PRIVACY POLICY

Last updated: September 5, 2024

This privacy notice for Justin Salcedo (doing business as Libellus) ("we", "us," or "our"), describes how and why we may collect, store, use, and share ("process") your information when you use our services ("Services"), like when you:

• Visit our website at https://libellus.io, or any website of ours that links to this privacy notice
• Download and use our mobile application (Libellus) or any other application of ours that links to this privacy notice
• Interact with us in other related ways, including sales, marketing, or events.

Do you have questions or concerns? This privacy notice will help you understand your privacy rights and options. If you disagree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at web@justinsalcedo.com

SUMMARY OF KEY POINTS

What personal data do we process? When you visit, use, or browse our Services, we may process personal information depending on how you interact with us and the Services, your choices, and the products and features you use. Learn more details about the personal information you disclose to us

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, and comply with the law for security and fraud prevention purposes. We may also process your information for other purposes with your consent. We only process your information where we have a valid legal reason. Learn more information about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more details about when and with whom we share your personal information.

How do we keep your information secure? We have organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, and we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to breach our security and collect access inappropriately, steal or modify your information. Learn more information about how we keep your information secure.

What are your rights? Depending on your location, applicable privacy law may mean you have certain rights regarding your personal information. Learn more information about your privacy rights.

How do you exercise your rights? The easiest way is to submit an interested party access request or contact us. We will consider and act on any request by applicable data protection laws.

Please review the complete privacy notice to learn more about how we use our collected information.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

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

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

Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• usernames
• email addresses

Sensitive information. We do not process sensitive information.

Application data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

• Mobile device data. We automatically collect device information (such as ID, model, and manufacturer of your mobile device), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, carrier of Internet services, and mobile telephone operator, besides Internet Protocol (IP) address (or proxy server). Suppose you are using our application(s). In that case, we may also collect information about the telephone network associated with your mobile device, the operating system or platform of your mobile device, the type of mobile device you use, the unique device ID, and information about the features of our application(s) that you accessed.
• Push notifications. We may request push notifications permissions to inform you about your account or certain app features. If you wish to opt out of receiving these communications, you can disable them in your device settings.

This information is primarily needed to maintain the security and operation of our applications, troubleshoot, and conduct internal analysis and reporting.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Google API

Our use of information received from Google APIs will be by Google API Services User Data Policy, including the Limited use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In brief: We process your information to provide, improve, and administer our Services, communicate with you, and comply with the law for security and fraud prevention purposes. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and manage user accounts. We may process your information to enable you to create and log into your account, as well as keep your account up and running.
• To save or protect the vital interest of an individual. We may process your information where necessary to save or protect the vital interests of an individual, such as to prevent harm.

3. WHAT LEGAL BASES DO WE BASED ON TO PROCESS YOUR INFORMATION?

In brief: We only process your personal information where we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with regulations, to provide you with services to celebrate or fulfill our contractual obligations, to protect your rights or to pursue our legitimate business interests.

This section applies to you in the EU or the UK.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more details about withdrawing your consent.
• Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in that we are involved.
• Vital interests. We may process your information where it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

This section applies to you in Canada.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a particular purpose or in situations where we can infer your permission (i.e., implied consent). You can withdraw your consent at any time.
In some rare cases, applicable law may allow us to process your information without your consent, including, for example:

• If the collection is clearly for the benefit of an individual and consent cannot be obtained promptly
• For investigations, fraud detection, and prevention
• For commercial transactions, as long as certain conditions are met
• If it is contained in a witness statement, collection is necessary to evaluate, process, or resolve an insurance claim.
• To identify injured, sick, or deceased people and communicate with the closest relatives
• If we have reasonable grounds to believe that a person has been, is, or might be a victim of financial abuse
• Suppose the collection and use with consent can reasonably be expected to compromise the availability or accuracy of the information. In that case, the collection is reasonable for investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or court rules relating to the production of records
• If an individual produced it during their employment, business, or profession, the collection is consistent with the purposes for which they created the information.
• If the collection has the sole journalistic, artistic, or literary purpose
• If the information is publicly available and regulations specify it.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Brief: We may share information in specific situations described in this section and with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

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

We will only retain your personal information for as long as necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information longer than when users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If this is impossible (for example, because we store your data in backup archives), we will securely delete it. We will store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SECURE?

In brief: our goal is to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our security measures and efforts to protect your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that the Hackers, cybercriminals, or other unauthorized third parties will not be able to circumvent our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In brief: in some regions, such as the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access and control over your personal information. Depending on your country, province, or state of residence, you may review, change, or cancel your account anytime.

You have certain rights under applicable data protection laws in some regions (such as the EEA, the United Kingdom, Switzerland, and Canada). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or deletion, (iii) to restrict the processing of your personal information, (iv) where applicable, to the portability of the data; and (v) not be subject to automated decision making. In certain circumstances, you may also have the right to object to processing your personal information. You may make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" bellow.

We will consider and act on any request by applicable data protection laws.

Suppose you are in the EEA or the United Kingdom and believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your Member State data protection authority or the UK Data Protection Authority

You can contact the Federal Commissioner for Data Protection and Information in Switzerland.

Withdraw your consent: If we rely on your consent to process your personal information, which may be express and implied consent under applicable law, you can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" bellow.

However, please note that this will not affect the lawfulness of the processing before your withdrawal nor, where permitted by applicable law, will it affect the processing of your personal information carried out based on lawful processing grounds other than consent.

Account information

If at any time you would like to review or change your account information or cancel your account, you can:

• Log in to your account settings and update your user account.

If you request to cancel your account, we will deactivate or delete it and its information from our active databases. However, we may retain certain information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.

If you have questions or comments about your privacy rights, email us at web@justinsalcedo.com.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or functions of our Services.

8. CONTROLS FOR DO NOT TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference, not to monitor or collect data about your online browsing activities. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In brief: you may have additional rights depending on the country in which you reside.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) that we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and wish to make such a request, please submit your request to us in writing using the Contact information provided below.

If you are under 18, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information below. Include the email address associated with your account and a statement that you reside in California. We will keep data private on the Services, but please note that our systems may not entirely or comprehensively remove data (e.g., backups, archives, and related).

Australia and New Zealand

We collect and process your personal information according to the obligations and conditions set out by the Australian Privacy Act 1988 and the New Zealand Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Laws, particularly regarding what personal information we collect from you, what sources, for what purposes, and other recipients of your personal information.

If you do not wish to provide personal information necessary to fulfill your applicable purpose, it may affect our ability to provide our services, in particular:

• Offer you the products or services you want.
• Respond or assist with your requests
• Manage your account with us
• Confirm your identity and protect your account

You can request access to or correct your personal information at any time. You may contact us using the contact details provided in the "HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?" section

Suppose you believe we are unlawfully processing your personal information. In that case, you have the right to complain about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of the New Zealand Privacy Principles by the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You can request access to or correct your personal information anytime by contacting us using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are dissatisfied with the way we deal with any complaint regarding our processing of personal information, you may contact the regulator's office, details of which are:

The Information Regulator (South Africa)

General inquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA Form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

10. DO WE UPDATE THIS NOTICE?

In brief: We will update this notice to comply with applicable laws.

We may update this privacy notice from time to time. An updated "Revised" date at the top will indicate the updated version. If we make material changes to this privacy notice, we may notify you by prominently posting a notice or directly sending you a notification. We encourage you to review this privacy notice frequently to remain informed of how we protect your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

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

• Email: web@justinsalcedo.com

12. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details of how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent so that we can process your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please complete and submit an interested-party access request.