Privacy Policy

Last updated: July 24, 2026

This Privacy Policy explains how Gizzmo Inc. collects, uses, stores, and shares information in connection with the Qurable Snapp platform (the “Platform,” “Service,” or “App”), including our web dashboard, customer-facing loyalty portal, and AI messaging assistants that operate over Instagram, Facebook Messenger, WhatsApp, and email.

The Platform is operated by Gizzmo Inc. (“we,” “us,” “our”), a company based in San Jose, California, United States.

1. Who this policy covers

This policy applies to two groups of people:

• Business users — the administrators and team members of a business (an “Organization”) who use the Qurable Snapp dashboard to run loyalty programs, campaigns, and customer engagement.
• End customers — individuals who interact with an Organization’s loyalty program through our AI assistants (Instagram, Messenger, WhatsApp, email) or the customer loyalty portal.

Important note about Organizations. When an end customer enrolls in a loyalty program, the business whose channel they messaged (the “Business” or “Organization”) also collects and uses their information for its own purposes (for example, rewards fulfillment and customer support). In most cases the Organization is the primary controller of loyalty-program data, and Gizzmo Inc. processes that data on the Organization’s behalf. If you have questions about how a specific Organization uses your data, please contact that Organization directly.

2. What the Platform does

The Platform provides:

• A dashboard for Organizations to manage customers, loyalty tiers, coupons, campaigns, and analytics;
• AI assistants that answer questions, onboard customers into loyalty programs, and manage basic loyalty interactions;
• A customer-facing portal where end customers can view rewards, coupons, and program status;
• Integrations with third-party platforms (Meta/Instagram/Facebook, WhatsApp, Google, and email providers) needed to deliver these features.

3. Information we collect

Depending on how you interact with the Platform, we may collect:

A. Account and business information (business users)

• Name, email address, and profile details;
• Authentication data (Google sign-in identifiers, or email one-time passcodes);
• Organization membership, role, and settings you configure.

B. Messaging and social-account information (end customers)

• Your messages and responses in a chat, including attachments you send;
• Public profile information a platform makes available (for example, username, page-scoped ID, profile name, profile picture, locale, and time zone), subject to your settings and each platform’s APIs.

C. Loyalty information you provide

• Contact details such as email address or phone number;
• Basic identity details such as name and date of birth, where you choose to provide them;
• Loyalty preferences (for example, interests, preferred store or location, and communication preferences).

D. Technical and security data

• Logs, timestamps, approximate device and connection metadata, and error and audit records;
• Identifiers needed to operate integrations (for example, page IDs, conversation IDs, and access tokens), which are stored securely and, where applicable, encrypted.

Sensitive information. Please do not send sensitive personal data (for example, government ID numbers, payment card details, or health data) through the chat. If such data is sent, it may be processed as part of your message.

4. How we use your information

We use information to:

• Provide, operate, and maintain the Platform and complete loyalty onboarding;
• Authenticate users and secure accounts;
• Respond to requests and provide customer support;
• Monitor and protect the Platform (fraud prevention, abuse detection, and troubleshooting);
• Improve service quality and user experience (see Section 5);
• Comply with legal obligations and enforce our terms and policies.

5. AI processing

The Platform’s assistants use automated systems (AI) to generate responses.

• Input: your messages and related context, such as the loyalty onboarding flow.
• Output: automated responses and next-step instructions.

We do not use the content of your conversations to train or fine-tune third-party foundation models. We may use de-identified and aggregated data to monitor, evaluate, and improve the Platform’s performance, safety, and reliability.

6. Legal bases (EEA / UK)

If you are in the European Economic Area or the United Kingdom, we process personal data under one or more of these legal bases:

• Performance of a contract — to provide the Service you request;
• Legitimate interests — service improvement, security, and preventing abuse, balanced against your rights;
• Consent — where required, such as certain marketing communications or optional data uses;
• Legal obligation — compliance with applicable law.

7. California privacy rights (CCPA / CPRA)

If you are a California resident, you have the right to know what personal information we collect, to request access to and deletion of that information, to correct inaccurate information, and to opt out of the “sale” or “sharing” of personal information as those terms are defined under California law. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. You may exercise these rights using the contact details in Section 15, and we will not discriminate against you for doing so.

8. How we share information

We may share information:

• With the Organization you interact with, to administer its loyalty program and provide support;
• With service providers who help us run the Platform (hosting, databases, analytics, monitoring, AI model providers, and customer support tools), under contractual confidentiality and security obligations;
• With platform partners (such as Meta and Google) as required to operate the relevant integrations and comply with their platform terms;
• For legal and safety reasons — to comply with law, protect rights and safety, and prevent fraud or abuse;
• In a business transaction — as part of a merger, acquisition, financing, or sale of assets, subject to this policy.

We do not sell your personal information.

9. International data transfers

Our service providers may process data outside your country, including in the United States. Where required (for example, for EEA/UK data), we rely on appropriate safeguards such as Standard Contractual Clauses or other lawful transfer mechanisms.

10. Data retention

We retain personal data only as long as necessary to:

• Provide the loyalty and Platform services;
• Maintain security and audit records;
• Meet legal, accounting, or reporting obligations.

Retention periods vary by data type and by the Organization’s configuration and legal requirements. When data is no longer needed, we delete or de-identify it. You can request deletion (see Section 11).

11. Your rights and choices

Depending on your location, you may have rights to:

• Access, correct, or delete your personal data;
• Object to or restrict certain processing;
• Receive a copy of your data (data portability);
• Withdraw consent where processing is based on consent.

To exercise a right, contact us using the details in Section 15 and include enough information for us to locate your records (for example, the channel and username you used, the Organization you interacted with, and the request you want to make). Where an Organization is the primary controller of loyalty-program data, we may direct you to that Organization or coordinate with them to fulfill your request.

12. Security

We use reasonable administrative, technical, and organizational measures to protect data, including access controls, encryption of sensitive tokens, encryption in transit where supported, and monitoring. No system is completely secure, so please avoid sharing highly sensitive information through chat.

13. Children’s privacy

The Platform is not intended for children under 13 (or a higher age where required by local law). If you believe a child has provided personal data, please contact us to request deletion.

14. Third-party platforms

Your use of Instagram, Facebook, Messenger, WhatsApp, Google, and email services is also governed by those providers’ own terms and privacy policies. These providers may process your data independently of us.

15. Contact

For privacy questions or requests, contact:

Gizzmo Inc. San Jose, California, United States Email: privacy@qurable.co

16. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above and, where appropriate, provide additional notice.