Adzi Privacy Policy

Last Updated: May 04, 2026

1. Introduction

VELRIO LIMITED is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, process, and share your personal information when you use the Service (as this term is defined below). It is an integral part of our Terms of Service, and by accessing or using the Service, you confirm that you have read, understood, and agree to the practices described in this Policy. If you do not agree with this Privacy Policy, you must cease using the Service and may request deletion of your data as described below.

Findmy LLC collects and processes personal data in connection with the Service, including its operation and technical support, as described in this Privacy Policy.

For purposes of this Policy, the following definitions apply:

2. Data Controller and Contact Information

For the purposes of applicable data protection laws (such as the GDPR and UK GDPR), the data controller of your Personal Data is Findmy LLC ("Company", "we", "us" or "our"). Findmy LLC is a Delaware limited liability company with offices at 501 E las Olas Blvd, Suite 300, Fort Lauderdale, Fl 33301, USA. If you have any questions, requests, or concerns regarding your Personal Data or this Privacy Policy, please contact us by email at: [email protected]. Please include "Privacy Inquiry" in the subject line of your email so we can route your request to the appropriate team.

3. Information We Collect

We collect information about you in several ways: (1) information you provide directly to us, (2) information collected automatically when you use the Service, and (3) information from third parties or integrated services. We limit our collection to what is relevant for operating and improving Adzi. Below we explain the categories of Personal Data we collect.

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information from Third Parties

In certain cases, we may obtain information about you from third-party sources:

In all cases, any information we obtain from third-party sources will be combined with information you provide and information collected automatically, and treated according to this Privacy Policy.

4. How We Use Your Information

We process your Personal Data for the following purposes, and rely on appropriate legal bases (outlined in Section 5) for each purpose. In essence, we use the collected information in order to operate and improve the Service, communicate with you, personalize your experience, and fulfill our obligations. Below we describe each of these purposes in more detail:

4.1. To Provide and Maintain the Service: We use your information to operate the Adzi platform and deliver core features and content to you. This includes using your registration information to create and secure your account, authenticating your logins, and enabling you to access the materials, tools, and personalized plans. We process the inputs you provide (for example, your responses to our questionnaire or queries submitted to our AI tools) to generate the results or content you request. We also use technical data to ensure the Service works correctly on your device, to adapt to your screen size or language, and to monitor the Service's uptime and performance. Maintaining the Service also involves routine administrative and technical activities like backing up our database, updating software, and cybersecurity measures. In short, we use whatever information is necessary to provide you with the services and features you have requested and to ensure Adzi is running smoothly. This also means fixing errors or bugs you might encounter - e.g. if an error log or crash report indicates something didn't load properly for you, we will use that information to troubleshoot the issue. Without processing your personal data for these core functions, we would not be able to offer the Service to you.

4.2. To Manage Your Account and Provide Support: We process personal data to administer your user account and to assist you when you reach out for help. For example, we use your email (or phone number, if provided for contact) to communicate with you about your account status, to send password reset links upon request, or to notify you of changes to your subscription. If you contact us with a support question or issue, we will review your information (such as your account details and any relevant usage logs) and the content of your request in order to respond. This may involve accessing your account settings or usage history to replicate an issue and find a solution. We also use your information to manage preferences or settings you configure in your account (for instance, if you opt-in or opt-out of certain features or communications, our systems will record and honor those preferences). Providing effective customer service is an important part of our contract with you, so we use whatever information is necessary (and appropriate) to fulfill your inquiries and requests. This can include technical support, answering questions about content, or processing requests to exercise your data rights.

4.3. To Communicate With You: We use your contact information to send you important administrative or transactional communications related to the Service. This includes messages such as confirmation emails when you register, welcome emails with guidance on getting started, notifications about changes to our Terms of Service or this Privacy Policy, alerts about security or privacy issues, and receipts or invoices for your purchases. These communications are necessary for us to perform the Service and keep you informed. They are not promotional in nature, and you cannot opt out of receiving critical service announcements (aside from canceling your account) because we need to ensure you receive them. In addition, if you have opted in to receive marketing communications from us (or if otherwise permissible under applicable law), we will use your email address (or other provided channel) to send you newsletters, updates, and offers about our products and services. For example, we may send tips on how to better use Adzi, information about new features or special promotions for subscription upgrades. You can always opt out of marketing emails by clicking the "unsubscribe" link in any such email, or by contacting us directly - we will respect and execute such opt-outs promptly. We may use third-party email services to manage and deliver our email communications, but these providers are only allowed to use your email for sending our messages and not for other purposes (see "Service Providers" in Section 6). Note: opting out of marketing emails will not affect your receipt of important service-related communications (described above) which we will still send when necessary.

