0. Data Controller

The data controller responsible for the processing of personal data via this Site is:

Nazar Mishchenko ("Next10")
Hohenzollernstr. 51
75177 Pforzheim
Germany

Email: privacy@next10.live
Telephone: +49 160 93512675

If you have any questions about how your personal data is processed, you can contact the data controller using any of the above details.

1. Information We Collect

Information You Provide to Us

We collect information you voluntarily provide to us when you join our waitlist, including:

• Name - your first and last name
• Email address - to communicate waitlist updates and marketing communications
• Device platform - iPhone, Android, or both (to tailor launch communications)
• Referral source - how you found out about Next10 (optional)
• Feature suggestions - any optional feedback you provide

How Your Information Reaches Us

When you submit the waitlist form on next10.live, your data is transmitted directly to a Google Sheet maintained by us, using Google Apps Script. Google LLC acts as our data processor for this storage. Google's servers are located in the United States; we rely on Google's certification under the EU–US Data Privacy Framework and Standard Contractual Clauses to ensure your data receives equivalent protection to EU law.

Information Automatically Collected

When you visit our Site, we may automatically collect technical information, including browser type and version, operating system, referring URLs, device type and screen resolution, pages visited and time spent, approximate geographic location (country/region level), and anonymised IP address.

2. How We Use Your Information

We use the information you provide for the following purposes:

• Waitlist management — to record your place on the waitlist and verify the integrity of submissions.
• Marketing and launch communications — to send you emails about the Next10 app, including: development updates, behind-the-scenes news, beta access invitations, launch announcements, post-launch product updates, new feature releases, and other information we believe will be useful to you as someone interested in the app. These emails are sent on the basis of your explicit consent given at signup. You can unsubscribe at any time using the link at the bottom of any email, or by emailing privacy@next10.live.
• Service and security — to operate, maintain, secure, and improve the Site.
• Analytics — to understand (in aggregated, anonymised form) how visitors use the Site, subject to your cookie consent.
• Legal compliance — to comply with applicable laws and to detect, prevent, or address fraud or misuse.

We will never sell, rent, or trade your personal information to third parties for their own marketing purposes.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on the following lawful bases to process your personal data:

• Consent (Article 6(1)(a)) - You joined our waitlist and gave explicit consent to receive marketing communications about Next10.
• Legitimate Interests (Article 6(1)(f)) - Operating, maintaining, and improving our website and services, where such interests are not overridden by your rights.
• Legal Obligation (Article 6(1)(c)) - Compliance with applicable laws and regulations.

You may withdraw consent at any time by contacting us at privacy@next10.live or using the unsubscribe link in any email we send you.

4. How We Store Your Information

Your waitlist data is stored in a Google Sheet maintained by us, processed through Google Apps Script. Google LLC acts as our data processor for this purpose, subject to Google's Privacy Policy and the Google Cloud Data Processing Addendum. Our website is hosted on GitHub Pages, subject to GitHub's Privacy Statement.

We implement appropriate technical and organisational security measures to protect your data against accidental loss, unauthorised access, alteration, or disclosure. Access to your personal data is restricted to those with a legitimate need to process it.

5. Sharing Your Information

We do not sell your personal data. We may share your information only with the following data processors and in the following limited circumstances:

• Google LLC (Google Sheets and Google Apps Script) — acting as our data processor for waitlist storage and form processing. Google processes data on our instructions in accordance with the Google Cloud Data Processing Addendum. Data may be stored on Google servers in the United States, protected by the EU–US Data Privacy Framework and Standard Contractual Clauses.
• Google LLC (Google Analytics) — acting as our analytics processor, only if you have consented to analytics cookies. IP addresses are anonymised before storage.
• GitHub, Inc. — website hosting (GitHub Pages). GitHub does not have access to waitlist submissions; it only serves the static site files.
• Legal Requirements — We may disclose information where required by law, court order, or governmental authority.
• Business Transfers — In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction, with appropriate notice to you.

6. Cookies and Tracking Technologies

Our Site may use cookies and similar technologies. For full details on what cookies we use, why we use them, and how to manage them, please see our Cookie Policy.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right to Access - Request a copy of the personal data we hold about you.
• Right to Rectification - Request correction of inaccurate or incomplete data.
• Right to Erasure - Request deletion of your personal data where we have no compelling reason to continue processing it.
• Right to Restrict Processing - Request that we temporarily stop processing your data in certain circumstances.
• Right to Data Portability - Receive your data in a structured, commonly used, machine-readable format.
• Right to Object - Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent - Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@next10.live. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are in the EEA or UK, you also have the right to lodge a complaint with your local supervisory authority. In Germany, this is the relevant state data protection authority (Landesbeauftragte für Datenschutz). In the UK, this is the Information Commissioner's Office (ICO).

8. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the CCPA as amended by the CPRA grants you additional rights:

• Right to Know - What personal information we collect, use, disclose, or sell.
• Right to Delete - Request deletion of personal information we have collected.
• Right to Correct - Request correction of inaccurate personal information.
• Right to Opt-Out - We do not sell or share personal information for cross-context behavioural advertising.
• Right to Non-Discrimination - We will not discriminate against you for exercising your CCPA rights.

To submit a CCPA request, contact us at privacy@next10.live with the subject line "CCPA Request".

9. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you. Your waitlist position is determined on a first-come, first-served basis based on submission timestamp, without any algorithmic scoring.

10. Children's Privacy

Our Site is not directed at children. We do not knowingly collect personal data from anyone under the age of 16 in the European Economic Area, or under the age of 13 in other jurisdictions, without verified parental or guardian consent.

If you believe a child has provided personal data to us without appropriate consent, please contact us at privacy@next10.live and we will delete the information promptly.

11. Links to Third-Party Sites

Our Site may contain links to third-party websites such as Instagram, X (Twitter), and others. These links are provided for convenience only. This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. International Data Transfers

Your personal information may be transferred to, stored in, and processed in countries other than your own, including the United States, where Google's infrastructure is located. When we transfer data outside the EEA or UK, we ensure appropriate safeguards are in place, including Google's certification under the EU–US Data Privacy Framework and Standard Contractual Clauses (SCCs), to maintain the same level of protection required under GDPR.

13. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by law:

• Waitlist data — Retained for as long as you remain subscribed to Next10 communications. You can withdraw at any time, after which we will delete your data within 30 days, except where retention is required by law.
• Post-launch marketing data — If you continue to consent to marketing communications after the app launches, we will retain your contact details and engagement data until you unsubscribe or request deletion.
• Analytics data — Retained in anonymised, aggregated form indefinitely; individual session data for up to 14 months (the default in Google Analytics 4).
• Legal and compliance records — Retained as required by applicable law, typically 6 years under German commercial law (HGB §257).

14. Security of Your Information

We use reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorised access, use, or disclosure. These include access controls, data encryption in transit (HTTPS/TLS), and regular security assessments. However, no method of internet transmission is 100% secure.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will revise the "Last updated" date at the top of this page. If we make material changes, we will notify you by email (where we have your contact details) or by prominently posting a notice on our Site.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact the data controller:

• Name: Nazar Mishchenko ("Next10")
• Address: Hohenzollernstr. 51, 75177 Pforzheim, Germany
• Email: privacy@next10.live
• Telephone: +49 160 93512675

We aim to respond to all enquiries within 5 business days.