Privacy Policy

Effective Date: September 8, 2026
Last Updated: September 8, 2026

This Privacy Policy explains how Xelerate Lab LLC ("Vulto Planner," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal information when you access or use Vulto Planner, our website, web application, related services, integrations, communications, and other features that link to this Privacy Policy (collectively, the "Service").

Vulto Planner is a personal productivity and planning service designed to help individuals organize tasks, plan their days and weeks, manage goals and routines, track time, and coordinate work and personal responsibilities.

By using the Service, you acknowledge the practices described in this Privacy Policy.

1. Who We Are

The entity responsible for Vulto Planner and the processing of personal information described in this Privacy Policy is:

Xelerate Lab LLC
1021 E Lincolnway Suite #10762
Cheyenne, Wyoming 82001
United States

Privacy: [email protected]
Security: [email protected]
Support: [email protected]

Where applicable under data protection law, Xelerate Lab LLC acts as the data controller for personal information processed through the Service.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information processed through:

• the Vulto Planner website;
• the Vulto Planner web application;
• account registration and authentication;
• Daily Planning;
• Daily Wrap-Up;
• Daily Journal;
• Weekly Planning;
• Weekly Review;
• Tasks and Subtasks;
• Life Areas and Lists;
• Weekly Goals;
• Inbox and Inbox Folders;
• Routines and recurring Tasks;
• priorities;
• Focus Mode;
• estimated and Actual Time tracking;
• scheduling and timeboxing;
• integrations you choose to connect;
• customer support;
• billing and subscription management;
• product communications; and
• other Vulto Planner services that link to this Privacy Policy.

This Privacy Policy does not govern websites, applications, or services operated independently by third parties, even where they integrate with Vulto Planner.

3. Information We Collect

The information we collect depends on how you use the Service and which features you choose to enable.

3.1 Account Information

When you create or maintain an account, we may collect:

• name;
• email address;
• securely protected authentication credentials;
• authentication method;
• account identifier;
• profile information;
• account creation date;
• account preferences; and
• account status.

If you use password-based authentication, passwords are protected using appropriate cryptographic password-protection practices. We do not need access to your plaintext password.

3.2 Professional and Onboarding Information

During onboarding or account configuration, you may choose to provide information such as:

• whether you work;
• occupation;
• professional role or title;
• preferred organizational structure;
• initial Lists or Life Areas; and
• other onboarding preferences.

Some onboarding information may be optional.

4. User Content

The Service allows you to create and store information as part of your personal productivity system ("User Content").

User Content may include:

• Task titles;
• Task notes;
• Subtasks;
• Life Areas;
• Lists;
• Weekly Goals;
• Inbox Tasks;
• Inbox Folder names;
• future-planning horizons;
• Routines;
• priorities;
• Due Dates;
• scheduled dates;
• timeboxes;
• Estimated Time;
• Actual Time;
• Focus Mode history;
• completion history;
• rollover information;
• Daily Journal entries;
• planning history;
• Weekly Review information;
• attachments;
• links; and
• other information you choose to enter.

You control the content you choose to place in the Service.

Because Vulto Planner can be used for both personal and professional planning, User Content may contain personal, confidential, or sensitive information that you voluntarily provide.

We do not require you to enter sensitive personal information into Tasks, notes, Daily Journal entries, or other free-text areas unless a particular feature explicitly requires that information.

5. Daily Journal and Reflection Information

Daily Journal entries are treated as User Content.

The current version of Vulto Planner does not publish your Daily Journal to Slack, Microsoft Teams, or other third-party collaboration platforms.

If we later introduce functionality that allows you to publish or share Daily Journal content with third-party services, such sharing will occur only through functionality you choose to use. We will update our privacy disclosures where required.

6. Authentication Information

6.1 Email and Password

If you register using email and password, we process the information necessary to authenticate and secure your account.

Passwords are intended to be stored using appropriate cryptographic password-protection techniques rather than as readable plaintext.

6.2 Google Sign-In

If you choose Sign in with Google, Google may provide information that you authorize, such as:

• your Google account identifier;
• name;
• email address;
• profile image, where provided; and
• other basic profile information included in the authentication permission you approve.

We use this information to:

• create or identify your Vulto Planner account;
• authenticate you;
• prevent unauthorized access;
• associate your login with the correct account; and
• provide the Service.

Using Google Sign-In does not automatically give Vulto Planner access to your Google Calendar, Gmail, Google Drive, or other Google Workspace data.