4.4. For Research, Analytics, and Service Improvement: We analyze the information we collect about users' interactions with our Service in order to understand usage trends and make improvements. This means using data like device information, usage logs, and feedback to gain insights into how our product is performing and how it can be enhanced. For example, we might evaluate which lesson modules are most frequently completed or where users tend to drop off in a tutorial, and then use that insight to improve our content or user interface. We might perform A/B testing (showing different users slight variations of content or layout) and measure the results to see which version is more effective. We also monitor the effectiveness of new features by analyzing how often they're used and gathering user feedback or success rates, which helps us refine those features. In doing so, we often work with aggregated or pseudonymized data whenever possible, for instance, generating statistics on overall feature usage rather than focusing on any single user. If we use analytics cookies or similar technologies to assist in this (as described in Section 3.2), we will do so in compliance with applicable requirements. The end goal of processing data for this purpose is to continuously improve the content, functionality, and security of Adzi, providing a better experience for all users. In some cases, research and development may involve machine learning: for example, we may use a sample of anonymized user queries to the AI tools to train or fine-tune the AI models that power it. If you have opted out of such use of your data, however, your queries will be excluded from model training datasets. All improvement-related processing is done under careful controls to protect your privacy (e.g., using internal analytics tools or trusted partners, and stripping out direct identifiers whenever feasible).

We may also analyze user interactions with the Service, including navigation patterns, feature usage, and engagement with content, to better understand how users interact with the platform and to improve functionality, usability, and overall user experience. Such analysis is typically performed using aggregated or pseudonymized data wherever possible.

4.5. To Personalize Content and Advertising: We want to make the Adzi experience as relevant as possible to each user. We may use the information we have about you to personalize your experience within the Service, for example by tailoring content, advertising creatives, tools, and recommendations based on your activity, preferences, and interactions with the platform. We may also use limited analytics and attribution data to understand how users discover and engage with the Service, and to improve the relevance and effectiveness of our features and user experience. Any advertising or marketing use of data is done in accordance with applicable law, for example, in certain jurisdictions we will only do targeted advertising if you have given consent for advertising cookies. Your choices: You have the ability to influence how your data is used for advertising. As mentioned above, you can opt out of third-party advertising cookies by using industry tools like NAI or DAA opt-out pages, or by adjusting your mobile device settings to limit ad tracking. On the web, enabling your browser's Do Not Track (DNT) signal or using browser extensions can also reduce tracking. Keep in mind that even if you opt out of personalized ads, you may still see non-targeted ads for Adzi (or other services); they just won't be tailored using cookies or your behavior.

4.6. To Process Payments: When you make a purchase or subscribe to Adzi’s paid offerings, we process the necessary Personal Data to complete the transaction. This includes using your payment information to charge the correct amount, verifying that the payment was successful, and updating your account's subscription status. Our use of your data for payments also covers activities like sending you billing receipts or notifications of upcoming subscription renewals, and handling any billing-related inquiries or disputes. As noted, we rely on third-party payment processors, so much of this processing is actually done by them on our behalf, but we retain enough information (like transaction IDs and subscription identifiers) to manage your billing internally. Processing payments inherently involves sharing data with the payment gateway and banks involved, and we ensure that industry-standard security measures (such as encryption) are in place for these flows. Without using your data in this way, we couldn't charge you or provide paid features you sign up for, so this processing is essential when you choose to make use of paid services.

4.7. To Enforce Our Terms and Prevent Fraud/Misuse: We are committed to maintaining a trusted and secure environment, so we use personal data to enforce our agreements and policies, and to detect or prevent harmful, fraudulent, or illegal activities. This can include monitoring for violations of our Terms of Service. We may use certain data (like device identifiers or IP addresses) to ensure one individual isn't creating multiple free trial accounts in a manner that violates our terms. If we suspect that an account is engaged in fraud or abuse (such as using stolen credit cards, engaging in harassing behavior on any community features, or attempting to hack or spam our systems), we will investigate using the data we have, this might involve reviewing account activity logs or sharing information with law enforcement if appropriate. We also use your information to protect our rights, property, and safety, as well as those of our users and others. This type of processing is aimed at keeping Adzi safe and trustworthy for everyone.

