Effective Date: April 17, 2026

Quantum Tunneling Ltd (QT LTD) (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our mobile application VESPER (“App”). By using the App, you agree to the practices described in this policy.

1. Information We Collect

• Personal Information: When you register, you may provide your name, email address, and other contact details.
• Financial and Transaction Data: You may enter budgets, spending transactions, gambling activities, comps (e.g., free play, hotel, food, and beverage credits), and related financial data.
• User-Generated Content: You may submit notes, trip agendas, photos, or PDFs, some of which may be shared as community notes with your explicit consent.
• Usage Data: We collect data about how you interact with the App, such as pages visited, features used, session duration, and inferred data from interactions (e.g., preferences derived from usage patterns).
• Device Information: We collect device identifiers, IP addresses, operating system, and browser type for analytics and security purposes.
• Location Data: If you enable location services, we may collect general location data (e.g., city-level) to enhance trip planning features.

2. How We Use Your Information

We use your information to:
– Provide and improve the App’s functionality, such as tracking budgets and transactions.
– Enable the sharing of community notes and, in future releases, trip agendas, with your explicit consent.
– Analyze usage patterns to enhance user experience and develop new features.
– In future releases, use anonymized data to train AI models for generating insights and recommendations (e.g., budget optimization or trip planning suggestions).
– Moderate user-generated content, such as photos and PDFs, for safety and compliance.
– Comply with legal obligations and respond to legal requests, such as subpoenas.
– Send you service-related communications, such as updates or account notifications.

3. Data Sharing

We do not sell your personal information. We may share your information as follows:
– **Community Notes**: With your explicit consent, your notes may be shared as anonymized community notes, visible to other users.
– **Future Trip Agendas**: With your explicit consent, trip agendas may be shared in future releases.
– **Service Providers**: We share data with third-party vendors (e.g., cloud storage, analytics providers) who assist in operating the App, subject to strict confidentiality agreements.
– **Affiliates and Business Transfers**: We may share data with affiliates or in the event of a merger, acquisition, or asset sale.
– **Emergencies**: We may disclose data if necessary to protect safety, property, or rights.
– **AI Insights**: Anonymized data may be used to train AI models for generating insights, ensuring no personally identifiable information is included.
– **Legal Compliance**: We may disclose data to comply with applicable laws or respond to valid legal processes.
We do not share your data with external Las Vegas sources or advertisers linked in the App.

4. User Consent and Control

– **Community Notes and AI Use**: You must provide explicit consent to share notes as community notes or use your anonymized data for AI insights. You can withdraw consent at any time via the App’s settings.
– **Data Access, Correction, Deletion, and Portability**: You may request access to, correction of, deletion of, or portability of your personal information by contacting us at info@qtmobapps.com. We will respond within 30 days, subject to legal obligations.
– **Authorized Agents and Appeals**: You may designate an authorized agent to make requests on your behalf. If a request is denied, you may appeal the decision.
– **Opt-Out**: You may opt out of non-essential data collection (e.g., analytics) or marketing communications via the App’s settings or by following unsubscribe instructions in emails.
– **Upload Controls**: You can manage or delete uploaded photos and PDFs via the App’s settings.

5. Data Security

We implement industry-standard security measures, such as encryption and access controls, to protect your data. However, no system is completely secure, and we cannot guarantee absolute security. We encourage users to use strong passwords, enable two-factor authentication where available, and avoid sharing sensitive information unnecessarily.

6. Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this policy or as required by law. For example, financial transaction data may be retained for up to 7 years for audit purposes, while uploaded photos and PDFs are retained until deleted by you or us. If you request deletion, we will remove your data, except where retention is required for legal or operational purposes.

7. Third-Party Links

The App may contain links to third-party websites or services (e.g., hotel or casino websites), which may include advertisements. We are not responsible for their privacy practices. Please review their policies before sharing information. No user data is transferred to these sites via the App.

8. International Users

We operate from Canada and host data on servers in the United States. If you are located outside Canada or the United States, your data may be transferred to and processed in these countries, where privacy laws may differ. By using the App, you consent to this transfer. We implement safeguards, such as Standard Contractual Clauses (SCCs) or the EU-U.S. Data Privacy Framework (DPF), to ensure appropriate protection levels in compliance with applicable laws, including PIPEDA (Canada), GDPR (EU), CCPA/CPRA (U.S.), and equivalent regulations in your jurisdiction.

9. Children’s Privacy

The App is not intended for users under 18. We do not knowingly collect data from children under 18. If we learn such data has been collected, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes via the App or email. Your continued use of the App constitutes acceptance of the updated policy.

11. Contact Us

If you have questions or concerns about this Privacy Policy, contact us at info@qtmobapps.com or Quantum Tunneling Ltd (QT LTD), 1311 Harvest Hills Dr NE, Calgary, AB, Canada, T3K 4W5.