Access to additional Google services requires separate authorization where applicable.

7. Information From Integrations

You may choose to connect Vulto Planner with third-party applications and services.

Integrations may include services such as:

• Google Calendar;
• Asana;
• Linear;
• Jira;
• Gmail;
• GitHub; and
• other productivity, communication, or developer services.

We access third-party information only after the required authorization has been provided and only to the extent reasonably necessary to provide the integration functionality you choose to use.

The exact information accessed depends on:

• the integration;
• the permissions requested;
• the features you enable; and
• the permissions you approve with the third-party provider.

We will update this Privacy Policy if the introduction of an integration materially changes our processing practices.

8. Google Calendar and Google User Data

Vulto Planner may allow you to connect your Google account to Google Calendar functionality.

8.1 Information We May Access

Depending on the Google Calendar features you enable and the permissions presented to you during authorization, Vulto Planner may access information such as:

• calendar identifiers;
• calendar names;
• calendar metadata;
• event titles;
• event start and end times;
• event descriptions where required by the feature;
• event status;
• recurrence information;
• attendee or availability information where required;
• timezone information; and
• other Calendar information reasonably necessary to provide the feature you authorize.

If Vulto Planner provides functionality that creates or modifies Google Calendar events, we may also request permission to perform those actions on your behalf.

We seek to request only the Google permissions reasonably necessary for the features being provided.

9. How We Use Google User Data

Google user data accessed through Google APIs is used only to provide or improve user-facing Vulto Planner functionality that you choose to use.

For example, Google Calendar data may be used to:

• display calendar events alongside your planned Tasks;
• help you understand available time during your day;
• avoid scheduling work over existing events;
• support timeboxing;
• synchronize Task-related calendar blocks where enabled;
• create or update calendar events at your direction where supported;
• keep authorized calendar information synchronized; and
• provide other clearly disclosed Calendar-related productivity functionality.

We do not access Google user data for unrelated purposes.

10. Google API Limited Use

Vulto Planner's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Google user data obtained through Google APIs will not be:

• sold to data brokers or information resellers;
• sold or transferred to advertising platforms for targeted advertising;
• used for personalized or interest-based advertising;
• used to determine creditworthiness;
• used for lending decisions;
• used for surveillance;
• used for purposes unrelated to the user-facing functionality for which access was granted; or
• used to train or improve generalized or general-purpose artificial intelligence or machine-learning models.

Human access to Google user data is restricted except where:

• you explicitly authorize access to specific information;
• access is reasonably necessary to investigate security incidents, abuse, or technical problems;
• access is required by applicable law; or
• information has been appropriately aggregated or anonymized for legitimate internal operations permitted by applicable law and Google policy.

11. Disconnecting Google and Google Data Retention

You may disconnect your Google account from Vulto Planner using the integration settings made available through the Service.

You may also revoke Vulto Planner's access through your Google Account's third-party access or security settings.

When you disconnect or revoke Google access:

• Vulto Planner will stop making new requests to Google using the revoked authorization;
• OAuth access tokens, refresh tokens, or similar authorization credentials associated exclusively with the integration will be revoked, invalidated, or deleted as soon as reasonably practicable;
• Google-derived cached or synchronized information will be deleted or de-linked from active Vulto Planner systems within 30 days, unless retention is required by law or the information has become independent User Content through an explicit action you took;
• residual copies may remain in protected backups for up to 90 days before being overwritten through normal backup rotation; and
• Vulto Planner Tasks or other native User Content that you intentionally created using information from the integration may remain unless you delete that content.

12. Usage and Technical Information

When you access the Service, we may automatically collect technical information such as:

• IP address;
• browser type;
• browser version;
• device type;
• operating system;
• language;
• timezone;
• approximate geographic region derived from IP address;
• pages and features used;
• dates and times of access;
• authentication activity;
• application errors;
• crash information;
• performance information;
• session activity;
• feature interactions;
• referral information; and
• security-related logs.

We use this information to operate, secure, maintain, debug, analyze, and improve the Service.

13. Product Analytics

We may use analytics technologies to understand how users interact with the Service.

Analytics information may include:

• feature usage;
• navigation patterns;
• session activity;
• performance information;
• aggregate retention information;
• conversion information; and
• technical errors.

Where required by applicable law, non-essential analytics technologies will be used only after obtaining appropriate consent.

We do not use private Task content, Task notes, Daily Journal entries, or Google API user data for advertising profiling.

