CityBuzz, Inc. – Global Privacy Policy & Data Sovereignty Protocol

Version: 2.0.0

Effective Date: February 20, 2026

Last Revised: March 13, 2026

1. Introduction and Corporate Vision

CityBuzz, Inc. (“CityBuzz,” “we,” “us,” or “our”) is a real-time, geographically organized communication platform designed to be the "heartbeat" of the modern city. Our Service allows users to discover, share, and discuss local events through a specialized "Buzz" interface. This Privacy Policy is our formal commitment to transparency, outlining the lifecycle of your data. We operate under a "Privacy by Design" framework, ensuring that your data remains secure, localized, and under your control.

2. Information We Collect: The "User-Defined" Data Taxonomy

CityBuzz is designed to be a privacy-first platform. Unlike traditional location-based apps, we do not track or store your device’s precise GPS location.

• Account Credentials: We collect your name (or chosen display name), a unique @username, a verified email address, and a cryptographically hashed password.
• User-Defined Location: To participate in a conversation, you manually input or select the city you wish to "Buzz" in. This selection is used solely to route your messages to the correct thread and is not used to track your physical movements over time.
• User-Generated Content (UGC): We store the text of your posts, comments, thread titles, and multimedia files (images/videos) that you share with the community.
• Interaction Metadata: We collect data on who you "Report" or "Block" to ensure your personal feed remains safe and free from harassment.

3. Purpose of Processing and Data Utilization

We use your information to power the CityBuzz experience:

• Manual Local Routing: To ensure your messages appear in the city chat you have explicitly selected.
• The Ranking Algorithm: We use engagement signals (replies, shares, and "Buzz" velocity) to determine which threads move to the top of the feed.
• Real-Time Notifications: To alert you when a thread in your selected city is gaining traction or when someone replies to your message.
• Platform Integrity: To identify and mitigate bot attacks, coordinated spam, and bad actors.
• Brand Evolution: We analyze aggregated, de-identified data to understand which app features are most effective.

4. Artificial Intelligence and Automated Processing (AB 2013)

In accordance with California’s AB 2013, CityBuzz discloses its use of automated systems:

• Safety AI: We utilize machine learning to scan for prohibited content, including hate speech and physical threats, before they reach the community.
• Ranking AI: Our "Buzz Feed" is organized by algorithms that analyze "Local Intent" based on user engagement.
• AI Training Safeguards: We may use public thread content to train our internal local-relevance models. WE NEVER use your private messages (DMs), your real name, or your selected cities to train generalized AI models.
• Human-in-the-Loop: You have the right to request a human review of any automated decision that results in an account suspension.

5. Legal Bases for Processing

For users in the EEA, UK, and other regulated jurisdictions, we process data under:

• Contractual Necessity: We must process your selected city and email to provide the Service you requested.
• Legitimate Interests: To protect our users from fraud, ensure app security, and improve the "Buzz" algorithm.
• Legal Obligation: When required to comply with statutory requirements or law enforcement mandates.
• Consent: Specifically for any marketing communications you may opt-in to in the future.

6. How We Share and Disclose Information

CityBuzz is not a data broker. We do not sell your personal information. We share data only with:

• Infrastructure Partners: Secure cloud providers (e.g., AWS/Google Cloud) who host our database under strict confidentiality.
• Safety Vendors: Specialized tools used to identify and remove illegal content.
• Legal/Safety Mandates: We will disclose information if required by a valid subpoena, court order, or if we believe in good faith that disclosure is necessary to prevent immediate physical harm.
• Corporate Transactions: In the event of a merger or acquisition, your data remains subject to these privacy protections.

7. International Data Transfers and Sovereignty

CityBuzz is headquartered in California, USA. We operate a global infrastructure and may transfer data across borders. For international users, we utilize Standard Contractual Clauses (SCCs) to ensure that your data receives a level of protection equivalent to that of your home jurisdiction (e.g., GDPR compliance). We ensure all data "in transit" is protected by the latest cryptographic standards.

8. Data Retention and The "Live" Protocol

Because CityBuzz is about the "Now," we do not believe in permanent data hoarding.

• Thread Archiving: Public threads that have been inactive for more than 180 days are moved to a de-identified archive or purged.
• The Deletion Lifecycle: When you utilize the "Delete Account" button in your profile:
  1. Your profile is instantly hidden.
  2. Your personal identifiers are scrubbed from our active production systems within 30 days.
  3. Encrypted backups are fully purged within 60 days.

9. Data Security and Technical Safeguards

We implement industry-leading security to protect the "Buzz":

• Encryption: Data is encrypted in transit via TLS 1.3 and at rest via AES-256.
• Administrative Security: We use role-based access controls and multi-factor authentication for all internal administrative tools (including the Admin Panel).
• UI/UX Integrity: Our "multiline" chat inputs and gradient interfaces are designed to prevent "input injection" attacks and other common mobile vulnerabilities.

10. Children’s Privacy (Strict 13+ Policy)

CityBuzz is a platform for adults and young adults.

• Strict Age Limit: The Service is prohibited for anyone under 13 years of age.
• Verification: We utilize age-verification prompts and OS-level "Age Signals" to prevent underage access.
• Immediate Purge: If we discover an account belonging to a child under 13, we perform an immediate, permanent purge of all associated data.
• Teen Protections (13-17): Users in this bracket have heightened privacy defaults and are automatically opted-out of any non-essential data profiling.

11. Your Privacy Rights (CCPA/GDPR/Delete Act)

You are the owner of your data. CityBuzz provides "Self-Service" privacy tools directly within your User Profile to ensure you can exercise your rights in real-time. Depending on your location, you have the following rights:

• Access & Portability: You may request a copy of the personal data we have collected about you.
• Correction: You can edit your name, @username, or verified email at any time via the Profile Edit screen.
• The "Delete Act" (2026): CityBuzz honors all deletion and opt-out requests. You may initiate an immediate account purge using the "Delete Account" button in your settings, or submit a request via the California DROPplatform.
• Opt-Out & Preference Management: You may utilize the Privacy Settings and Notifications toggles in your profile to opt-out of data processing, ranking algorithms, or communication alerts.
• Right to Limit & Block: You have the right to limit your exposure to specific content. This can be exercised via the "Blocked Content" manager in your profile.
• Non-Discrimination: We will never penalize you, charge different prices, or provide a diminished service for exercising your privacy rights.

12. Cookies and In-App Tracking

We use minimal tracking technologies to ensure the app works correctly:

• Session Integrity: To keep you logged in as you move through different city threads.
• Fraud Prevention: To identify and block "Sybil" attacks (multiple fake accounts from one device).
• Analytics: To see which cities are being selected most frequently so we can optimize server resources.
• You can manage these preferences via your device's "Privacy" or "App Tracking" menus.

13. Changes to This Privacy Policy

As CityBuzz evolves—adding new features like Stories or Messaging updates—we may update this Policy. We will notify you of material changes via an in-app "System Thread" or a notification to your registered email address.

14. Contact Information and Data Privacy Officer

If you have any questions, concerns, or wish to exercise your legal rights, please contact our Data Privacy Office:

CityBuzz, Inc. Attn: Data Privacy Officer

1 Tabania Way

Email: privacy@citybuzz.app