Service Communications Policy

1. Introduction

This Service Communications Policy explains how Proper User UAB, a company incorporated and registered in the Republic of Lithuania (“Proper,” “we,” “us,” or “our”), communicates with users regarding the operation, security, and functionality of the Proper User platform and Proper ID application (collectively, the “Services”).

These communications are mandatory and form part of the core Services.

By creating an account and using the Services, you acknowledge and agree to receive these communications.

2. Mandatory Service Communications

As part of providing identity verification services, we will send essential communications, including but not limited to:

• OTP authentication codes
• Security alerts
• Login confirmations
• Account activity notifications
• Verification status updates
• Re-verification requests
• System updates
• Regulatory compliance notices
• Platform authentication confirmations
• Partner platform access confirmations

These communications are necessary for the secure and lawful operation of the Services.

3. Communication Channels

Service communications may be delivered through:

• Email
• SMS
• Push notifications
• In-app notifications
• Other secure electronic communication channels

Users are required to maintain valid contact information.

4. Legal Basis

Service communications are processed under:

• Article 6(1)(b) GDPR – Performance of a contract
• Article 6(1)(c) GDPR – Compliance with legal obligations
• Article 6(1)(f) GDPR – Legitimate interests (security and fraud prevention)

These communications do not require separate marketing consent.

5. Non-Optional Nature

Because Proper provides security-sensitive identity verification services:

• OTP delivery cannot be disabled
• Security alerts cannot be disabled
• Verification notices cannot be disabled
• Regulatory notifications cannot be disabled

Users who do not wish to receive such communications must discontinue use of the Services and request account deletion.

6. Distinction from Marketing Communications

Proper may offer separate marketing communications in the future.

However, the communications covered in this Policy are strictly service-related and essential for:

• Identity verification
• Fraud prevention
• Platform authentication
• Legal compliance

7. Data Processing for Communications

To deliver service communications, we process:

• Email address
• Phone number
• Device notification identifiers
• Account logs
• Verification activity records

All processing complies with GDPR requirements.

8. Retention of Communication Logs

We maintain records of:

• Communication delivery
• OTP issuance
• Verification confirmations
• Security notifications

These logs are retained for fraud prevention, regulatory compliance, and audit purposes.

9. Governing Law

This Policy is governed by the laws of the Republic of Lithuania.

Any disputes shall fall under the exclusive jurisdiction of Lithuanian courts.

10. Contact Information

Operator:

Proper User UAB

Republic of Lithuania

Email: support@properuser.com

Website: www.properuser.com