Effective Date

This Privacy Policy is effective as of the date the Vòya application becomes publicly available.

1. Introduction

Vòya (“Vòya,” “we,” “our,” or “us”) is committed to protecting your personal data with transparency, accountability, and security.

This Privacy Policy explains how we collect, use, process, store, and protect your information when you access or use the Vòya platform (“Platform”).

This Policy applies to all users, including:

• Free users 
• Paid/subscribed users 
• Limited-access users 

By accessing or using Vòya, you enter into a legally binding agreement with Vòya and agree to the practices described in this Privacy Policy and any applicable Terms of Service. If you do not agree to these terms, you must immediately discontinue use of the Platform.

2. Legal Compliance Framework

We are committed to complying with applicable data protection and student safety laws, including:

• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection 
• Children's Online Privacy Protection Act 
• Family Educational Rights and Privacy Act (where applicable) 

3. Information We Collect

3.1 Personal & Profile Information

We may collect:

• Name, email address, phone number 
• Profile preferences 
• Academic details (institution, GPA, courses, credits) 
• Career data (resume details, skills, experience, job preferences) 

3.2 Usage & Activity Data

We collect how you interact with the Platform, including:

• Features used (academic tools, resume builder, mock interviews) 
• Time spent and activity logs
• Community interactions (posts, comments, likes, reports) 
• Engagement with deals and offers 

3.3 Device & Technical Information

We may collect:

• Device type, OS version, app version 
• Log files, crash reports, diagnostics 
• Approximate location (region/city level only) 

We do not require precise GPS tracking for core features.

3.4 Communication Data

We collect:

• Messages sent via support 
• Feedback submissions 
• Contact details for response purposes 

4. How We Use Information

We use your data to:

4.1 Provide Core Services

• Account creation and authentication 
• Feature access and personalization 

4.2 Academic & Career Support

• GPA calculations and academic tracking 
• Resume generation and job recommendations 
• Mock interview simulations 

4.3 Notifications

• Academic reminders 
• Career updates 
• Relevant offers and deals 

Users can control notifications within app settings.

4.4 Analytics & Improvement

We use aggregated and anonymized data to:

• Improve performance 
• Enhance user experience 
• Develop new features 

5. AI & Automated Decision-Making Disclaimer

Certain features of Vòya rely on artificial intelligence, including:

• Resume generation 
• Job recommendations 
• Mock interview simulations 

These outputs:

• Are generated using algorithms and user-provided data 
• May not always be accurate, complete, or suitable 

AI-generated content is provided for informational purposes only and does not constitute:

• Career advice 
• Financial advice 
• Legal advice 

You are solely responsible for reviewing and validating AI-generated outputs before relying on them.

5.1 Third-Party AI Services Disclaimer

Certain AI features within Vòya are powered by third-party artificial intelligence providers. Vòya does not own, operate, or control these underlying AI systems. Accordingly:

• Vòya takes no responsibility for the accuracy, completeness, reliability, or appropriateness of any content, suggestion, recommendation, or output generated by third-party AI systems 
• Vòya is not liable for any actions taken by users based on AI-generated content, including but not limited to career decisions, academic choices, or financial actions 
• Third-party AI providers operate under their own privacy policies, terms, and data processing agreements, which are independent of Vòya’s obligations 
• AI outputs may reflect limitations, biases, or errors inherent in underlying models; Vòya makes no representation that such outputs are free from these limitations 

Users should exercise independent judgment when acting on AI-generated content. To the extent permitted by applicable law, Vòya’s liability arising from reliance on AI-generated content is limited in accordance with Section 19 of this Policy. Vòya does not, however, exclude liability for any harm caused by its own gross negligence or willful misconduct in the delivery of AI features.

6. Voice Data & AI Processing

Some features may process text and voice inputs for AI-driven functionality.

• Voice data is used only within the session to generate responses and feedback 
• We do not use voice data for unrelated purposes 

Processing may involve secure transmission to third-party AI providers.

Users should avoid sharing:

• Sensitive personal data 
• Confidential academic or financial information 

7. Data Sharing & Disclosure

We do not sell personal data.

7.1 Service Providers

We may share limited data with trusted providers for:

• AI processing 
• Resume tools 
• Job listings 
• Payments 
• Analytics and infrastructure

7.2 Legal Obligations

We may disclose data:

• To comply with legal requirements 
• To protect user safety or platform integrity 

7.3 Business Transfers

In the event of a merger or acquisition, data may be transferred with appropriate safeguards.

8. Community Data & Moderation

Content shared in the Community module is:

• Publicly visible to other users 

8.1 Content License Grant

By submitting, posting, or uploading any content to the Community module or any other part of the Platform, you grant Vòya a worldwide, royalty-free, non-exclusive, sublicensable, and transferable license to use, display, reproduce, distribute, adapt, and publish such content across any current or future media formats, solely for the purpose of operating, promoting, and improving the Platform. This license terminates when you delete your content or account, except where content has been shared with others or is retained for legal compliance purposes.

You represent and warrant that you own or have the necessary rights to the content you submit, and that such content does not violate any applicable laws or third-party rights.

