Privacy Policy

1. INTRODUCTION

This Privacy Policy ("Policy") describes how Forevle B.V. ("Forevle," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use our website at forevle.com, our mobile applications, and our interactive story platform (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Services.

This Policy should be read together with our Terms of Service, which govern your use of the Services.

2. WHO WE ARE

Forevle B.V. is a private limited liability company organized under the laws of the Netherlands, with its registered office in Amsterdam. For the purposes of data protection law, Forevle B.V. is the "data controller" of your personal information.

Contact Information:

Forevle B.V. Amsterdam, The Netherlands Email: [email protected]

3. INFORMATION WE COLLECT

We collect information in the following ways:

3.1 Information You Provide Directly

(a) Account Information

When you create an account, we collect: - Username - Email address (via third-party authentication services) - First and last name (if provided by your authentication service, such as Google)

(b) Profile Information

You may choose to provide additional information, such as: - Profile photo (imported from third-party services like Google or Gravatar) - Other optional profile details you choose to add

(c) Content You Create

When you use the Services, we collect: - Stories, scenarios, and other creative content you create - Text inputs and prompts you provide to our AI systems - Character descriptions, plot outlines, and narrative content - Choices and interactions within interactive stories - Tags, titles, and descriptions you assign to content

(d) Communications

When you contact us, we collect: - Support requests and correspondence - Feedback and suggestions - Any other information you choose to provide

(e) Payment Information

When you make purchases, our payment service providers collect: - Payment card details - Billing address - Transaction information

Note: We do not directly store your payment card details. This information is collected and processed by our third-party payment service providers (such as Stripe) in accordance with their own privacy policies and PCI-DSS standards.

3.2 Information Collected Automatically

When you use the Services, we automatically collect:

(a) Device and Technical Information - Device type and model - Operating system and version - Browser type and version - Screen resolution - Device identifiers - Language preferences

(b) Usage Information - Pages and features you access - Stories you play and create - Time spent on the Services - Clicks, scrolls, and navigation paths - Features you use and actions you take - Session duration and frequency - Referring URLs and exit pages

(c) Location Information - Country determined from your IP address - General geographic region

We use this information to determine your approximate location for purposes including content localization, compliance with regional laws, and analytics.

(d) Log Data - IP address - Access times and dates - Error logs and performance data - API requests and responses

3.3 Information from Third Parties

(a) Authentication Services

If you sign in using a third-party service (such as Google), we receive: - Your name (if provided by the service) - Email address - Profile photo (if available) - Unique identifier from that service

(b) Analytics Providers

We receive aggregated and individual analytics data from services like Google Analytics and Microsoft Clarity, including information about how users interact with our Services.

4. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

4.1 Providing and Operating the Services

• •Creating and managing your account
• •Processing your transactions and subscriptions
• •Generating AI-powered content based on your inputs
• •Storing and displaying your created content
• •Enabling you to play interactive stories
• •Providing customer support

4.2 Improving and Developing the Services

• •Analyzing usage patterns and trends
• •Understanding how users interact with features
• •Identifying and fixing bugs and errors
• •Developing new features and functionality
• •Conducting research and analytics

4.3 AI Systems and Content Processing

• •Processing your inputs through AI Systems to generate content (visuals, dialogue, interactive elements)
• •Analyzing AI inputs and outputs for safety, content moderation, and quality assurance
• •Aggregated and anonymized analysis to understand usage patterns and improve the Services

We do not use your content to train AI models. Any future AI training program will be opt-in only and subject to the terms described in our Terms of Service and AI Disclosure.

4.4 Content Moderation and Safety

• •Monitoring content for violations of our Terms of Service and Creator Guidelines
• •Detecting and preventing illegal content, including content that may exploit minors
• •Identifying attempts to create content depicting real persons without authorization
• •Enforcing content ratings and age restrictions
• •Protecting the safety and integrity of the Platform

4.5 Personalization

• •Customizing your experience based on your preferences and usage
• •Recommending stories and content based on your interests
• •Tailoring features and functionality based on your location or demographics
• •Providing targeted content and features to specific user segments

4.6 Communications

• •Sending transactional emails (account verification, password resets, purchase receipts)
• •Responding to your inquiries and support requests
• •Sending service-related announcements and updates
• •With your consent, sending marketing and promotional communications

