At Levy, we're developing an AI-powered app to protect your online activity, and your privacy is at the core of our mission. This Privacy Policy ("Policy") outlines how Anzo Labs PTE. LTD., a company registered in Singapore ("we," "us," "our," or "Levy"), collects, uses, discloses, stores, and protects your personal data in connection with our website and Early-Bird Program (collectively, the "Services"). This Policy complies with the Personal Data Protection Act 2012 (PDPA) of Singapore and is designed to be transparent about our practices.

As Levy is not yet launched, our data collection is limited to what is necessary for the Early-Bird Program waitlist. We encourage you to read this Policy carefully. By participating in the Early-Bird Program or using our website, you consent to the collection, use, and disclosure of your personal data as described herein. If you do not agree, please do not use our Services or provide your personal data.

For questions or concerns, contact us at support@getlevy.co.

1. Scope of This Policy

This Policy applies to personal data collected when you:

Join the Levy Early-Bird Program by submitting a one-time USD $20 deposit.
Interact with our website (e.g., submitting inquiries or accessing content).
Communicate with us via email or other channels.

"Personal data" refers to any information relating to an identified or identifiable individual, as defined under the PDPA. Levy is an upcoming app designed to monitor your device screen to protect against online threats like scams and phishing. As Levy is in development and not yet operational, we do not currently collect screen data, audio, or other device-related information.

This Policy does not apply to data processed by third parties not controlled by us (e.g., Stripe's payment processing) or to data you share with others outside our Services.

2. Personal Data We Collect

During the Early-Bird Program, we collect only the following personal data:

Personal Identifiers: Your name and email address, provided when you join the waitlist.

Payment Information: Limited details (e.g., credit card type, last four digits, and expiration date) processed securely by Stripe, our third-party payment processor, when you submit the USD $20 deposit.

Communications: Information you provide when contacting us (e.g., via support@getlevy.co), such as your name, email, and the content of your message.

Cookies and Similar Technologies: We may use cookies or similar technologies to collect non-personal data, such as your browser type, device type, or website usage patterns, to improve website functionality and user experience. Cookies are small text files stored on your device. At this stage, our use of cookies is minimal and primarily for analytics or technical purposes, and we do not collect personal data through cookies unless explicitly stated.

We do not collect any other personal data, including device data, screen captures, or behavioral data, as Levy is not yet operational.

3. How We Collect Personal Data

We collect personal data in the following ways:

Directly from You: When you sign up for the Early-Bird Program by entering your name and email on our website, make a deposit via Stripe, or contact us with inquiries or support requests.

Automatically via Cookies: We may use cookies or similar technologies to collect non-personal data about your interaction with our website, such as pages visited or session duration. You can manage cookie preferences through your browser settings, though disabling cookies may affect website functionality.

We do not collect personal data from third parties or other automated sources during this pre-launch phase.

4. Purposes of Collecting and Using Personal Data

We collect and use your personal data only for the following purposes, in accordance with the PDPA:

Administering the Early-Bird Program: To process your deposit, confirm your waitlist status, and provide 12 months of free access to Levy upon launch.
Communication: To send you updates about Levy's development, launch, changes to our Terms of Service or this Policy, or refund confirmations.
Payment Processing: To facilitate your deposit and, if applicable, process refunds via Stripe.
Customer Support: To respond to your inquiries or support requests.
Website Improvement: To analyze non-personal data collected via cookies (e.g., website usage patterns) to enhance our website's functionality and user experience.
Legal and Regulatory Compliance: To comply with Singapore laws, including the PDPA, and maintain records for accounting or tax purposes.

We will not use your personal data for any other purpose without your prior consent, except as required by law (e.g., to respond to a court order).

5. Legal Basis for Processing

Under the PDPA, we process your personal data based on the following legal bases:

Consent: By joining the Early-Bird Program or submitting your data, you consent to our collection, use, and disclosure as described in this Policy.
Contractual Necessity: Processing is necessary to fulfill our obligations under the Terms of Service (e.g., processing your deposit or providing waitlist benefits).
Legal Obligations: Processing is required to comply with Singapore laws, such as tax or accounting requirements.
Legitimate Interests: We may process data to improve our Services or communicate program updates, provided this does not override your rights and freedoms.

You may withdraw your consent at any time (see Section 7).

6. Consent and Your Rights to Withdraw

By providing your personal data, you consent to its collection, use, and disclosure as outlined in this Policy. You may withdraw your consent at any time by:

Emailing support@getlevy.co to request removal from the waitlist and a refund of your deposit, as described in our Terms of Service.

