Privacy Policy

1. Introduction

Welcome to pebbl ("we," "our," or "us"). We operate the pebbl platform, which includes our website, mobile applications, and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, share, and protect your information when you use our Service.

By using pebbl, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our Service.

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, username, password (encrypted), and optional display name
• Profile Information: Occupation, interests, location (city/state level), and verification method
• Civic DNA Profile: Your responses to civic preference questions (currently planned for up to ten dimensions, subject to change):
  • Governance scale preferences (local vs. centralized)
  • Freedom-security balance
  • Change orientation
  • Institutional trust levels
  • Moral foundations
  • Participation style
  • Economic values
  • Environmental priority
  • Urban-rural identity
  • Globalization stance
• Content: Posts, comments, votes ("pebbls"), and other contributions you make
• Trust Ratings: Trust scores you assign to other users when inviting them
• Communication Data: Messages, feedback, and support requests

2.2 Information We Collect Automatically

• Usage Data: Pages visited, features used, time spent, click patterns
• Device Information: Device type, operating system, browser type, and version
• Network Information: IP address (anonymized after session), general location (country/region)
• Performance Data: App crashes, errors, and performance metrics

2.3 Information from Third Parties

• Legislative Data: Public information from government databases for our AI assistant
• Verification Services: Identity verification data (only confirmation, not raw data)
• Social Connections: If you connect social accounts, basic profile information

3. How We Use Your Information

3.1 To Provide and Improve Our Service

• Create and manage your account
• Enable civic discussions and voting features
• Calculate and display your Community Influencer (CI) score
• Generate personalized AI recommendations based on your Civic DNA
• Provide ballot assistance and legislative information
• Improve our algorithms and user experience

3.2 For Safety and Security

• Verify user identities to maintain platform integrity
• Detect and prevent fraud, spam, and abuse
• Enforce our Terms of Service and community guidelines
• Protect users from harmful content through moderation

3.3 For Research and Analytics

• Understand civic engagement patterns (aggregated data only)
• Improve our Civic DNA framework
• Generate insights about community consensus
• Academic research (with explicit consent and anonymization)

4. Data Sharing and Disclosure

We may share your information in these limited circumstances:

• With Your Consent: When you explicitly agree to share specific information
• Public Content: Posts, comments, and votes you make publicly
• Service Providers: Trusted partners who help operate our Service (under strict confidentiality agreements)
• Legal Requirements: When required by law, subpoena, or court order
• Safety: To protect rights, property, or safety of pebbl, users, or the public
• Aggregated Data: Non-identifiable statistical data for research or public insights
• Business Transfers: In the event of merger, acquisition, or sale (your rights remain protected)

5. Your Privacy Controls

Control	Description	How to Use
Data Sharing Level	Choose between Minimal, Balanced, or Full sharing	Settings → Privacy → Data Sharing
Anonymity Level	Public, Pseudonymous, or Anonymous participation	Settings → Privacy → Identity
Zero-Knowledge Mode	Enhanced encryption for maximum privacy	Settings → Privacy → Advanced
Data Retention	Set how long we keep your data (90-365 days)	Settings → Privacy → Data Retention
AI Personalization	Control what data AI uses for recommendations	Settings → AI Assistant

6. Data Security

We protect your data through:

• Encryption: All data encrypted in transit (TLS 1.3) and sensitive data at rest
• Password Security: Argon2 hashing (industry best practice)
• Access Controls: Role-based permissions and audit logging
• Regular Audits: Security assessments and penetration testing
• Incident Response: 72-hour breach notification commitment
• Infrastructure: Secure cloud hosting with redundancy and backups

7. Your Rights

You have the right to:

• Access: Request a copy of all data we have about you
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and personal data
• Portability: Export your data in a machine-readable format
• Restriction: Limit how we process your data
• Objection: Opt-out of certain data uses (e.g., research)
• Withdrawal: Revoke consent for data processing at any time

To exercise these rights, contact us at privacy@pebbl.vote or use the tools in your account settings.