4.7 Security and Fraud Prevention

• •Protecting against unauthorized access to accounts
• •Detecting and preventing fraud, abuse, and malicious activity
• •Enforcing our Terms of Service
• •Protecting the rights, property, and safety of Forevle and our users

4.8 Legal Compliance

• •Complying with applicable laws, regulations, and legal processes
• •Responding to lawful requests from public authorities
• •Establishing, exercising, or defending legal claims

4.9 Advertising

• •Displaying advertisements on the Services
• •Measuring the effectiveness of advertising campaigns
• •With appropriate consent, delivering targeted advertising based on your interests and behavior

5. LEGAL BASES FOR PROCESSING (EEA/UK USERS)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal data based on the following legal grounds:

5.1 Performance of Contract

We process data necessary to provide you with the Services, including: - Account creation and management - Processing transactions - Providing AI-generated content - Storing your created content - Customer support

5.2 Legitimate Interests

We process data based on our legitimate interests, where those interests are not overridden by your rights, including: - Improving and developing the Services - Analytics and research - Content moderation and safety - Security and fraud prevention - Personalization of the Services

5.3 Consent

We process certain data based on your consent, including: - Marketing communications - Non-essential cookies (analytics and advertising) - Any other processing where we have specifically requested your consent

You may withdraw your consent at any time, which will not affect the lawfulness of processing before withdrawal.

5.4 Legal Obligation

We process data as necessary to comply with legal obligations, including: - Tax and financial reporting requirements - Responding to valid legal requests - Compliance with content moderation laws (such as the Digital Services Act)

6. COOKIES AND TRACKING TECHNOLOGIES

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. We use cookies and similar technologies (such as pixels, local storage, and scripts) to operate, secure, and improve the Services.

6.2 Types of Cookies We Use

(a) Essential Cookies

These cookies are necessary for the Services to function and cannot be disabled. They include: - Authentication cookies (keeping you logged in) - Security cookies (protecting against fraud) - Session management cookies - Load balancing cookies

(b) Analytics Cookies

These cookies help us understand how users interact with the Services. We use: - Google Analytics – to analyze website traffic and usage patterns - Microsoft Clarity – to understand user behavior through session recordings and heatmaps - Other analytics tools as implemented from time to time

These cookies collect information such as pages visited, time on site, click patterns, and navigation paths.

(c) Advertising Cookies

These cookies are used to deliver relevant advertisements and measure their effectiveness. They may be set by us or by third-party advertising partners and may track your activity across different websites.

6.3 Cookie Consent

When you first visit our Services, you will be presented with a cookie consent banner that allows you to: - Accept all cookies - Reject non-essential cookies - Customize your cookie preferences

Essential cookies cannot be disabled as they are necessary for the Services to function.

Analytics and advertising cookies require your consent before being placed on your device. You can change your cookie preferences at any time through the cookie settings link in the footer of our website.

6.4 Do Not Track

Some browsers offer a "Do Not Track" (DNT) setting. We currently do not respond to DNT signals, as there is no industry standard for how to interpret these signals. However, you can manage your cookie preferences through our cookie consent tool.

7. HOW WE SHARE YOUR INFORMATION

We may share your information in the following circumstances:

7.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including: - Payment processors (such as Stripe) for transaction processing - Cloud hosting providers for data storage and computing - Analytics providers (such as Google Analytics, Microsoft Clarity) for usage analysis - AI service providers for content generation and processing - Email service providers for transactional and marketing communications - Customer support tools for managing inquiries - Content delivery networks for performance optimization

These providers are contractually obligated to use your information only for the purposes of providing services to us and in accordance with this Policy.

7.2 AI Service Providers

To provide AI-powered features, we may share your inputs (such as story prompts, text, and character descriptions) with third-party AI service providers. These providers process your data solely to generate content for you and are bound by confidentiality and data protection obligations.

7.3 Other Users

Certain information may be visible to other users of the Services: - Your username and profile photo (if provided) - Stories and content you publish publicly - Your activity on public leaderboards or rankings (if applicable) - Comments or interactions on public content (if such features are available)

You control whether your content is private, unlisted, or public through the visibility settings in the Services.

7.4 Legal Requirements

We may disclose your information if required to do so by law or in response to: - Valid legal process (court orders, subpoenas, warrants) - Requests from law enforcement or government authorities - To protect the rights, property, or safety of Forevle, our users, or others - To detect, prevent, or address fraud, security, or technical issues

7.5 Business Transfers

If Forevle is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

7.6 With Your Consent

We may share your information for other purposes with your consent or at your direction.

