Introduction
SCOVR™ (“we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy explains how AMVLET Technologies Ltd., as the operator of SCOVR, collects, uses, discloses, and safeguards your personal data when you use our website SCOVR.COM or any related services (collectively, the “Services”). We adhere to the Seychelles Data Protection Act 2023 and other applicable privacy laws, which aim to protect individuals’ personal data and privacy. By using our Services or providing us with your personal information, you agree to the practices described in this Privacy Policy.

Data Controller and Contact
The data controller responsible for your personal data is AMVLET Technologies Ltd., a company registered in the Republic of Seychelles (referred to as “SCOVR” or “the Company” in this policy).

If you have any questions or requests regarding your personal data or this Privacy Policy,
you can contact us at: Email: hi [at] scovr [dot] com

*Postal Address
AMVLET Technologies Ltd.
Vistra Corporate Services Centre
Suite 23, 1st Floor, Eden Plaza, Eden Island
Mahé
Republic of Seychelles

*Please note that our registered office in Seychelles cannot receive or process correspondence. Any letters sent to our corporate address will not reach our team. Email ensures your request is handled securely.

Personal Data We Collect
We collect only the personal data that is necessary for the purposes set out in this policy. The types of personal data we may collect include:

Contact Information
When you join our waitlist or otherwise sign up on our Site, we collect your first name and email address. This allows us to identify you and communicate with you (for example, to send you updates about SCOVR’s launch or news).

Account Credentials
If you register for a SCOVR account (SCOVR ID), we will collect the information needed to create and secure your account, such as a username or SCOVR ID and a password. This is used for authentication and login purposes.

Communications
If you contact us directly (for example, via email or a contact form), we will receive the information you provide in your message (such as your name, email, and the content of your inquiry).

Usage Data
When you visit our website, certain technical information may be collected automatically, such as your IP address, browser type, and operating system. We collect such data through server logs without using any cookies or tracking scripts, for the purposes of ensuring security and analysing aggregate usage of our Site. No cookies are used on our Site at this time.

Optional Profile Information
(In the future, if our Services allow you to create a user profile or provide additional details, we will collect any information you choose to provide such as a profile photo, bio, interests, etc. However, as of now, our pre-launch waitlist only requires a first name and email.)We do not collect any sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health information, or the like, as these categories may receive additional safeguards under Seychelles law. We also do not knowingly collect personal data from children (see Children’s Privacy below).

How We Use Your Data
We will only process your personal data fairly and lawfully and for the specific purposes that we have communicated to you. The purposes for which SCOVR processes your data include:

Providing and Improving Our Services
We use your information to operate the waitlist and, in the future, to create and manage your SCOVR account and deliver the social networking service. For example, your email will be used to send you an invitation when SCOVR launches or to allow you to log in to the SCOVR app with your credentials.

Communication
We use your first name and email to send you updates, newsletters, or announcements about SCOVR’s development, new features, and launch. (For instance, if you sign up for the waitlist, we will email you when SCOVR becomes available and share important news.) We may also respond to your inquiries or support requests using your contact details.
Consent-Based Communications: Where required by law or where we deem appropriate, we will only send you promotional emails if you have consented to receive them. You always have the option to opt out of such emails by clicking an unsubscribe link (if provided) or by contacting us.

Service Personalization (Future Use)
Once the SCOVR platform is live, we might use certain data (like your app usage or location, if provided) to personalize your experience – for example, suggesting local meet-ups or friends. Any such features will be clearly explained and, if they involve new data collection, we will update this Privacy Policy accordingly.

Legal and Security Purposes
We may process personal data as necessary to comply with legal obligations or to protect our legal rights. For example, we might retain records of communications for legal record-keeping, or use information to investigate and prevent fraudulent activities or violations of our Terms and Conditions. We also use usage data (like IP addresses) to monitor for unusual or suspicious activities on our website for security purposes.We will not use your personal data for any purposes that are incompatible with the original purposes for which it was collected without obtaining your consent or complying with applicable law. In practice, this means we will not sell your personal information to third parties, and we will not use it for any unrelated marketing without your permission.

Legal Bases for Processing
SCOVR processes your personal data on the following bases:

Consent
By joining our waitlist or otherwise providing your personal data, you consent to our collection and use of your information for the stated purposes (e.g. emailing you updates).

Performance of a Contract
When the SCOVR platform is launched, if you create an account or use our Service, we will process your data as necessary to perform our contract with you (i.e., to provide the SCOVR ID service and associated features).

Legitimate Interests
We may process certain data for our legitimate interests, such as improving the website and services, ensuring IT security, and communicating with users about product updates, provided these interests are not overridden by your data protection rights.

Legal Obligation
In some cases, we may need to process or retain data to fulfil a legal obligation (for example, record-keeping for compliance or responding to lawful requests by authorities). (Even when we rely on consent as a legal basis, you are entitled to withdraw that consent at any time as described below in Your Rights. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.)

