Privacy Policy

Please read this Privacy Policy to learn how Logopony OÜ ("Peeqd," "we," "us," or "our") collects and treats your personal information when you visit our website, peeqd.app, or access our services (collectively, the "Service"). By using or accessing our website or Service in any manner, you acknowledge that you have read the practices and policies outlined below, and you understand that we will collect, use, and share your information as described in this Privacy Policy.

Your use of the Service is at all times subject to our Terms of Use and/or any separate agreement you have entered into with us, as applicable. Any terms we use in this Privacy Policy without defining them shall have the definitions given to them in our Terms of Use.

Peeqd may change this Privacy Policy at any time. The most current version can be accessed at https://peeqd.app/privacy. By continuing to access or use peeqd.app, you accept any changes or revisions to this Privacy Policy.

If you do not agree to this policy, do not use peeqd.app.

1. Who We Are

1.0 Definitions

"Personal Data" or "personal information" means any information that identifies or relates to a particular individual, including information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws. "Public Information" means information about Instagram accounts that those account holders have made publicly available on Instagram or other platforms — it is not information you provide directly to Peeqd when creating your account. "Service" means our website, dashboard, reports, alerts, and related features at peeqd.app. This Privacy Policy does not cover the practices of companies we do not own or control (such as Instagram, Meta, Stripe, or other third-party platforms and service providers except as described herein).

1.1 Controller Identity

The data controller responsible for your personal information is:

Logopony OÜ
6 Sepapaja, 15551 Tallinn, Estonia

For privacy questions, contact: [email protected]

1.2 Scope

This Policy applies to information we collect through the peeqd.app website, dashboard, mobile or responsive web app, customer support interactions, and the product-update emails we send to subscribed users. It does not apply to:

• information you provide to Instagram or any third-party platform (governed by that platform's own privacy policy);
• the public Instagram data that we observe (which is information made public by the underlying account holders on the Instagram platform).

1.3 Unsupported Regions

Although our controller is established in Estonia, Peeqd is not supported for residents of the European Economic Area (EEA), the United Kingdom, Switzerland, the State of Illinois (U.S.A.), Russia, or other regions listed in our Terms of Use Section B.2 (collectively, "Unsupported Regions"). The Service is primarily directed at users in the United States and other Supported Regions defined in our Terms. If you are a resident of the EEA, the United Kingdom, Switzerland, Illinois, or Russia: do not use this Service. If you have already created an account, you must immediately cease use, cancel your subscription, and delete your account.

We do not block or restrict access to the Service based on IP address, geolocation, VPN use, or similar technical signals. At signup, every user represents that they are not a resident of an Unsupported Region; we rely on those representations in good faith. We do not knowingly collect, process, or store personal data of residents from Unsupported Regions.

This Policy does not provide GDPR-specific rights to users in Unsupported Regions because the Service is not intended for users in those regions. If you nevertheless accessed the Service and believe your personal data was collected in error, email [email protected] with verification of your residency and we will delete your account and associated data within 30 days.

2. Information We Collect

2.1 Information You Provide

When you create an account or use the Service, you provide:

• Account info: email address, password (hashed), country (for tax and compliance purposes);
• Subscription info (Paid Tier): your selected plan and payment method (we use Stripe — see Section 4);
• Tracking targets: Instagram usernames you ask us to monitor;
• Communications: messages you send to support, feedback you provide, survey responses;
• Optional profile data: profile photo, time zone, notification preferences.

2.2 Information Collected Automatically

When you use the Service, we automatically collect:

• Device info: IP address, browser type and version, operating system, device identifiers, screen size, language;
• Usage and analytics info: pages viewed, features used, search queries, dashboard interactions, session duration, referrer URL, click-through paths (via Google Analytics);
• Cookies and similar technologies: see Section 9;
• Performance and error data: crash logs, error reports, latency metrics.

2.3 Information We Observe from Instagram

To provide the Service, we observe publicly accessible information about Instagram accounts you ask us to track:

• public profile info (username, display name, bio, follower count, following count, post count);
• public posts (captions, hashtags, posting timestamps);
• public engagement signals (public likes by the tracked account on other public posts, public comments, public follows and unfollows of other public accounts);
• aggregated metadata about activity patterns.

We do not collect:

• private messages, direct messages, or private stories;
• content from private accounts;
• biometric identifiers (we do not run facial recognition, gait analysis, or any biometric processing on Instagram photos — we store and display photos as-published, without algorithmic identification);
• precise geolocation;
• payment card numbers (handled by Stripe).