7.7 Aggregated and Anonymized Data

We may share aggregated or anonymized data that cannot reasonably be used to identify you for any purpose, including research, analytics, and business purposes.

8. INTERNATIONAL DATA TRANSFERS

8.1 Where We Store Data

Forevle is based in the Netherlands, but we use service providers located in various countries, including the United States. As a result, your personal data may be transferred to and processed in countries outside of your country of residence, including countries that may not provide the same level of data protection as your home country.

The majority of our data is stored in the United States.

8.2 Safeguards for International Transfers

When we transfer personal data from the EEA, UK, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, we implement appropriate safeguards, including:

• •Standard Contractual Clauses (SCCs) approved by the European Commission
• •Data Processing Agreements with our service providers
• •Additional technical and organizational measures where appropriate

8.3 EU-U.S. Data Privacy Framework

Where applicable, we may rely on service providers that have certified their compliance with the EU-U.S. Data Privacy Framework for transfers to the United States.

9. DATA RETENTION

9.1 General Retention Principles

We retain your personal data for as long as necessary to: - Provide you with the Services - Comply with our legal obligations - Resolve disputes and enforce our agreements - Maintain the integrity and security of the Platform

9.2 Account Data

We retain your account data for as long as your account is active. If you request deletion of your account, we will process your request as described below.

9.3 Content Data

Content you create on the Platform is retained for as long as your Account is active. Upon Account deletion, content is handled as described in Section 9.6 below.

9.4 Transaction Records

We retain payment and transaction records for as long as required by applicable tax and financial reporting laws, which may be seven (7) years or longer depending on jurisdiction.

9.5 Log and Analytics Data

Server logs and analytics data are retained for periods appropriate to their purpose, typically ranging from ninety (90) days to two (2) years.

9.6 Account Deletion

When you request deletion of your Account:

(a) Retention Period: We retain your Account data for ninety (90) days following your deletion request to allow for account recovery and to address any pending issues.

(b) After 90 Days: Your personal data will be deleted, except as described below.

(c) What May Be Retained:

• •Data required by applicable law or legal process (e.g., transaction records for tax compliance)
• •Data necessary to enforce our Terms or protect our legal rights
• •Backup copies for a reasonable period as part of normal backup procedures

(d) Published Content: Content you published publicly that has been played by other users or incorporated into shared experiences presents a technical challenge. We will remove your personal identifiers (username, profile information) and attribute such content to "Deleted User." The underlying content may remain accessible to preserve the integrity of other users' experiences that depend on it. If you require complete removal of specific published content, contact us at [email protected] and we will assess on a case-by-case basis.

For more information, see Section 17.15 of our Terms of Service.

9.7 Post-Deletion Retention Period

Following an account deletion request, we retain identifiable account data for ninety (90) days to allow for account recovery and to address any pending issues. After this period, the anonymization process is completed.

10. YOUR RIGHTS AND CHOICES

10.1 Rights for All Users

Regardless of your location, you have the following choices:

(a) Account Information - You can access and update your account information through your account settings - You can request deletion of your account by contacting [email protected]

(b) Communications - You can opt out of marketing emails by clicking the "unsubscribe" link in any marketing email - You cannot opt out of transactional emails necessary for your use of the Services

(c) Cookies - You can manage your cookie preferences through our cookie consent tool - You can configure your browser to reject cookies (though this may affect functionality)

(d) Content Visibility - You can control whether your content is private, unlisted, or public

10.2 Rights for EEA/UK Users

If you are located in the EEA, UK, or Switzerland, you have additional rights under data protection law:

(a) Right of Access You have the right to request a copy of the personal data we hold about you.

(b) Right to Rectification You have the right to request correction of inaccurate or incomplete personal data.

(c) Right to Erasure ("Right to be Forgotten") You have the right to request deletion of your personal data in certain circumstances. Please note that this right is subject to limitations, including our need to retain anonymized data for platform integrity and certain data for legal compliance.

(d) Right to Restriction of Processing You have the right to request that we restrict processing of your personal data in certain circumstances.

(e) Right to Data Portability You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.

(f) Right to Object You have the right to object to processing of your personal data based on legitimate interests. We will cease processing unless we have compelling legitimate grounds that override your interests.

