Privacy Policy — VOW

This Privacy Policy explains how Orion GLE Ltd (“we”, “us”, “our”) processes personal data in relation to the VOW mobile application (“VOW” or the “App”). VOW may be offered as a pre-release/beta product.

1. Who we are

Orion GLE Ltd is the data controller for personal data processed in connection with VOW, unless stated otherwise. If you have questions or requests about this Policy or your data, contact support@oriongle.co.uk.

2. Summary

• We aim to minimise data. VOW is designed to work without requiring you to provide personal details.
• We do not sell personal data.
• If we use analytics/crash reporting, it will be to improve reliability and performance (see Section 6).
• Beta note: pre-release versions may collect limited diagnostic information to help fix issues.

3. Data we may collect

Depending on how VOW is configured and used, we may process:

• Support communications (if you email us): your email address and the information you include in your message.
• Diagnostics / crash data (optional): technical information about the device/app to help identify and fix faults.
• Basic usage events (optional): high-level, non-content events (e.g., app opened, feature used) to understand stability and improve UX.

We do not intentionally collect special category data (e.g., health data), and we do not request your contacts, photos, microphone, camera, or precise location unless explicitly stated in-app at the time a permission is requested.

4. Information processed on your device

VOW may store settings or progress locally on your device (e.g., preferences, local app state) so the app can operate. This information is primarily processed locally and may not be transmitted to us unless you enable features that require it (e.g., cloud sync) or send logs to support.

5. How we use your data

• To operate and provide VOW’s functionality.
• To respond to support requests and communicate with you.
• To maintain, secure, troubleshoot, and improve VOW (including fixing bugs and crashes).
• To comply with legal obligations and enforce our Terms.

6. Analytics and crash reporting

We may use reputable third-party services for crash reporting or analytics to improve VOW. Where used, these services may receive limited device/app information (e.g., OS version, device model, crash trace). We configure these tools to minimise data and avoid collecting content you enter into the app (where applicable).

If we introduce or change analytics providers, we will update this Policy and, where required, provide additional notice in the App.

7. Legal bases (UK GDPR)

We process personal data under one or more of the following lawful bases:

• Contract — to provide the App and related services you request.
• Legitimate interests — to maintain and improve the App, prevent fraud/abuse, and ensure security (balanced against your rights).
• Consent — where required for certain optional analytics or features (you can withdraw consent in-app where offered).
• Legal obligation — where we must comply with law or regulator requests.

8. Sharing your data

We may share limited information with:

• Service providers (processors) that help us deliver VOW (e.g., hosting, crash reporting), under contract and confidentiality.
• Legal/regulatory authorities where required by law or to protect our rights/users.

We do not sell personal data and do not share it for third-party marketing purposes.

9. International transfers

Some service providers may process data outside the UK. Where that occurs, we use appropriate safeguards (such as UK addendum to EU SCCs or other legally recognised mechanisms) to protect your data.

10. Data retention

• Support emails: retained as long as needed to resolve your request and for reasonable records.
• Diagnostics/analytics: retained for a limited period based on operational needs (typically months) unless longer retention is required for security or legal reasons.

We may retain anonymised, aggregated statistics that no longer identify you.

11. Security

We implement appropriate technical and organisational measures to protect personal data. No system is 100% secure; you should keep your device secure and up to date.

12. Children

VOW is not intended for children under 13. If you believe a child has provided us with personal data, contact us and we will take steps to remove it.

13. Your rights

Subject to UK GDPR, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Delete data
• Restrict or object to processing
• Data portability (where applicable)
• Withdraw consent (where processing is based on consent)

To exercise rights, email support@oriongle.co.uk. We may need to verify your identity.

14. Complaints

You can complain to the UK Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint. We would appreciate the chance to address your concerns first by contacting us.

15. Changes to this Policy

We may update this Policy from time to time. We will revise the “Effective date” above and, where appropriate, notify you in-app.