Privacy Policy

1. Introduction

Galeonica LLC ("Company," "Voolty," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at voolty.com (the "Site"), use our mobile applications, browser extensions, or any other services we offer (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection and use of your information as described in this Privacy Policy. If you do not agree, please do not use our Services.

This Privacy Policy applies to all users of the Services, regardless of location. Additional rights may apply to you depending on your jurisdiction, as described in the sections below.

2. Information We Collect

2.1 Information You Provide Directly

2.2 Information Collected Automatically

2.3 Information from Third Parties

We may receive information about you from third parties, including: (a) affiliate networks and merchant partners (transaction validation, order details); (b) analytics providers (aggregated usage data); (c) fraud prevention services (risk scoring, identity verification); and (d) social media platforms (if you choose to log in via a social account).

3. How We Collect Information

We collect information through the following methods:

• Direct Interactions: When you create an account, make a purchase through our platform, contact us, or participate in promotions.
• Automated Technologies: Through cookies, web beacons, pixel tags, browser extensions, and similar technologies as you navigate the Services.
• Third-Party Sources: From affiliate networks, analytics providers, fraud prevention services, and social media platforms, as described above.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and Maintain Services: To operate the platform, process cashback, manage accounts, and deliver the features you request.
• Process Transactions: To track purchases, calculate cashback, process withdrawals, and communicate with affiliate networks and merchants.
• Communicate with You: To send account notifications, cashback updates, customer support responses, and (with your consent where required) promotional communications.
• Personalize Experience: To tailor content, offers, and recommendations based on your preferences and usage patterns.
• Improve Services: To analyze usage trends, conduct research, test new features, and improve the functionality and performance of the Services.
• Prevent Fraud & Ensure Security: To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity and to protect the rights and safety of users and third parties.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.
• Enforce Terms: To enforce our Terms of Use and other agreements.

5. How We Share Your Information

We do not sell your personal information for monetary consideration. However, we may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including hosting, data analytics, payment processing, email delivery, fraud detection, and customer support. These providers are contractually obligated to use your information only for the purposes for which it was disclosed and in accordance with this Privacy Policy.

5.2 Affiliate Networks & Merchants

When you click through to a merchant, certain information (such as a unique tracking identifier, device information, and transaction data) is shared with affiliate networks and merchants to enable cashback tracking. This sharing is essential to the functioning of the Services.

5.3 Analytics & Advertising Partners

We may share anonymized or aggregated information with analytics and advertising partners for the purpose of understanding usage patterns, optimizing the Services, and delivering relevant advertising. Under certain privacy laws (including the CCPA/CPRA), some of these data-sharing arrangements may be considered a "sale" or "sharing" of personal information. See Section 12 for your opt-out rights.

5.4 Legal Requirements

We may disclose your information if required by law, subpoena, court order, or governmental request, or when we believe disclosure is necessary to: (a) comply with applicable law; (b) protect the rights, property, or safety of Galeonica LLC, our users, or the public; (c) detect, prevent, or address fraud, security, or technical issues; or (d) enforce our Terms of Use.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, sale of assets, or other business transaction, your information may be transferred as part of that transaction. We will provide notice if your information becomes subject to a different privacy policy.

5.6 With Your Consent

We may share your information for purposes not described in this Privacy Policy with your express consent.

6. Cookies & Tracking Technologies

6.1 What Are Cookies

Cookies are small data files placed on your device when you visit a website. We use cookies and similar technologies (web beacons, pixel tags, local storage) for the purposes described below.

6.2 Types of Cookies We Use

6.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling cookies may impair the functionality of the Services, including the ability to track and earn cashback. For more information, visit allaboutcookies.org.

6.4 Do Not Track Signals

Some browsers transmit "Do Not Track" (DNT) signals. There is currently no industry standard for responding to DNT signals. Accordingly, our Services do not currently respond to DNT signals. However, you may exercise your privacy rights as described in Sections 9–12 below.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. The retention period depends on the nature of the information and the purpose for which it was collected:

• Account data: Retained while your account is active and for up to 3 years after account closure.
• Transaction data: Retained for up to 7 years for tax, legal, and regulatory compliance.
• Marketing data: Retained until you unsubscribe or request deletion.
• Log and analytics data: Retained for up to 2 years.