We use:

• Automated moderation tools 
• Manual review processes 

However:

• Moderation is not immediate 
• Some content may remain visible temporarily 

We reserve the right to:

• Remove content 
• Restrict access 
• Suspend accounts 

9. Data Retention

We retain data only as long as necessary for:

• Service delivery 
• Legal compliance 
• Dispute resolution 

Upon account deletion:

• Personal data is deleted or anonymized 
• Some data may be retained where legally required 

10. Data Security

We implement:

We process personal data in accordance with applicable data protection laws and regulations, including but not limited to the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, the Children’s Online Privacy Protection Act (COPPA), and the Family Educational Rights and Privacy Act (FERPA) where relevant.

To meet UAE PDPL requirements for transparency and legal basis mapping, each category of data processing is tied to a specific lawful ground as follows:

• Account Creation & Platform Access – Lawful Basis: Performance of a Contract. Processing your name, email, and credentials is necessary to create and maintain your account and deliver the services you have requested. 
• Analytics & Platform Improvement – Lawful Basis: Legitimate Interests. We use aggregated and anonymized usage data to understand how the Platform performs and to improve features. This processing is proportionate and does not override your fundamental rights or freedoms. 
• Marketing Notifications & Offers – Lawful Basis: Consent. We send promotional notifications, offers, and career updates only where you have given prior consent. You may withdraw consent at any time through the in-app notification settings, and withdrawal will not affect the lawfulness of any processing carried out before withdrawal. 
• AI-Powered Features (Resume, Interview, Recommendations) – Lawful Basis: Performance of a Contract and, where applicable, Consent. Processing your profile, academic, and career data through AI tools is necessary to deliver the core features you have signed up for. Where processing extends beyond core service delivery (for example, use of voice data), we rely on your explicit consent. 
• Legal Compliance & Dispute Resolution – Lawful Basis: Compliance with a Legal Obligation. Certain data is retained or disclosed to meet regulatory requirements, respond to lawful requests, or protect the rights of Vòya and its users. 

Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing conducted before withdrawal. Where processing is based on legitimate interests, you have the right to object, and we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

• Encryption 
• Access controls 
• Secure storage 
• Monitoring systems 

However:
No system is completely secure.

Users are responsible for:

• Protecting login credentials

11. Data Loss Disclaimer

We do not guarantee that all data will always be preserved.

Data loss may occur due to:

• System failures 
• Technical issues 
• Third-party disruptions 

Users should maintain backups of:

• Resumes 
• Academic records 
• Personal notes 

12. User Rights (US + UAE Aligned)

Depending on applicable laws, users may have the right to:

• Access personal data 
• Correct inaccuracies 
• Request deletion 
• Restrict processing 
• Withdraw consent 

Requests can be submitted via in-app support.

13. Children’s Privacy & Student Safety

• Users under 13 years are not permitted (COPPA compliance) 
• Users aged 13–18 require parental/guardian consent 

We do not knowingly collect data from children under 13.

If such data is identified, it will be deleted.

14. International Data Transfers

Your data may be processed in:

• United States 
• United Arab Emirates 
• Other jurisdictions where providers operate 

We implement safeguards to ensure lawful cross-border data protection.

15. Third-Party Integrations

Vòya integrates with third-party services for:

• AI processing 
• Resume creation 
• Job listings 
• Payments 

We are not responsible for:

• Their accuracy 
• Availability 
• Independent privacy practices 

16. Subscriptions & Payment Data

Subscriptions are managed via app stores.

• We do not directly store full payment details 
• Billing and refunds are governed by app store policies 

We may collect limited data related to:

• Subscription status 
• Cancellation feedback (optional) 

17. Intellectual Property & Ownership

All intellectual property rights in the Platform, including but not limited to software, design, features, content, AI outputs generated by the Platform, branding, trademarks, trade names, and proprietary methodologies, are owned exclusively by Vòya or its licensors. Nothing in this Privacy Policy or your use of the Platform transfers any intellectual property rights to you.

You agree that you will not, directly or indirectly:

• Copy, reproduce, modify, distribute, sell, lease, sublicense, or transfer any portion of the Platform or its content 
• Reverse engineer, decompile, disassemble, or attempt to extract the source code of the Platform or any of its components 
• Rescale, rebrand, white-label, or otherwise commercially exploit any part of the Platform without prior written consent from Vòya 
• Create derivative works from any part of the Platform or use any automated tool to scrape, mine, or extract data from it 

18. Warranty Disclaimer

THE PLATFORM AND ALL CONTENT, FEATURES, AND SERVICES ARE PROVIDED ON AN “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, VÒYA EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:

• Any implied warranty of merchantability, fitness for a particular purpose, or non-infringement 
• Any warranty that the Platform will be uninterrupted, error-free, secure, or free of viruses or other harmful components 
• Any warranty regarding the accuracy, completeness, or timeliness of any content, data, or AI outputs available through the Platform 
• Any warranty that access to the Platform will be continuous, timely, or available at any particular time 

Your use of the Platform is at your sole risk.