Upon withdrawal, we will cease processing your personal data and delete it from our records within 7 business days, except where retention is required by law (e.g., for tax purposes).

Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

7. Your Rights Under the PDPA

As a data subject under the PDPA, you have the following rights:

Access: Request details about the personal data we hold about you and how it is processed.
Correction: Request correction of inaccurate or incomplete personal data.
Withdrawal of Consent: Withdraw consent for processing, as described in Section 6.
Complaints: Raise concerns about our data handling practices with us or the Personal Data Protection Commission (PDPC) of Singapore.

To exercise these rights, email support@getlevy.co with your request, including your full name and email address. We will respond within 30 days, as required by the PDPA. If we cannot fulfill your request (e.g., due to legal obligations), we will explain why.

8. Disclosure of Personal Data

We do not share your personal data with third parties except in the following limited circumstances:

Stripe: Your payment details are processed by Stripe, our third-party payment processor, in accordance with their Privacy Policy (https://stripe.com/privacy) and Terms of Service (https://stripe.com/legal). We do not store your full payment details, such as credit card numbers.

Legal Requirements: We may disclose personal data to comply with Singapore laws, regulations, or legal processes (e.g., court orders or government requests).

Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to a successor entity, subject to equivalent or stronger privacy protections and PDPA compliance.

We do not sell, rent, or share your personal data for marketing purposes or with any other third parties without your consent.

9. Data Security

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

Encryption: Using secure, encrypted connections (e.g., HTTPS) for data transmission on our website and via Stripe.
Access Controls: Limiting access to your personal data to authorized personnel who require it to perform their duties.
Secure Storage: Storing personal data on servers with industry-standard security protocols, hosted in compliance with PDPA requirements.

While we strive to protect your personal data, no system is 100% secure. We cannot guarantee absolute security against unauthorized access or breaches. If you suspect any security issues, contact us immediately at support@getlevy.co.

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in Section 4 or to comply with legal obligations:

Waitlist Participants: Your name, email, and payment details are retained until Levy launches, you withdraw from the waitlist, or we terminate the Early-Bird Program.

Refunds or Withdrawal: If you request a refund or withdraw consent, we will delete your personal data within 7 business days, except for limited payment records required for accounting or tax purposes (retained for up to 7 years under Singapore law).

Non-Delivery: If Levy does not launch, we will delete all personal data after processing refunds, subject to legal retention requirements.

When personal data is no longer needed, we securely delete or anonymize it to prevent unauthorized use.

11. International Data Transfers

Your personal data is primarily stored and processed in Singapore, in compliance with the PDPA. However, as Stripe operates globally, your payment details may be processed in jurisdictions outside Singapore (e.g., the United States). Stripe complies with applicable data protection laws, including the EU-US Data Privacy Framework, to ensure adequate protection. We ensure that any international transfers meet PDPA requirements, such as obtaining your consent or ensuring equivalent safeguards.

If you are located outside Singapore, you acknowledge that your personal data may be transferred to and processed in Singapore or other jurisdictions as described above.

12. Third-Party Services

Our Services integrate with Stripe for payment processing. Stripe's handling of your payment details is governed by their Privacy Policy (https://stripe.com/privacy). We are not responsible for the privacy practices of Stripe or other third-party websites linked from our Services. We encourage you to review their policies before providing data.

Our website may contain links to external sites not controlled by us. We are not responsible for their privacy practices or content.

13. Future Data Practices

Upon Levy's launch, the app will operate locally on your device to monitor your screen for online threats, minimizing data collection and enhancing privacy. We will update this Policy before launch to address additional data processing activities (e.g., screen monitoring) and obtain your consent as required by the PDPA. You will be notified of these changes via email or our website.

14. Updates to This Policy

We may update this Policy to reflect changes in our practices, legal requirements, or the development of Levy. Material changes will be communicated via email or by posting an updated Policy on our website at least 7 days before they take effect. Your continued use of our Services or participation in the Early-Bird Program after such changes constitutes acceptance of the updated Policy. If you do not agree, you may withdraw from the waitlist as described in Section 6.

15. Contact Us

For questions, concerns, or requests regarding your personal data or this Policy, please contact our Data Protection Officer via email at support@getlevy.co

We will respond to your inquiries within 30 days, as required by the PDPA. You may also lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore if you believe we have mishandled your personal data.

17. Governing Law

This Policy is governed by the laws of Singapore, in accordance with the PDPA. Any disputes arising from this Policy will be resolved through binding arbitration in Singapore, as outlined in our Terms of Service, unless otherwise required by law.

Thank you for trusting Levy with your personal data. We're committed to protecting your privacy while building a safer internet for you.