Privacy Policy

Effective date: July 26, 2026

The O’Connor Company LLC, doing business as Denver Deals (“Denver Deals,” “we,” “us,” or “our”), operates the Denver Deals mobile application and the website at denverdeals.app (together, the “Service”). This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices you have.

BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, YOU MUST IMMEDIATELY DISCONTINUE USE OF THE SERVICE.

We may collect, use, and share information as described in this Policy.

1. Who We Are

Denver Deals is operated from Denver, Colorado, United States. To contact us about this policy, email privacy@denverdeals.app.

2. Information We Collect

We collect personal information in the following categories, depending on how you interact with the Service. “Personal information” means any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual or household.

Information you give us

• Account information — email address, password (stored hashed), display name, account type (shopper or merchant).
• Merchant business information — business name, business address, business phone, Google Place ID, business category, logo image (optional).
• Deal redemption activity — which deals you claim and when.
• Communications — messages you send to support.

Information collected automatically

• Device information — device model, operating system version, app version, language.
• Approximate and precise location — with your explicit permission, we collect location information while you are actively using the app to show nearby deals, determine claim eligibility, and support redemption. After you actively claim a deal, we may also collect location information in the background for the limited purpose of determining whether you arrive within the required proximity of the claimed merchant location. This limited background collection stops when arrival is confirmed, your 45-minute redemption window expires, or the deal is cancelled. We do not collect location information passively or continuously when you are not using the app or do not have an active claimed deal, and you can revoke location permission at any time in your device settings.
• Push notification token — a Firebase Cloud Messaging identifier used to deliver deal alerts and claim notifications.
• Usage and diagnostic data — pages and screens viewed, actions taken, error logs.

Information from third parties

• Google Places — when a merchant searches for and selects their business during onboarding, we receive that business’s public Place data (such as name, address, and coordinates) from Google to verify the merchant’s fixed business location. We do not track a merchant’s real-time location.
• Stripe — when a merchant subscribes, Stripe processes the payment and returns a transaction status and subscription identifier. We do not receive or store full card numbers.

3. How We Use Information

We use the information we collect to:

• Create and maintain your account.
• Show you deals near your current location while you are actively using the app.
• Verify your eligibility to claim and redeem a deal, including by checking proximity while you use the app and, after you actively claim a deal, monitoring for arrival at the claimed merchant location until arrival is confirmed, the redemption window expires, or the deal is cancelled.
• Send push notifications about deals, claim timers, and merchant cancellations.
• Send merchants reminders and suggestions relating to their own business activity on the Service — for example, that they have not posted a deal recently, or a prompt to repeat an offer they have run before. These may be timed using signals that are not personal information, such as local weather or publicly scheduled local events. Merchants can turn these off at any time in the app’s notification settings.
• Process merchant subscription payments through Stripe.
• Send SMS or voice verification messages to merchants during location verification, as described in Section 5.
• Detect, investigate, and prevent fraud, abuse, and violations of our Terms of Service.
• Provide customer support and respond to your inquiries.
• Improve the Service and develop new features.
• Comply with legal obligations.

4. How We Share Information

We do not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration, including as “sale” or “sharing” may be defined under the California Consumer Privacy Act (“CCPA”), the Colorado Privacy Act (“CPA”), or any other applicable privacy law.

We share information only as described below, with service providers that process information on our behalf and with other parties when necessary to operate the Service, comply with law, or protect rights and safety:

• Service Providers and Contractors. The following third-party service providers process personal information on our behalf solely to provide services to us, and are contractually prohibited from using such information for their own purposes:
  • Railway — application hosting.
  • PostgreSQL (managed by Railway) — primary data store.
  • Redis (managed by Railway) — session and rate-limit cache.
  • Firebase Cloud Messaging (Google) — push notification delivery.
  • Stripe — payment processing for merchant subscriptions.
  • Google Places API — merchant location verification.
  • Resend — transactional email delivery (account verification, security notifications, claim alerts).
  • Twilio — SMS and voice delivery of one-time verification codes to merchant business phone numbers, as described in Section 5.
• Merchants receive limited information when you claim or redeem one of their deals, such as a unique claim code, claim or redemption timestamps, and confirmation that a claim was associated with the merchant’s fixed business location. Merchants do not receive your email address, phone number, or your precise device location data.
• Legal, Regulatory, and Safety Disclosures. We may disclose personal information to governmental or regulatory authorities, law enforcement agencies, courts, or other third parties when we have a good-faith belief that such disclosure is necessary to: (i) comply with a legal obligation, subpoena, court order, or other applicable law or regulation; (ii) enforce our Terms of Service or other applicable agreements; (iii) protect the rights, property, or safety of Denver Deals, our Users, or the public; or (iv) detect, prevent, or address fraud, security incidents, or technical issues.
• Business Transfers. In the event of a merger, acquisition, consolidation, reorganization, sale of substantially all of our assets, or other similar corporate transaction, personal information may be transferred to, or acquired by, a successor entity. We will provide notice to affected Users before their personal information is transferred and becomes subject to a materially different privacy policy, to the extent required by applicable law.

5. SMS and Voice Messaging

When a Merchant registers a business location, Denver Deals sends a one-time passcode (“OTP”) via SMS text message or automated voice call to the business phone number on file with Google Places, for the sole purpose of verifying Merchant’s ownership of that phone number. Message frequency is limited to one message per verification request and typically occurs once per business location during onboarding. Message and data rates may apply, as determined by your mobile carrier.

Denver Deals engages Twilio, Inc. (“Twilio”) to deliver these SMS and voice messages on our behalf. Twilio processes the recipient phone number and message content solely to effect delivery and is contractually prohibited from using such information for its own purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Mobile telephone numbers, text messaging originator opt-in data, and consent information are excluded from every category of information sharing described in this Policy; this information will not be shared with, sold to, or disclosed to any third party or affiliate for their marketing or promotional purposes.

