mEUvy - Legal Documentation

PRIVACY POLICY

Last Updated: April 25, 2025

1. INTRODUCTION

1.1. Our Commitment to Your Privacy: At mEUvy (“we,” “our,” or “us”), operated by Vaic.at B.V., we are fundamentally committed to protecting your privacy. Our approach is built around the principle of data minimization and processing data only where and when necessary. The most defining aspect of our privacy posture is that all personal data you provide within the App remains entirely on your device and never leaves your device, touching neither our servers nor any third-party servers.

1.2. Applicability: This Privacy Policy explains how we handle (or, more accurately, how the App handles on your device) your personal information when you use our mobile application (the “App”). It should be read in conjunction with our Terms of Service, Disclaimer of Liability, Cookie Policy, Accessibility Statement, and Data Security Practices, which collectively govern your use of the App.

1.3. Legal Basis and Compliance: We design and operate the App in adherence to the principles of data protection, including data minimization, purpose limitation, transparency, and user control, as required by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable privacy laws. The legal basis for processing the data you provide within the App is your explicit consent (as described in Section 5) and the necessity for the performance of a contract with you (the Terms of Service) to provide the personalized features you request through the App’s local processing functionality.

1.4. Purpose of this Policy: This Privacy Policy aims to provide you with clear, comprehensive, and transparent information about: * The types of information you may voluntarily provide within the App. * Our stringent data collection practices (and, importantly, our deliberate non-collection practices). * How your information is used, processed, and stored locally on your device. * The security measures implemented to protect your data on your device. * How long your data is retained (under your control). * Your rights under applicable data protection laws and how you can exercise them locally within the App. * How you provide and withdraw your consent for local processing. * Why certain common privacy concerns (like international data transfers or third-party sharing) are not applicable to mEUvy.

We encourage you to read this Privacy Policy carefully to understand our unique approach to handling your information.

2. INFORMATION WE COLLECT (AND THE DATA WE EXPLICITLY DO NOT COLLECT)

2.1. Data You Provide Voluntarily: When you use certain features of the App, you may choose to provide personal information to enable personalized comparisons and insights. This data is provided by you directly into the App’s local storage interface. The categories of information you may choose to provide include: * Location Preferences: Specific cities or regions within the EU you are interested in comparing or considering for relocation. * Financial Information:Details such as your current or expected salary, income brackets, tax filing status, employment type, and potentially other income sources relevant for tax estimation. * Personal Economic Factors: Estimates or typical figures for your monthly expenditures across various categories (e.g., housing costs like rent or mortgage, transportation, food, utilities, entertainment, personal care, clothing) and other discretionary spending patterns. * Lifestyle Preferences: Information about your desired social activities, cultural interests, preferred climate, importance of certain amenities, desired commute times, and general quality of life priorities. * Family Circumstances: Data related to your household size, number of dependents, their ages, and specific needs such as educational requirements (e.g., schooling costs, availability). * Professional Details: Information about your industry, job title, work location preferences (e.g., remote, in-office, hybrid), and specific job requirements that might impact location choice.

This data is provided by you explicitly to receive tailored results from the App's comparison tools. It is considered personal data as it relates to an identifiable individual, but crucially, **this data is processed and stored only locally on your device.**

2.2. Data We Absolutely Do Not Collect Automatically or Transmit: In line with our core privacy principle, mEUvy is designed not to collect personal data from your device automatically and not to transmit any user data off your device. We want to be unequivocally clear about what we do not do: * No Analytics or Tracking: We do not integrate or use any third-party analytics Software Development Kits (SDKs) or tracking libraries (e.g., Google Analytics, Firebase Analytics, Mixpanel, etc.). We do not track your usage behavior beyond facilitating the core functionality on your device. * No Advertising Identifiers: We do not collect, store, or use mobile advertising identifiers (like Apple’s IDFA or Android’s AAID). * No Device Fingerprinting: We do not employ techniques to uniquely identify your device for tracking purposes (device fingerprinting). * No Server-Side Logging: We do not operate servers that log your activity within the App, the data you input, or how you use the features. * No Cookies or Similar Tracking Technologies (Server-Side):As detailed in our Cookie Policy, since the App is a mobile application and does not involve web Browse interacting with our servers for user data, we do not use HTTP cookies or similar server-side tracking technologies. * No Automatic Data Transmission: There is no functionality built into the App to automatically transmit your personal data, preferences, or usage statistics to our servers or any external endpoint. * No Creation of User Profiles on Our Side: Because we do not receive your data, we cannot and do not create profiles of our users, track their behavior across sessions or devices, or segment them for any purpose.

All processing that involves your personal data is executed within a closed environment on your device, with no outbound connections for data transmission related to your personal input or usage.

2.3. Technical Device Information (Processed Locally): For the essential functioning and display of the App, we may access and store basic technical configuration data locally on your device. This information is necessary for the App to render correctly and function optimally on your specific hardware and software environment. This information may include: * Device screen size and resolution. * Device operating system version. * System language settings. * Current time zone setting.

This technical information:
* Remains stored exclusively on your device.
* Is used solely to enable the App to adapt its interface and functionality to your device.
* Is never transmitted to our servers or any third parties.
* Is automatically deleted from the App's local storage when you uninstall the App.

3. HOW WE USE YOUR INFORMATION (LOCAL PROCESSING ONLY)

3.1. Purpose Limitation – All Processing On-Device: The information you voluntarily enter into the App is used solely for the following specific and limited purposes, all of which are executed entirely on your device: * Personalized City Comparisons: To generate comparisons between selected cities based on your provided location preferences and other factors. * Income and Tax Estimations: To calculate potential net income in different locations by applying estimated tax rates and social contributions based on the financial and professional data you provide and the reference data available to the App. * Cost of Living and Housing Affordability Analysis: To estimate living costs and assess housing affordability in your preferred cities using your expenditure data and the App’s reference data. * Quality of Life and Lifestyle Insights: To provide context and insights into quality of life factors based on your lifestyle preferences and the available city data. * Informing Relocation Decisions: To act as a tool to help you visualize potential lifestyle changes and make more informed personal decisions about potential relocation within the EU, based on the localized comparisons and calculations. * Local Personalization: To sort, filter, and prioritize information presented within the App based on your stored preferences and input data, enhancing your in-app experience. * Local Analytics (If consented): If you choose to enable the local analytics permission, limited, anonymized local usage insights may be processed on your device only to help improve the user interface and performance on your device. This data is never transmitted externally.

**No data processing related to your personal information occurs on our servers.**

3.2. Strictly No Secondary Uses: We uphold a strict policy against using your personal data for any purposes beyond the core functionality of providing you with localized city comparisons and insights. We absolutely do not: * Use your data for marketing, advertising, or promotional purposes. * Share, sell, rent, trade, or otherwise provide your information to third parties (e.g., advertisers, data brokers, other companies). * Create user profiles or conduct behavioral analytics on our servers, as we do not receive your data. * Aggregate or anonymize your personal data for any purpose on our side, as we do not have access to it. * Monetize your information in any way.

4. DATA STORAGE, SECURITY, AND RETENTION

4.1. Local Storage Only – Under Your Control: * Primary Location: All personal information, preferences, and any comparisons or data summaries you save within the App remain stored locally on the internal storage of your mobile device (e.g., phone or tablet). * No Backend Database: Vaic.at B.V. maintains no central backend database that collects, stores, or processes user-specific data entered into the mEUvy App. * No Cross-Device Synchronization: Your data is not synchronized or accessible across multiple devices, nor is it accessible via a web interface, as it exists only on the device where it was entered. * No Cloud Backups Facilitated by Us: We do not perform or facilitate automatic cloud backups of the personal data stored by the App to services like iCloud or Google Drive. Any cloud backup of your device is managed solely by you through your device’s operating system settings and is outside of our control.

4.2. On-Device Data Security Measures: While we never receive your data, we recognize the importance of protecting it while it resides on your device. We have implemented the following security measures within the App, as further detailed in our Data Security Practices: * Local Encryption: Sensitive personal data stored within the App’s local storage is encrypted using industry-standard encryption algorithms (e.g., AES-256). Encryption keys are managed securely, often leveraging your device’s secure enclave or equivalent hardware-backed storage where available. * Secure Storage Mechanisms: We utilize secure local storage APIs and mechanisms provided by the device’s operating system to store encrypted data, aiming to prevent unauthorized access by other applications on the device where possible. * Memory Management: We employ practices to clear sensitive information from device memory when it is no longer actively needed for immediate processing. * Secure Coding Practices: Our development team follows secure coding guidelines and conducts security reviews to minimize vulnerabilities within the App itself. * Application Integrity: App releases are digitally signed, and measures like code obfuscation and tamper detection are used to help ensure the integrity of the installed application. * Third-Party Component Vetting: We carefully select and vet any third-party libraries used in the App for security vulnerabilities and restrict those with unnecessary permissions or tracking capabilities.

This "no-server" architecture inherently eliminates many traditional data security risks associated with centralized data collection and storage, such as remote database breaches or man-in-the-middle attacks on data transmission to a server.

4.3. Data Retention – Controlled by You: Since all your personal data is stored locally on your device: * You, as the user, have complete control over the retention period of your data. * You can delete specific data points or perform a complete data reset at any time using the in-app functions provided. * Uninstalling the App from your device will permanently remove all data associated with the App from your device’s local storage. * We recommend periodically reviewing and updating the information you have stored within the App to ensure its accuracy and relevance to you.

5. USER CONTROLS AND CONSENT MECHANISMS

5.1. Granular Data Control – Affecting Local Processing: The App provides you with detailed controls over your experience and the local processing of your data through various preference settings: * Analytics Permission (Local Only): A toggle to enable or disable the processing of anonymized local usage insights on your device. This data never leaves your device and is used only to identify potential improvements for the user interface and performance within your App instance. * Personalization Permission: A toggle to enable or disable the use of your provided preferences (like location interests, lifestyle factors) for sorting, filtering, and ranking city comparison results locally on your device. * Storage Permission: Controls over what types of information the App is permitted to store locally for future use. * Data Retention Settings: Options to set automatic data expiration timeframes for certain types of locally stored data.

All these preference settings are stored locally on your device and directly influence how the App processes data *on your device*. They do not affect any server-side processes, as none exist for user data.

