PRIVACY POLICY

1. Introduction

• This Privacy Policy describes how VALIDOWL, owned by URLAUNCHED LTD (“we”, “our”, “us”), collects, uses, stores, and shares your personal data when you use our website, including when cookies or third-party tools (such as analytics, authentication, or infrastructure monitoring services) are active.

• We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Cyprus Law 125(I)/2018.

2. Data Controller

• URLAUNCHED LTD is the data controller for all personal data processed through the VALIDOWL platform. You can contact us at:
• Email: hello@validowl.com
  Postal: Aiolou & Panagioti Diomidous 9, Katholiki, Limassol, Cyprus, 3020

3. What Personal Data We Collect

We may also collect professional and account information you authorize us to access via third-party integrations, such as LinkedIn.
This includes your name, profile picture, headline, and employment history.

4. How We Use Your Data (Purposes and Legal Bases)

5. Sharing Your Data

• We do not sell your personal data. We may share your data with:

• - Employers and other users (your profile is public on VALIDOWL by design)
  - Service providers (hosting, support, analytics, payment processing)
  - Legal authorities when required under applicable law
  - Partners with whom you directly interact via the platform

• We share data with service providers for analytics, infrastructure, and monitoring, including:

• - Amazon Web Services (data hosting, EEA) - for secure hosting and data storage within the EEA.
  - LinkedIn (OAuth-based profile syncing) - to support OAuth-based login and profile population (only if the user consents).
  - Google Analytics, Firebase, Amplitude (user behavior tracking) - for behavioral analytics, pseudonymized tracking.
  - New Relic (server performance and health) - for performance monitoring and infrastructure diagnostics.

• These providers are bound by data processing agreements and are compliant with GDPR. We do not sell or rent personal data to any third party.

6. Data Retention

• We retain your personal data for as long as your account is active or as needed to:

• - Maintain reference history,
  - Prevent fraud or abuse,
  - Fulfill legal obligations,
  - Defend against legal claims.

• Published reviews and references may be retained even after account deactivation, under our legitimate interest (Article 6(1)(f) GDPR) to support the integrity of employment reference data.

7. Account Deletion & Data Retention Policy

• Users may request account deactivation at any time. However, due to the platform’s purpose of maintaining transparent, trustworthy references:

• - Account deletion does not guarantee removal of previously submitted or published reviews, ratings, or endorsements about the user.
  - All reference data is subject to moderation but cannot be unilaterally deleted by the subject or author unless proven inaccurate or unlawful.
  - Re-creating accounts to evade prior data is prohibited and may result in a ban.

• This is permitted under GDPR Article 17(3) where data is retained for fraud prevention, public interest, or legal claims.

• Some analytics and infrastructure data may be retained in pseudonymized form to detect abuse, secure the platform, or maintain performance insights - even after account deactivation - in accordance with Article 17(3) GDPR.

8. Your Rights Under GDPR

• You have the right to:

• - Access your personal data (Art. 15)
  - Correct inaccurate or outdated information (Art. 16)
  - Request deletion or correction (with limitations, Art. 17)
  - Restrict processing in certain situations (Art. 18)
  - Object to processing (Art. 21)
  - Data portability (Art. 20)
  - Withdraw consent at any time if processing is based on consent (Art. 7)

• To exercise any of the above rights, contact us at: hello@validowl.com

9. Security

• We implement technical and organizational measures to protect your data from unauthorized access, loss, or alteration, including:

• - TLS encryption
  - Role-based access controls
  - Regular system audits

10. International Transfers

• Your data is stored in the European Union. If we transfer data outside the EU/EEA, we ensure adequate safeguards under GDPR Chapter V, such as Standard Contractual Clauses (SCCs).

• Data may be stored within the EEA or securely transferred outside the EEA via Standard Contractual Clauses where applicable. Our infrastructure is hosted on AWS, which adheres to GDPR-aligned data processing standards.

11. Cookies & Tracking Technologies

• We use cookies and similar technologies to:

• - Enable core platform functionality (e.g. user sessions, secure login)
  - Analyze user behavior (e.g. page views, session duration, clicks)
  - Personalize profile building and onboarding (e.g. LinkedIn integration)
  - Monitor server health and diagnose technical issues (e.g. New Relic)

• You can adjust cookie preferences using your browser or via our cookie banner. For more details, see our Cookie Policy.

12. Changes to This Privacy Policy

• We may update this policy from time to time. Significant changes will be communicated on the Platform or via email.

13. Use of LinkedIn API

• We offer the option to register or populate your profile using your LinkedIn account. When you opt in, we access your public LinkedIn profile and import data you authorize. This feature uses OAuth authentication and no credentials are stored. Data is only processed with your consent and is covered under this Privacy Policy.

14. Contact & Complaints

• If you have concerns, contact us at:
• URLAUNCHED LTD
  Aiolou & Panagioti Diomidous 9
  Katholiki, Limassol, Cyprus, 3020
  Email: hello@validowl.com
• You may also file a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus: