Privacy Policy (FaceLuck - AI Face Lottery)

Last updated: August 2026

CDPlus ("we", "our", or "us") operates the FaceLuck - AI Face Lottery mobile application (the "Service"). This page informs users of our policies regarding the collection, use, disclosure, retention, and protection of personal data and sensitive user information when using our Service.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Section 1. No Personal Information Collection

We strictly prioritize user privacy. FaceLuck - AI Face Lottery does not collect, store, transmit, or request any personally identifiable information (PII) such as your real name, email address, phone number, physical address, or contact list.

Section 2. No Advertisements or Third-Party Analytics

This app is completely ad-free and contains no third-party trackers.

• We do not integrate any advertising frameworks (such as Google AdMob).

• We do not use any third-party tracking, analytics, or crash reporting services that collect user data.

• No personal data or device usage data is sent to us or any third-party servers.

Section 3. Collection, Use, Sharing, Retention, and Deletion of Face Data

FaceLuck - AI Face Lottery features face analysis for generating lottery numbers and physiognomy entertainment. To protect sensitive user information, we strictly comply with Apple’s App Store Review Guideline 5.1.1, Section 3.3.3(C), and Section 3.3.3(K) of the Apple Developer Program License Agreement regarding Face Data:

1. What Face Data We Collect:

   • The app processes real-time facial landmark coordinate points (such as the positions of face contours, eyes, nose, and mouth) from images selected or captured by the user.

   • We DO NOT collect, extract, or generate face recognition templates, biometric identity profiles, or permanent facial image files.

2. Planned Use of Face Data:

   • Face landmark data is used solely and exclusively to perform real-time mathematical calculations for generating lottery numbers and physiognomy feature commentary inside the app.

3. Storage and Location Practices:

   • 100% On-Device Processing. All facial feature detection is executed locally within the device's temporary volatile memory (RAM) using Google ML Kit On-Device SDK.

   • Zero Cloud Storage: Face data and user images are never uploaded, transmitted, or stored on external servers, cloud databases, or remote systems.

4. Third-Party Sharing and Disclosure Practices:

   • No Third-Party Sharing: We do not share, sell, rent, disclose, or transfer face data or facial images to any third parties, advertising partners, data brokers, or external services under any circumstances.

5. Retention and Deletion Practices:

   • Zero Retention (Immediate Discard): Face data is retained temporarily in volatile RAM only for the fraction of a second required to complete the analysis.

   • Automatic Discard: Face landmark data is permanently and automatically purged from RAM immediately after the result is generated. No face data persists in local file storage or databases.

Section 4. Local Data Storage on Your Device

Any records generated by the app (such as saved lottery history or result cards) are saved exclusively on your local device storage. You have complete control over this data, and we cannot access, view, or restore your locally saved records.

Section 5. Children’s Privacy

Our Service is not directed to anyone under the age of 13. We do not knowingly collect or request personal data or face data from children under 13.

Section 6. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the updated Privacy Policy on this page and updating the "Last updated" date at the top.

Section 7. Contact Us

If you have any questions, concerns, or inquiries regarding this Privacy Policy or Face Data practices, please contact us:

• Developer / Provider: CDPlus

• Contact Email:  oojoo50@gmail.com