Privacy Policy

1. Introduction

This Privacy Policy explains how Nissus LLC ("Vatrelo," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when you access or use the Vatrelo website, platform, and related services (collectively, the "Service").

Vatrelo is operated by Nissus LLC, a Wyoming limited liability company.

This Privacy Policy applies to information collected from Members, Creators, website visitors, and other individuals who interact with the Service.

By using the Service, you acknowledge the practices described in this Privacy Policy.

2. Information We Collect

We collect information that you provide directly to us, information generated through your use of the Service, and information provided to us by third-party service providers.

A. Information Members Provide

Depending on how you use Vatrelo, we may collect:

• First name;
• Email address;
• Avatar image submitted for a Member Card;
• Username;
• Links to your social media profiles (e.g., Instagram, TikTok, YouTube, X/Twitter, Facebook);
• Boost status updates, if you purchase the Boost Add-On;
• Purchase, subscription, and billing information;
• Information necessary to provide the Membership or Add-On Services (including Boost and Featured Spot);
• Communications you send to Vatrelo; and
• Other information you voluntarily provide to us.

Because a Membership is a recurring subscription, Members generally need to create a Vatrelo account and maintain a valid payment method on file.

B. Information Creators Provide

Creators register and authenticate for Vatrelo exclusively through Instagram. When a Creator registers, we may collect:

• Name, username, and profile photo obtained through Instagram authentication;
• Email address, where provided through Instagram authentication or otherwise required for account or payment purposes;
• Creator profile information;
• Payment and payout information;
• Information required to establish and maintain a Stripe Connect account;
• Identity verification information required by Stripe or another payment provider;
• Referral information relevant to Featured Spot eligibility (Section 11 of our Terms of Service); and
• Communications with Vatrelo.

Vatrelo may receive certain information from Instagram in connection with Creator authentication, and from Stripe in connection with Creator onboarding, identity verification, payment processing, and payouts.

C. Payment Information

Payments are processed through third-party payment processors, including Stripe.

Vatrelo does not intentionally collect or store complete payment card numbers.

Payment processors may collect and process payment card information, billing information, identity information, and other information necessary to process transactions (including recurring subscription billing) and comply with applicable financial, fraud-prevention, and regulatory requirements.

Vatrelo may receive limited payment-related information from payment processors, such as transaction identifiers, payment status, payment method type, subscription status, transaction amount, currency, and related information.

Stripe's processing of personal information is also governed by Stripe's applicable privacy policies and terms.

D. Member Card and Add-On Content

When a Member purchases a Membership, Vatrelo collects and stores the avatar, username, and social media links submitted for the Member Card.

If the Member purchases the Boost Add-On, Vatrelo may also collect the status updates submitted through Boost.

If the Member purchases or holds a Featured Spot, Vatrelo collects information necessary to administer it, including purchase timing, queue position, and Display Period timing described in our Terms of Service.

Because the Vatrelo is intentionally public, Member Cards, Boost status updates, and Featured Spot placement may be displayed publicly for as long as the underlying Membership remains active.

E. Information Automatically Collected

When you access or use Vatrelo, we may automatically collect information such as:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Approximate geographic information derived from IP address;
• Language and regional settings;
• Referring website or page;
• Pages and content viewed;
• Features used;
• Actions taken on the Platform;
• Dates and times of access;
• Session information;
• Error and diagnostic information; and
• Other technical or usage information.

We use this information primarily to operate, secure, maintain, analyze, and improve the Service.

3. How We Use Personal Information

We may use personal information for the following purposes:

Providing the Service

We use information to:

• Process Membership subscriptions and Add-On purchases (Boost, Featured Spot);
• Create and display Member Cards;
• Display linked social media profiles;
• Display Boost status updates and Featured Spot placement where purchased;
• Operate Creator Vatrelo profiles;
• Administer Featured Spot eligibility and the purchase/queue mechanics;
• Process Creator payouts;
• Provide customer support;
• Communicate with Members and Creators; and
• Otherwise provide the Service.

