Privacy Policy

This agreement is intended to explain how this application collects, uses, shares, and protects your personal information.

Important Notice for California Residents

Pursuant to the **California Consumer Privacy Act of 2018 (CCPA)**, if you are a California resident, you have the right to submit the following requests:

• To know the categories of personal information we process.
• To know the categories of sources from which personal information is obtained.
• To know the purpose for processing your personal data.
• To know the categories of third parties with whom we may share your personal information.
• To obtain specific pieces of personal information about a particular user (provided that the data furnished in the request is sufficiently reliable to identify that user).

Please refer to the following sections in this Privacy Policy for detailed information:

• Section I: Information We Process / Detailed Introduction to Information Categories, Sources, and Processing Purposes \>\>
• Section III: Information Sharing / How Your Information is Shared \>\>

Please note: According to the CCPA, personal information does not include de-identified or aggregated consumer information.

Opt-Out Options (To Stop Processing and Sharing)

1. To Stop Personal Information Processing:

• ○ If you do not want us to continue processing your personal information, please contact us at **Aliciaharkatharine@protonmail.com**.
• Important Note: In most cases, the application will not be able to continue functioning without essential functional data. Therefore, we recommend that you **uninstall the application from your device**.

2. To Stop Sharing Device Identifiers and Geolocation Data:

• If you do not want us to share device identifiers and geolocation data with service providers, please check your device settings and opt-out (refer to "Section VII: How to Opt-Out" below for details).

Submitting Consumer Requests (Access, Transfer, or Deletion of Data)

To submit a verifiable consumer request to exercise your right to access, transfer, or delete personal data, please contact us at **Aliciaharkatharine@protonmail.com**.

Please ensure that you include the phrase "Your Confidentiality Rights in California" in the body of your request.

Preparation for Submitting a Request:

1. Provide Sufficient Information to Verify Identity:

• You may be required to provide information such as your name, address, city, state/province/region, postal code, and email address so that we can reasonably verify that you are the subject of the personal information collected or their authorized representative.
• We may use this information to ask you a series of security questions to verify your identity.
• If you submit a request through an authorized agent, the agent must provide **written authorization or power of attorney signed by you**.

2. Describe Your Request in Detail:

• Please describe your request in detail so that we can correctly understand, evaluate, and respond to it.

Please note: We will be unable to respond to your request or provide personal information if we are unable to: (i) verify your identity or your authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you to provide additional information or documents to verify your identity. Before taking any action regarding your personal information, we may also conduct checks, including using **third-party identity verification services**. This is considered a safeguard designed to prevent the disclosure of your personal information due to fraudulent or malicious requests.

Our Commitment:

• Personal information provided in a verifiable consumer request will be used **only to verify the requestor’s identity or their authority to make the request**, and for no other purpose.
• We will retain this information as reasonably necessary for the purposes mentioned above and will delete it once the purpose is fulfilled.
• We strive to respond to a verified consumer request within forty-five (45) days of receipt. If we need more time, we will inform you in writing of the reason and the extension period.
• Limitation: We are only required to respond to two requests per customer per year.

Equal Rights Guarantee

The way we handle your requests will in no way constitute **discrimination**, meaning that if you choose to exercise your rights, we will not set different prices or products or provide different levels or quality of service against you.

Exception: In certain circumstances, if you choose to delete your personal information from our records, we may be unable to continue providing you with our services.

Data Sale Declaration

We do not sell any of your personal data to third parties.

I. Types of Information We Process

The information we process falls into the following categories:

1\. Functional Information and Information Submitted by You

This information is **essential for the performance of the contract between you and us**. Without it, we would not be able to provide the full functionality of the application or the services you request.

• Activity Information Directly Related to Your Use of the App:

    ⚪︎ Upon relevant settings on your device, we may access your photos (to search for similar photos).

    ⚪︎ Important Declaration: We do not collect, use, or store data contained in your calendar events or photos on any server.

• Locally Stored Files:

    ⚪︎ All files that may be processed are stored on your **local device and/or iCloud storage space**, and we cannot access these files.

    ⚪︎ Only you can export files through the application and share them with specific parties.

• Payment Details (Only potentially required for subscription cancellation):

    ⚪︎ If you have purchased a subscription on the App’s webpage and wish to cancel by contacting us at **Aliciaharkatharine@protonmail.com**, we may ask you to provide one of the following pieces of information:

• The email address registered when you purchased the subscription.
• The receipt number used to identify the payment.
• The unique identification number of the invoice.

2\. Automatically Processed Information

With your permission, we use third-party automated data processing technologies (advertising and analytics tools) to analyze certain information sent by your device through our application.