About analytical inferences (AI Insights): as part of generating your report, our system may produce AI-generated analytical content from a tracked account's publicly observable activity — including personality-type approximations, persona snapshots, interest analysis, engagement patterns, lifestyle indicators, venues mentioned, and discussion-topic suggestions. These outputs are described in Section 3.3, are approximate, and carry an explicit "informational use only" disclaimer in both this Policy and within the product interface. They are not psychological diagnoses, consumer reports, or verified statements of fact.

2.4 Information from Third Parties

We may receive limited information from:

• Stripe, our payment processor: transaction status, last 4 digits of card, billing country (we never receive full card numbers);
• Authentication providers (if you sign in with Google or Apple): your verified email and name;
• Customer support tools: chat transcripts, ticket metadata;
• Analytics provider (Google Analytics): aggregated traffic and usage data.

3. How We Use Information

3.1 Legal Bases and Purposes of Use

Under applicable data protection laws, we process Personal Data only where we have a proper reason: to comply with legal obligations; to perform our contract with you; for our legitimate interests in operating, securing, and improving the Service (balanced against your rights); or where you have given consent (such as optional marketing emails, which you may withdraw at any time).

We use the information we collect to:

• (a) Provide the Service — show you reports about the Instagram accounts you track; deliver dashboards, alerts, and exports;
• (b) Process payments — bill paid subscribers, handle refunds, prevent fraudulent charges;
• (c) Support — answer your questions, troubleshoot, restore lost access;
• (d) Improve the Service — analyze usage to fix bugs, prioritize features, measure performance, evaluate new functionality;
• (e) Communicate — send transactional emails (receipts, account notices, security alerts) and, if you have not opted out, product-update emails to subscribed users;
• (f) Secure the Service — detect abuse, prevent fraud, investigate violations of our Terms, defend against threats;
• (g) Comply with law — meet legal, regulatory, and tax obligations; respond to lawful requests from authorities.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice in advance.

3.2 We Do Not Sell or Share for Cross-Context Behavioral Advertising

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). We do not engage in profiling that produces legal or similarly significant effects, and we do not work with advertising networks or data brokers.

3.3 Use of AI in Our Product / No Training on Your Data

(a) We use AI / large language models inside the product to generate analytical content describing the Instagram accounts you ask us to track. AI-generated content in our reports includes:

• personality-type approximations (e.g., MBTI-style indicators);
• persona snapshots and personality hints;
• interest and content-theme analysis;
• accounts the tracked account publicly engages with;
• lifestyle indicators inferred from public posts;
• venues and public locations mentioned in account activity;
• discussion topics suggested by recent content;
• notable patterns or anomalies in posting activity.

All AI outputs are derived solely from publicly observable Instagram activity of the accounts you ask us to track. We do not access private accounts, private messages, or any non-public data to produce these outputs.

(b) We do not use your personal information — your account info, dashboard usage, search queries, or messages to support — to train any AI / ML model, whether ours, our vendors', or any third party's. AI is used only at inference time to generate report content, then discarded by the AI provider per its API processing terms.

(c) AI-generated content is approximate, generated by automated systems, and provided for informational purposes only. It is not:

• a psychological diagnosis, professional assessment, or clinical evaluation;
• a consumer report or background-check report under the Fair Credit Reporting Act or any analogous law;
• a verified statement of fact about any individual;
• a basis for credit, employment, housing, insurance, or other consequential decisions about any person.

AI outputs may be inaccurate, incomplete, or out of date. You should not rely on them as the sole basis for any action affecting another person.

(d) AI processing of public Instagram activity is performed by selected commercial AI providers under contractual data-protection terms. We send only the publicly observable Instagram content necessary to generate the requested analysis; AI providers process this content as our service providers and may not use it to train their general-purpose models.

(e) Your responsibility. Our Terms of Use Section C.2(k) and (l) prohibit using AI Insights to physically locate or approach a person, or as input to consequential decisions. By using the Service, you agree to use AI outputs only for lawful informational purposes.

4. Who We Share Information With

4.1 Service Providers

We work with carefully selected service providers who process information on our behalf, under contractual confidentiality and data protection obligations. We share the minimum information necessary for each provider to perform its function. Categories include:

• Cloud infrastructure — server hosting, content delivery, and database services (Germany (European Union));
• Payment processing — Stripe, Inc., for subscription billing and fraud prevention;
• Communications — transactional email delivery and customer support tools;
• Analytics — Google Analytics for aggregate usage and performance measurement;
• AI providers — generation of analytical insights from public Instagram activity (see Section 3.3);
• Security and reliability — error monitoring, abuse detection, backup.

