Portability Privacy Notice

Status: OWNER-APPROVED LAUNCH WORDING — PUBLISHED SEPTEMBER 30, 2026 — PROFESSIONAL REVIEW DEFERRED

Effective date: September 30, 2026.

Portability is operated by AI Lead Lab LLC, a Florida limited liability company, with mailing address 7901 4th St N, Ste 300, St. Petersburg, FL 33702, United States ("Portability," "we," "us"). Support, privacy, legal, and rights requests use support@portabilityapp.net. No separate DPO or EU/UK representative is established in the current company records; one must be appointed and disclosed before a jurisdiction makes it legally required.

Scope

This notice explains how Portability handles personal information through the Portability mobile apps, website, account, travel planning, discovery, bookings, memberships, Creator tools, Kid's Corner, rewards, referrals, commissions, support, and connected-provider features. Some features are available only where an approved provider and legal path exist. A hidden or unavailable capability does not collect data merely because it exists in the product specification.

Information we handle

• Account and contact information, including account identifiers, name, email, authentication-provider identifiers stored as one-way hashes, preferences, membership, and support correspondence.
• Travel information that you enter or save, including trips, itinerary items, timing, reminders, notes, places, preferences, and offline items.
• Optional location information when an adult invokes a location-based feature. Manual location entry remains available. Child sessions do not request precise location.
• Search, discovery, saved items, interests, app activity, and preference signals needed to provide and improve chosen features.
• Photos, camera input, microphone input, profile media, Creator content, livestreams, replays, public/member-page content, chat, reports, and other content that you choose to create. Microphone use is push-to-talk and not continuously recorded.
• Push-notification tokens and notification choices.
• Booking, offer, merchant, reward, price-match, savings, and provider transaction records where a real approved provider supplies them.
• Apple App Store and Google Play product, purchase, restore, renewal, refund, revocation, and lifecycle information. Portability's server verifies purchases and controls entitlements. Google raw purchase tokens are represented by one-way SHA-256 digests in authority tables, and Android uses a pseudonymous account binding to prevent purchase misattribution.
• Referral attribution, sponsor relationships, commission ledgers, earnings status, payouts, KYC/tax verification status, and necessary fraud/reconciliation evidence. Sponsors receive aggregate or permitted information, not private identities or travel activity merely because a referral exists.
• Xaman public wallet address, transaction references, and public-ledger information when an approved wallet feature is used. Portability does not request or accept seeds or private keys.
• Device, security, reliability, and diagnostic information that is redacted in observability systems. Portability does not use behavioral advertising or cross-app tracking.

Why we use information

We use information to provide requested features; authenticate and secure accounts; save and synchronize trips; personalize chosen travel experiences; verify store purchases and entitlements; fulfill bookings and digital purchases; operate rewards, referrals, commissions, and payouts; provide Creator and community tools; respond to support, privacy, and safety requests; prevent fraud and abuse; comply with legal, tax, accounting, child-safety, and store obligations; and improve reliability using privacy-minimized diagnostics.

The legal bases depend on the activity and region: performance of a contract, consent, compliance with legal obligations, protection of users and the service, and legitimate interests where lawful and not overridden by individual rights. Portability is intended to be available worldwide where legally, technically, commercially, provider, payment, and store supported. A feature or transaction remains unavailable in a jurisdiction until any required regional legal-basis table, representative disclosure, consent, contract, provider, payment, transfer, or operational control is completed and published where required.

Permissions and choices

Portability requests location, camera, photos, microphone, and notifications only when the user invokes a feature that needs them. Manual or typed alternatives remain available where practical. You can change operating-system permissions and in-app choices. Denying an optional permission limits only the dependent feature.

Sharing and service providers

We share only what is necessary with Apple and Google for store purchases; authentication, cloud, security, analytics, support, communications, travel, booking, mapping, livestream, child-safety/creation, KYC/tax, payout, and wallet providers that are actually activated for the release; authorities when legally required; and transaction counterparties when necessary to complete an action you request.

Provider-dependent capabilities remain disabled where a provider, contract, credential, country, or legal approval is absent. We do not sell child profiles or use child data for behavioral advertising. We do not disclose private trip or earnings information to a referral sponsor merely because the sponsor relationship exists.

