VerseLab California Privacy Disclosure (CCPA/CPRA) ================================================= Last updated: 2025-12-02 This California Privacy Disclosure ("Disclosure") supplements the VerseLab Privacy Policy and applies only to residents of California in their capacity as consumers, as defined under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). If there is any conflict between this Disclosure and the general Privacy Policy with respect to California residents, this Disclosure controls. When we say "VerseLab," "we," "us," or "our," we mean the operator of the VerseLab app and related services. When we say "you" or "your," we mean a California resident using VerseLab. 1. Categories of personal information we collect ---------------------------------------------- In the past 12 months, we may have collected the following categories of personal information about you, as defined by California law: * **Identifiers** such as your email address, display name, username, IP address, device identifiers, and account ID. * **Customer records information** such as basic account profile information (for example, bio, avatar, clubs you join or manage, notification preferences), and subscription or purchase history where applicable. * **Internet or other electronic network activity information** such as interactions with VerseLab features (for example, views, likes, follows, comments, shares, and participation in slams and clubs), log data, approximate location derived from IP address, device and app information (for example, app version, operating system, crash logs), and limited analytics needed to operate and improve VerseLab. * **User-generated content** such as poems, images, videos, comments, direct messages, club posts and events, and other content you create, upload, or provide through VerseLab. * **Commercial information** such as products or subscriptions you purchase in VerseLab and related transaction information (processed via our billing partners; we do not store full payment card numbers). * **Inferences** drawn from the information above to personalize your in-app experience (for example, recommended poems or clubs, ranking in your feed, suggested challenges). We do **not** knowingly collect sensitive personal information as defined under the CPRA (such as social security numbers, precise geolocation, or financial account login credentials), beyond what is strictly necessary to process payments via trusted providers. 2. Sources of personal information --------------------------------- We collect personal information from: * **You directly** when you create an account, set up or edit your profile, create or interact with content, participate in slams or clubs, contact us, or otherwise use VerseLab. * **Your device and browser** when you use VerseLab, including through cookies or similar technologies on web, to maintain your session, security, and preferences. * **Service providers and partners** such as authentication providers, analytics tools, and advertising partners that help us deliver, secure, and improve VerseLab. 3. How we use personal information --------------------------------- We use the categories of personal information described above for the following business purposes: * To create, maintain, and secure your VerseLab account. * To provide core VerseLab features (feeds, creation tools, clubs, messaging, challenges, competitions, notifications, search, and discovery). * To personalize content and recommendations, such as suggesting poems, slams, or clubs that may interest you. * To provide customer support and respond to your requests. * To maintain the safety and integrity of VerseLab, including detecting, preventing, and responding to abuse, fraud, spam, and security incidents, and enforcing our EULA and community guidelines. * To measure and improve the performance and quality of VerseLab (including debugging and analytics). * To show in-app advertising and to measure the performance of campaigns, **only using de-identified or aggregated information** (see Section 5 below). * To comply with legal obligations and respond to lawful requests. 4. How we share personal information ----------------------------------- We share personal information with: * **Service providers and processors** who help us operate VerseLab (for example, hosting, authentication, database and storage, messaging and notifications, analytics, error monitoring, customer support, and payment processing). These entities are contractually obligated to use personal information only to provide services to us and not for their own independent purposes. * **Other VerseLab users and the public** when you choose to make content public or interact socially (for example, posting poems, joining clubs, commenting, or participating in slams). Please be mindful that publicly posted content may be viewed, shared, or copied by others. * **Law enforcement, regulators, and other parties** where required by law, legal process, or to protect the rights, property, or safety of you, us, other users, or the public. * **Entities involved in a corporate transaction** (such as a merger, acquisition, or sale of assets) as permitted by law, in which case your information may be transferred as part of that event. 5. No sale of personal information; limited sharing for advertising ------------------------------------------------------------------ VerseLab does **not** sell your personal information, and we have not sold personal information in the past 12 months. We may share **de-identified or aggregated information** with partners for purposes such as: * Measuring and improving the effectiveness of in-app advertising and marketing campaigns. * Understanding general usage patterns to improve VerseLab features and performance. When we work with advertising and analytics partners, we implement technical and contractual measures designed to help ensure that any information we share for these purposes does **not** identify you personally. For example, we may: * Use randomized or hashed identifiers instead of your direct identity. * Aggregate metrics across many users. * Configure partners to avoid combining the information we share with other data to identify you. You can also control certain tracking and advertising preferences via your device or platform settings (for example, "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android) and by adjusting in-app notification and email preferences. 6. Retention of personal information ----------------------------------- We retain personal information for as long as necessary to achieve the purposes described in this Disclosure and in our Privacy Policy, including providing VerseLab services, maintaining business records, and complying with legal obligations. When we no longer need personal information for these purposes, we take steps to delete, de-identify, or aggregate it. If you delete your account, we begin the process of removing or de-identifying personal information associated with your account, subject to technical, legal, and safety constraints (for example, maintaining certain records for fraud prevention, security, or legal compliance). 7. Your California privacy rights -------------------------------- If you are a California resident, you have the following rights, subject to certain exceptions and limitations under California law: * **Right to Know / Access**: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources of that information, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it. * **Right to Delete**: You have the right to request that we delete personal information we collected from you, subject to certain exceptions (for example, where we need the information to provide VerseLab, protect security, or comply with legal obligations). * **Right to Correct**: You have the right to request that we correct inaccurate personal information that we maintain about you. * **Right to Non-Discrimination**: We will not discriminate against you for exercising any of your CCPA/CPRA rights. For example, we will not deny services, charge different prices, or provide a different level or quality of services solely because you made a privacy request. VerseLab does not sell personal information and does not process "sharing" of personal information for cross-context behavioral advertising in the sense contemplated by the CPRA. 8. How to exercise your rights ------------------------------ You can exercise certain privacy rights directly in the app (for example, by updating your profile or preferences in Account Settings, using available export tools, or deleting your account). For other requests under California law (including requests to know/access, delete, or correct your personal information): * Email us at **privacy@verselabapp.com** with the subject line "California Privacy Request"; or * Follow any in-app request flows we may add for data access or deletion. When you make a request, we may need to verify that you are the account holder or an authorized agent. This may include asking you to confirm control of your account (for example, by signing in or responding from your registered email address) or providing limited additional information so we can match you to our records. We will respond to verifiable consumer requests within the time periods required by California law. You may also authorize an agent to make requests on your behalf. If you do so, we may require proof of the agent's authorization and still need you to verify your identity directly with us. 9. Children ---------- VerseLab is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (or any higher age required in your jurisdiction). If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it. 10. Changes to this Disclosure ----------------------------- We may update this California Privacy Disclosure from time to time. When we do, we will revise the "Last updated" date above. If we make material changes, we may also provide additional notice in the app or by email. 11. Contact us ------------- If you have questions about this Disclosure or our privacy practices, or if you would like to exercise your California privacy rights, you can contact us at: * Email: **privacy@verselabapp.com**