Cookies and Tracking
We do not use cookies or similar tracking technologies on our website at this time. We do not deploy any third-party analytics scripts or advertising trackers that collect personal data. Any future implementation of cookies or trackers will be disclosed via an updated Privacy Policy and, if required, through a cookie consent banner or similar mechanism. For now, you can rest assured that simply browsing our Site will not place any cookies on your device.

Data Sharing and Disclosure
We treat your personal data with care and confidentiality. We do not sell or rent your personal data to third parties. Furthermore, we only share your data in the following circumstances:

Service Providers
We may share information with trusted third-party service providers who perform functions and services on our behalf. For example, we might use an email service platform to send out our waitlist updates or use cloud hosting providers to store our database. These service providers will only have access to the information necessary to perform their tasks and are contractually obligated to protect your data and use it solely for providing services to us.

Within Our Corporate Group
If AMVLET Technologies Ltd. has affiliates, parent, or subsidiary companies (collectively, the “AMVLET GROUP”), we may share data within our corporate group as needed to support the SCOVR Service (for example, if certain operations or support are handled by another entity within our group). All group members will abide by the same privacy protections outlined here.

Legal Requirements
We may disclose your personal data if required to do so by law or in response to valid legal requests (e.g., a subpoena, court order, or request from law enforcement or regulatory authority). We may also disclose information if we believe in good faith that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users or the public, or (iv) protect against legal liability.

Business Transfers
In the event of a reorganization, merger, acquisition, or sale of all or part of our business, any personal data we hold may be transferred to the relevant third party as part of the transaction. We will ensure that the new owner will continue to honour the privacy rights and commitments we make in this policy. Any third parties with whom we share data will be bound to protect that data in compliance with applicable privacy standards. We will never disclose more information than necessary for the purpose at hand, and we will not allow third parties to use the data for their own independent marketing or purposes unrelated to the reason we shared it.

International Data Transfers
SCOVR is available to users in multiple countries (including Saudi Arabia, UAE, USA, EU, Switzerland, and others). Your personal data may be transferred to and stored on servers located in countries outside your jurisdiction during waitlist or Beta.

Once SCOVR is live, we will store and process your personal data within your jurisdiction (data residency), with only limited, safeguarded cross-border transfers when strictly necessary (e.g., security telemetry or 24/7 support).
Data residency (once live). We will store and process your personal data within your jurisdiction: In particular, as a Seychelles-based service, the data we collect will be processed in our user's jurisdiction.

Saudi Arabia: under PDPL, SDAIA/CST guidance
United Arab Emirates: under PDPL, applicable federal/emirate rules
European Union/EEA: under GDPR
Switzerland: under revDSG
United States: under SOC 2, HIPAA

Other countries
In-country where we operate a local cluster; if not yet available, the nearest compliant regional cluster will be used temporarily until your local cluster launches. Additionally, we may use cloud services or service providers based in other countries (for example, email or infrastructure providers in the United States or Europe). Whenever we transfer personal data outside your country of residence, we will take steps to ensure that adequate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable law. We will never transfer your personal data to another country or put your data at undue risk.

Data Retention
We keep your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law. Specifically:If you join our waitlist, we will retain your first name and email for as long as the waitlist is active, and we continue to send updates, or until you request deletion. If you choose not to join SCOVR when invited, you may request that we remove your data from the waitlist.If you create a SCOVR account when the service launches, we will retain your account data for as long as you maintain an active account. If you decide to delete your account, we will remove or anonymize your personal data within a reasonable timeframe, except for any data we are required to keep for legal compliance or legitimate business purposes. Please note that we have a one account policy.If you contact us with a question or support request, we may keep that correspondence and your contact details for a period necessary to address your issue and maintain records of our communications.We periodically review the data we hold. When personal data is no longer needed for its intended purpose, and we are not legally required to retain it, we will securely delete or anonymize it. For example, if our waitlist campaign ends and a user has not created an account or engaged further, we may delete their waitlist information after a certain period.Please note that backup systems might retain residual copies of your personal data for a short duration even after deletion, but such copies will be removed in accordance with our backup retention schedules.

Data Security
We take appropriate security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

Technical safeguards
We use encryption, secure servers, and HTTPS (SSL/TLS) protocol to encrypt data in transit. Stored passwords are hashed, and sensitive data is encrypted at rest where applicable. Our databases and systems are protected by firewalls and access controls to prevent unauthorised access.

Organisational measures
We restrict access to personal data to employees or contractors who need that information to operate or develop our Service. Those who have access are subject to confidentiality obligations. We provide training to our team about data protection and security best practices.

Testing and updates
We regularly update our software and systems to address security vulnerabilities. We may perform security testing or audits to ensure our safeguards remain effective.