(g) Rights Related to Automated Decision-Making You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects, subject to certain exceptions.

(h) Right to Withdraw Consent Where processing is based on consent, you have the right to withdraw consent at any time.

10.3 Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframes required by applicable law (generally within one month for GDPR requests).

We may need to verify your identity before processing your request. If we cannot verify your identity, we may request additional information.

10.4 Complaints

If you are located in the EEA or UK and believe we have violated your data protection rights, you have the right to lodge a complaint with your local data protection supervisory authority. For users in the Netherlands, this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority).

11. SECURITY

11.1 Security Measures

We implement technical and organizational measures designed to protect your personal data, including:

• •Encryption of data in transit using TLS/SSL
• •Encryption of sensitive data at rest
• •Access controls limiting who can access personal data
• •Regular security assessments and monitoring
• •Employee training on data protection and security

11.2 No Guarantee

While we take reasonable measures to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data.

11.3 Your Responsibilities

You are responsible for: - Maintaining the confidentiality of your account credentials - Using strong, unique passwords - Notifying us immediately of any unauthorized access to your account

12. CHILDREN'S PRIVACY

12.1 Account Requirements

You must be at least eighteen (18) years old to create an Account on Forevle. We do not permit minors to create their own accounts, and we do not knowingly collect personal information directly from minors for account creation purposes.

12.2 Minor Access Through Parent Accounts

As described in our Terms of Service, parents or legal guardians may permit minors under their supervision to access the Services through the parent's Account. In such cases:

• •The Account remains the parent's Account, and all data is associated with the parent
• •The parent is responsible for the minor's use and any content created
• •The parent has agreed to our Terms of Service on behalf of the minor

We do not create separate profiles or collect separate personal information for minors using a parent's Account.

12.3 Unauthorized Minor Accounts

If we discover that a minor has created their own Account (not through authorized parent access), we will take steps to delete that Account and associated personal data promptly.

If you believe a minor has created an unauthorized Account, please contact us immediately at [email protected].

13. THIRD-PARTY LINKS AND SERVICES

The Services may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access.

We are not responsible for the privacy practices or content of third-party services.

14. 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.

How We Notify You: - We will post the updated Policy on this page with a new "Last Updated" date - For material changes, we may provide additional notice, such as email notification or a prominent notice within the Services

Your Continued Use: Your continued use of the Services after any changes to this Policy constitutes your acceptance of the updated Policy. If you do not agree with any changes, you should stop using the Services.

15. CONTACT US

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

Forevle B.V. Amsterdam, The Netherlands Email: [email protected]

We aim to respond to all inquiries within a reasonable timeframe.

16. ADDITIONAL INFORMATION FOR EEA/UK USERS

16.1 Data Controller

Forevle B.V. is the data controller responsible for your personal data. Our contact details are provided in Section 15.

16.2 Data Protection Contact

For data protection inquiries, please contact our privacy team at [email protected].

16.3 Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law. The lead supervisory authority for Forevle is:

Autoriteit Persoonsgegevens (Dutch Data Protection Authority) Postbus 93374 2509 AJ Den Haag The Netherlands Website: https://autoriteitpersoonsgegevens.nl

You may also contact the supervisory authority in your country of residence.

16.4 Necessity of Processing

Provision of certain personal data (such as email address and username) is necessary to create an account and use the Services. If you do not provide this information, you will not be able to use the Services.

17. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

17.1 California Consumer Privacy Act (CCPA)

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

(a) Right to Know You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collection, and the categories of third parties with whom we share it.

(b) Right to Delete You have the right to request deletion of your personal information, subject to certain exceptions.

(c) Right to Correct You have the right to request correction of inaccurate personal information.

(d) Right to Opt-Out of Sale/Sharing You have the right to opt out of the "sale" or "sharing" of your personal information for targeted advertising purposes.

(e) Right to Non-Discrimination We will not discriminate against you for exercising your privacy rights.

17.2 Categories of Information

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

17.3 Sale and Sharing of Personal Information

We may share personal information with advertising partners in ways that could be considered a "sale" or "sharing" under California law. You can opt out of this by adjusting your cookie preferences or contacting us at [email protected].

17.4 Exercising Your Rights

To exercise your California privacy rights, please contact us at [email protected]. We will verify your identity before processing your request.