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FEEL FIRST DAILY – PRIVACY POLICY

Last Updated: December 29, 2025

This Privacy Policy describes how Feel First, Live Free, LLC (“we,” “us,” or “our”) collects, uses, discloses, and protects information about users (“you”) of the Feel First Daily mobile application and related services (collectively, the “App”).

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the App.

This Privacy Policy is incorporated into and made part of our Terms of Use.

1. Who We Are and Scope

Feel First, Live Free, LLC is the controller of your personal data where this Privacy Policy applies. This means we decide how and why your personal data is processed when you use the App.

This Privacy Policy applies to information we collect:

  • Through the Feel First Daily App;
  • Through related services and communications; and
  • Where applicable, through our support channels and contact forms.

If you access the App from jurisdictions with specific privacy laws (such as the European Economic Area, the United Kingdom, or certain U.S. states), additional rights or disclosures may apply as described in this Policy.

2. Information We Collect

The information we collect depends on how you use the App and your settings. We may collect the following categories of information.

2.1 Information You Provide to Us

  • Account Information: If you create an account, we may collect your name, email address, username, password, and similar identifiers.
  • Emotional Check-Ins and Journal Entries: We may collect the information you enter into the App, such as emotional labels, reflections, notes, goals, intentions, and responses to prompts. This information can be highly sensitive and may reveal your emotional state, mental health, relationships, work, or personal life.
  • Communication with Us: If you contact us (for support, feedback, or other purposes), we may collect the content of your communications and your contact details.
  • Preferences and Settings: Information about your preferences in the App, such as notification settings, language, or display options.

2.2 Information Collected Automatically

When you use the App, we may automatically collect certain technical and usage information, such as:

  • Device Information: Device type, operating system and version, device identifiers (such as advertising IDs or other device IDs), and mobile network information.
  • Usage Information: Dates and times of access, features or screens used, interaction patterns, and other usage analytics.
  • Log Information: IP address (where applicable), app crashes, performance data, and diagnostic logs.

We may use third-party analytics tools to help us understand how the App is used so we can improve it. These tools may collect information described above.

2.3 Information from Third Parties

If you choose to connect the App with third-party services (for example, sign-in providers, cloud backup, or other integrations, if offered), we may receive information from those services according to their policies and your settings.

We do not control how third parties handle your data and encourage you to review their privacy policies.

3. Special Category Data (Health-Related and Emotional Information)

Your emotional check-ins, reflections, and related content may reveal information about your mental or emotional health. Under some privacy laws (such as the EU/UK General Data Protection Regulation), this may be considered “special category” or sensitive personal data (for example, data concerning health or mental health).

We only process this type of data:

  • To provide the App and its features to you (for example, saving your entries and showing you patterns);
  • With your explicit consent where required by law, which you provide by actively using these features and, where applicable, by accepting specific in-app consent prompts; and
  • In de-identified or aggregated form for analytics and improvement, where it no longer identifies you.

You may withdraw your consent at any time by deleting your entries, changing your settings (where available), or deleting your account. Withdrawing consent will not affect the lawfulness of processing based on consent before withdrawal.

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

We use the information we collect for the following purposes. Where applicable (for example, in the European Economic Area or United Kingdom), we also describe our legal bases for processing.

4.1 To Provide and Operate the App

  • Creating and managing your account;
  • Enabling core features (such as emotional check-ins, journaling, and viewing your history);
  • Synchronizing data across devices (if available).

Legal bases (where applicable):

  • Performance of a contract (Art. 6(1)(b) GDPR) – necessary to provide the App and services you request;
  • For emotional and mental health-related entries, explicit consent for processing special category data (Art. 9(2)(a) GDPR), where applicable.

4.2 To Support and Personalize Your Experience

  • Saving your entries and reflections;
  • Providing prompts, insights, or content that may be tailored to your use;
  • Remembering your preferences.

Legal bases:

  • Performance of a contract;
  • Our legitimate interests in improving user experience (Art. 6(1)(f) GDPR), where such interests are not overridden by your rights;
  • Explicit consent for special category data where required.

4.3 To Improve the App and Develop New Features

  • Analyzing usage and performance;
  • Fixing bugs and improving stability;
  • Testing and developing new features, and understanding how users interact with the App.

Legal bases:

  • Our legitimate interests in analyzing and improving the App (Art. 6(1)(f) GDPR);
  • Where local law requires consent for certain analytics or tracking, your consent.

4.4 To Communicate with You

  • Responding to your requests and inquiries;
  • Sending service-related communications (such as security notices, changes to this Privacy Policy or our Terms of Use);
  • Sending optional tips, feature updates, or other non-essential communications, where permitted by law and your preferences.

Legal bases:

  • Performance of a contract;
  • Our legitimate interests in keeping you informed (Art. 6(1)(f) GDPR);
  • For non-essential or marketing communications, where required by law, your consent (Art. 6(1)(a) GDPR).

4.5 To Ensure Security and Prevent Misuse

  • Protecting the App, our users, and our systems from fraud, abuse, and security threats;
  • Enforcing our Terms of Use and other policies.

Legal bases:

  • Our legitimate interests in ensuring the security and integrity of the App and protecting our rights and those of others (Art. 6(1)(f) GDPR);
  • Compliance with legal obligations where applicable (Art. 6(1)(c) GDPR).