4.8. To Comply with Legal Obligations: Finally, we will process and/or disclose your Personal Data when necessary to comply with our legal obligations. This includes situations such as responding to lawful requests by public authorities or law enforcement (e.g., complying with a court order or valid subpoena), fulfilling our regulatory reporting duties, or meeting financial and tax record-keeping requirements. For example, under U.S. law we might be required to retain and report certain transaction information for tax purposes or to prevent money laundering. If we receive a request from a government agency concerning a user's data, we will only comply if the request is legally valid and necessary. We may also use or preserve data as needed to exercise our legal rights or defend against legal claims, for instance, retaining certain account records if we are in a litigation hold or if a dispute arises with a user. Additionally, we may disclose information if we believe in good faith that it's necessary to prevent an imminent harm (such as to prevent fraud or to protect someone's safety), though this typically falls under legal obligations or our legitimate interests in safety. In summary, when the law requires us to process or share data, we will do so, but we will limit the Personal Data to what is necessary and will ensure any disclosure is properly authorized.

5. Legal Basis for Processing (EEA, UK, Brazil, and Canada)

If you are located in a jurisdiction that requires a lawful basis for processing personal data (such as under the GDPR in the European Union, UK GDPR in the United Kingdom, or similar laws), we only process your Personal Data when we have a valid legal basis to do so. This section explains the legal grounds we rely on for the processing activities described above:

For Brazilian users: In compliance with the LGPD, we note that the above bases correspond to LGPD legal bases such as your consent (Art. 7(I)), when needed; performance of a contract (Art. 7(V)); legitimate interests of the controller (Art. 7(IX)), balanced against your rights; and compliance with legal obligations (Art. 7(II)). We will also rely on other bases as appropriate (for instance, credit protection or the regular exercise of rights in judicial processes, if applicable).

For Canadian users (PIPEDA): We will typically obtain your consent for the collection, use, or disclosure of personal information, except where otherwise permitted by law. By using the Service, you consent to our data practices as described, and you may withdraw consent for non-essential uses. Some of our processing may also be under what PIPEDA recognizes as reasonable purposes for our business, in line with your expectations (we always strive to meet the PIPEDA principles of accountability, transparency, and individual access, among others).

If you have any questions about the legal basis on which we collect and use your personal information, please contact us (see Section 14 "Contact Us").

6. How We Share Your Information

We treat your Personal Data with care and confidentiality. We do not sell your Personal Data to third parties for money, and we do not share it with third parties for their own independent marketing purposes. However, we do share your information with certain trusted third parties in the following circumstances, and only for the purposes described in this Privacy Policy:

7. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your Personal Data. We are committed to honoring these rights and have processes in place to enable you to exercise them. These rights may include:

These rights are not absolute and they may have certain conditions or limitations under applicable law. For instance, we might not be able to fully comply if a request is unduly excessive or jeopardizes the rights of others, but we will always respond and explain our decision.

Exercising Your Rights: To exercise any of your applicable privacy rights (other than lodging a complaint with an external authority), you may contact us at: [email protected]. Please clearly state your request for example, "I am requesting access to my personal data" or "Please delete my account and all related data." For your privacy and security, we will need to verify your identity before processing certain requests, especially for access, deletion, or portability. We may ask you to provide information that matches our records (such as verifying your email address or other account details) to ensure you are the account holder. We will respond to your request within the timeframe required by law (generally within 30 days for most laws like GDPR, with the possibility of extension if necessary). If we need more time or cannot fulfill your request, we will inform you of the reason (subject to any legal restrictions). There is no fee for exercising your rights unless the requests are manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request (but we would provide an explanation in such cases).

Additional Notice for Brazilian Users (LGPD): In addition to the rights listed above, users in Brazil have rights under the LGPD including: the right to confirmation of the existence of processing, the right to anonymization, blocking or deletion of unnecessary or excessive data or data processed in non-compliance with the law, and the right to information about entities with which we have shared your data. We believe these are largely covered by the rights described in this section. We will handle requests from Brazilian users in accordance with the LGPD's requirements. If needed, you can designate an authorized agent to make requests on your behalf (we will take steps to verify the agent's authority and your identity).

Additional Notice for Canadian Users: While PIPEDA does not enumerate rights in the same way as GDPR, you have the right to access the personal information we hold about you and the right to request correction of any inaccuracies. You also have the right to challenge our compliance with PIPEDA's principles by contacting us or the Office of the Privacy Commissioner of Canada. We will assist with your access requests and provide you with your information, subject to any exceptions permitted by law (for example, information that would reveal personal data about another individual). If you withdraw consent for certain processing (where consent was the basis), we will stop that processing, provided no legal exception applies.

We are committed to respecting all users' rights irrespective of location. Even if you are not in a region with specific privacy laws, we will endeavor to honor your requests about your Personal Data to a reasonable extent. If you have any questions or concerns about your rights or how to exercise them, please contact us at the email provided above.

