Regional Addendum

Legal Basis for Processing

Under the UK GDPR and EU GDPR, we process your personal data on the following lawful bases:

• Performance of contract: To provide the Service — creating your account, building your Vibe profile, enabling matching and messaging
• Consent: For processing screenshot uploads, optional location access, and non-essential cookies. You can withdraw consent at any time through the app or by contacting us
• Legitimate interests: For fraud prevention, safety enforcement, product improvement, and analytics — where these interests don't override your rights
• Legal obligation: To comply with applicable UK/EU laws and regulations

Your Additional Rights

In addition to the rights listed in our Privacy Policy, you have the right to:

• Restrict processing: Ask us to limit how we use your data in certain situations
• Object to profiling: Request human review of decisions made solely by automated means that significantly affect you (including Vibe matching and Signal Analysis)
• Lodge a complaint: Contact your local supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk. In the EEA, contact your national Data Protection Authority

International Transfers

Where your data is transferred outside the UK or EEA, we rely on adequacy decisions or Standard Contractual Clauses (SCCs) approved by the relevant authority. You may request a copy of the applicable safeguards by contacting us.

Consumer Rights & Paid Features

If you purchase a subscription or digital content, you have the right to cancel within 14 days (the "cooling-off period") under the Consumer Contracts Regulations 2013 (UK) or the Consumer Rights Directive (EU), unless you have expressly consented to immediate access and acknowledged that you waive your right of withdrawal.

Your statutory rights under the UK Consumer Rights Act 2015 or applicable EU consumer protection law are not affected by our Terms of Use.

Disputes

If you reside in the UK, our Terms are governed by the laws of England and Wales, and you may bring claims in the courts of England and Wales. If you reside in the EEA, you may bring claims in the courts of your country of residence. EU users may also use the European Commission's Online Dispute Resolution platform at ec.europa.eu/consumers/odr.

Personal Data Protection Act (PDPA)

Under the PDPA 2012, you have the following rights:

• Access: Request information about how your personal data has been used or disclosed in the past year
• Correction: Request correction of errors or omissions in your personal data
• Withdrawal of consent: Withdraw consent for the collection, use, or disclosure of your personal data (though this may affect our ability to provide the Service)
• Data portability: Request a copy of your data in a commonly used format, where applicable under the data portability obligation

We will respond to access and correction requests within 30 days.

International Transfers

Where your data is transferred outside Singapore, we ensure that the receiving party is bound by legally enforceable obligations to provide a comparable standard of protection as required by the PDPA.

Complaints

If you are unsatisfied with how we handle your data, you may contact us at hello@getminimal.app. You may also lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg.

Disputes

If you reside in Singapore, our Terms are governed by the laws of Singapore. Disputes are subject to the non-exclusive jurisdiction of the courts of Singapore. Your rights under the Consumer Protection (Fair Trading) Act are not affected.

Digital Personal Data Protection Act, 2023

Under the DPDP Act, 2023, Minimal acts as a "Data Fiduciary." You, as a "Data Principal," have the following rights:

• Right to access: Obtain a summary of your personal data and the processing activities performed on it
• Right to correction and erasure: Request correction of inaccurate data or erasure of data that is no longer necessary
• Right to grievance redressal: Contact us with any grievance regarding the processing of your data
• Right to nominate: Nominate another individual to exercise your rights on your behalf in the event of your death or incapacity

You may exercise these rights through the app or by contacting us at hello@getminimal.app.

Consent

We process your personal data based on your free, specific, informed, and unambiguous consent, as required by the DPDP Act. You may withdraw consent at any time through the app. Withdrawal of consent may affect our ability to provide certain features of the Service.

International Transfers

Your data may be transferred to countries not restricted by the Central Government under the DPDP Act. We comply with all applicable conditions and notifications issued under the Act regarding cross-border data transfers.

Grievance Redressal

For any grievances related to your personal data, contact us at hello@getminimal.app. We will acknowledge your grievance promptly and resolve it within 30 days. If you are not satisfied with our response, you may approach the Data Protection Board of India once constituted.

Disputes

If you reside in India, our Terms are governed by the laws of India. Disputes are subject to the exclusive jurisdiction of the courts in Bengaluru, Karnataka. Your rights under the Consumer Protection Act, 2019 and the DPDP Act, 2023 are not affected.