14. Cookies and Similar Technologies

We may use cookies, local storage, session storage, and similar technologies.

These technologies may be used for:

Essential Functions

Including:

• authentication;
• account security;
• session management;
• remembering application state; and
• preventing fraud or abuse.

Preferences

Including:

• appearance;
• timezone;
• planning preferences;
• interface settings; and
• other user choices.

Analytics

Where enabled, analytics technologies may help us understand how the Service performs and how features are used.

Where legally required, we will request consent before setting non-essential cookies or similar technologies.

You may also control cookies through your browser settings.

Disabling essential technologies may prevent parts of the Service from functioning correctly.

15. Communications

We may use your email address to send:

Service Communications

Such as:

• account verification;
• password reset information;
• security alerts;
• subscription notices;
• important product changes;
• material changes to legal terms; and
• other transactional communications.

You generally cannot opt out of communications necessary to operate or secure your account.

Product and Marketing Communications

Where permitted by law, we may send information about:

• product updates;
• new features;
• educational content;
• promotions; and
• related announcements.

You may unsubscribe from optional marketing communications using the unsubscribe mechanism provided in those messages.

16. Customer Support

If you contact us for support, we may process:

• your name;
• email address;
• support request;
• screenshots you provide;
• diagnostic information;
• correspondence;
• account information reasonably necessary to investigate the issue; and
• other information you voluntarily send to us.

We use this information to:

• respond to your request;
• diagnose problems;
• improve the Service;
• prevent abuse; and
• maintain support records.

We do not require access to private User Content unless reasonably necessary for your support request and permitted by applicable law.

17. Payment and Subscription Information

Payment transactions and subscription payments may be processed by Stripe.

Depending on the transaction, we may receive information such as:

• billing name;
• billing address;
• subscription status;
• payment status;
• transaction identifier;
• payment method type;
• the last four digits of a payment card where provided by Stripe; and
• billing history.

Complete payment-card information is generally processed directly by Stripe rather than stored by Vulto Planner.

Stripe processes information according to its own terms, privacy policy, and applicable legal obligations.

18. How We Use Personal Information

We may process personal information for the following purposes.

18.1 Providing the Service

Including to:

• create and maintain accounts;
• authenticate users;
• store Tasks and User Content;
• operate Daily Planning;
• operate Daily Wrap-Up;
• store Daily Journal entries;
• operate Weekly Planning and Weekly Review;
• maintain Weekly Goals;
• manage Routines;
• calculate Task timing;
• support Focus Mode;
• support Task rollover;
• provide Inbox functionality;
• synchronize data across sessions;
• operate integrations; and
• provide other requested features.

18.2 Personalizing the Service

Including to:

• remember preferences;
• display relevant planning information;
• apply workload thresholds;
• respect planning times;
• maintain timezone settings;
• preserve organizational structures; and
• improve the usefulness of planning workflows.

18.3 Operating and Improving Vulto Planner

Including to:

• understand feature usage;
• identify bugs;
• analyze performance;
• conduct product research;
• improve usability;
• develop new functionality; and
• maintain service reliability.

18.4 Customer Support

Including to:

• respond to questions;
• investigate reported issues; and
• resolve account problems.

18.5 Security

Including to:

• prevent fraud;
• detect abuse;
• protect accounts;
• enforce security controls;
• investigate suspicious activity; and
• maintain infrastructure security.

18.6 Communications

Including transactional communications and, where permitted, optional product or marketing communications.

18.7 Legal Compliance

Including to:

• comply with applicable legal obligations;
• respond to lawful legal process;
• establish, exercise, or defend legal claims; and
• enforce applicable agreements.

19. Legal Bases for Processing

Where the General Data Protection Regulation ("GDPR"), UK GDPR, or another applicable law requires us to identify a legal basis, we generally rely on one or more of the following.

Performance of a Contract

We process information when necessary to provide the Service you request, including:

• creating your account;
• storing your Tasks;
• providing planning functionality;
• maintaining your settings;
• operating integrations; and
• providing customer support.

Legitimate Interests

We may process information where reasonably necessary for legitimate interests such as:

• securing the Service;
• preventing fraud;
• debugging;
• understanding product performance;
• improving functionality; and
• operating our business.

When relying on legitimate interests, we consider the potential effect on your privacy rights.

Consent

We rely on consent where required, including for:

• certain integrations;
• certain cookies or analytics technologies;
• certain marketing communications; and
• other processing where consent is legally required.

You may withdraw consent where applicable.