8. Age Requirements

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18 years old. If you are under 18, you must only use the Service with parental or guardian consent. Parents or legal guardians should supervise the use of our Service by minors and are responsible for ensuring that minors' use is in accordance with this Policy.

If we become aware that we have inadvertently collected Personal Data from a child under 18 without appropriate consent, we will take immediate steps to delete such information from our records. If you believe that a child under 18 may have provided us with personal information without your (the parent's) consent, please contact us at: [email protected] immediately, and we will investigate and promptly remove the data in question. We do not sell the personal data of minors under 18 as defined by applicable laws (including the Children's Online Privacy Protection Act, COPPA, in the U.S., which generally applies to children under 13, and similar laws). Our commitment is to protect children's privacy and comply with all relevant laws and regulations regarding children's data.

9. International Data Transfers

Adzi is a global service, and your Personal Data may be transferred to, stored in, and processed in countries other than your own. In particular, the data we collect is often stored on servers in the United States, using cloud infrastructure provided by Amazon Web Services (AWS), and may also be processed in the European Union (for example, if we have team members or contractors in the EU, or if we use European-based infrastructure) or other jurisdictions. This means that your information could be subject to privacy laws that are different from those in your home country.

However, regardless of where your data is processed, we protect it in accordance with this Privacy Policy and take appropriate safeguards to ensure its security and integrity. When we transfer Personal Data from individuals in the EEA, UK, or Switzerland to countries that the European Commission (or relevant UK/Swiss authorities) has not deemed to have an "adequate" level of data protection (such as the United States), we rely on approved legal mechanisms to ensure your data remains protected. These mechanisms may include:

We also require that our service providers and partners, regardless of location, maintain adequate security measures and, where required by law, enter into data processing agreements including transfer safeguards.

Your Rights and Protections: If you are a resident of the EEA, UK, or certain other jurisdictions, you have rights to be informed about and object to certain international transfers. We have put the above measures in place to protect your data when transferred internationally, and we remain responsible for it as the controller.

If you have questions about our international data handling, please contact us. By using our Service or providing information to us, you acknowledge the transfer of your personal data across borders as described here, and understand that the data may become subject to the laws of the destination country.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. If we make material changes to how we handle your Personal Data, we will provide you with notice in advance of the change becoming effective, as required by law. This may include a prominent notice on our website(s), in Services notification, or an email notification to the address associated with your account. We will indicate at the top of the Policy the date of the latest revision (see "Last Updated" date).

Whenever we update the Policy, we will give you the opportunity to review the revised terms. If you continue to use the Service after the new Privacy Policy has taken effect, this will constitute your acceptance of the changes. However, if any changes require your consent (for example, if we plan to use your Personal Data for a new purpose that requires consent under applicable law), we will obtain your consent accordingly.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. If you do not agree with any updates or changes, you should cease using the Service and may request that your data be deleted.

11. California Privacy Rights (CCPA and "Shine the Light" Law)

This section applies solely to residents of California, USA, and supplements the rest of our Privacy Policy. It describes how we handle personal information of California consumers and the rights that California consumers have under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and California's "Shine the Light" law.

Categories of Personal Information Collected: In the 12 months preceding the Last Updated date of this Policy, we have collected the following categories of personal information (as defined by CCPA) about California consumers through the Service: identifiers (like name, email address, IP address); personal information categories listed in California Civil Code §1798.80 (such as payment information, limited to transactional records since we don't store card numbers); characteristics of protected classifications; internet or other electronic network activity information (device and usage data as detailed in this Policy); geolocation data (to the limited extent of general location via IP); and inferences drawn from the above (e.g., a user's potential interests or preferences based on usage). We collect these categories of information from the sources and for the purposes described in Sections 3 and 4 of this Policy.

Disclosure of Personal Information: We may disclose the above categories of personal information to third parties for our business purposes, as described in Section 6 (e.g., to service providers like cloud hosts, analytics providers, payment processors, etc., and in other limited circumstances like legal compliance). In the past 12 months, we have disclosed the following categories of personal information for business purposes, with reference to CCPA categories: Identifiers (to service providers like email and payment processors), Customer Records information (transaction data to payment processors), Commercial information (subscription details to payment processors for billing), Internet/Network Activity (to analytics and security service providers), and Geolocation (IP-based region to analytics/security providers). We do not use or disclose sensitive personal information for purposes that California law gives a right to limit (such as using sensitive data for inferring characteristics).

Sale and Sharing of Personal Information: We do not "sell" personal information for monetary consideration, and we also do not "share" personal information as defined under CCPA/CPRA (i.e., we do not disclose personal information to third parties for cross-context behavioral advertising purposes). In other words, we have not sold or shared California consumers' personal information with third parties for their own marketing or advertising. All data sharing we engage in is for the business purposes described in this Policy (service provision, analytics, etc.). Therefore, the opt-out rights related to the sale or sharing of personal information are not applicable in our case. We also do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

California Consumer Rights under CCPA: If you are a California resident, you have the following rights with respect to your personal information (subject to certain limitations under the law):

To exercise any of your California rights, you (or your authorized representative) can contact us at: [email protected]. We may need to verify your identity (for example, by confirming information we have on file or asking for additional details) before fulfilling your request, as required by law. California law permits you to use an authorized agent to make a request on your behalf, but we will require proof of the authorization and still take steps to verify the identity of the consumer associated with the request.

"Shine the Light" Law: California's "Shine the Light" law (Civil Code Section §1798.83) allows users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes (as defined in that law). We do not share personal information with unaffiliated third parties for their own direct marketing purposes without your consent. Nonetheless, if you are a California resident, you may make a "Shine the Light" request once per year. To do so, please email us at:_ [email protected] _with the subject line "Request for California Shine the Light Information". In your request, please attest to the fact that you are a California resident and provide a current California address for our response. We will provide you any relevant information required by law for the preceding calendar year, or inform you that we do not engage in the type of sharing covered by the law (which is currently the case). Please note that the Shine the Light law does not cover all information sharing, our response will be limited to information relating to covered categories of personal information and sharing.

For more details about our privacy practices, you can refer to the main body of this Privacy Policy. The rights provided to California consumers under CCPA largely overlap with the GDPR rights described in Section 7, and we have a single process to handle requests, so you can use the contact methods in Section 7 or above to reach us.

12. Data Retention

We will retain your Personal Data only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy. In practice, this means we keep your information for as long as you have an account or ongoing relationship with us, and for a certain period thereafter as needed to comply with legal obligations or protect our interests.

For example, we retain account information and profile data while your account is active. If you delete your account (or it's been inactive for a long time), we will initiate deletion of personal data associated with your account, except for data we are required or permitted to keep by law. Typical reasons we might keep some data after account deletion or last use include:

In general, if you ask us to delete your data, we will do so and only retain whatever is necessary. When Personal Data is no longer needed, we either delete it or anonymize it (so it can no longer be associated with you). For example, we might convert a dataset into an aggregate statistical report that contains no personal identifiers and retain that aggregated information indefinitely for business analysis.

To give some illustrative retention periods: basic account data is typically kept for a short period (30-60 days) after account deletion in case of accidental deletion or reactivation, then removed; communications like support emails may be retained for 1-2 years (unless a longer period is required) to help us reference past interactions if you contact us again; analytics data is generally retained in aggregate form and personal identifiers in analytics logs are deleted or anonymized after 14 months by Google Analytics by default, etc. Financial transaction records are often kept for 7 years (to comply with accounting laws). These are general guidelines and may change.

If you have specific questions about our data retention policies for different types of data, feel free to contact us. We aim to not hold on to Personal Data longer than necessary and to securely dispose of information once it is no longer needed.

13. Control tracking

You have different means to control tracking: for example, you can disable certain cookies (as discussed in Section 3.2) or use private browsing modes or browser extensions that block trackers. We do honor any specific opt-out mechanisms provided by the tools we integrate. For instance, if you use the Google Analytics opt-out add-on, our Google Analytics script will respect that and stop tracking on our site for that browser. Similarly, if an ad platform provides an opt-out cookie and you have it present, our integration with that platform will acknowledge it.

Third-party services that we use may have their own policies regarding DNT. For example, some might honor DNT and some might not. We do not make any representations for third-party behavior, so we encourage you to review the privacy policies of those services (e.g., Google, Facebook, etc.) to learn about their commitments.

  1. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how Findmy LLC handles your Personal Data, please do not hesitate to contact us. We value your privacy and will do our best to address any issue.

Data Controller: Findmy LLC

Address: 501 E las Olas Blvd, Suite 300, Fort Lauderdale, Fl 33301, USA

Email: [email protected]

When reaching out via email, please include a clear subject line (e.g., "Privacy Inquiry" or "Data Subject Request") and provide as much detail as possible about your question or request, along with your contact information. This will help us respond more efficiently. We may need to verify your identity for certain requests as noted in Section 7.

We will respond to your inquiries as soon as reasonably possible, generally within 30 days or earlier if required by law.

Thank you for reading our Privacy Policy.

We are dedicated to protecting your personal information and enabling you to use Adzi with confidence.