Privacy Policy

Last updated: 2026-07-06 · Version v2.1

1. Data controller

Virelya is the data controller for your personal data. For any question, email [email protected].

2. Data collected and purpose

Virelya only collects data necessary for the service.

Card identity (first name, last name, role, company, professional email, phone, website, location, avatar, logo, background): provided by you. Purpose: generate your digital business card. Legal basis: contract performance (Art. 6.1.b GDPR).
Authentication (email + hashed password, or Google OAuth): handled by Supabase. Purpose: secure your access.
Approximate location (only if you enable Explorer): to display nearby cards. Legal basis: explicit consent.
Photos (gallery or camera): only for backgrounds and avatars you select. No photo is read without your action.
Messaging and calls (if you use these features): the content of messages you send (text and voice messages), plus metadata and any recaps of your calls. Purpose: deliver your conversations and calls with other users. Legal basis: contract performance (Art. 6.1.b). Important: these exchanges are not end-to-end encrypted — they are encrypted in transit and at rest, but remain technically accessible to Virelya for moderation and safety.
Teams (if you create or join a team): your membership, role, posted announcements and the team's brand template. A team admin can see members and enforce a visual identity on your primary card. Legal basis: contract performance.
Social features: recommendations you give or receive, referral code, view count of your cards. Purpose: networking and sharing features.
Moderation: reports and blocks you submit. Purpose: community safety and terms enforcement. Legal basis: legitimate interest (Art. 6.1.f).
Notifications: token stored to alert you (AI portrait ready, new message, team announcement, incoming call).
Contact book (only if you grant permission via "Find your friends on Virelya" or at first launch): Virelya scans your contacts to identify people who already have a Virelya card and proposes them to add to your wallet. Server-side data processed: ONLY irreversible SHA-256 cryptographic fingerprints of normalized phones and emails — NEVER the plain values. Privacy strategy: pattern similar to Signal/WhatsApp. The content of your contact book (names, nicknames, photos, personal notes) stays on your phone and is never transmitted. When a contact matches a Virelya user, their Virelya identifier may be added to that contact's entry in your phone book (a custom URL field, without modifying name or notes). Legal basis: explicit consent (GDPR Art. 6.1.a) — you can revoke this permission at any time in your phone's system Settings.
Technical data (device model, OS, app version): aggregated and anonymized for diagnostics.

3. Sub-processors

Virelya relies on the following sub-processors. Each applies its own GDPR safeguards.

Supabase (Germany, eu-central-1) — database + image storage hosting.
Sentry (Germany, DE region) — anonymized crash collection. Auth headers and tokens automatically redacted before sending.
PostHog (United States) — product analytics (usage volume, journey). No session replay enabled. You can opt-out in Settings → Privacy.
Google (Gemini, Maps) — AI image generation and map display. Text prompts you write and photos used for AI generation transit through their servers.
OpenAI — logo image generation.
LiveKit — real-time infrastructure for audio/video calls (only when you make or receive a call).
Apple / Google (push notifications) — only when enabled by you.

4. Retention

Account data: as long as your account is active. Deleted within 30 days after account closure.
Technical logs: 90 days maximum.
Backups: 30 days after account deletion.

5. Your rights

In accordance with GDPR Articles 15-22, you have:

Access: receive a copy of your data. Email [email protected].
Rectification: edit your data directly in the app, anytime.
Erasure: Settings → Danger zone → Delete my account. Active data is deleted after every step succeeds; technical backups expire within 30 days. If you no longer have access to the app, use the account deletion request page.
Portability: receive your data in a structured format (JSON).
Opposition: refuse analytics in Settings → Privacy.
Complaint: you can file a complaint with the CNIL or your local DPA.

6. International transfers

Some sub-processors (PostHog, Google, OpenAI) host part of the data in the United States. Transfers rely on the European Commission Standard Contractual Clauses (or Data Privacy Framework for certified sub-processors).

7. Security

All communication is HTTPS-encrypted. Passwords are hashed (bcrypt via Supabase) — Virelya never sees your password in plain text. Data access is protected by Row Level Security at the database level.

8. Contact

For any question, write to [email protected]. Reply within 30 days maximum.

Publisher

Virelya is published by Teddy Barbin, sole trader (EI), trading as “Karukera Labs”.
Principal place of business: Port Blanc, 97190 Le Gosier, Guadeloupe, France.
SIREN 824 591 713 — SIRET 824 591 713 00014.
Publication director: Teddy Barbin.
Contact: [email protected]

Host: TO BE COMPLETED — name, address and hosting region.