Payments and Transactions

We use information to:

• Process recurring subscription payments;
• Process refunds and cancellations;
• Process Creator payouts;
• Maintain transaction and billing records;
• Prevent fraudulent transactions;
• Detect suspicious activity; and
• Resolve payment disputes and chargebacks.

Platform Operation

We use information to:

• Operate and maintain Vatrelo;
• Authenticate users;
• Maintain accounts and subscriptions;
• Monitor Platform performance;
• Troubleshoot technical problems;
• Improve functionality and user experience; and
• Develop new features and services.

Safety, Security, and Fraud Prevention

We may use information to:

• Detect and prevent fraud;
• Detect abuse, including manipulation of the Featured Spot queue or referral eligibility;
• Investigate suspicious activity;
• Protect the security of Vatrelo;
• Protect users, Creators, and third parties;
• Enforce our Terms of Service; and
• Prevent attempts to manipulate purchases, subscriptions, refunds, accounts, or other Platform functionality.

Legal and Compliance Purposes

We may use information to:

• Comply with applicable laws and regulations;
• Respond to lawful requests from governmental authorities;
• Establish, exercise, or defend legal claims;
• Enforce our agreements; and
• Maintain records required for legal, accounting, tax, or regulatory purposes.

Communications

We may use your contact information to send:

• Purchase and subscription confirmations;
• Billing and renewal notifications;
• Refund and cancellation notifications;
• Account-related messages;
• Security notifications;
• Important service announcements;
• Customer-support communications; and
• Other transactional communications.

Where permitted by law, we may also send marketing or promotional communications.

You may unsubscribe from marketing emails at any time by using the unsubscribe mechanism provided in the communication or by contacting us.

4. Legal Bases for Processing

Where applicable, including for individuals located in the European Economic Area (EEA), United Kingdom, or other jurisdictions that require a legal basis for processing, we may process personal information based on one or more of the following:

Performance of a Contract

We process information when necessary to provide the Service you requested, including:

• Processing Membership subscriptions;
• Providing Boost and Featured Spot Add-On Services;
• Processing Creator payouts; and
• Providing customer support.

Legitimate Interests

We may process information where necessary for our legitimate business interests, including:

• Operating and improving Vatrelo;
• Fraud prevention;
• Platform security;
• Analytics;
• Customer support;
• Maintaining business records; and
• Protecting our legal rights.

We consider and balance our legitimate interests against applicable privacy rights.

Consent

Where required by law, we process information based on your consent.

You may withdraw consent where processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

Legal Obligations

We may process information when necessary to comply with applicable legal, regulatory, tax, accounting, or governmental requirements.

5. How We Share Personal Information

We may disclose personal information to the following categories of recipients.

A. Creators

When a Member purchases a Membership, the applicable Creator may receive access to the Member Card and information associated with the membership that is necessary to operate and manage the Creator's Vatrelo.

If a Member purchases the Boost Add-On or holds a Featured Spot, the applicable Creator may see the associated status update or position because that content forms part of the public display purchased by the Member.

B. Payment Providers

We share information with payment processors and financial service providers, including Stripe, to:

• Process subscription payments;
• Process refunds and cancellations;
• Process Creator payouts;
• Verify identities;
• Prevent fraud;
• Handle disputes and chargebacks; and
• Comply with applicable financial and regulatory requirements.

C. Hosting and Infrastructure Providers

We use third-party providers to host and operate Vatrelo.

These providers may process information on our behalf, including account information, Member Card content, technical information, and other data necessary to provide the Service.

Our hosting infrastructure may include Supabase, Cloudflare, and other cloud infrastructure or storage providers.

D. Email and Communications Providers

We may use third-party providers, such as Resend, to send transactional and marketing communications.

These providers may process email addresses and information necessary to deliver communications on our behalf.

E. Analytics Providers

We may use analytics services, including Google Analytics, to understand how users interact with Vatrelo, measure Platform performance, and improve the Service.

Analytics providers may collect information such as device information, IP address, pages viewed, interactions, and other usage information.