5.2. Explicit Consent for Local Processing: Your explicit and informed consent is required before you can access and use the App’s core comparison features that involve the processing of personal data you provide. Our consent process is designed to be transparent and ensure you understand how your data is handled (locally): * Presentation: You are presented with this Privacy Policy and the Terms of Service in a clear, accessible format. * Requirement to Review: You are typically required to scroll through the full text of the legal content to ensure you have the opportunity to read it. * Affirmative Action: You must provide explicit agreement through an affirmative action, such as checking a clearly labeled consent box or clicking an “I Agree” button. * Local Record: A timestamped record of your consent is stored locally within the App on your device. * Version Tracking: The App tracks which version of the Privacy Policy and Terms of Service you have consented to.

By providing consent, you are agreeing to the local processing of the data you input within the App for the purposes described in Section 3.1.

5.3. Withdrawal of Consent: You may withdraw your consent at any time. Withdrawing consent will stop future processing of your data for the specific purpose to which the consent related (e.g., personalization). You can withdraw consent by: * Toggling off specific granular permission settings within the App. * Using the “Reset All Data” function within the App, which deletes all stored personal data. * Uninstalling the App from your device, which permanently removes all associated data and implicitly withdraws all consent.

Withdrawing consent affects future processing but does not invalidate processing that occurred based on consent given before withdrawal.

5.4. Policy Updates and Re-Consent: When we make updates to this Privacy Policy or other relevant Policies: * You will be notified within the App upon launching it after an update. * Material changes to the Policy (e.g., significant changes in how data is handled, if our architecture ever changed to involve server processing – a hypothetical) will require you to review and provide renewed explicit consent to the updated Policy before you can continue using the App’s features that rely on processing personal data. * A summary of the key changes may be provided to help you understand the updates. * Previous versions of the Policy may remain accessible within the App for your reference.

6. YOUR RIGHTS UNDER GDPR AND OTHER PRIVACY LAWS

Even though we do not collect or store your personal data on our servers, the App is designed to respect and facilitate the exercise of your rights under the GDPR and other applicable data protection laws concerning the data processed locally on your device. Because we do not hold your data, exercising these rights involves interacting directly with the data stored on your device through the App’s interface, rather than requiring us to perform actions on your behalf on a remote server.

6.1. Right to Access (GDPR Article 15): You have the right to obtain confirmation as to whether personal data concerning you is being processed and, where that is the case, access to the personal data. In mEUvy, you can access a comprehensive overview of the personal data you have entered and which is stored locally by navigating to the App’s “My Data” or similar section, which displays the information in a structured format.

6.2. Right to Rectification (GDPR Article 16): You have the right to obtain the rectification of inaccurate personal data and to have incomplete personal data completed. You can correct or update any information you have provided directly through the App’s edit or input functions for each data point.

6.3. Right to Erasure (“Right to be Forgotten”) (GDPR Article 17): You have the right to the erasure of personal data concerning you without undue delay. You can exercise this right by deleting specific data points or by using the “Reset All Data” or “Clear All Data” function within the App, which permanently removes all personal data stored by the App from your device. Uninstalling the App also achieves this.

6.4. Right to Restriction of Processing (GDPR Article 18): You have the right to obtain restriction of processing. You can restrict the local processing of certain data categories by using the granular permission settings (Section 5.1) or by temporarily disabling specific features within the App without necessarily deleting the associated data.

6.5. Right to Data Portability (GDPR Article 20): You have the right to receive the personal data concerning you in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller.The App provides an export function that allows you to export the data you have entered in a common format directly from your device.

6.5.1. Overview of Your Data Portability Right: In accordance with the GDPR Article 20 and other applicable privacy laws, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit this data to another controller without hindrance. mEUvy fully supports this right through comprehensive export functionality built directly into the App.

Unlike traditional online services where you must submit a data portability request to the service provider, mEUvy’s local-only architecture means you can exercise this right immediately and independently at any time, without waiting for our response or processing.

6.5.2. Available Export Formats: The App provides multiple export format options to ensure maximum compatibility and usefulness of your exported data:

JSON Format (.json): A structured, machine-readable format ideal for importing into other applications or systems. This format preserves the hierarchical structure of your data and is widely supported across platforms and applications.
Comma-Separated Values (.csv): A simple tabular format that can be opened with spreadsheet applications (e.g., Microsoft Excel, Google Sheets) or imported into many database and analysis systems. Your data is organized into columns and rows with appropriate headers.
Plain Text Format (.txt): A human-readable format that presents your data in a clearly organized structure with appropriate labeling and formatting for easy reading.
PDF Format (.pdf): A document format that preserves the visual presentation of your data, suitable for archiving or sharing. The exported PDF includes formatting to make the data easily readable and is organized into logical sections.

6.5.3. Data Categories Included in Exports: A complete data export from mEUvy includes all categories of personal data you have voluntarily provided within the App:

Location Preferences: Your selected cities or regions of interest within the EU.
Financial Information: Any income, salary, tax, or other financial details you have entered.
Personal Economic Factors: Expenditure information across various categories you have provided.
Lifestyle Preferences: Your indicated preferences regarding social activities, cultural interests, climate preferences, etc.
Family Circumstances: Information about household size, dependents, and related needs you have entered.
Professional Details: Industry, job title, work location preferences, and other professional information you have provided.
Saved Comparisons and Results: Any comparison results or insights you have saved within the App.
App Settings and Preferences: Your personalization settings, display preferences, and other App-specific settings.
Consent Records: Timestamps and versions of policies you have consented to (without any server-side verification, as all consent is managed locally).

6.5.4. How to Access and Use Data Export Functionality:

The data export function is designed to be intuitive and accessible:

Access the Export Function: Navigate to the “Settings” or “My Data” section within the App, where you will find the “Export My Data” or similarly labeled function.
Select Export Format: Choose your preferred format from the available options (JSON, CSV, TXT, PDF).
Select Data Categories (Optional): If you prefer, you can choose to export only specific categories of data rather than a complete export.
Initiate Export: Tap the “Export” button to generate the export file.
Save or Share: The App will generate the export file locally on your device and prompt you to save it to your device’s storage or share it using any available sharing method (e.g., email, cloud storage, messaging apps).

The entire export process occurs locally on your device, with no data transmission to our servers or any third parties during this process.

6.5.5. Security Considerations for Exported Data

When exporting your data, please be mindful of the following security considerations:

Exported Files Are Not Encrypted: While data is encrypted within the App’s local storage (as detailed in our Data Security Practices), exported files are not automatically encrypted. If your exported data contains sensitive information, we recommend storing it securely or encrypting it using appropriate tools on your device.
Sharing Considerations: If you choose to share your exported data via email, messaging, or cloud storage, be aware that these transmission or storage methods may not be secure. Consider the sensitivity of your data before sharing it through these channels.
Device Security: Exported files stored on your device are subject to your device’s security measures. We recommend maintaining strong device security (passcode, biometric protection) and considering secure deletion of export files when they are no longer needed.

6.5.6. Importing Data into Other Services:

The structured formats provided (particularly JSON and CSV) are designed to facilitate importing your data into other applications or services, should you wish to do so. However, please note that:

The compatibility of exported data with other services depends on those services’ import capabilities and data structures.
We cannot guarantee that all third-party services will be able to interpret or use the exported data effectively.
Some manual adjustments may be required when importing your data into specific services due to differences in data models or requirements.

6.5.7. Data Portability Limitations

While we strive to provide comprehensive data portability, there are some inherent limitations:

Reference Data: The App’s reference data (e.g., statistical information about cities, tax rates, economic indicators) is not included in personal data exports, as this is not personal data you have provided.
Derived Insights: Complex derived insights or calculations may not be fully portable to other services due to the proprietary nature of the underlying algorithms and models.
Format-Specific Limitations: Some data structures may be simplified when exported to certain formats (particularly CSV), due to the inherent limitations of those formats in representing complex hierarchical data.

6.6. Right to Object (GDPR Article 21): You have the right to object to processing based on legitimate interests or public interest. While our primary legal basis is consent, where processing is based on other principles (like local analytics, if enabled), you can object through the granular permission settings.

6.7. Right Not to be Subject to Automated Decision-Making (GDPR Article 22): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. While the App uses algorithms to perform calculations and comparisons, these processes: * Occur solely on your device. * Are based directly on the data you provided and the reference data youaccessed locally. * Do not involve automated decision-making by us that produces legal or similarly significant effects for you. The App provides information for your decision-making process, rather than making a decision for you or about you remotely. You control the input and interpretation of the output.

How to Exercise Your Rights: As explained above, because your data is local, you exercise these rights directly through the App’s user interface and your device’s capabilities. You do not need to submit a request to Vaic.at B.V. for access, rectification, erasure, restriction, or portability of the personal data stored within the App on your device.

7. CHILDREN’S PRIVACY

The mEUvy App is not directed to individuals under the age of 16. We do not knowingly collect or solicit personal information from anyone under 16 years of age. If we become aware that a person under 16 has provided personal information within the App, and we were to somehow gain access to it (which is not our design), we would take immediate steps to delete such information. If you believe that we might have information from a child under 16 (e.g., if such data was included in an anonymized local analytical insight that you consented to share and we somehow accessed it), please contact us immediately using the details in Section 9.

8. INTERNATIONAL DATA TRANSFERS

A key benefit of mEUvy’s local-first architecture is that no international transfers of your personal data occur. Your personal data remains on your device, which is under your physical control, regardless of your geographical location. Therefore, cross-border data protection concerns related to transferring your data to different jurisdictions or outside the EU are not applicable to the data you input and process locally within the App. Local data protection laws of your current location may apply to the data stored on your device.

9. DATA PROTECTION OFFICER AND CONTACT INFORMATION

Even though our architecture means we do not act as a data controller or processor of your personal data on our servers, we take our privacy responsibilities seriously. We have appointed a Data Protection Officer (DPO) to oversee our privacy practices, provide guidance on data protection matters related to the App’s design, and serve as a point of contact for questions regarding this Privacy Policy and data protection principles.