We do not share information with advertising networks, data brokers, marketing-data buyers, or any third party for the purpose of building or enriching commercial profiles of you.

A current list of named service providers, with locations and brief descriptions of data processed, is available on request at [email protected]. We will respond within 14 days. We update our list of providers when material changes occur.

4.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor entity. We will notify you of any such transfer affecting your information.

4.3 Legal Compliance

We may disclose information when we believe in good faith that disclosure is:

• required by law, regulation, legal process, or governmental request;
• necessary to enforce our Terms;
• necessary to detect, prevent, or address fraud, security, or technical issues;
• necessary to protect the rights, property, or safety of Peeqd, our users, or the public.

When legally permitted, we will give affected users notice before disclosing in response to government requests.

4.4 No Sale of Personal Information

Consistent with Section 3.2, we do not sell personal information for monetary or other valuable consideration.

5. How Long We Keep Information

5.1 Retention Schedule

We retain information for the following periods:

We may retain certain information beyond these periods when required by law, when needed to defend against legal claims, or when contained in a record we are legally required to preserve.

5.2 Deletion

When information reaches the end of its retention period or you request deletion:

• account-level data is permanently deleted from production within 30 days;
• backup copies are overwritten on rolling cycles within 90 days;
• de-identified, aggregated data may be retained indefinitely for product analytics.

6. Security

6.1 Safeguards

We employ commercially reasonable technical and organizational measures to protect your information, including encryption of data in transit, restricted access for personnel, and due diligence on our service providers. No security program is impenetrable. If you suspect unauthorized access to your account, contact [email protected] immediately.

6.2 Breach Notification

If we experience a security incident that affects your personal information, we will notify affected users without undue delay and consistent with applicable law, generally within 72 hours of becoming aware of the incident's nature and scope, when notification is required or appropriate.

7. Your Privacy Rights

7.1 Universal Rights

Regardless of where you live, you may:

• Access — request a copy of the personal information we hold about you;
• Correct — ask us to correct inaccurate information;
• Delete — ask us to delete your account and associated data, subject to legal retention obligations;
• Export — receive your information in a portable format;
• Withdraw consent — for any processing based on consent;
• Opt out of product-update emails — via the unsubscribe link in each email or via account settings;
• Complain — contact us with concerns, or contact your local data protection authority where applicable. As an EU-established controller, our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee.

7.2 How to Exercise Your Rights

Email [email protected] from the address associated with your account, describing the right you wish to exercise. We will:

• acknowledge your request within 7 days;
• respond substantively within 45 days (extendable by 45 more days for complex requests, with notice);
• verify your identity before fulfilling sensitive requests.

There is no fee for most requests. We may charge a reasonable fee for excessive or repeated requests, or refuse such requests, consistent with applicable law.

7.3 Cookies Choices

See Section 9 for cookie-specific controls.

8. California Privacy Rights

8.1 Notice to California Residents

This Section 8 applies to California residents and supplements Section 7. We comply with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) and, where applicable, California's Data Broker Registration law (Senate Bill 361, effective January 1, 2026).

8.2 Categories of Information

In the past 12 months, we have collected the following CCPA-defined categories of personal information:

We do not collect: precise geolocation, biometric info, sensitive personal information (as defined under CPRA), or Personal Data of anyone under 18 that we knowingly process as a Service user.

8.3 California Resident Rights

You have the right to:

• Know — what categories of personal information we collect, the sources, the purposes, and to whom we disclose it (this Policy provides that disclosure);
• Access — request a copy of the specific personal information we have collected about you in the prior 12 months;
• Delete — request deletion (subject to legal exceptions);
• Correct — request correction of inaccurate information;
• Limit use of sensitive personal information — we do not collect SPI as defined under CPRA, so this right is not applicable;
• Opt out of sale or sharing — as stated, we do not sell or share for cross-context behavioral advertising, so there is nothing to opt out of;
• Non-discrimination — we will not discriminate against you for exercising any CCPA right.

To exercise these rights, follow the process in Section 7.2.

8.4 Authorized Agents

You may designate an authorized agent to make a request on your behalf. We will require written proof of authorization and verification of your identity.

8.5 California Data Broker Registration (SB 361)

Peeqd is not a "data broker" within the meaning of California Civil Code §1798.99.80 because:

• (a) the personal information we process about Instagram users is information those users have made publicly available on Instagram, not information we collect through covert means;
• (b) we provide our subscribers with analytics and aggregation as a direct service for which subscribers contract with us — not "selling" the underlying personal information as a stand-alone product;
• (c) we do not maintain or offer a generally-available data product (such as a marketing list, identity-verification dataset, or background-check report) to the broader market.