F. Legal and Safety Disclosures

We may disclose personal information where reasonably necessary to:

• Comply with applicable law;
• Respond to subpoenas, court orders, or lawful governmental requests;
• Protect the rights, property, or safety of Vatrelo;
• Protect users or third parties;
• Investigate fraud or abuse;
• Enforce our Terms of Service; or
• Defend legal claims.

G. Business Transfers

If Nissus LLC or Vatrelo is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, dissolution, or similar transaction, personal information may be transferred as part of that transaction.

Where required by applicable law, we will provide appropriate notice concerning such transfer.

6. Public Content

Vatrelo is designed around public display of Member Cards.

When you purchase a Membership, your avatar, username, and linked social media profiles are intentionally displayed publicly on the applicable Creator's Vatrelo for as long as your membership remains active.

If you purchase the Boost Add-On, your status updates may be displayed publicly beneath your Member Card.

If you purchase or hold a Featured Spot, your Member Card's position above the main list is publicly visible.

Publicly displayed content may be:

• Viewed by the Creator;
• Viewed by other Vatrelo users;
• Viewed by members of the public;
• Shared or reposted by the Creator;
• Shared or reposted by Vatrelo;
• Captured through screenshots or recordings;
• Shared through social media; or
• Copied or otherwise distributed by third parties.

Vatrelo cannot control how third parties use content after it becomes publicly available.

The rights and permissions concerning Member Content are described in greater detail in our Terms of Service.

7. Cookies and Similar Technologies

Vatrelo may use cookies, pixels, local storage, and similar technologies.

These technologies may be used for:

Essential Technologies

These are necessary for the Service to function, including:

• Login sessions;
• Security;
• Authentication;
• Checkout and subscription management;
• Payment functionality; and
• Basic Platform functionality.

Analytics Technologies

We may use analytics technologies, including Google Analytics, to understand how visitors use Vatrelo and to improve the Platform.

You may be able to control cookies through your browser settings.

Disabling certain cookies may affect the functionality of Vatrelo.

Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Member Card and Add-On Content

A Member Card, Boost status update, and Featured Spot record may remain displayed for as long as the underlying Membership remains active, and may be automatically deleted or archived from Vatrelo's active systems within a reasonable period after the membership ends.

However, copies may remain in:

• Backups;
• Security systems;
• Logs;
• Fraud-prevention systems;
• Legal records;
• Dispute records; or
• Other systems where immediate deletion is technically impractical or legally unnecessary.

Content associated with a report, dispute, fraud investigation, legal claim, or other security matter may be retained for as long as reasonably necessary to resolve the matter.

Account, Subscription, and Transaction Information

We may retain account, subscription, payment, transaction, payout, and related records for as long as reasonably necessary to:

• Operate the Platform;
• Maintain financial and accounting records;
• Comply with tax and legal obligations;
• Prevent fraud;
• Resolve disputes;
• Enforce agreements; and
• Protect our legal rights.

Retention periods may vary depending on the type of information and applicable legal requirements.

9. International Data Transfers

Vatrelo is operated by Nissus LLC, a Wyoming, United States company.

Vatrelo and its service providers may process personal information in the United States and other countries.

As a result, your information may be transferred to, stored in, or processed in a country other than the country in which you live.

These countries may have privacy laws that differ from those in your country of residence.

Where applicable law requires safeguards for international transfers, we will use legally recognized transfer mechanisms or other appropriate safeguards.

10. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• Access controls;
• Authentication controls;
• Encryption or secure transmission where appropriate;
• Restricted access to personal information;
• Security monitoring;
• Third-party security measures; and
• Secure handling and deletion practices.

However, no method of transmission over the Internet or method of electronic storage is completely secure.

Therefore, we cannot guarantee absolute security of personal information.

We encourage users to protect their account credentials and notify us promptly if they believe their account or information has been compromised.

11. Your Privacy Rights

Depending on where you live and subject to applicable law, you may have certain rights concerning your personal information.