Legal Obligations

We may process information when necessary to comply with applicable law, regulation, or valid legal process.

20. How We Share Information

We do not disclose personal information except as described in this Privacy Policy.

20.1 Service Providers and Subprocessors

We use third-party service providers and subprocessors to help operate Vulto Planner.

These may include providers of:

• cloud hosting;
• database infrastructure;
• authentication;
• email delivery;
• analytics;
• error monitoring;
• customer support;
• security;
• content delivery;
• file storage;
• payment processing; and
• other technical infrastructure.

These providers may process information on our behalf only as reasonably necessary to perform their services and subject to applicable contractual, security, and legal safeguards.

Our current subprocessor list is available at:

https://planner.vulto.co/subprocessors

We may update the subprocessor list as our infrastructure and vendors change.

20.2 Connected Services

When you connect a third-party integration, information may be exchanged with that third party as necessary to provide the functionality you requested.

The third party's own processing of information is governed by its privacy policy and applicable agreements.

20.3 At Your Direction

We may disclose information when you intentionally instruct the Service to share, export, publish, send, or otherwise transfer information.

20.4 Legal Requirements

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable law;
• comply with a valid court order, subpoena, or other legal process;
• protect the rights or safety of users or others;
• investigate fraud or security incidents;
• enforce our agreements; or
• protect Xelerate Lab LLC, Vulto Planner, or our users.

20.5 Business Transfers

If Xelerate Lab LLC is involved in a:

• merger;
• acquisition;
• financing;
• restructuring;
• bankruptcy;
• sale of assets; or
• similar corporate transaction,

personal information may be transferred as part of that transaction, subject to applicable law.

21. Sale of Personal Information and Advertising

Vulto Planner is a subscription productivity service.

We do not sell personal information to data brokers.

We do not sell private Task content, Task notes, Daily Journal entries, attachments, or integration data.

We do not use Google API user data for advertising.

We do not share personal information for cross-context behavioral advertising or targeted advertising as those concepts are defined under applicable privacy laws.

If these practices materially change, we will update this Privacy Policy and provide any legally required choices before applying the changed practices.

22. Artificial Intelligence and Model Training

The current Service does not use your private:

• Task content;
• Task notes;
• Daily Journal entries;
• Weekly Goals;
• private attachments; or
• Google API user data

to train generalized or general-purpose artificial intelligence or machine-learning models.

If we introduce artificial-intelligence functionality that materially changes how User Content is processed, we will update this Privacy Policy and provide additional disclosures or consent mechanisms where required.

Google user data will remain subject to applicable Google API Limited Use requirements.

23. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Our current retention framework is as follows.

23.1 Active Account Data

Account information and User Content are generally retained while your account remains active and as necessary to provide the Service.

23.2 User Content

User Content is generally retained until:

• you delete the content;
• you delete your account; or
• an applicable feature removes or archives information according to its disclosed behavior.

23.3 Deleted Accounts

Following an account-deletion request, personal information associated with your account will generally be deleted or anonymized from active systems within 30 days.

Certain information may be retained longer when reasonably necessary to:

• comply with law;
• prevent fraud or abuse;
• resolve disputes;
• enforce agreements;
• maintain financial or transactional records required by law; or
• establish, exercise, or defend legal claims.

23.4 Backups

Residual copies of information deleted from active systems may remain in protected backups for up to 90 days before being overwritten through normal backup rotation.

Backup copies are not intended to be used as ordinary active application data.

23.5 Security and Technical Logs

Security, operational, and technical logs may generally be retained for up to 90 days.

Specific records may be retained longer where reasonably necessary to investigate a security incident, fraud, abuse, legal claim, or other legitimate security or legal matter.

23.6 Google-Connected Data

Google-derived cached or synchronized data is generally removed from active systems within 30 days after the relevant Google integration is disconnected or authorization is revoked, subject to the circumstances described in Section 11.

Residual backup copies may remain for up to 90 days through normal backup rotation.

We may retain information that has been appropriately aggregated or anonymized so that it can no longer reasonably identify you.

24. Account Deletion

You may request deletion of your Vulto Planner account through:

• account settings, where available; or
• [email protected].

Following a verified account-deletion request, account information and User Content will generally be deleted or anonymized from active systems within 30 days, subject to the limited retention exceptions described in this Privacy Policy.

