PRIVACY POLICY
This privacy policy applies to the FramLab Photo Editor & Art app (hereby referred to as "Application") for mobile devices that was created by Sapphire Global Tech Ltd (hereby referred to as "Service Provider") as a Freemium service. This service is intended for use "AS IS".
This Privacy Policy outlines the types of information we collect through the App, how we use and safeguard that information, and the choices you have regarding your personal data. It applies to all users of the App and reflects our commitment to transparency and compliance with major data protection laws and platform policies, including:
General Data Protection Regulation (GDPR) – for users in the European Economic Area (EEA)
California Consumer Privacy Act (CCPA) – for users in California, USA
Google Play Developer Policies – as required by Google Play for apps distributed through its platform
By downloading, installing, accessing, or using the App, you agree to the terms of this Privacy Policy and consent to the collection and use of information as described herein. If you do not agree with any part of this Privacy Policy or our practices, we kindly ask that you refrain from using the App.
1- EU User Consent Policy & GDPR Compliance
In compliance with the EU ePrivacy Directive and the General Data Protection Regulation (GDPR):
We obtain explicit consent from users in the European Economic Area (EEA) before processing personal data or using cookies/ad IDs for personalized and non-personalized ads.
We prompt users to select their ad preferences (Personalized or Non-Personalized) in accordance with Google’s EU User Consent Policy.
This ensures that our practices align with both legal and platform requirements for handling user data in a transparent and responsible manner.
2- Information Collection and Use
The Application collects information when you download and use it. This information may include information such as
a. Device Information
We collect information related to your mobile device to help ensure compatibility and functionality of the App. This includes:
Device model and manufacturer (e.g., Samsung Galaxy S21)
Operating system and version (e.g., Android 13)
Unique device identifiers (such as Android ID or Advertising ID)
Hardware information, including screen size and resolution
Language and country settings
This data helps us optimise the app for various device types and provide better performance across different hardware configurations.
b. Log Data
When you use the App, our systems automatically collect certain log information to help monitor performance and identify technical issues. This can include:
IP address (used temporarily for diagnostics and not stored long-term)
Type of internet browser or device software (if applicable)
Date and time of access to the App
In-app actions and transitions
Error messages, exception logs, and crash diagnostics
Log data is used strictly for technical purposes and is stored securely with access restricted to authorized personnel only.
3- Third Party Access
Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.
Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:
The Service Provider may disclose User Provided and Automatically Collected Information:
As required by law, such as to comply with a subpoena, or similar legal process;
when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
4- User Data Access Policy
User are required to upload an image in order to use Ai Avatar feature & other core features. The uploaded image is solely used for the purpose of enabling the basic functionality of the app, We collect user data solely to enable core app functionality. The app requires storage permission to allow users to upload images for the AI Avatar feature. To generate accurate and high-quality results, these images are temporarily uploaded to our secure servers. We temporarily retain your uploaded image for the generation process for the recent 30 minutes to our secure servers, All user data, including uploaded images, is automatically & permanently deleted from our servers within 30 minutes after user AI Avatar is successfully created.
We do not use, share, or sell this data to third parties for any personal or commercial purposes. The data is used exclusively to provide the requested functionality to the user.
To support the core functionality of the App—such as detecting outdated apps and managing installed applications—we access and process certain app-related data on your device. This is handled with care and transparency as outlined below:
5- Collected Data
We collect only the package names (i.e., app identifiers) of the apps installed on your device. This allows us to determine which apps may have updates available.
- Data Storage
All collected data is securely encrypted and stored on protected servers with appropriate technical safeguards in place to prevent unauthorised access.
- Usage
The data is never shared with third parties. It is used solely for the intended purpose of identifying and notifying users about available app updates.
- Consent Requirement
In compliance with evolving Google Play policies, we explicitly request user consent within the App before activating any feature that requires access to this data. Users will only be able to use the software update feature after granting this permission.
- How We Use Information
We use the information collected from you for the following purposes:
- Maintain and improve app functionality
Ensuring the App runs smoothly and reliably with ongoing updates and enhancements.
- Personalize your app experience
Tailoring features and content based on your usage to better meet your needs.