Incident response
In the unlikely event of a data breach or security incident, we have procedures in place to respond promptly. Although Seychelles law does not currently mandate breach notifications, we intend to notify affected users and relevant authorities of significant breaches as a matter of transparency and trust. Keep in mind that no method of transmission over the internet or electronic storage is 100% secure, so we cannot guarantee absolute security of your data. However, we strive to use commercially acceptable means to protect your personal information. You also play a role in security: please consider using a strong, unique password for your SCOVR ID account and

notify us immediately at: hi [at] scovr [dot] com

f you suspect any unauthorised use of your account or any security vulnerability.

Your Rights
Under Seychelles law and other applicable data protection laws, you have certain rights regarding your personal data. We are committed to upholding these rights, which include:

Right to Confirmation and Access
You are entitled to ask us to confirm whether we are processing any personal data about you. If we do, you are entitled to access that data and receive a copy of the personal information we hold on you, along with information on how we process it.

Right to Correction
If any of your personal data that we hold is inaccurate or out-of-date, you are entitled to request that we correct or update it. We encourage you to keep your information with us current (for example, if you have an account profile, you can update certain information directly).

Right to Erasure
You are entitled to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent (where applicable) or object to processing. We have no overriding legitimate grounds to continue, or if we have processed your data unlawfully. Upon a valid request, we will erase your information, except to the extent we are required to retain it by law or have a legitimate interest in retaining it (for instance, for legal claims or record-keeping).

Right to Object or Restrict Processing
In certain circumstances, you may have the right to object to or ask us to limit the processing of your personal data (for example, if you contest the accuracy of the data or when you have objected to processing and are awaiting verification of our legitimate grounds). If you object to receiving marketing emails from us, we will honour that objection and stop sending you such communications.

Right to Data Portability
For data that you have provided to us and is processed by automated means because of consent or contract, you may have the right to request a copy of that data in a structured, commonly used, machine-readable format. You may also have it transmitted to another service provider where technically feasible. (Note: This right applies largely to jurisdictions like the EU under GDPR. We will endeavour to assist with such requests to the extent applicable.)

Right to Withdraw Consent
If we are processing your personal data based on your consent, you are entitled to withdraw that consent at any time. This will not affect the lawfulness of processing that was done before withdrawal. For example, if you no longer want to be on our waitlist mailing, you can unsubscribe or contact us to remove you, and we will stop processing your data for that purpose.

Right to Complain
We hope to resolve any questions or concerns you have about our use of your data. However, if you feel we have not addressed your concern satisfactorily, you are entitled to lodge a complaint with the Office of the Data Protection Commissioner in Seychelles (once this authority is established under the Data Protection Act 2023) or any relevant supervisory authority in your country of residence (for example, PDPL in Saudi Arabia).

To exercise your rights
Please contact us at: hi [at] scovr [dot] com with your request.

We may need to verify your identity before fulfilling certain requests (to ensure that we do not disclose data to an unauthorised person). We will respond to your request within a reasonable timeframe and in accordance with applicable law. In general, we will not charge a fee for processing your request, unless it is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request (as permitted by law).

Children’s Privacy
SCOVR’s Services are not intended for children under the age of 13+. We do not knowingly collect personal data from anyone under 13+ years old. If you are under 13+, please do not provide any personal information to us or use our Service. In the event we learn that we have inadvertently collected personal data from a user under 13+, we will take steps to delete such information as soon as possible. Parents or guardians who believe that their child may have provided us with personal information can contact us at: hi [at] scovr [dot] com, and we will promptly investigate and address the issue. (If in the future we open any features for younger audiences, we will do so in compliance with applicable youth privacy laws and update this policy accordingly.)

Changes to This Privacy Policy
We may update this Privacy Policy occasionally to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will post the updated policy on this page and update the “Last updated” date at the bottom.

Material changes will be highlighted or communicated (for example, via email notice or a notice on our website) to ensure you are informed. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.Your continued use of SCOVR’s services after any changes to this Privacy Policy constitutes your acceptance of the updated terms, to the extent permitted by law. If you do not agree with any updates or changes, you should stop using the Services and can request that we delete your personal data as outlined above.

Contact Us
If you require any further assistance, concerns, or requests regarding this Privacy Policy or your personal data, please contact us: Email: hi [at] scovr [dot] com.

*Postal Address
AMVLET Technologies Ltd.
Vistra Corporate Services Centre
Suite 23, 1st Floor, Eden Plaza
Eden Island
Mahé
Republic of Seychelles

*Please note that our registered office in Seychelles cannot receive or process correspondence. Any letters sent to our corporate address will not reach our team. Email ensures your request is handled securely.

We will be happy to assist you and address any issues to the best of our ability. Your privacy is important to us, and we appreciate the trust you place in SCOVR.

Last Updated: 25. September 2025