To opt out of SMS messages, reply STOP to any message you receive from us. For assistance, reply HELP or contact us at support@denverdeals.app.

6. Your Rights and Choices

Depending on your jurisdiction of residence, you may have certain rights with respect to your personal information. We will not discriminate against you for exercising any of the rights described in this Section. To the extent any right described below is not recognized under the laws of your jurisdiction, Denver Deals is under no obligation to honor such a request, though we will endeavor to accommodate reasonable requests where operationally feasible.

• Access and correction — you can access and update certain account information from within the app.
• Account deletion — you can request permanent deletion of your account from within the app. Deletion removes your personal profile and unlinks historical claim records where reasonably feasible; some information may be retained in anonymized or deidentified form, or as reasonably necessary for fraud prevention, legal compliance, dispute resolution, and financial reconciliation.
• Location permission — location access requires your explicit device-level permission, and you can revoke that permission in your device settings at any time. Without required location permission, some features of the Service, including claiming and redeeming deals, may not function.
• Push notifications — you can disable push notifications in your device settings or within the app.
• Marketing Communications. We do not send marketing emails at launch. If we introduce marketing communications in the future, we will do so only with your separate, affirmative opt-in consent where required by applicable law. You will have the right to withdraw your consent and unsubscribe from marketing communications at any time by following the unsubscribe instructions included in any such communication or by contacting us at privacy@denverdeals.app.

State-Specific Privacy Rights. Residents of California, Colorado, Virginia, Connecticut, Utah, and other jurisdictions with applicable comprehensive privacy laws may have additional statutory rights, which may include: (i) the right to know or access the categories and specific pieces of personal information we have collected about you; (ii) the right to correct inaccurate personal information; (iii) the right to delete personal information, subject to certain exceptions; (iv) the right to obtain a portable copy of personal information you have provided to us; (v) the right to opt out of the sale or sharing of personal information, targeted advertising, or certain profiling activities, where applicable; and (vi) the right to non-discrimination for exercising any of the foregoing rights. To submit a verifiable privacy rights request, contact us at privacy@denverdeals.app. We may take reasonable steps to verify your identity before processing your request. Where required by applicable law, you may appeal our decision regarding your request by replying to our written response. We will process all requests within the timeframes required by applicable law.

7. Data Retention

We retain personal information for no longer than is reasonably necessary to fulfill the purposes for which it was collected, as described in this Policy. Specifically, we retain personal information for as long as: (i) your account remains active and the information is needed to provide the Service; (ii) is necessary to verify claims and redemptions, process payments, prevent fraud, resolve disputes, and satisfy legal and regulatory obligations; or (iii) is otherwise permitted under applicable law. Location data associated with browsing sessions or claim verification is retained only for as long as reasonably necessary for those specific purposes, after which it is deleted, deidentified, or aggregated as appropriate. Upon account deletion, we will delete or deidentify your personal profile and unlink historical claim records where reasonably feasible, subject to our right to retain the minimum information necessary for legal compliance, fraud prevention, dispute resolution, and financial reconciliation. Different categories of personal information may be subject to different retention periods, and we will apply retention schedules in accordance with applicable legal requirements.

8. Children

The Service is not intended for, directed to, or designed to attract individuals under the age of eighteen (18) years (“Minors”). We do not knowingly solicit or collect personal information from Minors and do not knowingly allow Minors to register for or use the Service. Use of the Service by Minors is prohibited without verifiable parental or guardian consent. If you are a parent or guardian and believe that your child has provided personal information to us without your consent, please contact us immediately at privacy@denverdeals.app. Upon verification, we will take prompt steps to delete the relevant information from our systems. To the extent applicable, this Policy is intended to comply with the Children’s Online Privacy Protection Act (“COPPA”) and similar laws.

9. Security

We implement and maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or destruction. Such measures include, without limitation, encryption of data in transit using HTTPS/TLS, hashed storage of passwords using industry-standard algorithms, scoped access tokens, role-based access controls, and restricted access to production systems. Notwithstanding the foregoing, no method of electronic transmission, storage, or processing is completely secure, and we cannot guarantee the absolute security of personal information. In the event of a data breach that creates a risk of harm to affected individuals, we will notify impacted Users and applicable regulatory authorities as required by applicable law.

10. International Users

The Service is operated and managed from the United States. If you access or use the Service from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where privacy laws may differ from and may be less protective than those of your country of residence. By using the Service, you consent to the transfer of your information to the United States and its processing in accordance with this Policy. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information.

11. Changes to This Policy

We reserve the right to amend or update this Policy at any time to reflect changes in our data practices, the Service, or applicable legal requirements. The revised Policy will be posted at this URL with a new “Effective Date” at the top. For material changes — including changes to the categories of personal information we collect, the purposes for which we use it, or the third parties with whom we share it — we will provide advance notice through the app, by email to the address associated with your account, or through other prominent means. Your continued use of the Service after the revised Policy becomes effective constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must discontinue your use of the Service.

12. Contact

Questions about this policy: privacy@denverdeals.app

13. Governing Law

This Policy shall be governed by and construed in accordance with the laws of the State of Colorado, without regard to its conflict of laws principles, and subject to applicable federal law. If any provision of this Policy is found to be unlawful, void, or unenforceable for any reason, that provision shall be deemed severable from this Policy and shall not affect the validity and enforceability of the remaining provisions. This Policy, together with our Terms of Service and any other agreements incorporated herein by reference, constitutes the entire agreement between you and Denver Deals with respect to the subject matter hereof and supersedes all prior or contemporaneous understandings regarding such subject matter.