VIM — Privacy Policy

1. Overview

This Privacy Policy explains how VIM AD DYNAMICS LLC and its affiliates ("VIM", "we", "us", or "our") collect, use, disclose and protect personal data when you access or use our websites, mobile applications, APIs and other services (collectively, the "Services"). It also explains your rights and choices regarding your personal data.

By using the Services you consent to the collection and processing described in this policy. If you do not agree, do not use the Services.

2. Data We Collect

We collect the following categories of information:

2.1 Information you provide

• Account information: name, email address, phone number, username, password.
• Profile data: profile photo, cover image, biography, birthdate, location, education, work information.
• Content you create: posts, comments, messages, stories, videos, images, and other materials you upload.
• Payment and payout information: bank account or payment provider details, tax identifiers, billing address (required for wallet payouts and monetization).
• Verification documents: identity documents, corporate documents (e.g., for CNPJ or corporate account verification) submitted for KYC/AML.

2.2 Information we collect automatically

• Usage data: pages visited, features used, timestamps, search queries, content interactions (views, likes, comments).
• Device and connection data: device identifiers, operating system, browser, IP address, mobile carrier, language, time zone.
• Analytics and performance data: crash reports, performance metrics, and aggregated engagement statistics.

2.3 Information from third parties

• Social login providers: when you sign in with third-party services (e.g., Facebook), we may receive profile information and authorization tokens from those providers.
• Third-party services: payment processors, advertising partners, analytics providers, and identity verification vendors may provide data to us.

2.4 Aggregated and de-identified data

We may aggregate or de-identify personal data for analytics, research and product improvement. Aggregated or de-identified data is not personal data and may be used without restriction.

3. How We Use Personal Data

We use personal data for the following purposes:

• Provide and operate the Services: create and manage accounts, deliver content, enable social interactions, and provide customer support.
• Monetization and payments: manage points, wallets, payouts, billing, tax reporting and fraud prevention.
• Security and integrity: detect and prevent abuse, fraud, and other harmful activity; enforce our Terms of Use.
• Personalization: personalize content, recommendations, and advertising (where permitted).
• Analytics and product improvement: measure usage, improve features, and develop new products.
• Legal and compliance: comply with legal obligations, respond to lawful requests, and protect rights and property.

4. Legal Bases for Processing (where applicable)

Depending on your jurisdiction, we rely on one or more of the following legal bases to process personal data:

• Performance of a contract: to provide the Services you request (e.g., account management, payouts).
• Consent: where you have given consent for specific processing activities (e.g., marketing communications, personalized ads).
• Legitimate interests: for fraud prevention, security, product improvement and direct communications, balanced against your rights and interests.
• Legal obligation: to comply with laws, tax reporting and regulatory requirements.

5. Sharing and Disclosure

We may share personal data with the following categories of recipients:

• Service providers: payment processors, hosting providers, analytics and monitoring services, identity verification vendors, and other vendors who perform services on our behalf.
• Advertising and measurement partners: ad networks and measurement providers to serve and measure ads (subject to your choices and applicable law).
• Affiliates and subsidiaries: for internal business purposes and centralized operations.
• Legal and safety: to comply with legal obligations, respond to lawful requests, enforce our Terms, or protect rights, property or safety.
• Business transfers: in connection with a merger, acquisition, reorganization or sale of assets; we will notify users where required by law.

5.1 Third-party content and links

The Services may contain links to third-party websites and services. We are not responsible for the privacy practices of those third parties. Review their privacy policies before providing personal data.

6. Cookies and Tracking Technologies

We and our partners use cookies, web beacons, SDKs and similar technologies to collect information about your activity and device. These technologies enable essential site functions, analytics, personalization and advertising.

You can manage cookie preferences through your browser settings and, where provided, our in-app controls. Disabling certain cookies may affect functionality.

7. Security

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration and destruction. Measures include encryption in transit (TLS), access controls, monitoring and secure development practices.

However, no system is completely secure. You should protect your account credentials and notify us immediately of any unauthorized access.

8. Data Retention

We retain personal data as long as necessary to provide the Services, comply with legal obligations, resolve disputes and enforce agreements. Retention periods vary by data type and purpose; we apply deletion or anonymization when data is no longer needed.

9. Your Rights and Choices

Subject to local law, you may have rights including:

• Access: request access to personal data we hold about you.
• Correction: request correction of inaccurate or incomplete data.
• Deletion: request deletion of your personal data (subject to exceptions).
• Portability: request a copy of your data in a structured, machine-readable format.
• Restriction/Objection: request restriction of processing or object to certain processing (e.g., direct marketing).
• Withdraw consent: where processing is based on consent, you may withdraw consent at any time.

To exercise rights, contact us at the address below. We may require verification and will respond within applicable legal timeframes.

10. International Data Transfers

VIM operates globally. Personal data may be transferred to, stored and processed in the United States, Brazil and other countries where our service providers operate. When we transfer data across borders we implement safeguards such as standard contractual clauses, data processing agreements and other measures required by applicable law.

11. Children

The Services are not directed to children under the age required by local law to form a binding contract. We do not knowingly collect personal data from children without parental consent. If we learn that we have collected personal data from a child without appropriate consent, we will take steps to delete the data.

12. Privacy Considerations for Points, Wallet and Monetization

Because the Services include a points and wallet system, additional processing may occur:

• Transaction records: we store earning events, redemptions, payout requests and related metadata for fraud prevention, accounting and regulatory compliance.
• KYC/AML: payout requests require identity verification and may require submission of government IDs, corporate documents (for entities such as CNPJ), and tax information. These documents are processed securely and retained as required by law.
• Fraud detection: we analyze behavioral and device signals to detect abuse; this may include automated profiling for risk scoring. You have the right to request information about automated decisions where applicable by law.

13. Advertising and Personalization

We may show ads from third-party advertisers. With your consent where required, we and our partners may use data to deliver personalized ads. You can opt out of personalized advertising through in-app settings or by following opt-out mechanisms provided by advertising partners.

14. Legal Requests and Law Enforcement

We may disclose personal data in response to lawful requests by public authorities, to comply with legal obligations, to protect rights and property, or to