Data Protection Officer: Email: dpo@vaicat.com

For general inquiries, support, or other matters not related to privacy or data protection, please contact us at: Email: support@vaicat.com

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices (if our fundamental architecture were to change, which is not planned), technological advancements, legal requirements, or to clarify our existing commitments. When we make changes:

TERMS OF SERVICE

Last Updated: April 25, 2025

1. ACCEPTANCE OF TERMS

1.1. Binding Agreement: By downloading, installing, accessing, or using the mEUvy mobile application (the “App”), you are creating a legally binding contract between you and Vaic.at B.V. (“we,” “our,” or “us”), the owner and operator of mEUvy. You acknowledge that you have read, understood, and agree to be bound by these Terms of Service (“Terms”), our Privacy Policy, Disclaimer of Liability, Cookie Policy, Accessibility Statement, Data Security Practices, and any other policies or guidelines we may post within the App or on our website from time to time (collectively, the “Policies”). These Terms and the Policies constitute the entire agreement between you and us regarding your use of the App.

1.2. Affirmative Consent: Your agreement to these Terms is manifested by taking an affirmative action, such as clicking an “I Accept,” “Agree,” “Continue,” or similar button or checkbox presented to you within the App. If you do not agree to these Terms and the Policies, you must not use the App and should uninstall it immediately.

1.3. Updates to Terms: We reserve the right, at our sole discretion, to modify or replace these Terms and the Policies at any time. We will provide notice of material changes as described in Section 12 below. By continuing to access or use the App after any revisions become effective, you agree to be bound by the revised Terms and Policies. If you do not agree to the new Terms or Policies, you must stop using the App.

2. DESCRIPTION OF SERVICE

2.1. Purpose and Nature of the Service: mEUvy is designed as an informational and educational tool to assist users in exploring and comparing potential relocation opportunities within the European Union. Its primary function is to provide data-driven insights based on user-provided preferences and publicly available data sources. The App facilitates personalized comparisons related to income, taxes, cost of living, quality of life factors, housing, employment, and social considerations across various EU cities.

2.2. Local Processing Only: A fundamental characteristic of mEUvy is its privacy-centric architecture. All user-provided personal data and preferences remain stored and processed exclusively on your local device. The App does not transmit this personal data to our servers or any third parties. This design principle significantly differentiates mEUvy and impacts how the service operates and your rights are exercised (as further detailed in our Privacy Policy and Data Security Practices).

2.3. Not Professional Advice: IMPORTANT DISCLAIMER: The information, data, calculations, estimates (including tax and cost of living), comparisons, and insights provided by mEUvy are for general informational and educational purposes only. They are based on statistical averages, available data, and algorithms, and may not reflect your specific personal circumstances, financial situation, legal status, or current market conditions. mEUvy does not provide, and should not be considered a substitute for, professional advice of any kind, including but not limited to financial, tax, legal, immigration, career, real estate, healthcare, or social service advice. You should always consult with qualified professionals and verify critical information from official sources before making any significant life decisions, especially those related to relocation, finances, or legal matters.

2.4. Data Sources and Limitations: The App utilizes data from various public and private third-party sources (e.g., governmental statistics, economic research, public databases). While we strive to use reputable sources, we cannot guarantee the absolute accuracy, completeness, timeliness, or reliability of this data. Economic conditions, laws, regulations, and market prices can change rapidly. Calculations are often based on averages and generalized models, which may not account for all relevant variables or reflect individual situations. You acknowledge and accept these inherent limitations of the data and calculations provided by the App. (See Section 8 and our full Disclaimer of Liability for more details).

3. USER ELIGIBILITY AND DEVICE REQUIREMENTS

3.1. Age Requirement: You must be at least eighteen (18) years of age to use the App. By using the App, you represent and warrant that you meet this age requirement.

3.2. Local Legal Compliance: You are solely responsible for ensuring that your access to and use of the App complies with all applicable laws, regulations, and treaties in your current country of residence and any country you are considering relocating to. We do not warrant that the App or its content is appropriate or available for use in any particular location.

3.3. Device Compatibility and Requirements: Use of the App requires a compatible mobile device (smartphone or tablet) with a supported operating system (iOS or Android), sufficient storage space for local data storage, and potentially an internet connection for initial download, updates, and accessing external links (though core functionality is designed for offline use with locally stored data). You are responsible for obtaining and maintaining the necessary device, software, and connectivity.

3.4. Single-Device Use: Due to the local nature of data storage, your personalized data and settings are tied to the specific device on which you use the App. There is no automatic cross-device synchronization or cloud backup service provided by mEUvy.

4. USER CONDUCT AND RESPONSIBILITIES

4.1. Acceptable Use: You agree to use the App only for its intended purpose as a personal, non-commercial informational tool for exploring relocation options within the EU. Your use must be lawful, ethical, and in compliance with these Terms and all applicable laws.

4.2. Prohibited Activities: You agree not to use the App for any purpose that is unlawful or prohibited by these Terms, or to engage in any conduct that could damage, disable, overburden, or impair the App, or interfere with any other party’s use and enjoyment of the App. Prohibited activities include, but are not limited to: (a) Using the App for any illegal or unauthorized purpose. (b) Reverse engineering, decompiling, disassembling, or attempting to derive the source code of the App, except to the extent permitted by mandatory applicable law. (c) Modifying, adapting, translating, or creating derivative works based on the App. (d) Removing, circumventing, disabling, damaging, or otherwise interfering with security-related features or features that enforce limitations on use of the App. (e) Distributing, copying, renting, leasing, selling, exporting, importing, or otherwise exploiting the App or its content without explicit authorization. (f) Using automated means, bots, spiders, scrapers, or similar data gathering and extraction tools to access or interact with the App. (g) Attempting to gain unauthorized access to any part of the App or our systems. (h) Introducing malware, viruses, worms, or other harmful material into the App or our systems. (i) Engaging in any activity that disrupts or overloads our infrastructure, even if no personal data is involved. (j) Impersonating any person or entity, or falsely stating or otherwise misrepresenting your affiliation with a person or entity. (k) Providing false, inaccurate, or misleading information within the App (though user-provided data is for local processing only, accuracy is necessary for meaningful results). (l) Using the App in a manner that infringes upon the intellectual property rights of Vaic.at B.V. or any third party.

4.3. User Provided Information: While your personal data remains on your device, you are responsible for the accuracy, legality, and completeness of any information you voluntarily choose to provide within the App for comparison and personalization purposes (e.g., financial details, lifestyle preferences). You understand that the quality of the App’s output depends on the information you input.

5. INTELLECTUAL PROPERTY RIGHTS

5.1. Ownership: All rights, title, and interest in and to the mEUvy App, including all software, algorithms, data compilation (excluding your personal input data), design, graphics, interfaces, features, functionality, documentation, and all related intellectual property rights (including copyrights, trademarks, patents, and trade secrets) are and shall remain the exclusive property of Vaic.at B.V. or its licensors. This includes the “mEUvy” name, logo, and any other trademarks or service marks associated with the App.

5.2. Limited License: Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to download, install, and use the App solely for your personal, non-commercial use on a single device owned or controlled by you, strictly in accordance with these Terms and the accompanying documentation. This license does not grant you any right to: (a) Copy, modify, or create derivative works of the App or its content. (b) Distribute, sublicense, lease, rent, or lend the App to any third party. (c) Use the App for any commercial purpose or for the benefit of any third party. (d) Make the functionality of the App available to multiple users through any means. (e) Use any automated means to access or use the App.

5.3. User Data Ownership: You retain ownership of the personal data and preferences that you voluntarily input into the App. However, you acknowledge that this data is stored and processed locally on your device only, and we do not access, collect, store, or control this data on our servers.

5.4. Feedback: If you provide us with any feedback, suggestions, comments, bug reports, or ideas regarding the App or our services (“Feedback”), you agree that we may use such Feedback for any purpose, including improving the App or developing new products and services, without any obligation to compensate you or credit you. You grant us an unlimited, perpetual, irrevocable, non-exclusive, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, display, perform, and create derivative works of your Feedback.

6. PRIVACY AND DATA PROTECTION

6.1. Core Principle: Local Data Processing: Your privacy is paramount. As stated in our Privacy Policy, the core principle of mEUvy is that all personal data you provide or that is processed for personalization remains entirely on your device and never touches our servers. We do not collect, store, transmit, or have access to your personal data.

6.2. Comprehensive Privacy Policy: Our detailed Privacy Policy explains the types of information you may provide within the App, our strict data non-collection practices (no analytics, no tracking, no server-side logging), how your information is used locally on your device, how it is stored and protected on your device, your rights under applicable data protection laws (such as GDPR), and how you can control your data and provide/withdraw consent.

6.3. Consent: By agreeing to these Terms, you also acknowledge and agree to the practices described in our Privacy Policy. Explicit consent mechanisms for data processing within the App are handled locally on your device as described in the Privacy Policy.

6.4. Data Security: While we do not handle your data on our servers, we have implemented security measures to protect the data residing on your device, as detailed in our Data Security Practices document. These measures include local encryption and secure coding practices.

6.5. No International Data Transfers: Because your personal data remains on your device, no international transfers of your personal data occur in connection with your use of the App.

6.6. Children’s Privacy: The App is not intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16.

7. DATA STORAGE, SECURITY, AND USER CONTROL

7.1. Local Device Storage: All personal data, preferences, and saved comparisons you create within the App are stored locally on the storage of your mobile device.

7.2. No Cloud Storage or Synchronization: We do not provide or facilitate cloud storage, backup, or synchronization of your personal data across devices. Your data exists only on the device(s) where you input it.

7.3. On-Device Security: We employ technical and organizational measures to help protect the data stored locally on your device, including local encryption and secure storage practices, as outlined in our Data Security Practices document. However, the overall security of your data on your device is also dependent on your device’s security settings and practices.

7.4. User Control and Deletion: You have full control over the data stored locally within the App. As described in the Privacy Policy, you can access, modify, or delete your data at any time using the in-app functions. Uninstalling the App will permanently remove all associated data stored by the App from your device.

7.5. Data Retention: Since data is stored locally, you control its retention period. Data is deleted when you uninstall the App or use the in-app deletion features.