19. Limitation of Liability

To the maximum extent permitted by applicable law, including applicable consumer protection provisions in the UAE and the United States, Vòya’s total aggregate liability to any user for any claim arising out of or relating to the Platform, this Privacy Policy, or the services shall be limited to the total amount actually paid by that user to Vòya in the twelve (12) months immediately preceding the event giving rise to the claim. Where no such amount has been paid, our liability shall be limited to a reasonable amount proportionate to the nature of the claim and the services accessed, as determined by the applicable court or authority.

To the extent permitted by applicable law, Vòya shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of data, loss of profits, loss of revenue, loss of goodwill, or business interruption, however caused and under any theory of liability, even if Vòya has been advised of the possibility of such damages. This limitation does not apply where prohibited by mandatory consumer protection laws in the user’s jurisdiction.

Where a user has not made any payment to Vòya (for example, free-tier users), our liability shall be limited to the fullest extent permitted by applicable law, taking into account the nature of the services provided, the circumstances of the claim, and any mandatory protections that apply in the user’s jurisdiction. Nothing in this section limits liability for fraud, willful misconduct, or any other liability that cannot be excluded or limited by applicable law.

20. Dispute Resolution, Arbitration & Class Action Waiver

20.1 Governing Law & Jurisdiction

This Privacy Policy and any disputes arising from your use of the Platform shall be governed by and construed in accordance with the laws of the State of [INSERT STATE OF VÒYA REGISTRATION], United States, without regard to its conflict of law provisions. For users based in the UAE, applicable UAE law shall apply to the extent required by local regulations, including UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection.

20.2 Binding Arbitration

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy, the Platform, or your use of the services that cannot be resolved informally shall be submitted to binding arbitration administered by a recognized arbitration body (such as the American Arbitration Association) under its then-current rules. Arbitration shall take place in [INSERT STATE OF VÒYA REGISTRATION], United States. The arbitrator’s decision shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.

20.3 Class Action Waiver

YOU AND VÒYA AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION OR PROCEEDING. UNLESS BOTH PARTIES AGREE OTHERWISE, THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS, AND MAY NOT PRESIDE OVER ANY FORM OF CLASS OR REPRESENTATIVE PROCEEDING.

You may opt out of binding arbitration within 30 days of first accepting this Privacy Policy by sending written notice to Vòya via in-app support or the contact email provided in this Policy.

21. Force Majeure

Vòya shall not be liable for any failure or delay in performing its obligations under this Privacy Policy where such failure or delay results from any cause beyond Vòya’s reasonable control, including but not limited to acts of God, natural disasters, pandemics or epidemics, wars, civil unrest, acts of terrorism, cyberattacks, government regulations or restrictions, power failures, telecommunications or internet disruptions, or failures of third-party service providers.

In the event of a force majeure occurrence, Vòya will make reasonable efforts to notify users and restore normal service operations as soon as reasonably practicable.

22. Acceptable Use, Platform Safety & Misuse

By using the Platform, you agree to use it only for lawful purposes and in a manner consistent with all applicable local, national, and international laws and regulations. You agree that you will not:

• Upload, transmit, or distribute content that is harmful, threatening, abusive, harassing, defamatory, obscene, or otherwise objectionable 
• Impersonate any person or entity, or misrepresent your affiliation with any person or entity 
• Attempt to gain unauthorized access to any part of the Platform, its infrastructure, or other users’ accounts 
• Use the Platform for any fraudulent, deceptive, or unauthorized commercial purpose 

Vòya reserves the right to suspend or permanently terminate your account where there are reasonable grounds to believe a violation of this section or any other applicable terms has occurred. Where required by applicable law, Vòya will provide reasonable notice before termination except where immediate action is necessary to protect platform integrity, other users, or legal compliance. Vòya may also take legal action and cooperate with law enforcement authorities in connection with any suspected misuse of the Platform.

23. Global Data Protection Compliance

Where Vòya serves users outside the United States and the UAE, we acknowledge that additional data protection obligations may apply. We are committed to addressing the requirements of applicable international privacy frameworks to the extent they govern our operations. This includes:

• Honoring data subject rights (access, correction, deletion, portability, and objection) for users in applicable jurisdictions 
• Implementing appropriate technical and organizational safeguards for cross-border data transfers 
• Maintaining transparency about how personal data is collected, processed, and retained 
• Providing a mechanism to withdraw consent and opt out of non-essential data processing at any time 

Users in the European Economic Area or other jurisdictions with comparable data protection laws may submit requests for data access, portability, or erasure via in-app support. We will respond within the timeframe required by the applicable law.

24. Changes to This Privacy Policy

We reserve the right to update, modify, or replace this Privacy Policy at any time. When changes are made, we will:

• Post the updated Policy within the app with a revised effective date 
• Notify users of material changes via in-app notification or email where required by applicable law 
• Make changes effective upon publication unless a later date is specified 
• Seek fresh consent where required by applicable data protection laws 

Continued use of Vòya after a policy update constitutes your acceptance of the revised terms. Vòya also reserves the right to suspend or terminate access to the Platform where there are legitimate operational, legal, or safety grounds for doing so, and will provide reasonable advance notice where required by applicable law.