it outside of these territories if it is necessary for the performance of our contract with you or if we have your free, informed, clear and specific consent.

Transfers from and outside of the US

Personal Information we collect may be transferred to and processed in the Europe Union, including by our affiliate BookVitals App S.R.L.

Also, some of our third-party providers may be based outside the US. Their processing of your Personal Information will involve a transfer of data outside the US.

CHANGES TO OUR POLICY

We may change this Policy from time to time. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If permitted by law, your continued use of the Services after this Policy has been updated indicates your acceptance of changes made. In some cases, you will be given a choice to accept changes to this Policy. If you do not accept the terms of the updated Policy, you are not allowed to continue using or accessing the Services