Deleting your account may permanently remove access to:

• Tasks;
• Subtasks;
• Life Areas;
• Lists;
• Weekly Goals;
• Inbox;
• Inbox Folders;
• Routines;
• Daily Journal entries;
• time-tracking information;
• planning history;
• attachments; and
• other User Content associated with your account.

Residual data may remain in protected backups for up to 90 days through normal backup rotation.

We may ask you to verify your identity before processing an account-deletion request.

25. Export and Portability

Where Vulto Planner provides an export feature, you may use it to obtain a copy of supported User Content.

Where required by applicable law, you may also request a portable copy of personal information you provided to us.

Requests may be submitted to:

[email protected]

26. Your Privacy Rights

Depending on where you live, you may have legal rights regarding your personal information.

These may include the right to:

• request access to personal information;
• obtain a copy of personal information;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• withdraw consent;
• request portability;
• opt out of certain uses or disclosures;
• appeal certain privacy-request decisions where required by law; and
• lodge a complaint with an applicable data protection authority.

These rights are subject to applicable legal limitations and exceptions.

27. Exercising Your Rights

To exercise applicable privacy rights, contact:

[email protected]

or use privacy controls made available within Vulto Planner.

Please include enough information for us to understand your request.

We may need to verify your identity before completing certain requests.

We will not discriminate against you for exercising privacy rights granted by applicable law.

Where applicable, you may authorize another person to submit a request on your behalf, subject to legally permitted verification procedures.

28. European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area, United Kingdom, or Switzerland, applicable data protection law may provide additional rights concerning your personal information.

Depending on the circumstances, these may include rights to:

• access;
• correction;
• deletion;
• restriction;
• objection;
• portability;
• withdrawal of consent; and
• complain to your local supervisory authority.

Where processing relies on consent, withdrawing consent does not affect processing that occurred lawfully before withdrawal.

Where processing relies on legitimate interests, you may have the right to object in certain circumstances.

29. International Data Transfers

Vulto Planner may use service providers or infrastructure located in countries other than your country of residence.

As a result, personal information may be transferred to and processed in other jurisdictions, including the United States.

Where legally required, we use appropriate mechanisms intended to protect international transfers, which may include:

• adequacy decisions;
• Standard Contractual Clauses;
• the UK International Data Transfer Agreement;
• an applicable UK addendum;
• contractual safeguards; and
• other legally recognized transfer mechanisms.

Information about applicable transfer safeguards may be requested from:

[email protected]

30. California Privacy Rights

If you are a California resident and applicable law grants you privacy rights, those rights may include:

• the right to know what personal information we collect and use;
• the right to request access;
• the right to request deletion;
• the right to correct inaccurate personal information;
• the right to obtain information about categories of personal information disclosed to third parties;
• the right to opt out of sale or sharing where applicable;
• rights concerning certain uses of sensitive personal information where applicable; and
• the right not to receive discriminatory treatment for exercising applicable privacy rights.

For purposes of California privacy law, we do not sell personal information or share it for cross-context behavioral advertising as described in Section 21.

Requests may be submitted to:

[email protected]

or through any additional privacy-request mechanism made available through the Service.

31. Other U.S. State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state law.

Depending on the applicable law, these may include rights to:

• access;
• correction;
• deletion;
• portability;
• opt out of targeted advertising;
• opt out of certain sales of personal data;
• opt out of certain profiling; and
• appeal privacy-request decisions.

Where applicable, requests may be submitted to:

[email protected]

We do not use personal information for targeted advertising or sell personal information as described in this Privacy Policy.

32. Global Privacy Control and Similar Signals

Where applicable law requires us to recognize legally valid browser-based privacy preference signals, such as Global Privacy Control, we will process those signals as required.

Because Vulto Planner does not currently sell personal information or use it for cross-context behavioral advertising, such opt-out signals generally do not change those practices.

33. Security

We use reasonable administrative, organizational, and technical safeguards designed to protect personal information.

Depending on the system and information involved, safeguards may include measures such as:

• encrypted network communications;
• access controls;
• authentication controls;
• password hashing;
• secrets management;
• restricted production access;
• infrastructure monitoring;
• logging;
• backups;
• vulnerability management;
• secure development practices; and
• vendor security review.

No internet-based service or storage system can be guaranteed to be completely secure.

You are responsible for:

• maintaining the confidentiality of your credentials;
• using a secure password where password authentication is used;
• protecting devices used to access your account; and
• notifying us if you believe your account has been compromised.

