Effective date: January 1, 2026

This Privacy Policy (this “Privacy Policy”) applies to each individual’s access to and use of the www.villaritogether.com website (the “Site”), Services, Content, API, and Villari application (the “App”) (collectively, the “Products”), and all other sites and services owned and operated by Villari Inc., a Delaware corporation (“Villari,” “we,” “us,” or “our”). The Terms of Service (“TOS”) can be found here: Terms of Service. We have created this Privacy Policy to tell you what information the Products collect, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning stated in our TOS. By accessing, installing, downloading, or otherwise using any Product, you are agreeing to the terms of this Privacy Policy on behalf of Supervisor and each applicable Supervised User (also referred to herein as “you” or “your”). We encourage you to read this Privacy Policy, and to use the information it contains to help you make informed decisions. Capitalized terms not defined in this Privacy Policy shall have the meanings assigned to them in the TOS.

1. The Products. The Products assist Supervisor in monitoring e-mail communications and internet activity to detect and block online scams, fraud calls and digital threats to a Supervised User’s Device.
2. Information We Collect or Receive. In the course of operating the Products, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.
   
   1. Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with Personal Information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, email address, physical address, phone number, and login information. We do not collect any Personal Information from you when you use the Products unless you provide us with the Personal Information voluntarily.
   2. Payment Information. If you choose to subscribe to any Services, you will be required to provide us with your payment information, including, without limitation, credit card or debit card numbers (including expiration dates), account details including username and/or unique identifier, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment vendors under the terms and conditions of their privacy policies and terms of service, and we do not obtain access to any Payment Information in connection with such purchases or subscriptions.
   3. Geolocational Information. Certain features and functionalities of the Products are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect Geolocational Information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when the App is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
   4. Usage Data Analytics. We evaluate your use of the Products and Supervised User’s internet activity, compile reports on activity, collect demographic data and Usage Data, analyze performance metrics, and collect and evaluate other information relating to the Products and mobile and Internet usage in order to provide the Services. You consent to the processing of data about you in the manner and for the purposes set out in this Privacy Policy.
   5. Information Collected Indirectly. Our Services collect and analyze data acquired from third party applications used on Supervised User’s monitored devices. We may use such third party’s Application Programming Interface to collect data concerning activities on Supervised User’s monitored devices. Such information may include, without limitation, first and last name, username, profile picture, headline, unique identifier and access token, and email address.
   6. Other Information. In addition to the Personal Information, Payment Information, and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Products; your interactions with us; Supervised User’s internet activity; and information regarding your computer and mobile devices used to access the Products (collectively, the “Other Information”). Such Other Information may include:
      
      1. From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.
      2. From Your Activity. We may collect or receive information regarding:
         
         1. IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;
         2. Browser type and language;
         3. Referring and exit pages and URLs;
         4. Usage Data
         5. Date and time; and
         6. Details regarding your activity on the Products, such as search queries, email addresses, text messages received, names of websites visited, and other performance and usage data.
      3. About Your Mobile Device. We may collect or receive information regarding:
         
         1. Type of mobile device;
         2. Operating system and version (e.g., iOS, Android, or Windows);
         3. Carrier; and
         4. Network type (Wi-Fi, 3G, 4G, LTE).
      4. From Cookies. We may use both session cookies, which expire once you close the App or Site, and persistent cookies, which stay on your mobile device until you delete them, and other technologies to help us collect data and to enhance your experience with the App or Site. Cookies are small text files an app can use to recognize a repeat visitor to the app. We may use cookies for various purposes, including:
         
         1. Type of mobile device;
         2. To personalize your experience; and
         3. To analyze which portions of the Products are visited and used most frequently.

If you do not want us to deploy cookies in the App or Site, you can opt out by setting your mobile device or web browser to reject cookies. You can still use the App or Site if you choose to disable cookies, although your ability to use some of the features may be affected.

1. Information Collected by or Through Third-Party Companies. Third-party technology providers like AWS may collect Other Information, including IP addresses, to enable us to provide the Services. These third parties may use cookies and/or other technologies to collect Other Information for such purposes. We have no control over the collection of such information by such third-party technology providers, and any such collection or use will be subject to that third party’s applicable privacy policies.
2. How Information is Used and Shared.
   
   1. You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:
      
      1. Provide and improve our Products;
      2. Provide our services, including sharing Supervised User Information with Supervisor;
      3. Prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
      4. Resist malicious, deceptive, fraudulent, or illegal actions directed at the business and the Products and to prosecute those responsible for those actions;
      5. Solicit your feedback; and
      6. Inform you about our products and services.
   2. We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
   3. In an ongoing effort to better understand our users and the Products, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the Products. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business, and other third parties. We may also disclose aggregated user statistics to describe the Products to current and prospective business partners and investors and to other third parties for other lawful purposes.
   4. We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
   5. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
   6. To the extent permitted by law, we may also disclose the Information:
      
      1. When required by law, court order, or other government or law enforcement authority or regulatory agency; or
      2. Whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
3. Do-Not-Track. We do not use technology that recognizes a “do-not-track” signal from your web browser.
4. Accessing and Modifying Information and Communication Preferences. If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional emails related to the Products (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

1. Data Retention. We generally retain your Information for three months, after which it is automatically deleted. We may retain portions of your Information indefinitely as needed for the purpose of providing the Services.
2. How We Protect Your Information. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.
3. Important Notices to Non-U.S. Residents. The Products and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Products, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.
4. App Stores; External Websites. Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The Products may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-Party Privacy Policy and TOS when visiting any other websites.

1. Children. The Products are not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 18) not use the Products. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.
2. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the App and Site. By accessing the Products after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us. If you have questions about this Privacy Policy, please email us at info@villaritogether.com with “Privacy Policy” in the subject line or mail us at the following address:

10755 Scripps Poway Parkway
Suite 382
San Diego, CA 92131