These rights may include:

• The right to know whether we process personal information about you;
• The right to access personal information we hold about you;
• The right to request correction of inaccurate information;
• The right to request deletion of personal information;
• The right to receive certain personal information in a portable format;
• The right to object to certain processing;
• The right to restrict certain processing;
• The right to withdraw consent where processing is based on consent; and
• The right to lodge a complaint with a competent data protection authority.

These rights are subject to applicable legal exceptions and limitations.

To exercise applicable privacy rights, contact us at:

contact@vatrelo.com

We may need to verify your identity before completing certain requests.

We will respond to valid requests within the time period required by applicable law.

12. California Privacy Rights

This section applies to California residents to the extent the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), applies to Vatrelo.

California law provides eligible consumers with certain rights concerning their personal information, including rights to know/access, correct, delete, and certain rights concerning the sale or sharing of personal information.

Categories of Personal Information

Depending on how you use Vatrelo, we may collect categories of personal information including:

• Identifiers, such as name, email address, username, and IP address;
• Commercial information, such as purchase, subscription, and transaction information;
• Internet or other electronic network activity information, such as browsing and usage information;
• Geolocation-related information derived from technical information such as IP address;
• User-generated content, such as avatars, linked social profiles, and Boost status updates;
• Inferences derived from usage information; and
• Other information that may reasonably be associated with or linked to you.

We use these categories for the purposes described in Section 3 of this Privacy Policy.

Sale or Sharing of Personal Information

Vatrelo does not sell personal information for monetary consideration.

Vatrelo also does not currently share personal information for cross-context behavioral advertising.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

If our privacy practices change in a way that triggers additional rights or obligations under California law, we will update this Privacy Policy and provide any legally required notices or opt-out mechanisms.

California Privacy Requests

Eligible California residents may contact us at:

contact@vatrelo.com

Because Vatrelo operates exclusively online, we may use email as a method for submitting privacy requests where permitted by applicable California law. California's privacy rules require covered businesses to provide mechanisms for eligible consumers to exercise applicable rights, and online-only businesses may use an email address for certain requests.

We will not discriminate against you for exercising privacy rights provided by applicable law.

13. Children's Privacy

Vatrelo is intended only for individuals 18 years of age or older.

Minors may not:

• Create Vatrelo accounts;
• Purchase Memberships;
• Purchase Add-On Services (Boost or Featured Spot); or
• Appear on a Member Card.

We do not knowingly collect personal information from individuals under 18 in violation of applicable law.

If we learn that a person under 18 has provided personal information or submitted content in violation of our Terms, we may take reasonable steps to delete the information or content.

If you believe a minor has provided information to Vatrelo, contact us at:

contact@vatrelo.com

14. Third-Party Services and Links

Vatrelo may use or integrate third-party services, including payment processors, hosting providers, analytics providers, communication providers, and social media services.

Third-party services may have their own privacy policies and terms.

This Privacy Policy does not govern the privacy practices of independent third parties.

We encourage you to review the privacy policies of third-party services you use in connection with Vatrelo.

15. Social Media and Public Profiles

When a Member creates a Membership, the Member provides links to their social media profiles (e.g., Instagram, TikTok, YouTube, X/Twitter, Facebook) for public display and, where technically supported, direct linking.

Vatrelo does not control these third-party social media platforms and cannot guarantee that a linked profile will remain active, public, accessible, or available.

Any information that becomes publicly available through a third-party social media platform is subject to that platform's own privacy practices.

16. Do Not Track

Some web browsers may transmit "Do Not Track" signals.

Because there is currently no universally accepted standard for responding to such signals, Vatrelo may not respond to all browser-based Do Not Track signals.

Where required by applicable law, Vatrelo will honor legally recognized privacy preference signals.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• Our services;
• Our data practices;
• Technology;
• Applicable laws; or
• Business operations.

When we make material changes, we may provide notice through the Platform, by email, or through another reasonable method where required by law.

The updated Privacy Policy will include a revised "Last updated" date.

18. Contact Information

If you have questions about this Privacy Policy, our privacy practices, or your personal information, contact us at:

Vatrelo
Operated by Nissus LLC
Wyoming, United States
Email: contact@vatrelo.com