Privacy Policy

Urnovl (the website urnovl.co, the Urnovl apps for Android and iOS, and the Urnovl desktop app) is run by:

Anadyme Limited
Registered office: Pinelopis 5, Vera Court, Flat 401, 3101 Limassol, Cyprus
Registrar of Companies No.: HE 380526
EU company ID (EUID): CYDRCOR.HE380526
Email: support@urnovl.co

We are the "controller" of your personal data under the EU General Data Protection Regulation (GDPR). This means we decide why and how your data is used, and we are responsible for it.

We have not appointed a Data Protection Officer. For any privacy question, write to support@urnovl.co.

The table below lists each type of data, why we use it, the legal reason that allows us to use it (the "legal basis"), and how long we keep it.

If you do not give us the data we need for a feature (for example a shipping address for a physical order), we cannot provide that feature.

We send only service emails: sign-up codes, password resets, account messages and receipts. We do not send marketing emails to readers.

Everyone, including people without an account and search engines, can see:

• your display name, first and last name, profile picture, cover image, and the profile details you chose to add (about, location, website, social links, contact email);
• your public stories, inks, posts, canvases, comments, reviews, public shelves, your library, who you follow and who follows you;
• pages you run or belong to, competitions you host or enter (as the competition allows);
• Bravo messages sent from a chapter, which appear as a comment, unless you chose to send them anonymously.

People can find you by name in Urnovl search. Public pages may be indexed by search engines such as Google.

Private content (private stories, private shelves, your story bible and workspace) is visible only to you and to people you invite. Content you publish to followers or subscribers only is visible only to them.

Some people see more because of what they do on Urnovl:

• Pages that sell to you see your name, email, phone and shipping address for their orders, and your name, tier and subscription dates if you subscribe. If a subscription tier asks for a shipping address, the page sees it.
• People you send a Bravo to see your name, unless you send it anonymously.
• Competition hosts, co-host pages and judges see the entries submitted to their competition.
• People you invite to view a story workspace see its chapters, canvas and story bible.

When you report content, the author is not told who reported it.

Urnovl is the seller for every purchase on Urnovl, including Premium, page subscriptions, Bravos and store orders. Card payments are processed by Stripe. Stripe collects your card details directly. We receive only the payment result, your billing details and the country of your card.

Stripe also processes your data as an independent controller, for example to prevent fraud. See the Stripe Privacy Policy.

We issue your receipts through Elorus, our invoicing provider. Elorus sends the receipt to your email. Greek law requires us to report our invoices and receipts to the Greek tax authority (AADE) through its myDATA system.

We use your billing country and card country to charge the correct VAT for your country, as EU law requires.

Records of past purchases made with our former PayPal system are kept for the same tax period.

If you join the Partnership Program to earn money on Urnovl, we also collect:

• Individuals: your legal first and last name.
• Pages and businesses: the business legal name, business type, and the representative's first and last name.
• Tax profile: country of tax residency, Greek tax ID (AFM) or business tax ID, VAT ID, whether you are a registered freelancer, and changes to these details over time.
• Self-billing consent: the date, time, IP address and version of the agreement you accepted, allowing us to issue invoices on your behalf.
• Earnings: your revenue shares, the qualified reads of your stories, and each amount earned, held and paid.

We use this data to calculate and pay your earnings, issue the tax documents for your payouts, and meet our tax reporting duties. These include reporting to the Greek tax authority (AADE), and reporting sellers' income under EU Council Directive 2021/514 (known as "DAC7").

Your tax IDs are encrypted when stored.

Stripe Connect: to receive money you open a Stripe Connect account. Stripe collects the identity and bank details that financial law requires (for example your date of birth, address and bank account). Stripe keeps these details. We read them only when we need them to issue your tax documents.

Legal basis: contract (the Partnership Program terms) and legal obligation (tax law). We keep this data for up to 10 years after your last payment.

We never sell your personal data. We share it only with the service providers below, who process it for us under contract (as "processors"), or who act as independent controllers where stated.

We may also share data:

• with tax and public authorities, when the law requires it (for example AADE);
• with courts, police or lawyers, when needed to comply with the law, or to establish, exercise or defend legal claims;
• with a buyer or successor, if Urnovl is sold or merged. We will tell you before this happens.