- Analyze usage trends
Monitoring how the App is used to identify patterns and improve performance.
- Notify you about updates and app features
Sending important alerts, reminders, and information about new features or updates.
- Comply with legal and policy obligations
Ensuring adherence to applicable laws, regulations, and platform policies.
6- Opt-Out Rights
You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
7- Data Retention Policy
The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. If you'd like them to delete User Provided Data that you have provided via the Application, please contact them at sapphiregtech@gmail.com
and they will respond in a reasonable time.
8- Permission
To provide full functionality, the App may request the following permissions from your device. These permissions allow us to deliver App features
android.permission.ACCESS_NETWORK_STATE
Allows the app to check the status of network connections (Wi-Fi, Mobile data). Useful for detecting whether the device is connected before making network requests.
android.permission.INTERNET
Required for apps that need to access the internet for API calls, ads, updates, or other online services.
android.permission.CAMERA
Grants access to the device camera for capturing photos or videos directly within the app.
android.permission.READ_MEDIA_IMAGES
Allows the app (on Android 13+) to read image files stored on the device. It replaces broad storage permissions for more focused access.
android.permission.READ_EXTERNAL_STORAGE
Lets the app read files (photos, videos, documents) from external storage (SD card or shared storage). Required on older Android versions (before Android 13).
android.permission.WRITE_EXTERNAL_STORAGE
Allows the app to write or modify files on external storage. Commonly used for saving downloaded content, edits, or exports (deprecated in Android 11+).
com.photolab.coloreffects.photoart.DYNAMIC_RECEIVER_NOT_EXPORTED
_PERMISSION
A custom permission, defined by your app, usually for securing broadcast receivers so only trusted components can interact with them.
android.permission.READ_PHONE_STATE
Allows access to device info like IMEI, network info, or call state. Often used for analytics, ads, or managing features dependent on SIM/network.
android.permission.WAKE_LOCK
Keeps the device CPU awake while the screen is off, ensuring tasks like downloads, processing, or media playback continue without interruption.
com.google.android.finsky.permission.BIND_GET_INSTALL_REFERRER_SERVICE
Permission to bind to the Google Play Install Referrer service. Used for tracking where installs originated from (ads, campaigns, etc.).
com.google.android.gms.permission.AD_ID
Provides access to the Google Advertising ID, a unique ID used for personalized ads and attribution.
android.permission.ACCESS_ADSERVICES_ATTRIBUTION
Allows the app to use the Privacy Sandbox attribution API to measure ad performance while protecting user privacy.
android.permission.ACCESS_ADSERVICES_AD_ID
Provides access to the Privacy Sandbox’s new Ad ID, replacing older identifiers for more privacy-friendly ad tracking.
android.permission.ACCESS_ADSERVICES_CUSTOM_AUDIENCE
Lets the app join or interact with custom audiences in Privacy Sandbox (used for targeted ads in a privacy-safe way).
android.permission.ACCESS_ADSERVICES_TOPICS
Allows participation in Privacy Sandbox Topics API for interest-based advertising without tracking individuals.
9- Your Rights (Under GDPR)
While our App does not collect personal data such as your name, email, or contact details, we do process certain non-personal information (like device data and app usage) to improve your experience.
Under the General Data Protection Regulation (GDPR), you still have important rights related to your data, including:
Right to Access: You can request information about what data we collect and how we use it.
Right to Correction: If you believe any data we process is inaccurate, you can request corrections.
Right to Deletion: You may ask us to delete any data we hold about you where applicable.
Right to Object or Restrict Processing: You can object to or limit how we process your data, such as for analytics or advertising purposes.
Right to Withdraw Consent: If you have provided consent for any data processing, you can withdraw it at any time.
10- Children
The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.
The Application does not address anyone under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. In the case the Service Provider discovers that a child under 13 has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact the Service Provider (sapphiregtech@gmail.com) so that they will be able to take the necessary actions.
11- Security
The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains.
12- Changes
This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
This privacy policy is effective as of 2025-08-22
13- Your Consent
By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by us.
14- Contact Us
If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at sapphiregtech@gmail.com