Privacy Policy

1. Responsible Entity

Prezly (operated by A. Jegatheeswaran)
Switzerland
Email: info@prezly.app

This privacy policy explains how we collect, use, and protect your personal data in accordance with the Swiss Federal Act on Data Protection (nDSG/DSG).

2. Scope

This privacy policy applies to the Prezly mobile application (iOS and Android) and all associated services.

3. Data We Collect

We collect the following categories of personal data:

• Account data: Email address, display name
• Partner profiles: Name, preferences, occasions you create
• Product data: Products, gift ideas, photos you save
• Usage data: AI feature usage counts, app language preference
• Subscription data: Subscription status, purchase history (via Apple/Google)
• Technical data: Device type, app version (no tracking IDs)

4. Purpose of Processing

We process your data for the following purposes:

• Account management and authentication
• Core app features (gift curation, partner profiles, occasions)
• AI-powered suggestions (via Google Gemini API)
• Subscription management (via RevenueCat)
• Push notifications (if enabled)
• App improvement and error monitoring

5. Third-Party Services

We use the following third-party services:

• Google Firebase (Firestore, Auth, Cloud Storage) — Data center: Zurich, Switzerland
• Google Gemini API — AI-powered gift suggestions
• RevenueCat — Subscription and purchase management
• Apple App Store / Google Play Store — App distribution and payments

6. International Data Transfers

Your primary data is stored in Google Cloud Firestore in the Zurich (europe-west6) region. Some processing (e.g., AI features, subscription management) may involve data transfer to the United States, protected under the EU-U.S. Data Privacy Framework (DPF) and standard contractual clauses.

7. Data Retention

• Account and app data: Retained until you delete your account
• Subscription records: Retained for 10 years after expiration as required by Swiss law (OR Art. 958f)
• Upon account deletion, all personal data is permanently removed from our systems

8. Your Rights

Under the Swiss Data Protection Act, you have the following rights:

• Right of access (Art. 25 nDSG): Request information about your stored data
• Right to rectification (Art. 32 nDSG): Correct inaccurate data
• Right to deletion: Request deletion of your data via the app
• Right to data portability (Art. 28 nDSG): Receive your data in a portable format
• Right to withdraw consent: Revoke consent at any time
• Right to lodge a complaint: File a complaint with the FDPIC (see below)

9. Data Security

We protect your data with the following measures:

• All data transmitted via TLS encryption
• Firestore data encrypted at rest (AES-256)
• Firebase Security Rules restrict access to authenticated users only
• No data sharing with third parties for advertising purposes

10. Contact & Supervisory Authority

For questions about this privacy policy or to exercise your rights:

Email: info@prezly.app