Effective Date: 01 January 2025

This Non-User Policy explains how HolidayBuddie® processes limited personal information relating to individuals who do not hold an account on our platform (“Non-Users”), and outlines restrictions applicable to unauthorized access.

1. Processing of Non-User Information

HolidayBuddie may receive limited contact information relating to non-users in the following circumstances:

• When a registered user uploads contacts for connection discovery (subject to user consent);
• When necessary to verify account authenticity;
• When investigating suspected violations of platform rules, fraud, or security incidents.

The information received may include:

• Mobile phone number; and/or
• Email address

We do not collect additional contact list data beyond what is technically required for verification purposes.

2. Purpose of Processing

Non-user information is processed strictly for:

• Identity verification
• Fraud prevention
• Security monitoring
• Compliance with legal obligations

We do not use non-user information for marketing, advertising, or profiling purposes.

3. Data Retention

Non-user contact information is retained only for the duration necessary to:

• Complete verification processes;
• Investigate security concerns; or
• Comply with legal or regulatory obligations.

Where no legitimate security or legal purpose exists, such data is deleted or anonymized within a reasonable timeframe.

4. Lawful Basis (Where Applicable)

Where required under applicable data protection laws (including GDPR and similar frameworks), processing of non-user data is based on:

• Legitimate interests in ensuring platform security; and/or
• Compliance with legal obligations.

5. Rights of Non-Users

Where applicable under local data protection laws, non-users may have rights to:

• Request access to personal data we may hold;
• Request correction or deletion;
• Object to certain types of processing;
• Lodge a complaint with a supervisory authority.

To exercise such rights, please contact:

• contact@holidaybuddie.com

Identity verification may be required before processing requests.

Unauthorized Access & Non-User Restrictions

Access to HolidayBuddie services is restricted to registered users in accordance with our Terms of Service.

The following activities are strictly prohibited:

• Attempting to access user profiles or platform content without authorization
• Scraping, data mining, or automated extraction of platform content
• Use of bots, scripts, or automated tools to collect data
• Impersonation of registered users
• Circumvention of security measures

Unauthorized access or misuse may result in:

• IP blocking
• Legal action
• Reporting to relevant authorities

Reporting Concerns

If you believe your contact information has been uploaded without authorization, or you become aware of misuse of the platform by non-users, please contact:

• support@holidaybuddie.com

We will investigate concerns in accordance with applicable laws and internal procedures.

Regulatory Alignment

HolidayBuddie’s processing of non-user information is designed to align with applicable data protection frameworks, including:

• GDPR (Article 14 obligations)
• UK GDPR
• CCPA (where applicable)
• India’s Digital Personal Data Protection Act (DPDPA) 2023