8. DISCLAIMER OF WARRANTIES AND ACCURACY

8.1. “As Is” and “As Available”: THE APP IS PROVIDED “AS IS” AND “AS AVAILABLE,” WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VAIC.AT B.V. ON ITS OWN BEHALF AND ON BEHALF OF ITS AFFILIATES AND ITS AND THEIR RESPECTIVE LICENSORS AND SERVICE PROVIDERS, EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR otherwise, WITH RESPECT TO THE APP, INCLUDING ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND WARRANTIES THAT MAY ARISE OUT OF COURSE OF DEALING, COURSE OF PERFORMANCE, USAGE, OR TRADE PRACTICE.

8.2. No Warranties Regarding Accuracy or Reliability: Without limiting the foregoing, we provide no warranty or undertaking, and make no representation of any kind that the App will meet your requirements, achieve any intended results, be compatible, or work with any other software, applications, systems, or services, operate without interruption, meet any performance or reliability standards, or be error-free, or that any errors or defects can or will be corrected.

8.3. Specific Disclaimers regarding Content and Data: (a) Informational Nature: We specifically reiterate that the App provides informational content only. It is not professional advice. (b) Data Accuracy and Timeliness: We disclaim all warranties regarding the accuracy, completeness, timeliness, currency, reliability, or usefulness of any data, information, calculations, estimates (including tax and cost of living), comparisons, or content provided through the App. (c) Third-Party Data Sources: Data is derived from third-party sources whose accuracy we cannot guarantee. (d) Estimation and Averaging: Calculations and estimates are based on averages and models and may not reflect actual costs, taxes, or conditions applicable to your specific situation or location. (e) Regional Variations: City-level data may not capture granular differences within a city (e.g., neighborhood variations). (f) No Guarantees: We make no guarantees about the outcomes of decisions made using the App’s information.

8.4. Device and Data Responsibility: You acknowledge that the App’s proper function, data availability, and data security are dependent on your device, its operating system, storage capacity, and your personal security practices. We are not responsible for issues arising from your device.

8.5. Jurisdictional Limitations: Some jurisdictions do not allow the exclusion of or limitations on implied warranties or the limitations on the applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to you.

9. LIMITATION OF LIABILITY

9.1. Exclusive Risk: YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR USE OF THE APP IS AT YOUR SOLE RISK.

9.2. Exclusion of Damages: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL VAIC.AT B.V., ITS AFFILIATES, OR ANY OF ITS OR THEIR RESPECTIVE LICENSORS OR SERVICE PROVIDERS, BE LIABLE FOR ANY: (a) Direct, indirect, punitive, incidental, special, consequential, or exemplary damages. (b) Damages for loss of profits, revenue, business, savings, data, goodwill, or other intangible losses. (c) Damages for damage to your device, equipment, software, or data. (d) Damages for personal injury, pain and suffering, or emotional distress. (e) Damages arising out of or in any way connected with your access to or use of, or inability to access or use, the App. (f) Damages arising from any decisions or actions you take or fail to take based on information provided by the App, including relocation decisions, financial decisions, or career choices. (g) Damages arising from the accuracy, completeness, reliability, or timeliness of the App’s content or data. (h) Damages arising from any security breaches or data loss occurring on your local device. (i) Damages arising from third-party content or links accessed through the App.

9.3. Basis of the Bargain: You acknowledge and agree that the disclaimers, limitations of liability, and exclusions of damages set forth in these Terms are fundamental elements of the basis of the bargain between you and Vaic.at B.V., and that Vaic.at B.V. would not be able to provide the App to you without such limitations.

9.4. Jurisdictional Limitations: Some jurisdictions do not allow the exclusion or limitation of liability for certain damages, so some or all of the above limitations and exclusions may not apply to you.

10. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Vaic.at B.V., its affiliates, licensors, and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors, and assigns from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to: (a) Your violation of these Terms or any of the Policies. (b) Your use of the App, including, but not limited to, your use of the App’s content, data, or services other than as expressly authorized in these Terms. (c) Any decisions or actions you take based on information obtained from the App. (d) Your violation of any applicable law or the rights of any third party.

11. GOVERNING LAW AND DISPUTE RESOLUTION

11.1. Governing Law: These Terms and your use of the App shall be governed by and construed in accordance with the laws of the Netherlands, without giving effect to any choice or conflict of law provision or rule.

11.2. Dispute Resolution: Any legal suit, action, or proceeding arising out of or relating to these Terms or the App shall be instituted exclusively in the competent courts of Amsterdam, the Netherlands, unless mandatory consumer protection laws in your country of residence provide you with the right to bring proceedings in that jurisdiction. By using the App, you waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

11.3. EU Consumer Online Dispute Resolution: If you are a consumer residing in the European Union, you may have the option to resolve disputes with us out of court through the European Commission’s Online Dispute Resolution (ODR) platform. You can access the ODR platform at http://ec.europa.eu/consumers/odr/.

12. CHANGES TO TERMS AND POLICIES

We may update these Terms and the Policies (including the Privacy Policy, Disclaimer, etc.) from time to time. (a) Notification: We will notify you of material changes by posting the updated Terms/Policy within the App or through other reasonable means (e.g., a notification upon opening the App). (b) Material Changes: What constitutes a material change will be determined at our sole discretion, but may include changes to the core functionality of the App, how data is handled (if our architecture ever changed to involve server-side processing, which is not currently planned), or significant changes to your rights or obligations. (c) Continued Use: By continuing to use the App after the effective date of the revised Terms or Policies, you agree to be bound by the revised version. If you do not agree to the changes, you must stop using the App and uninstall it. (d) Access to Previous Versions: Previous versions of the Terms and Policies may be made available within the App or upon request.

13. TERMINATION

13.1. Termination by You: You may terminate your agreement with us at any time by uninstalling the App from your device. Upon uninstallation, your data stored locally by the App will be permanently removed.

13.2. Termination by Us: We may terminate or suspend your access to the App immediately, without prior notice or liability, for any reason, including but not limited to: (a) If you breach these Terms or any of the Policies. (b) If you violate any applicable law in connection with your use of the App. (c) If we discontinue the App or any part of it. (d) For any other reason we deem necessary or appropriate in our sole discretion.

13.3. Effect of Termination: Upon termination, your right to use the App will immediately cease. All provisions of these Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity, limitations of liability, and governing law.

14. THIRD-PARTY CONTENT AND LINKS

The App may display or link to content, data, resources, or services provided by third parties. We do not endorse and are not responsible for the accuracy, availability, or reliability of any such third-party content or links. Your interaction with any third-party website or service linked from the App is solely between you and the third party, and is subject to their terms and policies. We are not liable for any damage or loss caused by your use of or reliance on any third-party content, goods, or services.

15. ACCESSIBILITY

We are committed to making mEUvy accessible to people with disabilities. We strive to conform to WCAG 2.1 Level AA standards. Our Accessibility Statement, available within the App and referenced by these Terms, details the accessibility features implemented and known limitations. We welcome your feedback on accessibility issues to help us improve.

16. SEVERABILITY

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court or other tribunal of competent jurisdiction, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms will continue in full force and effect.

17. WAIVER

Except as otherwise set forth in these Terms, the failure to exercise or enforce any right or provision of these Terms will not constitute a waiver of future exercise or enforcement of that right or provision. The waiver of any right or provision will be effective only if in writing and signed by a duly authorized representative of Vaic.at B.V..

18. ENTIRE AGREEMENT

These Terms, together with the Privacy Policy, Disclaimer of Liability, Cookie Policy, Accessibility Statement, Data Security Practices, and any other Policies referenced herein, constitute the sole and entire agreement between you and Vaic.at B.V. regarding the App and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding the App.

19. CONTACT INFORMATION

If you have any questions about these Terms or the App, please contact us:

Email: legal@vaicat.com

For privacy-related inquiries, please refer to the contact information in our Privacy Policy. For security concerns, please refer to the contact information in our Data Security Practices. For accessibility feedback, please refer to the contact information in our Accessibility Statement.

DISCLAIMER OF LIABILITY

Last Updated: April 25, 2025

1. CRITICAL IMPORTANCE OF THIS DISCLAIMER

Please read this Disclaimer of Liability (“Disclaimer”) carefully before using the mEUvy application (the “App”). This Disclaimer is a critical part of the Terms of Service and other Policies governing your use of the App. By accessing, using, or relying on the App or any information provided through it, you acknowledge that you have read, understood, and agree to be bound by the terms of this Disclaimer. If you do not agree with any part of this Disclaimer, you must not use the App.

2. INFORMATIONAL AND EDUCATIONAL NATURE OF CONTENT

2.1. Strictly for Information: All content, data, calculations, estimates, comparisons, features, and information provided or made available through the mEUvy App are furnished solely for educational, informational, and illustrative purposes. The App is designed as a tool to assist users in exploring and understanding potential comparative aspects of different European locations based on user input and available public data. As outlined in our Terms of Service, the App is not a comprehensive advisory service or a substitute for thorough, independent research.

2.2. No Warranty of Accuracy or Completeness: While we endeavor to use reputable data sources and employ sound algorithms for comparisons and estimates, we do not warrant or guarantee the accuracy, completeness, timeliness, currency, reliability, or usefulness of any information provided through the App. Data changes rapidly, sources may have limitations, and calculations are often based on statistical averages and generalized models.

2.3. Independent Verification Required: You are solely responsible for independently verifying the accuracy and relevance of any information obtained from the App, particularly before making any decisions or taking any actions based on such information. Reliance on the App’s content is solely at your own risk.

3. NOT A SUBSTITUTE FOR PROFESSIONAL ADVICE

3.1. No Professional Expertise Provided: mEUvy explicitly does not provide, and the information within the App should never be considered a substitute for, professional advice across various critical domains. This includes, but is not limited to: * Financial or Tax Advice: We do not provide financial planning, investment, tax preparation, or specific tax advice applicable to your individual circumstances in any jurisdiction. Tax laws are complex and vary significantly. * Legal or Immigration Counsel: We do not provide legal advice related to immigration, visas, residency permits, citizenship, employment contracts, property law, or any other legal matters in any country. * Career or Employment Services: We do not provide professional career counseling, job placement services, or advice on specific employment opportunities. * Real Estate or Housing Advice: We do not provide real estate appraisals, property investment advice, or specific guidance on housing markets beyond generalized cost comparisons. * Healthcare or Social Services Guidance:We do not provide advice on healthcare systems, insurance, social security benefits, or access to social services in any location.

