Privacy Policy

We process personal information based on:

• **Contract:** To provide the Service (e.g., early access notifications, account management).
• **Consent:** For email communications and early access sign-ups.
• **Legitimate Interests:** For analytics to improve the Service, balanced against your rights.
• **Legal Obligation:** To comply with applicable laws.

We inform you of data collection via this Privacy Policy, accessible on tryoffimo.com and in-app. Processing is fair, not detrimental, unexpected, or misleading.

We minimize data collection for specific purposes. We collect the following to provide and improve the Service:

We collect only data necessary for declared purposes. Currently, we do not collect email addresses through our website. Early access notifications are managed through the iOS App Store pre-registration system. We do not process data beyond stated purposes (e.g., no advertising use, no sale of personal information).

**Accuracy:** We ensure data accuracy through appropriate technical and organizational measures. Contact privacy@tryoffimo.com to correct inaccuracies.

**Security:** We implement industry-standard technical measures (e.g., encryption, access controls) and organizational measures to protect your data. Analytics content is processed securely through Google Analytics with appropriate safeguards. No system is fully secure; you use the Service at your own risk.

We retain personal information only as long as necessary for the purposes outlined in this policy, unless longer retention is needed for legal compliance, dispute resolution, or Service delivery. Currently, we do not collect or store email addresses through our website. Anonymized analytics data may be retained indefinitely.

We embed privacy by design via:

• Minimal data collection (currently limited to anonymized analytics only).
• User-controlled preferences through device and browser settings.
• Consent for non-essential cookies and analytics.
• Anonymized analytics with no personally identifiable content.

We maintain contracts with processors:

• **Google:** Processes anonymized analytics data via Google Analytics 4 (see Google's privacy policy at policies.google.com/privacy).

Contracts stipulate processor responsibilities, security measures, and data return/deletion upon contract end. We ensure all processors comply with applicable data protection laws including GDPR and CCPA.

You have the following rights:

• **Informed:** This Policy details our privacy practices.
• **Access:** Request a copy of your data.
• **Rectification:** Correct inaccurate records.
• **Erasure:** Delete your data (unsubscribe or request deletion).
• **Restriction:** Limit processing.
• **Portability:** Export data in a machine-readable format.
• **Object:** Oppose processing (e.g., analytics).
• **Withdraw Consent:** Withdraw consent at any time, where applicable.

**For California residents (CCPA):**

• **Right to Know:** You can request details about the personal information we collect, use, or disclose.
• **Right to Delete:** You can request deletion of your personal information, subject to exceptions.
• **Right to Opt-Out:** Offimo does not sell personal information, so no opt-out is needed.

Exercise rights via email at privacy@tryoffimo.com. We respond within one month, extending if complex. Requests may be denied if legally permitted (e.g., unverifiable identity).

Contact our DPO at privacy@tryoffimo.com for GDPR inquiries or supervisory authority interactions.

When we use third-party services, data may be transferred to countries like the US (e.g., Google Analytics). We ensure such transfers comply with GDPR/UK GDPR (e.g., via Standard Contractual Clauses) and CCPA where applicable.

If a breach risks your rights and freedoms, we notify the relevant supervisory authority within 72 hours and affected users without undue delay. Processors (e.g., Google Analytics) must notify us immediately.

We process your data based on the following legal bases: to provide the Service (contract), pursue legitimate interests (e.g., analytics), comply with legal obligations, or with your consent (e.g., email communications). Uses include:

• **Service Delivery:** Provide access to the Service through the iOS App Store.
• **Improvement:** Analyze anonymized usage patterns via Google Analytics to enhance features and user experience.
• **Communication:** Early access notifications are managed through the iOS App Store pre-registration system.
• **Compliance:** Meet legal requirements (e.g., GDPR, CCPA) or prevent harm.

We share data as follows:

The Service is not intended for users under 13. Users aged 13-15 require verifiable parental consent (privacy@tryoffimo.com). Data from children under 13 is deleted immediately if discovered.

We may update this Policy to reflect Service changes or legal requirements. Updates will be posted on offimo.com at least 7 days before taking effect, with email notices for material changes where required. Continued use after updates constitutes consent.

For privacy inquiries, email privacy@tryoffimo.com.

For EU users, you can lodge a complaint with a supervisory authority. For UK users, you can contact the Information Commissioner's Office at www.ico.org.uk. For California residents, you can contact the California Attorney General.

Under the CCPA, California residents have specific rights:

• We collect personal information (e.g., email address, device identifiers, usage patterns) for the purposes outlined above.
• We do not sell your personal information.
• In the past 12 months, we have disclosed anonymized analytics data to Google Analytics for analytics purposes.
• To exercise your CCPA rights, contact us at privacy@tryoffimo.com.