OBJECTIVE:

1. In accordance with the laws of the United States, this Privacy and Personal Data Processing Policy ("Policy") outlines the procedures used by Clapp Technologies LLC ("BUZZLY") for the reception and processing of personal data from users and clients using its website and mobile application. The collected data is exclusively relevant for:

   • Conducting marketing, promotion, and advertising activities, sales, billing, debt collection, scheduling, technical support, market intelligence, service improvement, verifications, and inquiries, control, behavior, habit, and payment method enablement.

   • Fulfilling contractual obligations and the company's corporate purpose.

   BUZZLY will process personal data in compliance with this Policy and the applicable U.S. legal framework.

2. SCOPE:

   This Policy applies to the processing of personal data for all customers, potential customers, users, and partners accessing the website www.buzzly.com or the app with the identifier com.heyflup.flup or sharing their data with BUZZLY. Personal data may be transmitted to companies outside the United States for specific legal reasons and for studying user behavior for marketing purposes.

3. RESPONSIBILITIES:

   • Position/Area: Legal Management

     • Contact: info@heybuzzly.com

     • Responsibility: Update this policy when necessary.

   • Position/Area: Systems

     • Contact: +1 (863) 774-3099

     • Responsibility: Handle queries, quotes, and safeguard information.

4. DESCRIPTION:

   BUZZLY provides a service allowing access to its platform (website and mobile app) for allies and influencers to receive and send redeemable codes in local establishments. This aims to provide a new sales and advertising channel, analyze metrics for influencer posts, and enable discounts for future customers using the promotional codes.

GENERAL INFORMATION ABOUT CLAPP TECHNOLOGIES AS THE DATA PROCESSOR:

• Business Name: Clapp Technologies, LLC

• Trade Name: BUZZLY

• Email: info@heybuzzly.com

• Website: www.heybuzzly.com

Visiting the website doesn't require users to provide information. Users voluntarily provide necessary data (e.g., ID number, name, address, age, phone number, email) to fulfill contractual obligations. No sensitive data will be requested.

1. COLLECTION OF PERSONAL INFORMATION:

   • Automatically collected device information (browser, IP, timezone, cookies).

   • Purchase-related information (name, billing address, shipping address, payment information) during website interactions.

2. PRINCIPLES FOR DATA PROCESSING:

   In compliance with constitutional and legal guarantees:

   • Right to access, update, and rectify personal information.

   • Right to object to data processing.

   • Right to request data deletion.

   • Right to request proof of authorization for processing.

   • Right to revoke consent for data processing.

   • Right to file complaints with regulatory authorities.

   • Right to be informed about data processing.

3. CONSENT:

   Users provide consent through written, oral, platform interaction, or clear conduct. Silence is not considered consent. Exceptions include data required by public entities, publicly available data, medical emergencies, law-authorized processing, and civil registry data.

4. BUZZLY'S OBLIGATIONS:

   BUZZLY commits to fulfilling obligations to data subjects, collaborating with competent authorities, using databases exclusively for its purposes, obtaining written authorization for processing children's data, and ensuring data confidentiality.

5. RIGHTS AND OBLIGATIONS OF DATA SUBJECTS:

   • Data subjects can exercise rights to access, update, rectify, revoke consent, and file complaints.

   • Users must indemnify BUZZLY for any claims arising from improper website use, unauthorized data transmission, or policy non-compliance.

6. QUERY AND CLAIMS MANAGEMENT:

Users can contact BUZZLY for data-related inquiries or claims through the provided contact information.

1. MODIFICATIONS TO THE POLICY:

BUZZLY reserves the right to modify this Policy. Substantial changes will be communicated to data subjects, requiring new authorization.

1. EFFECTIVE DATE:

This Policy is effective from October 1, 2022. Stored data will be reviewed annually for accuracy and relevance, with the right to modify the policy unilaterally. Significant changes will be communicated to data subjects.