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include encryption of data in transit (TLS/SSL), access controls, regular security assessments, and employee training.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials and for any activity that occurs under your account.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request that we correct inaccurate or incomplete personal information.
• Right to Deletion: You may request that we delete your personal information, subject to certain exceptions.
• Right to Portability: You may request your personal information in a structured, commonly used, machine-readable format.
• Right to Opt-Out: You may opt out of the sale or sharing of your personal information, targeted advertising, or profiling.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise any of these rights, please contact us at privacy@voolty.com or visit our Do Not Sell My Personal Information page. We will respond to verifiable requests within the timeframe required by applicable law (typically 45 days, with possible extensions).

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

10.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of personal information as defined by the CCPA:

10.2 Your California Rights

As a California resident, you have the right to:

• Know what personal information we have collected, used, disclosed, and sold/shared in the preceding 12 months;
• Delete personal information we have collected from you, subject to certain exceptions;
• Correct inaccurate personal information;
• Opt out of the sale or sharing of your personal information;
• Limit the use of your sensitive personal information (if applicable);
• Non-discrimination for exercising your CCPA rights.

To exercise these rights, contact us at privacy@voolty.com or visit Do Not Sell My Personal Information.

10.3 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's identity and written authorization from you.

10.4 Financial Incentive Programs

Our cashback program constitutes a financial incentive program under the CCPA. By participating, you provide personal information (transaction data, browsing activity) in exchange for cashback rewards. You may opt out of this program at any time by closing your account. The value of the financial incentive is reasonably related to the value of the data provided, based on factors such as the cost of providing the Services and the revenue generated through affiliate partnerships.

11. Other State Privacy Rights

11.1 Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and Other States

If you reside in a state with comprehensive privacy legislation, you may have rights similar to those described in Sections 9 and 10, including the right to access, correct, delete, and port your data, as well as the right to opt out of targeted advertising, sale of personal data, and profiling.

To exercise your rights under applicable state privacy laws, contact us at privacy@voolty.com. We will process your request in accordance with the requirements of your state's applicable privacy law.

11.2 Right to Appeal

If we decline to take action on a request you have submitted, you have the right to appeal our decision. To submit an appeal, please email privacy@voolty.com with the subject line "Privacy Rights Appeal." We will respond within the timeframe required by applicable law.

12. Do Not Sell or Share My Personal Information

Under the CCPA/CPRA and other applicable state privacy laws, you have the right to opt out of the "sale" or "sharing" of your personal information. While we do not sell personal information for monetary consideration, certain data-sharing practices (such as sharing data with advertising and analytics partners for cross-context behavioral advertising) may constitute a "sale" or "sharing" under these laws.

To opt out, please visit our Do Not Sell or Share My Personal Information page or email privacy@voolty.com.

We also honor Global Privacy Control (GPC) browser signals as a valid opt-out request under applicable law.

13. Children's Privacy

The Services are not intended for individuals under the age of 18. We do not knowingly collect, solicit, or maintain personal information from anyone under 18. If we learn that we have collected personal information from a child under 18, we will promptly delete such information. If you believe we have collected information from a minor, please contact us immediately at privacy@voolty.com.

14. International Data Transfers

Voolty is operated from the United States. If you access the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence. By using the Services, you consent to the transfer of your information to the United States and the processing of your information as described in this Privacy Policy.

Where required by applicable law, we will implement appropriate safeguards for international data transfers, including standard contractual clauses or other mechanisms recognized under applicable data protection regulations.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. Any changes will be effective immediately upon posting the revised Privacy Policy on the Site with an updated "Last Updated" date. We encourage you to review this page periodically.

For material changes, we may provide additional notice via email or a prominent notice on the Site. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: