Legal

1. Introduction

Vicinity Inc. ("Vicinity," "we," "our," or "us") is committed to protecting the privacy and personal information of our users ("you" or "User"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you use the Vicinity mobile application, website, and related services (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree, please do not use our Services.

2. Information We Collect

We collect information in the following categories:

2.1 Information You Provide Directly
When you create an account, complete your profile, or interact with our Services, we collect: your name, email address, date of birth (for age verification), profile photo, travel biography and interests, cities you have visited or plan to visit, and any content you submit including messages, posts, and itineraries.

2.2 Location Information
Vicinity's core functionality relies on precise, real-time geolocation data. When you enable location services, we collect your GPS coordinates continuously while the app is in use. You may adjust location permissions in your device settings, but doing so will disable core features of the app. Location data is used solely to display your proximity to other users and is never sold to third parties.

2.3 Device and Usage Information
We automatically collect: device identifiers (IDFA, GAID), IP address, operating system and version, app version, crash logs and diagnostic data, pages and features accessed, and timestamps of interactions.

2.4 Communications
We retain messages exchanged between users on the platform for safety, moderation, and legal compliance purposes, as described in Section 5.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve the Services, including displaying nearby traveler profiles based on real-time location
• Verify that users meet our minimum age requirement of 16 years
• Generate AI-assisted profile personas, icebreaker suggestions, and travel itineraries
• Send you service-related communications, account notifications, and (with your consent) promotional messages
• Monitor for and enforce compliance with our Terms of Service and Community Guidelines
• Detect fraud, investigate abuse, and respond to reports of harmful conduct
• Comply with applicable laws, regulations, and legal process
• Conduct analytics and research to improve user experience and safety systems

4. Legal Bases for Processing (GDPR / PIPEDA)

Where applicable under the General Data Protection Regulation (GDPR), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), or similar legislation, we process your personal data on the following legal bases: (a) Contract performance — to deliver the Services you have registered for; (b) Legitimate interests — to ensure platform safety, prevent fraud, and improve our Services; (c) Legal obligation — to comply with applicable laws and respond to lawful requests; and (d) Consent — for optional features such as marketing communications and precise location sharing, which you may withdraw at any time.

5. Data Retention

We retain your personal data for as long as your account is active or as necessary to provide you with our Services. Upon account deletion, we will delete or anonymize your data within 30 days, except where we are required to retain it for legal, regulatory, or safety reasons (e.g., records of reported abuse, fraudulent activity, or law enforcement requests), in which case data may be retained for up to 7 years. Location data is stored in identifiable form for no more than 90 days from collection, after which it is aggregated or deleted.

6. Sharing and Disclosure

We do not sell your personal information. We may share your information with:

• Other Users: Your profile name, photo, approximate location (not precise coordinates), and bio are visible to other users of the platform within your configured proximity radius.
• Service Providers: We engage trusted third-party vendors for cloud hosting, analytics, fraud detection, and customer support who are contractually bound to process data only on our behalf and in accordance with applicable law.
• AI Infrastructure Partners: Anonymized, non-identifiable conversation snippets may be used to improve AI-generated features. No personally identifiable information is shared with AI model providers.
• Legal and Regulatory: We may disclose information to law enforcement, government authorities, or courts when required to do so by law, court order, or to protect the rights, property, or safety of Vicinity, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity, subject to the same privacy protections described herein.

7. Data Security

We implement industry-standard technical and organizational security measures including TLS encryption in transit, AES-256 encryption at rest, access controls, and regular security audits. However, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security and are not responsible for unauthorized access resulting from your own actions, such as sharing your credentials.

8. Children and Age Restrictions

Vicinity is strictly for users aged 16 and older. We do not knowingly collect personal information from individuals under 16. If we become aware that a user is under 16, we will immediately terminate their account and delete associated data. If you believe a minor has created an account, please contact us at privacy@vicinity.app. In jurisdictions where applicable law sets a higher age of digital consent (e.g., 18 in some regions), users must meet that local requirement.

9. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data, subject to legal retention obligations.
• Portability: Request your data in a structured, machine-readable format.
• Objection / Restriction: Object to or restrict certain processing activities.
• Withdraw Consent: Withdraw consent for processing where consent is the legal basis.

To exercise any of these rights, please contact us at privacy@vicinity.app. We will respond within 30 days. If you are in the European Economic Area, you have the right to lodge a complaint with your local supervisory authority.

10. International Data Transfers

Vicinity operates globally. Your information may be transferred to and processed in countries other than the country in which you reside, including Canada, the United States, and other jurisdictions. Where required by law, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission to protect your data during international transfers.

11. Cookies and Tracking Technologies

Our website uses cookies and similar technologies for analytics, security, and preferences. You may manage cookie preferences through your browser settings or our consent banner. Our mobile app does not use browser cookies but may use equivalent device-based identifiers for analytics and attribution, which you can limit through your device's privacy settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android).

12. Third-Party Links

Our Services may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by updating the "Last updated" date at the top of this page and, where appropriate, by sending you an in-app notification or email. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Privacy Team at:

© 2026 Vicinity Inc. · All rights reserved.