3.2. Seek Qualified Counsel: You should always consult with qualified, licensed professionals (e.g., financial advisors, accountants, lawyers, immigration consultants, real estate agents, career counselors) who are familiar with your specific situation and the relevant laws and regulations in the jurisdictions you are considering, before making any decisions.

4. LIMITATIONS OF DATA, CALCULATIONS, AND SCOPE

4.1. Potential for Inaccuracies and Outdatedness: Information presented in the App, derived from various sources (as referenced in the Terms of Service), is subject to becoming inaccurate or outdated due to: * Rapid economic fluctuations, market changes, and inflation. * Changes in local, regional, or national laws, tax codes, and regulations. * Variations in currency exchange rates. * Dynamic housing and labor market conditions. * Political developments or unforeseen events affecting socio-economic factors.

4.2. Average-Based Estimates: Many calculations and comparisons rely on statistical averages, aggregated data, and generalized models. These estimates: * May not accurately reflect your individual income, spending habits, or specific circumstances. * Cannot account for personal preferences or unique requirements. * Represent typical scenarios that may differ significantly from your actual situation. * Are approximations and should not be treated as precise figures.

4.3. Regional and Local Variations: While the App provides city-level data, it may not fully capture granular variations: * Neighborhood-specific differences in costs (e.g., rent, services). * Variations in the quality, type, or availability of housing or amenities for the same price point. * Micro-level factors affecting quality of life that are not quantifiable or universally applicable.

4.4. Temporal and Scope Limitations: Information may vary based on the time of year, current economic cycles, or specific legislative changes not yet reflected in available data. The App’s scope is limited to the data sources and cities included, and it may not cover all locations or all factors relevant to your decision.

5. USER’S SOLE RESPONSIBILITY AND ASSUMPTION OF RISK

5.1. Ultimate Responsibility: You acknowledge and agree that you are solely and exclusively responsible for any and all decisions you make, actions you take, or outcomes that result from your use of the App or your reliance on any information provided through the App. This includes, but is not limited to, decisions regarding relocation, finances, career changes, housing, or any other life choices.

5.2. Assumption of All Risks: By using the App, you expressly understand and agree that you assume all risksassociated with the use of the App, its content, and any decisions made in reliance on the information provided. This includes the risk of inaccurate data, flawed calculations, outdated information, and the failure to seek professional advice.

5.3. No Guarantees of Outcomes: We make absolutely no guarantees, promises, or warranties about the outcomes or success of any decisions you make using the App’s information. The App is a tool to explore possibilities; it does not predict or guarantee future results.

6. DISCLAIMER OF WARRANTIES

6.1. “AS IS” and “AS AVAILABLE”: THE APP AND ALL CONTENT, DATA, CALCULATIONS, ESTIMATES, AND INFORMATION PROVIDED THROUGH IT ARE FURNISHED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITH ALL FAULTS AND DEFECTS, AND WITHOUT WARRANTIES OF ANY KIND.

6.2. No Express or Implied Warranties: To the maximum extent permitted by applicable law, Vaic.at B.V. disclaims all warranties, conditions, and representations, whether express, implied, statutory, or otherwise, including, but not limited to: * Implied warranties of merchantability, fitness for a particular purpose, accuracy, title, and non-infringement. * Warranties that may arise out of course of dealing, course of performance, usage, or trade practice. * Warranties regarding the uninterrupted, error-free, or secure operation of the App. * Warranties regarding the accuracy, completeness, or reliability of any information, data, calculations, or estimates. * Warranties regarding the compatibility of the App with your device, operating system, or other software. * Warranties that defects or errors in the App or its content will be corrected.

7. LIMITATION OF LIABILITY

7.1. Exclusion of Liability: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL VAIC.AT B.V., ITS AFFILIATES, LICENSORS, SERVICE PROVIDERS, OR ITS OR THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AGENTS, OR ASSIGNS, BE LIABLE FOR ANY CLAIM, DAMAGES, LOSSES, OR LIABILITIES, INCLUDING, BUT NOT LIMITED TO: * Any direct, indirect, punitive, incidental, special, exemplary, or consequential damages. * Damages for loss of profits, revenue, business, savings, data (including loss or corruption of data stored locally on your device), goodwill, or other intangible losses. * Damages for damage to your device, equipment, software, or data. * Damages for personal injury, pain and suffering, or emotional distress. * Damages arising out of or in any way connected with: * Your access to or use of, or inability to access or use, the App. * Any decisions or actions you take or fail to take based on information provided by the App. * The accuracy, reliability, timeliness, or completeness of any information, data, calculations, or estimates provided by the App. * Any reliance on the App as a substitute for professional advice. * Any issues arising from the limitations of data or calculations as described in Section 4. * Any security breaches, unauthorized access, data loss, or data corruption occurring on your local device, as this is outside of our direct control (notwithstanding our on-device security measures detailed in our Data Security Practices). * Technical issues, errors, bugs, interruptions, or failures within the App, regardless of cause. * Compatibility issues between the App and your device, operating system, or other software. * Issues arising from third-party content, data sources, or external links accessed through the App. * The discontinuance or suspension of the App or any part of it. * Any issues related to the accessibility features of the App not meeting your specific individual needs (while we strive for accessibility as per our Accessibility Statement).

7.2. Basis of the Bargain: You acknowledge and agree that the disclaimers of warranties and limitations of liability set forth in this Disclaimer (and the Terms of Service) are fundamental elements of the basis of the bargain between you and Vaic.at B.V., and that Vaic.at B.V. would not be able to provide the App to you on an “as is, as available” basis without such limitations.

7.3. Jurisdictional Limitations: Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for certain types of damages. Therefore, some of the limitations and exclusions in Sections 6 and 7 may not apply to you, depending on your jurisdiction.

8. THIRD-PARTY CONTENT AND LINKS

The App may incorporate data, information, or content from third-party sources and may contain links to external websites, resources, or services not owned or controlled by us.

We are not responsible for the accuracy, completeness, timeliness, or reliability of any data or content obtained from third-party sources.
We do not endorse the content of any linked external sites.
We are not responsible for the availability or practices (including privacy and security) of any external sites or services linked from the App.
Your interaction with any third-party content or external site is solely at your own risk, and you should review their terms and policies.

You acknowledge that you bear all risks associated with using or relying on third-party content or external links accessed through the App.

9. ACKNOWLEDGEMENT

By using the mEUvy App, you acknowledge that you have read and understood this Disclaimer of Liability and agree that the limitations and exclusions of liability and disclaimers of warranties set forth herein are reasonable and acceptable to you.

10. CHANGES TO THIS DISCLAIMER

We reserve the right to modify this Disclaimer at any time, effective upon posting the updated version within the App. We will notify users of material changes in accordance with the procedures outlined in the Terms of Service. Your continued use of the App following any changes indicates your acceptance of the updated Disclaimer.

11. CONTACT INFORMATION

If you have any questions or concerns about this Disclaimer, please contact us:

Email: legal@vaicat.com

ADDITIONAL PRIVACY FRAMEWORKS COMPLIANCE

Last Updated: April 25, 2025

1. INTRODUCTION: mEUvy’S GLOBAL PRIVACY APPROACH

While mEUvy was designed with the European Union’s General Data Protection Regulation (GDPR) as a foundational privacy framework, we recognize that users may access our App from various jurisdictions with their own privacy regulations. This document outlines how mEUvy’s unique local-only processing architecture aligns with key privacy frameworks beyond the GDPR, providing transparency about our compliance posture.

Our fundamental privacy principle—that all personal data remains exclusively on your device and is never transmitted to our servers or third parties—creates an unusual but advantageous position regarding global privacy compliance.

2. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

2.1. Applicability Context: The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants California residents specific rights regarding their personal information and imposes requirements on businesses that collect such information.

2.2. mEUvy’s Compliance Position: mEUvy’s local-only architecture fundamentally alters the traditional CCPA/CPRA compliance paradigm in important ways:

No “Collection” Under CCPA/CPRA: Under the CCPA/CPRA, “collection” is defined as “buying, renting, gathering, obtaining, receiving, or accessing any personal information pertaining to a consumer by any means.” Because mEUvy does not receive, access, or otherwise obtain your personal information on our servers, we do not “collect” personal information in the legal sense defined by these regulations.
No “Sale” or “Sharing” of Personal Information: As we do not collect your personal information, we consequently cannot and do not sell, share, or disclose your personal information to any third parties, including for cross-context behavioral advertising purposes.
No Need for a “Do Not Sell or Share My Personal Information” Link: Since no selling or sharing occurs, the requirement for such mechanisms is not applicable to mEUvy.
Data Retention Not Applicable at Business Level: Since we do not retain your personal information on our servers, the CCPA/CPRA retention requirements do not apply at the business level. You control the retention of your data locally on your device.

2.3. California Consumer Rights and How to Exercise Them with mEUvy:

While traditional CCPA/CPRA rights requests (e.g., to know, delete, correct, etc.) directed to Vaic.at B.V. are not applicable due to our local-only architecture, the equivalent functionality is available directly through the App interface:

Right to Know/Access: You can view all your data within the App’s “My Data” section, which displays the information in a structured format.
Right to Delete: You can delete specific data points or all your data using the “Reset All Data” or individual deletion functions within the App.
Right to Correct: You can directly edit and update any information you have provided through the App’s input interfaces.
Right to Data Portability: You can export your data using the App’s export function. (See our detailed Data Portability section for more information.)
Right to Limit Use/Disclosure of Sensitive Personal Information: You control what information you input and how it is used through the App’s granular permission settings.

3. CANADA’S PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT (PIPEDA)

3.1. Applicability Context: PIPEDA establishes rules for how private-sector organizations collect, use, and disclose personal information in the course of commercial activities in Canada.

3.2. mEUvy’s Compliance Position: mEUvy’s architecture aligns exceptionally well with PIPEDA’s core principles:

Accountability: While we do not collect your personal information, we remain accountable for the App’s design, security measures, and our privacy practices.
Identifying Purposes: We clearly identify the purposes for which personal data may be processed (locally) within the Privacy Policy.
Consent: We obtain explicit consent before you can use the App’s features that process personal data locally, as detailed in our Privacy Policy.
Limiting Collection: Our approach goes beyond merely limiting collection—we avoid collection entirely, as all processing occurs locally on your device.
Limiting Use, Disclosure, and Retention: All uses of your data are limited to local processing for the purposes you’ve consented to, with no disclosure to third parties. You control retention through the App’s interfaces.
Accuracy: You can update and correct your information at any time through the App.
Safeguards: We implement appropriate security measures within the App to protect data stored locally, as detailed in our Data Security Practices.
Openness: Our detailed policies provide transparent information about our data practices.
Individual Access: You have direct access to all your data within the App.
Challenging Compliance: We provide contact information for our Data Protection Officer and welcome questions or concerns about our practices.

3.3. Exercising Your PIPEDA Rights: As with CCPA/CPRA rights, you can exercise the equivalent of your PIPEDA rights directly through the App’s interface, as there is no personal data stored or processed on our servers to access, correct, or challenge.

4. AUSTRALIA’S PRIVACY ACT AND AUSTRALIAN PRIVACY PRINCIPLES (APPs)

4.1. Applicability Context: Australia’s Privacy Act 1988 and the Australian Privacy Principles (APPs) regulate how personal information is handled by certain organizations.

4.2. mEUvy’s Compliance Position: Our local-only processing approach aligns with the APPs in the following ways:

Open and Transparent Management of Personal Information: Our comprehensive policies provide clear information about how the App manages personal information locally.
Anonymity and Pseudonymity: The App allows users to input only the information they choose, supporting anonymity and pseudonymity principles.
Collection, Use, and Disclosure: The App only processes the information you voluntarily provide, solely for the purposes described in our Privacy Policy, with no disclosure to third parties.
Direct Marketing: We do not collect user data for direct marketing purposes.
Cross-Border Disclosure: No cross-border disclosure occurs, as all data remains locally on your device.
Security, Access, and Correction: We implement appropriate security measures for local data, and you can directly access and correct your information through the App.

4.3. Exercising Your APP Rights: You can exercise your rights under the APPs directly through the App’s interface, as there is no personal data held on our servers to access or correct.

5. OTHER INTERNATIONAL PRIVACY FRAMEWORKS

5.1. Brazil’s Lei Geral de Proteção de Dados (LGPD): Brazil’s LGPD establishes rules similar to the GDPR for the processing of personal data. mEUvy’s local-only architecture aligns with the LGPD’s principles, as the App does not collect, store, or process personal data on our servers, and all processing is based on explicit consent and occurs locally on your device.

5.2. Japan’s Act on the Protection of Personal Information (APPI): Japan’s APPI regulates the handling of personal information. mEUvy’s approach aligns with APPI’s principles, as we do not handle personal information on our servers, and provide transparent information about the App’s local data processing.

5.3. South Korea’s Personal Information Protection Act (PIPA): South Korea’s PIPA establishes strict requirements for the collection and use of personal information. mEUvy’s local-only architecture provides strong alignment with PIPA’s principles, as no collection or use occurs at the server level.

6. THE UNIVERSAL ADVANTAGE OF mEUvy’S ARCHITECTURE

mEUvy’s unique approach to privacy—processing all personal data locally on your device with no transmission to our servers—creates a universal advantage for compliance with global privacy frameworks. By eliminating server-side data collection, retention, and sharing, we fundamentally reshape the traditional compliance landscape.

While we cannot eliminate all compliance obligations (we still maintain responsibility for the App’s design, security, and transparency), our architecture significantly reduces many traditional privacy compliance risks and challenges.

7. CONTACT INFORMATION

If you have any questions about mEUvy’s compliance with these or other privacy frameworks, please contact our Data Protection Officer:

Email: dpo@vaicat.com

For general inquiries not related to privacy, please contact:

Email: support@vaicat.com

COOKIE POLICY

Last Updated: April 25, 2025

1. INTRODUCTION – mEUvy DOES NOT USE COOKIES FOR TRACKING

Welcome to mEUvy. This Cookie Policy explains how we handle cookies and similar technologies in relation to our mobile application (the “App”). Our approach is fundamentally aligned with our privacy-first design: mEUvy does not use traditional cookies or similar tracking technologies in the conventional sense typically found on websites or apps that interact with remote servers for user tracking or data collection.

Instead of relying on server-side cookies or remote tracking, mEUvy operates primarily by storing and processing data locally on your device. This policy clarifies this distinction and explains the limited ways the App utilizes your device’s local storage features.

This Cookie Policy is part of our overall set of policies governing your use of the App, including our Terms of Service and, most importantly, our Privacy Policy, which provides comprehensive details on how your data is handled (locally).

2. WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES?

To provide context, it’s helpful to understand what is commonly meant by cookies and similar technologies.

Cookies: Small text files placed on your computer or mobile device by websites you visit. They are widely used to make websites work¹or function more efficiently, as well as to provide information²to the site owners. They can remember your login details, site preferences, or track your Browse activity across pages or even different websites. 1. casinobonusmarket-canada.com casinobonusmarket-canada.com 2. www.filter-tecnocar.com www.filter-tecnocar.com
Similar Technologies: This broad term includes technologies like:
- Local Storage (or HTML5 Web Storage): Allows websites or applications to store data directly in the browser or device’s storage. This data persists even after the browser/app is closed and reopened (unlike session cookies).
- Session Storage: Similar to local storage but the data is cleared when the browser/app session ends.
- Pixel Tags (Web Beacons): Small graphic images used to track user behavior on websites or in emails.
- Device Identifiers: Unique identifiers associated with your mobile device (e.g., IDFA on iOS, AAID on Android) used by advertisers or analytics providers to track usage and behavior across different apps.
- Fingerprinting: Techniques used to identify a device based on its unique configuration (e.g., operating system, browser type, screen resolution, installed fonts).

3. OUR APPROACH: EMPHASIZING NO TRACKING AND LOCAL STORAGE

Unlike most online services, mEUvy’s design fundamentally avoids the need for traditional remote tracking technologies.

3.1. No Server-Side Cookies or Remote Tracking: Because the mEUvy App processes your personal data entirely on your device and does not transmit this data to our servers, the concept of server-side cookies used for session management, tracking, or profiling is irrelevant to our operation. We do not set or read cookies from a server on your device. There are no advertising cookies, analytics cookies (sent to our servers), or social media cookies associated with your use of mEUvy.

3.2. Limited Use of Local Device Storage ONLY: The App utilizes your mobile device’s native local storage capabilities. This is a feature of your device’s operating system that allows applications to save small amounts of data directly onto the device itself. * What is Stored Locally: Data stored in the App’s local storage includes: * Your input data and preferences for city comparisons. * Your personalized settings (e.g., unit preferences, display options). * Records of your consent to the Terms of Service and Privacy Policy. * Cached reference data (like city lists, basic economic indicators) to improve performance and allow offline functionality after initial data download. * Crucially, this data: * Remains exclusively on your device. * Is never transmitted to our servers or any third parties. * Is used solely for enabling the App’s functionality, personalization, and improving performance on your device. * Not for Tracking:The use of local storage in mEUvy is fundamentally different from using cookies or similar technologies for tracking purposes. It is about saving the state of the application and your preferences locally for convenience and functionality, not about identifying or tracking your behavior across different apps or websites.

3.3. No Third-Party Tracking Technologies: In line with our strict privacy policy, we do not integrate or use any third-party SDKs or code that employ tracking technologies. This includes: * No third-party analytics SDKs that send data off your device. * No advertising networks or ad measurement SDKs. * No social media tracking pixels or SDKs. * No device fingerprinting libraries.

4. PURPOSES OF LOCAL STORAGE DATA

The data saved in the App’s local storage serves essential functional purposes to provide you with the mEUvy experience:

Saving User Input: To retain the financial information, lifestyle preferences, and other data you enter for comparisons across different sessions.
Remembering Preferences: To recall your settings (like language, display preferences, data presentation) so you don’t have to reconfigure them each time you open the App.
Storing Consent Records: To keep a local record of your agreement to the legal policies.
Caching Reference Data: To temporarily store frequently used static data (like lists of available cities or general economic indices) on your device, reducing loading times and potentially allowing limited offline access to previously accessed information.
Maintaining App State: To help the App resume from where you left off.

5. SECURITY OF LOCAL STORAGE DATA

While the data stored locally is on your device and not under our direct control on a server, we implement security measures within the App to help protect this data on your device, as detailed in our Data Security Practices. These measures include:

Local Encryption: Applying industry-standard encryption to sensitive personal data stored within the App’s local storage.
Secure Storage APIs: Utilizing secure mechanisms provided by the device’s operating system for data storage.
Secure Coding: Following practices to protect the integrity of the App and the data it handles locally.

It is important to remember that the overall security of your device and the data stored on it, including mEUvy’s local data, is also dependent on your device’s security settings, operating system updates, and your personal security practices.

6. YOUR CONTROL OVER LOCAL STORAGE DATA

You have complete control over the data stored by mEUvy in your device’s local storage. You can manage this data through:

In-App Functions: Using features like “Clear All Data,” “Reset,” or specific deletion options for individual data points within the App.
Device Settings: Adjusting application storage permissions via your device’s operating system settings (though be aware that restricting storage may impact App functionality).
Uninstalling the App: Deleting the App from your device will permanently remove all data stored by the App in your device’s local storage.

As the data is stored locally under your control, you determine its retention period.

7. RELATIONSHIP WITH PRIVACY POLICY

This Cookie Policy specifically addresses the use of cookies and local storage. For comprehensive information on how mEUvy handles your personal data in general, including the types of data you might provide, the purposes of localprocessing, your rights (like access, rectification, and erasure of locally stored data), children’s privacy, and contact information for privacy matters, please refer to our full Privacy Policy.

8. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to clarify our practices or reflect changes in technology or legal requirements. When we make changes:

We will notify you through the App.
We will update the “Last Updated” date at the top of this policy.
Material changes will be handled in accordance with the procedures outlined in the Terms of Service and Privacy Policy (e.g., requiring renewed consent if applicable, though unlikely for this specific policy unless our core architecture regarding data storage changes).

We encourage you to review this Cookie Policy periodically.

9. CONTACT US

If you have any questions about our approach to data storage, local storage use, or this Cookie Policy, please contact us:

Email: privacy@vaicat.com

COOKIE POLICY

Last Updated: April 25, 2025

1. INTRODUCTION – mEUvy DOES NOT USE COOKIES FOR TRACKING

2. WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES?

To provide context, it’s helpful to understand what is commonly meant by cookies and similar technologies.