Security concerns should be reported to:

[email protected]

34. Data Breaches and Security Incidents

If we become aware of a security incident affecting personal information, we will:

• investigate the incident;
• take reasonable measures to contain and remediate it;
• preserve appropriate records;
• notify regulators where legally required; and
• notify affected individuals where applicable law requires notification.

35. Children's Privacy

Vulto Planner is intended for users aged 16 years or older.

The Service is not directed to children under 16.

We do not knowingly collect personal information from children under 16 in violation of applicable law.

If you believe a child under 16 has provided personal information to us in violation of this policy, contact:

[email protected]

We will review the situation and take appropriate action.

If Vulto Planner is later intentionally made available to younger users, we will implement additional parental-consent or children's-privacy mechanisms where legally required.

36. Sensitive Information

Because Vulto Planner is a flexible personal productivity application, users may voluntarily place sensitive information into Tasks, notes, Daily Journal entries, attachments, or other User Content.

Please consider carefully what information you choose to store.

Unless specifically stated otherwise, Vulto Planner is not intended to serve as:

• an electronic medical record system;
• a banking record system;
• a password manager;
• a government identity repository; or
• a specialized regulated-records system.

We process voluntarily submitted User Content only for the purposes described in this Privacy Policy.

37. Automated Decision-Making

Vulto Planner may perform automated calculations and organizational functions such as:

• workload calculations;
• scheduling suggestions;
• Task rollover;
• recurrence calculations;
• time estimates;
• sorting;
• prioritization displays; and
• other productivity-related automation.

These functions are designed to assist you with personal planning.

They are not intended to make decisions concerning:

• employment eligibility;
• lending;
• creditworthiness;
• insurance eligibility;
• housing eligibility;
• access to essential services; or
• other decisions producing similarly significant legal effects.

You remain responsible for decisions about how to organize and act on your Tasks.

38. Third-Party Links

Tasks, notes, and other User Content may contain links to third-party websites or services.

Vulto Planner may also link to third-party providers or services.

We are not responsible for the privacy practices of independently operated third parties.

We encourage you to review their privacy policies before providing information to them.

39. Beta and Pre-Release Features

During beta or pre-release testing, some features may change, be added, or be removed.

We may collect additional technical information reasonably necessary to:

• identify bugs;
• evaluate reliability;
• measure performance;
• respond to tester feedback; and
• improve the Service.

Private User Content will not be treated as public merely because the Service is in beta or pre-release.

Material changes to how personal information is processed will be reflected in this Privacy Policy or appropriate additional disclosures.

40. Future Features and Integrations

Vulto Planner may evolve over time.

Future functionality may include additional:

• calendar integrations;
• project-management integrations;
• email integrations;
• developer-tool integrations;
• mobile applications;
• productivity features;
• rapid-capture functionality; and
• other services.

Before introducing functionality that materially changes how personal information is collected, used, or shared, we will update our privacy disclosures and obtain additional authorization or consent where required.

We do not request access to third-party data merely because a future feature may eventually use that information.

41. Data Minimization

We aim to collect and process information that is reasonably necessary for:

• providing the functionality requested by users;
• operating and securing the Service;
• complying with applicable legal obligations; and
• improving Vulto Planner.

For third-party integrations, we aim to request the minimum permissions reasonably necessary for the functionality being provided.

42. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• changes to Vulto Planner;
• new features;
• new integrations;
• changes in our business;
• changes in service providers;
• legal or regulatory developments; or
• privacy and security improvements.

When we update this Privacy Policy, we will revise the Last Updated date at the top of this document.

If a change materially affects how we use personal information, we will provide additional notice where required, such as through:

• email;
• an in-product notice;
• our website; or
• another appropriate mechanism.

Where applicable law or third-party API policy requires renewed consent, we will request that consent before applying the materially changed processing.

43. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or your personal information, contact:

Xelerate Lab LLC
1021 E Lincolnway Suite #10762
Cheyenne, Wyoming 82001
United States

Privacy: [email protected]
Security: [email protected]
Support: [email protected]

44. Google API Disclosure

For clarity:

Vulto Planner's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

For questions or requests concerning Google-connected data, contact:

[email protected]

45. Privacy Commitment

Vulto Planner is designed to help users organize important parts of their work and personal lives.

That means users may entrust the Service with information about:

• what they intend to do;
• what they are working toward;
• how they spend their time;
• what they write in private planning and reflection workflows; and
• services they choose to connect.

Our objective is to process that information only in ways reasonably necessary to provide, secure, maintain, and appropriately improve Vulto Planner while giving users meaningful control over their information.