• Data Source: Advertising identifiers for iOS devices (IDFA), or Advertising ID or Android ID for Android devices.
• Processing Method: Some integrated advertising or analytics tools (see the list in "Section III: Information Sharing" below) initiate automated processing of your personal data, including profiling (which involves any form of automated processing of personal data used to evaluate certain personal characteristics relating to you, in particular to analyze or predict your personal preferences, interests, behavior, location, or movements).
• Activation: The automated processing begins automatically once you allow our application to track your activity.
• Withdrawing Consent: You may withdraw your consent at any time (see "Section VII: How to Opt-Out" below).

Based on our **legitimate interests**, we may also process some information about your device and user behavior to improve our application and provide the best user experience. This information is typically **non-personal information**, accessed in an **aggregated form**.

Details of Processable Device and Behavioral Data:

Information Category	Specific Data Examples
Device Details	Device type, operating system type and version, model and manufacturer, screen size, density, orientation, volume and battery, device memory usage.
Internet Connection Info	Mobile carrier, network provider, network type, IP address, session timestamp and duration, speed, browser.
Location-Related Info	IP address, country/region/state/city associated with your SIM card or device, language settings, time zone, nearby points of business interest.
Other Device Identifiers	For example, User ID (if set by the app developer).
Application Info	Name, API Key (app identifier), version and properties. List of installed or running applications and/or processes on your device (recorded by some services).
Cookies and Similar Technologies	Used to operate the application more effectively, understand how users use it, improve marketing efforts, and deliver content and features you might be interested in.
Log File Information	Generated automatically each time you request access to the app or when the app is installed on your device, including the time and date you start and stop using the app, and how you interact with it.
Advertising-Related Info	Date and time a specific ad was shown; whether the ad was “clicked” or marked as a “conversion” event; ad content, type, and placement; whether you responded to the ad.
In-App Events	Information about your activities (tutorial steps, upgrades, payments, in-app purchases, custom events, progress events, methods of limiting user data processing).

Third-Party Disclaimer: The information automatically provided to advertising or analytics tools is generally **outside of our control**, and we are not responsible for the processing of such information. Certain services may perform personal data analysis and may use technologies to obtain information related to your personality and/or device beyond our responsibility. Any request regarding the disclosure of your personal information should be addressed directly to the relevant third party (see "Section III: Information Sharing").

3\. Payment Information (App Store/Google Play Purchases)

• Responsible Party: Our e-commerce service providers (such as Apple) are responsible for billing, processing, and charging for your purchases, and for processing your personal information to ensure its absolute security.
• Contractual Basis: The processing of this information is part of the performance of the contract between you and us.
• Our Access: We do not have access to or use your credit or debit card information.
• Applicable Rules: You can access the applicable "in-app" purchase rules and policies directly from the app store.

4\. Email Newsletters

• Information Source: When you register in the app and choose the "Sign in with Apple" option to provide your email information (including a unique, random email address generated by Apple, if chosen).
• Legal Basis: Based on our **legitimate interests**.
• Purpose: To send you information about special subscription offers, new features, and other app-related news (**"Newsletters"**).
• Market Analysis: We process some of your personal data (such as your name if provided, in-app registration date, subscription purchase date, geolocation data, activity information, etc.) for market analysis activities, specifically to send you targeted newsletters that best meet your needs and interests.
• Information Transfer: The email address information we receive may be transferred to email marketing tools to optimize and automate the email sending process (see "Section III: Information Sharing" for more on this).
• Unsubscribe: You can unsubscribe and opt-out of receiving newsletters at any time via the unsubscribe link in every email we send. We will process your unsubscribe request within a reasonable timeframe.

II. Purposes of Processing Your Personal Data

We use your information to continuously improve our application and provide you with new experiences:

Purpose No.	Purpose Description	Information Type Relied Upon
(a) To Provide Our Services	To provide you with all requested services. May process some of your payment information if you wish to cancel a subscription purchased on the app's webpage.	Functional Information, Submitted Information, Automatically Processed Information, Payment Information.
(b) To Improve, Test, and Monitor the Effectiveness of Our App	To better understand user behavior and trends, detect potential faults and technical issues, and to operate, protect, improve, and optimize our application.	Automatically Processed Information.
(c) To Provide Interest-Based (Behavioral) Advertising or Other Targeted Content	For marketing purposes (showing you ads that may be of interest to you based on your preferences); providing personalized content and information.	Automatically Processed Information.
(d) To Communicate with You	To communicate with you via newsletters, such as sending marketing notifications, receiving feedback on your experience with our app, and informing you of our policies and terms. Also used to respond to you when you contact us.	All information we hold.
(e) To Prevent Fraud and Spam, and Enforce the Law	To prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.	Your information.