Cookies: Small text files placed on your computer or mobile device by websites you visit. They are widely used to make websites work¹or function more efficiently, as well as to provide information²to the site owners. They can remember your login details, site preferences, or track your Browse activity across pages or even different websites. 1. casinobonusmarket-canada.com casinobonusmarket-canada.com 2. www.filter-tecnocar.com www.filter-tecnocar.com
Similar Technologies: This broad term includes technologies like:
- Local Storage (or HTML5 Web Storage): Allows websites or applications to store data directly in the browser or device’s storage. This data persists even after the browser/app is closed and reopened (unlike session cookies).
- Session Storage: Similar to local storage but the data is cleared when the browser/app session ends.
- Pixel Tags (Web Beacons): Small graphic images used to track user behavior on websites or in emails.
- Device Identifiers: Unique identifiers associated with your mobile device (e.g., IDFA on iOS, AAID on Android) used by advertisers or analytics providers to track usage and behavior across different apps.
- Fingerprinting: Techniques used to identify a device based on its unique configuration (e.g., operating system, browser type, screen resolution, installed fonts).

3. OUR APPROACH: EMPHASIZING NO TRACKING AND LOCAL STORAGE

Unlike most online services, mEUvy’s design fundamentally avoids the need for traditional remote tracking technologies.

4. PURPOSES OF LOCAL STORAGE DATA

The data saved in the App’s local storage serves essential functional purposes to provide you with the mEUvy experience:

Saving User Input: To retain the financial information, lifestyle preferences, and other data you enter for comparisons across different sessions.
Remembering Preferences: To recall your settings (like language, display preferences, data presentation) so you don’t have to reconfigure them each time you open the App.
Storing Consent Records: To keep a local record of your agreement to the legal policies.
Caching Reference Data: To temporarily store frequently used static data (like lists of available cities or general economic indices) on your device, reducing loading times and potentially allowing limited offline access to previously accessed information.
Maintaining App State: To help the App resume from where you left off.

5. SECURITY OF LOCAL STORAGE DATA

Local Encryption: Applying industry-standard encryption to sensitive personal data stored within the App’s local storage.
Secure Storage APIs: Utilizing secure mechanisms provided by the device’s operating system for data storage.
Secure Coding: Following practices to protect the integrity of the App and the data it handles locally.

6. YOUR CONTROL OVER LOCAL STORAGE DATA

You have complete control over the data stored by mEUvy in your device’s local storage. You can manage this data through:

In-App Functions: Using features like “Clear All Data,” “Reset,” or specific deletion options for individual data points within the App.
Device Settings: Adjusting application storage permissions via your device’s operating system settings (though be aware that restricting storage may impact App functionality).
Uninstalling the App: Deleting the App from your device will permanently remove all data stored by the App in your device’s local storage.

As the data is stored locally under your control, you determine its retention period.

7. RELATIONSHIP WITH PRIVACY POLICY

8. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to clarify our practices or reflect changes in technology or legal requirements. When we make changes:

We will notify you through the App.
We will update the “Last Updated” date at the top of this policy.
Material changes will be handled in accordance with the procedures outlined in the Terms of Service and Privacy Policy (e.g., requiring renewed consent if applicable, though unlikely for this specific policy unless our core architecture regarding data storage changes).

We encourage you to review this Cookie Policy periodically.

9. CONTACT US

If you have any questions about our approach to data storage, local storage use, or this Cookie Policy, please contact us:

Email: privacy@vaicat.com

ACCESSIBILITY STATEMENT

Last Updated: April 25, 2025

1. OUR COMMITMENT TO ACCESSIBILITY

At mEUvy, operated by Vaic.at B.V., we are deeply committed to ensuring that our mobile application is accessible to people of all abilities. We believe that everyone should have the opportunity to explore potential relocation options and access information about European cities, regardless of disability. Our goal is to create an inclusive user experience and remove barriers to digital access.

We are continually working to improve the accessibility of our App and applying relevant accessibility standards and best practices to ensure it is usable by the widest possible audience. Accessibility is integrated into our design and development process as part of our overall user-centric approach.

2. CONFORMANCE STATUS

We strive to make the mEUvy App conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. WCAG are a set of guidelines developed by the World Wide Web Consortium (W3C) aimed at providing a single shared standard for web content accessibility that meets the needs of individuals, organizations, and governments internationally. Level AA conformance is a widely recognized standard indicating significant steps have been taken to make content accessible.

We understand that achieving and maintaining accessibility is an ongoing process, and we are dedicated to continuous improvement.

3. ACCESSIBILITY FEATURES IMPLEMENTED

We have incorporated various features and design considerations into the mEUvy App to enhance accessibility. These include measures across different categories:

3.1. Visual Accessibility: * Dynamic Type Support: The App respects and supports system-level text size adjustments. Users can increase or decrease the text size in their device’s accessibility settings, and the App’s interface will adapt accordingly to make content more readable. * Sufficient Color Contrast: We design the App’s interface with sufficient color contrast between text and background elements to ensure readability for users with low vision or color deficiencies. We adhere to recommended contrast ratios where possible. * No Reliance Solely on Color: Information is not conveyed using color alone. Important distinctions or status indicators are also communicated through text labels, icons, or other non-color-dependent visual cues. * Compatibility with High Contrast Modes: The App is designed to be compatible with the high contrast mode settings available in the device’s operating system.

3.2. Screen Reader Support: * The App is built with support for native mobile screen readers, such as VoiceOver on iOS and TalkBack on Android. * Interactive elements (like buttons, fields, toggles) are properly labeled and assigned appropriate roles to be understandable by screen readers. * Non-text content that conveys meaning (e.g., icons) is provided with descriptive text alternatives. * Content is structured semantically using headings and logical reading order where applicable, allowing screen reader users to navigate the App effectively.

3.3. Motor Control Accessibility: * Adequate Touch Target Sizes: Interactive elements (like buttons, icons, toggles) are designed with sufficient touch target sizes (generally aiming for a minimum of 44×44 dp/pt) to make them easier to activate accurately by users with motor impairments. * Sufficient Spacing: Elements are spaced adequately to reduce the chance of accidentally activating adjacent controls. * No Time Limits on Standard Interactions: Core interactions within the App do not have strict time limits that would prevent users from completing tasks at their own pace. * Alternative Interaction Methods: Where complex gestures might otherwise be used, alternative methods (like standard button taps or form inputs) are provided.

3.4. Cognitive Accessibility: * Clear and Simple Language: Content, labels, and instructions within the App are written using clear, concise, and easy-to-understand language. * Consistent Layout and Navigation: The interface maintains a consistent layout and navigation patterns throughout the App to help users learn and predict how to interact with it. * Step-by-Step Processes: Complex workflows, such as entering detailed comparison data, are broken down into logical, manageable steps. * Clear Error Messages: Error messages are designed to be specific, easy to understand, and provide clear guidance on how to correct the error. * Help Text and Tooltips: Optional help text or tooltips are available for various features or data points to provide additional context and guidance.

4. KNOWN LIMITATIONS

While we strive for comprehensive accessibility, we are aware of certain limitations that currently exist within the App. We are actively working to address these in future updates:

Complexity of Data Visualizations: Some of the advanced data visualizations, graphs, or comparison charts that present complex information visually may not be fully or equally accessible to users relying solely on screen readers or those with certain cognitive disabilities due to the inherent visual nature of the data representation. We are exploring alternative ways to present this information accessibly.
Advanced Comparison Customization: Some highly specific or nuanced customization options within the comparison features may require finer motor control or more complex input methods than simpler interactions.
PDF/External Exports: While the App may offer options to export data (as mentioned in the Privacy Policy regarding the Right to Data Portability), the resulting file formats (e.g., PDF) may not always retain all the accessibility features present within the live App interface, depending on the device’s capabilities and the viewing software used.

We appreciate your understanding regarding these current limitations and encourage you to provide feedback on any accessibility barriers you encounter.

5. FEEDBACK AND CONTINUOUS IMPROVEMENT

Your feedback is invaluable in helping us improve the accessibility of mEUvy. If you encounter any accessibility barriers while using the App, have suggestions for improvement, or require assistance, please contact us.

When reporting an accessibility issue, please include as much detail as possible to help us understand and address the problem effectively. We recommend including:

The specific screen or feature in the App where the issue occurred.
A description of the accessibility barrier you encountered.
The steps you took that led to the issue.
Your device model and operating system version.
Any assistive technology you were using (e.g., screen reader, switch control, magnification software).

We actively review accessibility feedback and incorporate it into our development roadmap to make the App more inclusive.

6. COMPATIBILITY STATEMENT

The mEUvy App is designed to be compatible with the built-in accessibility features of its supported mobile operating systems (iOS and Android) and common assistive technologies, including:

iOS VoiceOver
Android TalkBack
System-level text size (Dynamic Type)
System-level display and contrast settings
System-level features like Switch Control or Voice Control (compatibility may vary based on feature complexity)

While we strive for broad compatibility, performance and specific interactions may vary slightly depending on the specific versions of the operating system, the assistive technology used, and the device hardware.

7. RELATIONSHIP WITH DISCLAIMER OF LIABILITY

This Accessibility Statement outlines our commitment and efforts towards making the App accessible. While we are dedicated to providing an accessible experience, this statement does not constitute a warranty that the App will meet the specific accessibility needs of all individual users or be compatible with all possible assistive technologies or device configurations. The limitations described in Section 4, and the general limitations of liability and warranty disclaimers as set forth in our Disclaimer of Liability and Terms of Service, apply to the accessibility of the App as well.

8. UPDATES TO THIS STATEMENT

We will review and update this Accessibility Statement periodically as we improve the accessibility features of the App and respond to feedback. Any significant changes to our accessibility practices or updates to this statement will be communicated through the App’s update notes or other appropriate channels.

9. CONTACT INFORMATION

If you have any questions, feedback, or require assistance regarding the accessibility of the mEUvy App, please contact our dedicated accessibility support:

Email: accessibility@vaicat.com

We welcome your input and are committed to making mEUvy more accessible for everyone.