The verified or configured launch service-provider set is limited to:

Travel inventory/booking/maps, Agentic/voice/translation, Creator Live, Kid's Corner generation/VPC, KYC/tax/fiat payout, Xaman mainnet, and third-party analytics or monitoring providers are not production-active. Their dependent capabilities remain unavailable and they must not be represented as active subprocessors until contract, credentials, data terms, country scope, retention, and activation are verified.

Public and community information

Information you intentionally publish on a member page, Creator profile, chat, livestream, replay, review, or other public/community surface may be visible to others. Earnings, payouts, private account information, private travel activity, and private transactions are not public by default. Community content remains subject to the Community Standards, moderation, report/block/mute tools, and safety/legal processes.

Children's privacy

Kid's Corner is designed for children under 13 in parent-selected age bands 3–5, 6–8, and 9–12. A verified parent controls entry, exit, settings, age band, library, creation, export, and deletion. Child profiles are pseudonymous and private by default; contact fields, adult navigation, direct purchases, social/Creator/live features, wallet/crypto, precise location, and behavioral advertising are prohibited in child sessions.

Kid's Corner remains unavailable until Portability has an approved verified-parent and verifiable-parental-consent flow, child-safe providers, required store declarations, and legal approval. See the Children's Privacy Notice for the direct notice, collection, consent, review, export, and deletion terms.

Retention

Portability keeps information only as long as needed for the disclosed purpose and approved legal obligations. The proposed launch schedule, subject to final owner and qualified-counsel approval, is:

• optional Creator replays expire after 30 days unless made private, downloaded, or deleted sooner;
• raw push-to-talk audio and child source/provider payloads are transient and must be deleted after the requested processing; generated child creations remain private until a verified parent deletes them;
• chat history remains until a user deletes their own view; deletion does not remove the other participant's lawful view or evidence that must remain for safety/legal obligations;
• active account, trip, saved/offline, preference, and public-profile information remains for the account or feature life and is removed from active systems within 30 days after a verified deletion request;
• local encrypted/offline information remains on the device until the user removes it, deletes the app/device data, or platform storage removes it;
• ordinary profile/contact/authentication/product-access information is removed or de-identified when account deletion is completed;
• contract acceptance and financial, tax, payout, refund, reconciliation, and accounting records remain for seven years after the applicable account closure, final settlement, or final dispute period stated in the approved schedule, subject to any longer or shorter period required by applicable law;
• rights-request, support, moderation, fraud, chargeback, and appeal records remain for 24 months after final closure unless the seven-year financial period or a documented legal hold applies;
• authentication, security, access, and abuse-prevention logs remain for 12 months; product analytics, redacted diagnostics, and raw store webhooks remain for 90 days;
• Creator replays expire after 30 days unless made private, downloaded, or deleted sooner; raw push-to-talk audio and child source/provider payloads are transient and deleted after the requested processing;
• encrypted operational backups remain only for the applicable provider recovery window or approved backup schedule, and affected records return to the ordinary schedule when a documented legal hold ends;
• Cloudflare, Hostinger, Supabase, Postmark, Apple, and Google may retain provider-side records under their applicable service terms and legal obligations.

Your rights and account deletion

Depending on your location, you may request access, correction, export, deletion, restriction, objection, withdrawal of consent, or appeal. Use the in-app privacy/account controls, visit https://portabilityapp.net/delete-account, or contact support@portabilityapp.net.

Account deletion removes ordinary profile, contact, authentication, product, and access data after recent reauthentication and cancellation instructions. Portability retains only records required for financial, tax, fraud, dispute, safety, compliance, and audit purposes, and explains the applicable retention. Deleting Portability does not itself cancel a subscription managed by Apple or Google; use the relevant store subscription controls.

Portability will honor applicable jurisdiction-specific response periods, authorized-agent rules, appeals, and regulator contacts. The final regional addendum must be approved before distribution in a region that requires more specific language.

Security and international transfers

Portability uses access controls, encryption in transit, protected secrets, server-authoritative financial and entitlement records, data minimization, redacted logs, fraud controls, and provider verification. No security method is absolute. We will provide legally required incident notices.

Information may be processed outside your country by the verified providers above under their applicable service terms and transfer mechanisms. Additional transfer language or representatives must be added before distribution in a region that requires them.

Changes and contact

We will post material changes, update the effective date, and provide additional notice or consent where required. Questions, rights requests, or complaints: support@portabilityapp.net; postal contact: AI Lead Lab LLC, 7901 4th St N, Ste 300, St. Petersburg, FL 33702, United States.