Notification of New Purposes: If any new purposes for processing your personal data arise, we will inform you of the start of processing for that purpose by making corresponding modifications to this Privacy Policy.

III. Information Sharing

We will only share your information with third parties as described in this Privacy Policy. We comply with the Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment in the US.

1\. Sharing with Third-Party Service Providers

We do not rent or sell your personal data to any third party. However, we may share information from tools such as log files, device identifiers, and location data with third-party organizations that provide automated data processing technologies for the application.

• Content Shared: Log files, device identifiers, and location data, etc.
• Purpose: To provide us with the necessary infrastructure required to deliver and improve our services.
• Advertising Partners: We may also share certain information, such as **Cookie data**, with third-party advertising partners to allow them to deliver targeted advertising they believe will be of most interest to you.
• Disclaimer: We cannot control or influence the tracking technologies of these third-party organizations or how they are used.

Entity Name	Service Provided	Location	Privacy Policy Link
Apple Inc.	Cloud Storage Provider	USA	https://www.apple.com/lae/privacy/
AppLovin Corporation	Ad Management/Analytics Service Provider	USA	https://www.applovin.com/privacy/
AppsFlyer Inc.	Analytics Service Provider	USA	https://www.appsflyer.com/legal/services-privacy-policy/
Firebase Crashlytics (Google LLC)	Analytics Service Provider	USA	https://policies.google.com/privacy, https://firebase.google.com/support/privacy
Admob Corporation	Ad Management/Analytics Service Provider	USA	https://policies.google.com/privacy?hl=zh-Hans
Adjust Corporation	Analytics Service Provider	Germany	https://www.adjust.com/terms/privacy-policy

Seeking More Information: If you would like more information about these services and their privacy options (including opting out), please review the respective websites and privacy policies. We are not responsible for the above third parties using your personal data in violation of our instructions.

2\. Links to Third-Party Websites/Services

Our application may contain links to **third-party websites/services**, or you may access our application through a third-party website. We are not responsible for the privacy practices of these third-party websites or services, whether linked to or from our application.

3\. Other Disclosure Scenarios

We may disclose your personal information if objectively required, for the public interest, or due to other unforeseen circumstances:

• As **required by law**.
• When we believe in good faith that disclosure is necessary to **protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request**.
• If we are involved in a **merger, acquisition, or sale of all or a portion of our assets**, we will notify you via email and/or a prominent notice on our application of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

IV. International Data Transfers

We and the third-party organizations providing automated data processing technologies for the application, or our third-party advertising partners, may transfer **automatically processed information across borders**, from your country or region to other countries or regions around the world.

• Legal Differences: If you are located in the European Union or other regions where data processing laws may differ from US laws, please note that we may transfer information (including personal information) to countries and jurisdictions that do not have the same data protection laws as your jurisdiction.
• Risk Warning: This means your personal information may be transferred to a **third country, a territory within a third country, or one or more specific sectors, or to an international organization**, whose data protection and confidentiality regulations may not provide the same level of personal data protection as your country/region.
• Our Efforts: We strive to ensure that all recipients of personal data provide appropriate protection for the personal data received.
• Your Consent: By using this application, you agree that we may transfer your personal data to any third country, a territory within that third country, or one or more specific sectors, or to an international organization.
• Data Storage: We use the services of hosting providers for data storage. We take your privacy seriously, so we encrypt your personal data as much as possible before sending it to hosting providers for storage. We only work with hosting providers that have passed our security and reliability audit.

V. Duration of Our Use of Your Personal Data (Data Retention)

• Retention Period: We generally retain your personal information for as long as is necessary to **perform the application's functions and fulfill legal obligations**.
• Deletion Request: If you no longer want us to use your information that has been actually accessed and stored, you can request that we **delete your personal information and close your account**.
• Exceptions: Certain data may still be stored for a period of time (but no longer than necessary for the storage purpose) to fulfill legal obligations (tax, accounting, auditing) or to maintain **security and data backup settings, prevent fraud, or other malicious activities**.

