Terms of Service

This Privacy Notice for Overay Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

- Download and use our mobile application (Vtyle), or any other application of ours that links to this Privacy Notice

- Engage with us in other related ways, including any sales, marketing, or events

**Questions or concerns?** Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [vtylecontact@gmail.com](mailto:vtylecontact@gmail.com).

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us **In Short:** We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. **Personal Information Provided by You.** The personal information that 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: **Sensitive Information** We do not process sensitive information. **Payment Data** We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Overay. You may find their privacy notice link(s) here: __________ **Social Media Login Data** We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from your social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

2. HOW DO WE PROCESS YOUR INFORMATION?

**In Short:** We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. 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 Logon Process:** Including verifying your identity. - **To Post Testimonials:** With your consent, to display your feedback on our Services. - **To Manage User Accounts:** To keep your account in working order. - **To Send Administrative Information:** Such as updates, security alerts, and support messages. - **To Protect Our Services:** Including fraud prevention and monitoring for abuse. - **To Enforce Our Terms, Conditions, and Policies:** Including legal compliance. - **To Respond to Legal Requests and Prevent Harm:** Such as complying with subpoenas or preventing potential threats.

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

**In Short:** We may share information in specific situations described in this section and/or 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.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

**In Short:** We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us: - Maintain the security of our Services and your account - Prevent crashes and fix bugs - Save your preferences - Assist with basic site functions We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to: - Help manage and display advertisements - Tailor advertisements to your interests - Send abandoned shopping cart reminders (depending on your communication preferences) The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites. To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?" Specific information about how we use such technologies and how you can refuse certain cookies is set out in our **[Cookie Notice](#)**.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

**In Short:** If you choose to register or log in to our Services using a social media account, we may have access to certain information about you. Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include: - Your name - Email address - Friends list - Profile picture - Other information you choose to make public on such a social media platform We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. **Please note:** We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

**In Short:** We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either: - **Delete** or **anonymize** such information - **Securely store** your personal information and isolate it from any further processing until deletion is possible (e.g., in backup archives)

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

**In Short:** We aim to protect your personal information through a system of 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 safeguards and efforts to secure 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 hackers, cybercriminals, or other unauthorized third parties will not be able to defeat 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.

8. DO WE COLLECT INFORMATION FROM MINORS?

**In Short:** We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly: - Collect data from children under 18 - Solicit data from children under 18 - Market to children under 18 - Sell personal information of children under 18 By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. **If we learn that personal information from users less than 18 years of age has been collected,** we will: - Deactivate the account - Take reasonable measures to promptly delete such data from our records **If you become aware of any data we may have collected from children under age 18,** please contact us at [vtylecontact@gmail.com](mailto:vtylecontact@gmail.com).

9. WHAT ARE YOUR PRIVACY RIGHTS?

**In Short:** You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. ### Withdrawing your consent If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section [HOW CAN YOU CONTACT US ABOUT THIS NOTICE?](#13-how-can-you-contact-us-about-this-notice) below. **However, please note:** - This will not affect the lawfulness of the processing before its withdrawal - When applicable law allows, it will not affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent ### Account Information If you would at any time like to review or change the information in your account or terminate your account, you can: - **Log in to your account settings** and update your user account. - **Upon your request to terminate your account,** we will deactivate or delete your account and information from our active databases. **However,** we may retain some information in our files to: - Prevent fraud - Troubleshoot problems - Assist with any investigations - Enforce our legal terms and/or comply with applicable legal requirements ### 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 - Reject cookies If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. **If you have questions or comments about your privacy rights,** you may email us at [contact@vtyle.com](mailto:contact@vtyle.com).

10. 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 have data about your online browsing activities monitored and collected. At this stage, 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. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

**In Short:** If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below. ### Categories of Personal Information We Collect We have collected the following categories of personal information in the past twelve (12) months: - **A. Identifiers:** Name, email address, phone number, etc. - **B. Personal Information Categories Listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))**: Name, email address, Social Security Number, driver's license, passport, etc. - **C. Commercial Information:** Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. - **D. Biometric Information:** Genetic, physiological, behavioral, and biological characteristics. - **E. Internet or Other Similar Network Activity:** Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. - **F. Geolocation Data:** Physical location or movements. - **G. Sensory Data:** Audio, electronic, visual, thermal, olfactory, or similar information. - **H. Professional or Employment-Related Information.** - **I. Education Information.** - **J. Inferences Drawn from Other Personal Information.** **We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:** - Receiving help through our customer support channels; - Participation in customer surveys or contests; - Facilitation in the delivery of our Services and to respond to your inquiries. **We will use and retain the collected personal information as needed to:** - Provide the Services - Improve and administer our Services - Comply with legal obligations

12. DO WE MAKE UPDATES TO THIS NOTICE?

**In Short:** Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may: - **Email us:** [vtylecontact@gmail.com](mailto:vtylecontact@gmail.com) - **Contact us by post:** ``` Overay Inc. 119 Central Road, Jung-gu Daejeon 901 CEO: So Kyung-min Business Registration Number: 871-81-02641 ``` - **Customer Inquiries:** [help@vtyle.com](mailto:help@vtyle.com) - **Partnership Inquiries:** [contact@vtyle.com](mailto:contact@vtyle.com)

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

Based on the applicable laws of your country or state of residence in the US, you may have the right to: - Request access to the personal information we collect from you - Receive details about how we have processed your information - Correct inaccuracies in your personal information - Get a copy of your personal information - Delete your personal information - Withdraw your consent to our processing of 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 fill out and submit a **[data subject access request](#)**.

Child Safety Policy (Prohibition of CSAE)

Prohibited Content

Our service strictly prohibits any form of child sexual abuse and exploitation (CSAE). Any content (photos, videos, text, etc.) depicting or suggesting sexual behavior involving minors will be removed immediately, and the responsible account(s) may be suspended or banned.

Actions for Violations

Users found to be involved in or promoting child sexual abuse/exploitation may have their accounts permanently suspended without notice. In severe cases, we may report such violations to relevant law enforcement agencies.

Reporting & Inquiries

If you encounter any such content or behavior, please report it via the following email. We do not operate a separate reporting form at this time. Email: help@vtyle.com We review all reports within 24 hours and will remove offending content and take appropriate action if necessary.

Effective Date and Operator

This Child Safety Policy is established and maintained by Overay, Inc. and is effective as of January 1, 2025. For questions regarding this policy, please contact us at the Customer Support email provided above.

These terms are effective as of January 08, 2025.