To the extent any California regulator concludes otherwise, we will register and comply with all applicable obligations promptly upon notice.

8.6 Shine the Light Law

California residents may request information about disclosures of personal information to third parties for those third parties' direct marketing purposes during the prior calendar year. We do not make such disclosures.

8.7 Other State Privacy Rights

Nevada: Nevada residents have the right to opt out of the sale of certain Personal Data. We do not currently sell your Personal Data as defined in Nevada Revised Statutes Chapter 603A. To submit a request, email [email protected] with the subject line "Nevada Do Not Sell Request" and include your name and email address.

Colorado, Connecticut, and Virginia: Residents of these states have rights to access, delete, correct, and opt out of certain processing under applicable state privacy laws. To exercise these rights, follow the process in Section 7.2. If we deny your request, you may appeal by emailing [email protected] with the state you are writing from and a description of your appeal. If your appeal is denied, your jurisdiction may allow you to file a complaint with your state Attorney General's Office.

9. Cookies and Similar Technologies

9.1 Cookies We Use

The Service uses cookies and similar technologies to operate and measure performance. Information we collect automatically may include your IP address, device type, browser type, operating system, language, referrer URL, pages viewed, session duration, and dashboard interactions.

We use the following categories:

We do not use marketing cookies, advertising pixels, interest-based advertising (IBA), or cross-site tracking for behavioral advertising. Certain content and features depend on strictly necessary cookies; if you block those cookies, you may not be able to sign in or use certain features.

9.2 Cookie Banner

If you are accessing the Service from a region where cookie consent is required, you will be presented with a cookie banner allowing you to accept or decline non-essential cookies. You can also manage cookies via your browser settings. Some Service features may not function correctly if you disable strictly necessary cookies.

9.3 Do Not Track and Global Privacy Control

We do not engage in cross-context behavioral advertising, so the practical impact of Do Not Track and Global Privacy Control browser signals on our processing is limited.

10. International Transfers

Logopony OÜ is established in Estonia (European Union). Our production infrastructure — where account data and Service data are hosted and processed — is located in Germany (European Union). Some of our service providers (such as payment processing and analytics) may process data in the United States and other countries. By using the Service, you acknowledge that your information may be processed in Estonia, Germany, the United States, and other jurisdictions where our providers operate.

Processing within the European Economic Area (for example, between Estonia and Germany) does not require additional transfer safeguards. Where personal information is transferred from the European Economic Area to countries that have not received an adequacy decision (such as the United States), we rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms with our service providers, as required by applicable law.

For California residents, we contract with service providers under terms requiring CCPA-compliant treatment.

The Service is not supported for EEA, UK, or Swiss residents (see Section 1.3). Users in Unsupported Regions must not sign up; mistaken signups are deleted upon verified request.

11. Children's Privacy

11.1 Service Age (18+)

The Service is directed to people who are at least 18 years old. Peeqd does not knowingly collect Personal Data from anyone under the age of 18. If you are under 18, do not create an account or use the Service. If you are aware that Peeqd has collected Personal Data from someone under 18, please contact [email protected] and the information will be removed as soon as is reasonably possible.

11.2 Public Information About Minors

Peeqd does not knowingly aggregate or provide Public Information reports about people under 18. However, our Service may surface Public Information about individuals between 13 and 17 that those individuals or third-party platforms have made publicly available on Instagram. Instagram users who do not want their data processed by Peeqd can make their account or posts private.

To request removal of Public Information about a person under 18 from reports generated through the Service, contact [email protected]. We reserve the right to deny or reverse a request if we believe it does not comply with our Terms of Use or other policies, or if removal is not technically feasible while honoring other users' lawful subscriptions.

11.3 California Minor Eraser (Cal. Bus. & Prof. Code §22581)

If you are a California resident under 18 with a registered account, you may request removal of content or information you posted by contacting [email protected]. Note that the Service is intended for users 18 and older; accounts created in violation of this age requirement are subject to deletion.

12. Changes to This Policy

We may update this Privacy Policy. The "Last Updated" date at the top reflects the latest revision. We will provide notice of material changes by a notice on the dashboard or other reasonable means in advance of the changes taking effect.

13. Contact

For privacy questions, requests, or complaints:

Email: [email protected]

Mail: Logopony OÜ, 6 Sepapaja, 15551 Tallinn, Estonia