Privacy Policy

Effective Date: 18th of February, 2026

This Privacy Policy describes how your personal information is collected, used, and shared when you use the VegaX app (the “App”) developed by Awared SLU (the “Company”, “we”, “us”, or “our”).

Information We Collect

When you use our App, we may collect the following information:

1. Personal Information

• Registration Information: You provide us with your name, email address, and age when you register for an account.
• Messages: We collect and store the messages you send and receive using encryption. We retain this request history until your account is deleted.

2. Technical Information

• Usage Data: Information on how you use the App, such as your interaction with user interface elements.
• Device Information: We may collect information about the device you are using the App on, including model, operating software, and unique device identifiers.

How We Use Your Information

We use the information we collect to:

• Operate and maintain the App.
• Improve your experience by personalizing the chat interactions.
• Communicate with you about updates, security alerts, and support messages.
• Conduct research and analysis to enhance the App.

AI Features and Third-Party Data Sharing

To deliver AI-powered chat and voice responses, we work with the following enterprise AI providers. Both operate under contractual Data Processing Agreements that include strict privacy guarantees.

AI Text Generation — Google Cloud (Vertex AI)

• No Training: Google is contractually prohibited from using your data to train or improve its AI models. Google Cloud DPA
• Zero Data Retention: Your inputs and outputs are processed in-memory and are not stored by Google after the response is generated. Vertex AI Zero Data Retention Policy
• Equal Protection: The privacy protections provided by Google Cloud under our agreement are equivalent to or greater than those set out in this Privacy Policy.
• Privacy Policy: cloud.google.com/privacy

AI Voice Synthesis — ElevenLabs

• No Training: ElevenLabs is contractually prohibited from using your data to train or improve its models under our Enterprise Data Processing Agreement.
• Zero Data Retention: Your message content is processed in-memory and is not stored on ElevenLabs' servers after the voice response is generated.
• Equal Protection: The privacy protections provided by ElevenLabs under our agreement are equivalent to or greater than those set out in this Privacy Policy.
• Zero Retention Policy: ElevenLabs Zero Retention Mode

Marketing and Attribution

We track the effectiveness of our advertising campaigns to understand where our users come from.

• Provider: We use Singular (Mobile Measurement Partner) for attribution.
• Data Collected: If you consent via the iOS Tracking prompt, we collect your IDFA (Identifier for Advertisers). We also collect your IP address and device User Agent.
• Purpose: To measure ad performance and detect fraud. We do not display third-party ads within our App.
• Privacy Policy: Singular Privacy Policy

Analytics and Measurement Partners

To monitor App performance and measure marketing effectiveness, we engage the following trusted partners.

Analytics — AppMetrica by Yandex

We use AppMetrica to monitor App stability and performance. AppMetrica processes anonymous, aggregated technical data (such as device type, OS version, and session statistics) that cannot be used to identify individual users. For more information, see the AppMetrica Privacy Policy.

Advertising Measurement — Meta

We use Meta's measurement tools to evaluate the effectiveness of our marketing activities. Meta may process certain device-level signals in accordance with your consent preferences and applicable platform guidelines. For more information, see the Meta Privacy Policy.

Sharing Your Information

We may share your information with third parties in the following situations:

• Service Providers: Companies that assist us in operating the App, such as server hosting or analytics providers.
• Legal Requirements: If required by law or subpoena, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your personal information may be transferred.

Your Rights (Andorra LQPD)

Under the Qualified Law 29/2021 on Personal Data Protection (LQPD) of Andorra, you have specific rights regarding your data:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can ask us to correct inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): You can request the deletion of your data when it is no longer necessary.
• Right to Opposition: You can object to the processing of your data for specific purposes (e.g., marketing).
• Right to Limitation of Treatment: You can request that we limit the processing of your data in certain cases.
• Right to Portability: You can request to receive your data in a structured, commonly used format.

To exercise these rights, please contact us at vegax@develotex.io.

Opt-out Options

If you do not want us to process your personal information anymore, please contact us via vegax@develotex.io. Since functional data is required for the App, you may need to delete your account.

iOS Tracking Opt-out

We use the AppTrackingTransparency (ATT) framework. When you open the App, you may be asked for permission to track your activity across other companies' apps and websites.

• If you allow tracking: We collect your IDFA (Identifier for Advertisers) to measure the effectiveness of our marketing campaigns via our partner, Singular.
• If you ask App not to track: We will not collect your IDFA. Singular will still receive basic device data (IP address, User Agent) for fraud prevention and probabilistic attribution, as permitted by Apple's guidelines, but you will not be profiled for targeted advertising.

You can change your choice at any time in your device settings: Settings > Privacy > Tracking.

Requests

To submit a verifiable consumer request for access, portability, or deletion of personal data, please contact us via vegax@develotex.io

When submitting a verifiable request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, zip code, and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent, such agent must provide written authorization or a power of attorney signed by you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot:
(i) verify your identity or authority to make the request; or
(ii) confirm that the personal information relates to you.

We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third-party identity verification services, to verify your identity before taking any action with your personal information. This is a safeguard measure to prevent disclosure of your personal information under a fake or scam request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete it after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

Data Security

We take reasonable measures to protect your personal information from loss, theft, misuse, and unauthorized access. However, no method of transmission over the internet or method of electronic storage is completely secure.

Age Restriction (18+)

The App contains content intended for adults. You must be at least 18 years old to use VegaX. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal data from a minor, we will delete it immediately.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us at vegax@develotex.io