Part of what partners earn depends on how many "qualified reads" their stories get. To keep this fair, we check every read automatically.

A read does not count, for example, when:

• authors read their own stories;
• the same person reads the same chapter again within 24 hours;
• the account is less than 3 days old (unless it has an active subscription);
• the reading or listening time is too short to be real.

We also look for unusual patterns, such as many reads from the same IP address in one day.

Device identifier. Our website and apps calculate a device identifier from browser and device characteristics (using the open-source FingerprintJS library, which runs on your device). We store it with each read, only to detect fake and automated reads. We never use it for advertising. It is deleted after 90 days together with the read record.

Automated decisions. The qualified-read check is automatic, and it affects how much partners earn. It never affects readers. If you are a partner and think a decision was wrong, write to support@urnovl.co. A person will review it.

Cookies are small files stored in your browser. We also use your browser's local storage, which works in a similar way. We use them for two purposes.

These keep Urnovl working. You cannot switch them off.

These are used only if you allow them in the cookie banner.

Your choice. You can change your choice at any time with the cookie icon in the bottom-right corner of the website, or by clearing your browser's cookies and storage. You can also block cookies in your browser settings, but some parts of Urnovl may then stop working.

Apps. The Android and iOS apps use Firebase Analytics for usage statistics. The Android app shows ads through Google AdMob, which uses your device's advertising ID. You can reset or delete this ID in your Android settings.

Do Not Track. We do not respond to "Do Not Track" browser signals. Use the cookie banner instead.

Our servers are in the European Union. Some providers listed in section 6 are in the USA. When your data goes to the USA, we rely on the EU-US Data Privacy Framework for providers certified under it. For the others we rely on the European Commission's Standard Contractual Clauses. You can ask us for a copy of these safeguards.

You can delete your account from the Settings tab of your profile, on the website or in the app:

1. Select Delete account.
2. We email you a confirmation link, valid for 5 minutes.
3. We check the request (for example, for open orders or payments) and then delete your account. You can cancel until then.

When we delete your account, we delete your profile, settings, stories, chapters, inks, posts, canvases, reviews, shelves, library, follows, memberships and the pages you own. Comments that have replies become "[Comment deleted]", so the conversation still makes sense.

We keep only what the law requires. Payment, receipt and payout records are anonymised (your name is removed from them) and kept for the tax period. Competitions you hosted that already have winners stay, without your name.

Cancel your Premium and page subscriptions before you delete your account.

Under the GDPR you have the right to:

• Access: get a copy of your personal data.
• Rectification: correct wrong or incomplete data. You can edit most of it yourself in your settings.
• Erasure: have your data deleted (see section 10).
• Restriction: ask us to pause the use of your data in some cases.
• Portability: get the data you gave us in a machine-readable format.
• Objection: object to uses based on our legitimate interests.
• Withdraw consent: at any time, for anything based on consent (for example cookies). This does not affect what we did before.
• Human review of automated decisions (see section 7).

To use any of these rights, write to support@urnovl.co from the email of your account. We answer within one month. We may ask you to prove your identity.

Complaints. You can complain to the Greek data protection authority:

Hellenic Data Protection Authority (HDPA)
Kifisias 1-3, 115 23 Athens, Greece
www.dpa.gr

You can also complain to the authority of the EU country where you live or work. We would like to try to solve the problem first, so please contact us.

You must be at least 15 years old to create an Urnovl account. You must be at least 18 years old to buy, to sell, or to join the Partnership Program.

We do not knowingly collect data from children under 15. If you believe a child under 15 has an account, write to support@urnovl.co and we will delete it.

We protect your data with encrypted connections (HTTPS), hashed passwords, encrypted tax IDs, access controls and regular backups. No system is perfectly secure. If a breach puts your rights at risk, we will tell the HDPA within 72 hours and tell you without undue delay, as the GDPR requires.

Keep your password secret. If you think someone used your account, change your password and write to us.

We may update this policy when Urnovl or the law changes. We will show the date of the last update below. If a change is important, we will tell you in the app, on the website or by email before it applies.