8. Children's Privacy and Age Requirements

8.1 Minimum Age Requirements

pebbl is not intended for users under 13 years of age (or higher minimum age in certain jurisdictions):

• United States: 13 years minimum
• European Union: 16 years minimum (or lower if permitted by member state law)
• California: 13 years, with enhanced protections for users under 18
• Other Jurisdictions: The minimum age required by local law

8.2 Age Verification

We may employ age verification measures including:

• Self-declaration of age during registration
• Third-party age verification services
• Credit card or identity verification where required by law
• Parental consent mechanisms for users 13-18

8.3 Parental Rights

Parents or guardians of users under 18 may:

• Request access to their child's personal information
• Request deletion of their child's account
• Refuse further collection of their child's information
• Contact us at parents@pebbl.vote for assistance

COPPA Compliance: We comply with the Children's Online Privacy Protection Act (COPPA) and will not knowingly collect personal information from children under 13 without verifiable parental consent.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable laws.

10. California Privacy Rights (CCPA/CPRA)

10.1 Your California Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: What personal information we collect, use, disclose, and sell
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of sale or sharing of personal information
• Right to Non-Discrimination: Equal service and pricing regardless of exercising privacy rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit Use: Limit use and disclosure of sensitive personal information
• Right to Data Portability: Receive your data in a portable format

10.2 Categories of Information We Collect

• Identifiers (name, email, IP address)
• Demographics (age, occupation, location)
• Commercial information (transaction history)
• Internet activity (browsing, interaction with our Service)
• Geolocation data (general location)
• Professional information (occupation, interests)
• Inferences (Civic DNA profile, preferences)

10.3 How to Exercise Your Rights

California residents may exercise their rights by:

• Email: privacy@pebbl.vote
• Mail: Address listed in Section 13
• Online: Through your account settings (when available)

10.4 Authorized Agents

You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization.

10.5 "Shine the Light" Law

California Civil Code Section 1798.83 permits users to request information regarding disclosure of personal information to third parties for direct marketing purposes. We do not share personal information for direct marketing.

11. European Privacy Rights (GDPR)

11.1 Legal Basis for Processing

If you are in the European Economic Area (EEA) or United Kingdom, we process your personal data based on:

• Consent: You've given clear consent for specific purposes
• Contract: Processing is necessary to fulfill our contract with you
• Legal Obligations: We must process data to comply with the law
• Vital Interests: Processing is necessary to protect someone's life
• Public Task: Processing is necessary for public interest
• Legitimate Interests: Our legitimate business interests, except where overridden by your rights

11.2 Your GDPR Rights

• Access: Obtain confirmation and copies of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure ("Right to be Forgotten"): Request deletion in certain circumstances
• Restriction: Limit processing of your data
• Data Portability: Receive data in structured, machine-readable format
• Object: Object to processing based on legitimate interests
• Automated Decision-Making: Not be subject to solely automated decisions
• Withdraw Consent: Withdraw consent at any time

11.3 Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy, typically:

• Account data: Duration of account plus 30 days
• Transaction data: 7 years for tax/legal requirements
• Marketing data: Until opt-out or consent withdrawal
• Analytics data: 26 months

11.4 International Transfers

We may transfer data outside the EEA/UK. We ensure appropriate safeguards through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Your explicit consent

11.5 Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. Find your authority at: https://edpb.europa.eu

11.6 Data Protection Officer

Contact our DPO at: dpo@pebbl.vote

12. Changes to This Policy

We may attempt to notify you of changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date
• Sending an email notification for significant changes (at our discretion)
• In-app notifications or banners

Your Responsibility: It is your responsibility to review this Privacy Policy periodically. Your continued use of the Service after any changes constitutes acceptance of those changes. If you do not agree with the updated Policy, you must stop using the Service immediately.

No Obligation to Maintain Features: We may discontinue, modify, or restrict any privacy features, controls, or options at any time without liability to you.

13. Contact Us

14. Privacy Policy Summary

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