VI. Exercising Your Rights

Applicable data protection laws grant you specific rights regarding personal information. You have the following choices regarding the personal information we collect about you:

Your Right	Description
Data Access and Portability	You can request to obtain a copy of your personal information.
Data Change or Correction	If you cannot update the data yourself through your account, you have the right to request that your data be **corrected, changed, updated, or rectified**.
Data Retention and Deletion	You have the right to request the deletion of all or part of the personal data we hold about you. User data is generally retained for the duration your user account exists or as long as necessary to provide the relevant services.
Right to Know and Information Sharing	You have the right to know whether your data is shared with third parties (see "Section III: Information Sharing" for details). You can contact us at any time if you have questions about this.
Restriction of Processing	In certain circumstances, you have the right to restrict the way we use your personal information.
Objection to Automated Processing	When your personal information is automatically processed, you can object to this processing method in certain circumstances.
Objection to Direct Marketing	If your personal information is used for direct marketing purposes, you can request that your data stop being used for these direct marketing purposes.

Regarding Objection to Automated Processing and Direct Marketing: Please contact the third-party service providers listed in "Section III: Information Sharing" to learn how to object to the processing of your data.

Right to Lodge a Complaint:

• If you believe your rights under applicable data protection laws have been violated, you also have the right to lodge a complaint with a **local data protection authority or supervisory body**.
• Note: You may need to provide supplementary information and sufficient objective evidence to support your complaint. In certain cases, you may be required to submit an initial complaint to us and, if necessary, request clarification before lodging a complaint with a local data protection authority or supervisory body.

VII. How to Opt-Out

1\. Opting Out of Marketing Tracking (iOS Devices)

You can manage your activity tracking permissions to prevent third-party service providers from displaying personalized ads based on your interests:

• Device Tracking Permission Settings:

    ⚪︎ Go to **"Settings" \> "Privacy & Security" (or "Privacy" in older iOS versions) \> "Tracking"**.

    ⚪︎ You can turn off or on the tracking permission for specific apps.

• "Allow Apps to Request to Track" Switch:

    ⚪︎ When this switch (located in **"Settings" \> "Privacy & Security" \> "Tracking"**) is off, you will not receive prompts from apps requesting to track your activity. Every app that requests tracking permission will be treated as if you tapped **"Ask App Not to Track"**.

    ⚪︎ For more information, please visit: https: // support.apple.com/en-us/HT212025

• Turning Off Apple's Ad Targeting:

    ⚪︎ Go to **"Settings" \> "Privacy & Security" (or "Privacy" in older iOS versions) \> "Apple Advertising"**, and turn the "Personalized Ads" switch off.

    ⚪︎ For more information, please visit: https: // support.apple.com/en-us/HT202074

Please note: Even if you opt out of certain interest-based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads relevant to the content of other digital products you are using.

2\. Opting Out of Location Data Processing (iOS Devices)

If you do not want third-party service providers to use your precise location data or street-level location information:

• Go to the "Settings \> Privacy & Security (or "Privacy" in older iOS versions) \> Location Services" menu.
• Turn off Location Services for the corresponding product.
• Then select the corresponding application and set the "Share My Location" status to **"Never"**.
• For more information, see here: https: //support.apple.com/en-us/HT203033.

VIII. Security

We take the security of your personal information very seriously. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

• Protective Measures: We take reasonable and appropriate steps to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
• Technical Implementation: We implement appropriate technical and organizational measures designed to effectively implement data protection principles, such as the data minimization principle, and to integrate necessary safeguards into the processing.
• Encryption: We strive to use appropriate and robust encryption algorithms (including hashing whenever possible) to encrypt your personal data.
• Risk Warning: No method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee its **absolute security**.
• Breach Notification: If your personal information is compromised as a result of a security breach, we will promptly notify you in accordance with applicable law.
• Contact Us: If you have any questions about the security of our application, you can contact us via the email address shown below.

IX. Children's Privacy

• Target Audience: Our application is **not directed to children**.
• Data Collection: We do not knowingly or intentionally collect or solicit any personal information from children.
• Definition of "Child": Generally, we treat individuals under 16 years of age as "children" (unless there is a legal basis to conclude otherwise).
• Guardian Responsibility: Only parents with supervisory responsibility are responsible for preventing their children from providing personal information through the application without obtaining the relevant **verifiable parental consent**.
• Data Deletion: If we discover that we have collected personal information from a child without verified parental consent, we will **delete that information as quickly as possible**.
• Contact Us: If you have reason to believe that we may hold any information about a child, please contact us.

X. Changes to the Privacy Policy

This Privacy Policy is **updated periodically**.

• Whenever we change this Privacy Policy, we will post the changes on this Privacy Policy page and in other places we deem appropriate.
• Depending on the specific circumstances, we may also provide you with notice of modifications or updates in other ways.

XI. How to Contact Us

If you have any questions about this Privacy Policy, please feel free to contact us at **Aliciaharkatharine@protonmail.com**.