DATA SECURITY PRACTICES

Last Updated: April 25, 2025

1. INTRODUCTION

At mEUvy, operated by Vaic.at B.V., the security of your data is a paramount concern. This is the case even though our core privacy principle dictates that we never receive, collect, or store your personal information on our servers. Because users may choose to input sensitive data (such as financial or lifestyle information) for localized processing and comparison, we are committed to implementing robust security measures to protect the data that resides on your device while using our application.

This document outlines the security measures we implement within the mEUvy App itself to safeguard your information in local storage. It complements our Privacy Policy, which details how your data is handled (locally), and our Terms of Service, which govern your use of the App.

2. OUR SECURITY PHILOSOPHY: Security By Design, Locally

Our approach to data security is deeply integrated into the App’s architecture and development process, following three core principles:

Data Minimization: We design the App to request and process only the minimum amount of personal data necessary to provide the requested localized comparisons and insights.
Local Processing: As detailed in our Privacy Policy, all personal data entered by the user is processed and stored exclusively on the user’s device. This eliminates numerous traditional server-side security risks.
Security By Design: Security considerations are integrated into the App’s design and development lifecycle from the outset, rather than being an afterthought. This includes secure coding practices, robust testing, and built-in protection mechanisms for local data.

3. ON-DEVICE DATA SECURITY MEASURES

While the data is on your device and under your control, we implement several layers of security within the mEUvy App to protect the information stored locally:

3.1. Data Encryption at Rest: * What is Encrypted: All sensitive personal data that you voluntarily input and that the App stores locally for personalization and comparison purposes (e.g., financial details, specific preferences, saved comparison parameters) is encrypted. * Encryption Standard: This data is encrypted using industry-standard, strong encryption algorithms (e.g., AES-256). * Secure Key Management: Encryption keys are managed and stored securely on your device, leveraging hardware-backed security features like the device’s Secure Enclave (on compatible iOS devices) or equivalent protected storage mechanisms available on the operating system. This helps protect the keys from being easily accessed by other applications or malware on the device. * Purpose: Encryption protects your data while it is stored on your device’s storage, making it unreadable to anyone who might gain unauthorized access to the physical storage medium without the decryption keys.

3.2. Secure Local Storage Implementation: * We utilize secure local storage APIs and frameworks provided by the mobile operating system (iOS and Android) that are designed to offer a higher level of protection compared to standard file storage. * This helps ensure that the App’s data is stored in a way that is isolated from other applications on the device and is less susceptible to unauthorized access by malicious software, subject to the security of the device’s operating system itself. (See Section 9 regarding limitations).

3.3. Secure Coding and Development Practices: Our development team adheres to secure coding principles and practices throughout the development process to minimize vulnerabilities within the App’s codebase. This includes: * Regular Security Code Reviews: Code is reviewed by peers specifically looking for security flaws. * Static and Dynamic Application Security Testing (SAST/DAST): Automated tools are used to analyze the code for potential vulnerabilities and test the running application for security weaknesses. * Dependency Vulnerability Scanning: Third-party libraries and components are regularly scanned for known security vulnerabilities. * Secure Input Handling:Implementing robust input validation and sanitization to prevent injection attacks or unexpected behavior from malicious data input (although user data is processed locally, this is still a critical security layer). * Protection against Common Mobile Vulnerabilities: Designing the App to mitigate risks outlined in security guides like the OWASP Mobile Security Testing Guide (MSTG) and the OWASP Mobile Top 10.

3.4. Application Integrity: To help ensure that the App you are running is the authentic, untampered version released by Vaic.at B.V., and to prevent malicious modification, we implement measures including: * Digital Signing: All official releases of the mEUvy App are digitally signed, allowing your device’s operating system to verify its authenticity and integrity. * Code Obfuscation: Applying techniques to make the App’s code more difficult to reverse engineer, which helps protect our algorithms and makes it harder for malicious actors to understand the App’s internal workings to find vulnerabilities. * Tamper Detection: Implementing mechanisms within the App that can detect if the App’s code or locally stored data has been maliciously altered on the device.

3.5. Memory Management: Sensitive information is handled carefully in device memory. Where possible and practical, sensitive data is cleared from memory (RAM) when it is no longer needed for immediate processing to reduce the window of exposure in case of advanced attacks targeting device memory.

4. THE SECURITY ADVANTAGE OF THE “NO SERVER DATA” MODEL

A fundamental security advantage of mEUvy’s architecture, where user personal data never leaves the device, is the elimination of numerous common attack vectors that target traditional applications:

No Remote Database Breaches: Since we do not have a central database of user personal data, there is no risk of a large-scale breach of user data from our servers.
No Data in Transit Interception: As personal data is not transmitted between your device and our servers (or any third parties), there is no opportunity for malicious actors to intercept this data during transmission.
Reduced Server Infrastructure Risk: We do not need to secure complex server infrastructure dedicated to storing or processing user personal data, removing a significant potential attack surface.
No Third-Party Data Sharing Risk: Because we do not share your personal data with third parties (as per our Privacy Policy), there is no risk of your data being exposed due to a security incident at a third-party service provider we interact with for data processing.

This architecture shifts the primary security focus to protecting the data while it is on the user’s device, which Section 3 addresses.

5. RESPONSIBLE USE OF THIRD-PARTY COMPONENTS

We carefully evaluate and limit the use of third-party libraries and components within the mEUvy App.

Security Vetting: All external dependencies are vetted for known security vulnerabilities before integration.
Limited Permissions: We select libraries that require the minimum necessary permissions.
Regular Updates: Integrated third-party components are regularly updated to patch security vulnerabilities discovered in those libraries.
No Tracking SDKs: As stated in our Privacy Policy and Cookie Policy, we explicitly avoid third-party SDKs with tracking, advertising, or extensive data collection capabilities.

6. SECURITY INCIDENT RESPONSE (App-Specific)

Our security incident response plan is focused on identifying and addressing potential vulnerabilities within the mEUvy application’s code or local data handling.

In the unlikely event that we become aware of a potential security vulnerability in the App itself, we will promptly investigate the nature and scope of the vulnerability.
If the vulnerability affects the security of data stored or processed by the App on your device, we will prioritize developing a fix.
We will notify affected users if appropriate and legally required, providing clear guidance on necessary actions (e.g., updating the App).
We will release security patches and updates to address the vulnerability as quickly as possible through the official app stores.

It is important to understand that because we do not control your device, our ability to respond to security incidents related to the device’s operating system, other apps, or physical compromise is limited to providing guidance and App updates.

7. SECURITY UPDATES AND MAINTENANCE

We are committed to maintaining the security of the mEUvy application over time through ongoing security maintenance:

Regular Security Patches: Releasing updates to fix discovered vulnerabilities.
Proactive Vulnerability Scanning: Regularly scanning our codebase and dependencies.
Monitoring Security Threat Intelligence: Staying informed about new mobile security threats and vulnerabilities.
Periodic Security Reviews: Reviewing our App’s security architecture and implementation periodically.

We strongly recommend that users keep their device’s operating system updated and install mEUvy App updates promptly to benefit from these security improvements, bug fixes, and vulnerability patches. Your active role in keeping your software updated is crucial for your security.

8. USER RECOMMENDATIONS FOR ON-DEVICE SECURITY

Since your personal data resides on your device, the overall security posture of your data while using mEUvy depends significantly on the security of your device itself. We strongly recommend the following practices:

Keep Device and OS Updated: Install operating system updates (iOS, Android) as soon as they are available. These often contain critical security patches.
Use Strong Device Authentication: Protect your device with a strong PIN, password, pattern, or biometric authentication (fingerprint, face recognition).
Use Official App Stores: Only download and install mEUvy from the official Apple App Store or Google Play Store. Avoid downloading the App from unofficial or third-party sources.
Avoid Jailbreaking or Rooting: Modifying your device’s operating system (jailbreaking iOS, rooting Android) can significantly weaken its security defenses and make data more vulnerable to other apps or malware.
Be Cautious of Other Apps: Install apps only from trusted sources and be mindful of the permissions you grant to other applications, as some malware could potentially attempt to access data stored by other apps if the device’s security is compromised.
Be Mindful of Physical Device Security: Keep your device secure and prevent unauthorized physical access.
Periodically Review and Manage Data: Use the App’s functions to review the data you have stored and delete information you no longer need.
Use In-App Reset Function: If you wish to remove all your data from the App, use the dedicated “Reset All Data” function or uninstall the App.

9. LIMITATIONS OF ON-DEVICE SECURITY

While we implement the security measures described herein within the mEUvy App, it is important to understand the inherent limitations when data resides solely on a user’s device:

Device Operating System Security: The security of your data ultimately relies in part on the security of the device’s underlying operating system, which is outside of our control.
Other Applications: While we aim for data isolation, the security environment on your device can be affected by other applications you install, especially if they are malicious or have excessive permissions.
Physical Access: If your device is physically compromised or falls into unauthorized hands, the data on it, including mEUvy’s local data, may be at risk, regardless of App-level security measures.
Malware: Your device can be susceptible to malware that could potentially bypass security measures, depending on the malware’s sophistication and the device’s security posture.
User Practices: The user’s own security habits (e.g., using weak passwords, installing apps from unofficial sources, connecting to unsecured networks) significantly impact the device’s overall security.

We cannot and do not guarantee the absolute security of your device or the data stored on it. Our responsibility is limited to the security measures implemented within the mEUvy application itself to protect the data to the extent possible within the device environment. As stated in our Disclaimer of Liability, we are not liable for data loss, corruption, or breaches that occur on your device.

10. REPORTING SECURITY VULNERABILITIES

We appreciate the efforts of security researchers and the community in helping us maintain the security of the mEUvy App. If you discover a potential security vulnerability in the App, we encourage you to report it to us responsibly.

Please provide detailed information about the potential vulnerability, including steps to reproduce it, the affected version of the App, and your device and operating system details, to:

Email: security@vaicat.com

We will investigate all legitimate reports and take appropriate action.

11. CHANGES TO THIS DOCUMENT

We may review and update this Data Security Practices document periodically to reflect changes in our security measures, address new threats, or clarify our practices. Any significant changes will be communicated through the App in accordance with our policies on updates.

12. CONTACT INFORMATION

If you have any questions about our data security practices, please contact us at:

Email: security@vaicat.com