4.6 To Comply with Legal Obligations and Protect Rights

  • Meeting legal, regulatory, and compliance obligations;
  • Responding to lawful requests and legal process;
  • Protecting our rights, property, safety, and that of our users and others.

Legal bases:

  • Compliance with legal obligations (Art. 6(1)(c) GDPR);
  • Our legitimate interests in defending our rights (Art. 6(1)(f) GDPR).

We may also use aggregated, de-identified, or anonymized data (which does not identify you personally) for research, analytics, and business purposes.

5. How We Share Information

We do not sell your personal information.

We may share information in the following limited circumstances:

5.1 Service Providers (Processors)

We may share information with trusted third-party service providers who help us operate, host, maintain, or analyze the App (for example, cloud hosting providers, analytics providers, email or notification services). These providers act as our processors and may only use the information as necessary to perform services for us and must protect it in accordance with appropriate contractual obligations.

5.2 Aggregated and De-Identified Data

We may share aggregated, de-identified, or anonymized data that does not reasonably identify you with third parties for research, analytics, product development, or other lawful purposes.

5.3 Legal, Safety, and Compliance

We may disclose information if we believe in good faith that such disclosure is reasonably necessary to:

  • Comply with any applicable law, regulation, legal process, or governmental request;
  • Enforce our Terms of Use or other agreements;
  • Protect our rights, property, or safety, or that of our users or others; or
  • Detect, prevent, or address fraud, security, or technical issues.

5.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will take reasonable steps to ensure that the receiving party continues to handle your information in a manner consistent with this Privacy Policy.

6. International Data Transfers

We may store and process your information in countries other than the country where you live. For example, our servers or service providers may be located in the United States or other jurisdictions.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or other regions with laws governing data transfers, we will take steps to ensure that your personal data has an adequate level of protection when transferred outside those regions, including by:

  • Relying on adequacy decisions where available; and/or
  • Using Standard Contractual Clauses or other legally recognized transfer mechanisms approved by the European Commission or relevant authorities.

You can contact us for more information about the safeguards we use for international data transfers.

7. Data Storage, Security, and Retention

7.1 Security

We use reasonable physical, technical, and organizational measures designed to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These include measures such as encryption in transit, access controls, and restricted access to personal data on a need-to-know basis.

However, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the security of your account credentials and limiting access to your devices.

7.2 Retention

We retain your information for as long as necessary to:

  • Provide and improve the App;
  • Comply with our legal obligations;
  • Resolve disputes; and
  • Enforce our agreements.

By way of example:

  • Emotional check-ins and journal entries are generally retained until you delete them or delete your account, subject to any backup or archival retention described below.
  • Account information is retained while your account is active and for a reasonable period thereafter where necessary for legitimate business purposes or legal obligations.
  • Aggregated, de-identified data may be retained for longer, as it no longer identifies you.

We may retain certain information in backup or archival systems for a limited period consistent with our backup policies, even after it has been deleted from our active systems.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information.

8.1 Access, Update, or Delete Information

  • Access and Update: You may access and update certain account or profile information directly within the App or by contacting us.
  • Deletion: You may request deletion of your account or certain information, subject to our legal obligations and legitimate business needs. Deleting your account may permanently erase some or all of your User Content from our active systems. We may retain limited information as required by law or for legitimate business purposes.

8.2 Additional Rights (EEA, UK, and Similar Jurisdictions)

If you are located in the EEA, UK, or a jurisdiction with similar rights, you may have the right to:

  • Request access to the personal data we hold about you;
  • Request correction of inaccurate or incomplete personal data;
  • Request deletion of your personal data;
  • Request restriction of processing of your personal data;
  • Object to certain processing (including where we rely on legitimate interests);
  • Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller (data portability);
  • Withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing prior to withdrawal; and
  • Lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law.

To exercise any of these rights, please contact us using the details in the “Contact Us” section below. We may need to verify your identity before responding to your request.

8.3 Communications Preferences

You may opt out of non-essential communications (such as optional tips or promotional messages) by following unsubscribe instructions in the messages or adjusting your settings where available.

We may still send you important service or administrative communications (such as security alerts or notices about changes to this Privacy Policy or our Terms of Use).

9. Children’s Privacy

The App is not intended for and may not be used by individuals under the age of eighteen (18), or under the age of majority in their jurisdiction, whichever is higher.

We do not knowingly collect personal information from children under this age. If we learn that we have collected personal information from a child in violation of this policy, we will take reasonable steps to delete it as soon as possible.

If you believe that a child has provided us with personal information, please contact us.

10. Third-Party Services and Links

The App may contain links to third-party websites or services or allow you to connect or integrate with third-party tools. This Privacy Policy does not apply to those third parties.

We are not responsible for the privacy practices of third parties, and we encourage you to read their privacy policies before providing information to them or using their services.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do:

  • We will revise the “Last Updated” date at the top of this page; and
  • In some cases, we may provide additional notice (such as a notification within the App).

Your continued use of the App after any changes become effective will signify your acknowledgment of and agreement to the updated Privacy Policy. If you do not agree with the changes, you must stop using the App.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise any rights available to you, please contact us at:

Feel First, Live Free, LLC

Email: info@michellevazzana.com

Mailing Address: PO Box 14958, North Palm Beach, FL 33408

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