PIXUP - AI PHOTO ENHANCER 

PIXUP - AI PHOTO ENHANCER

IMPORTANT PRIVACY INFORMATION

In order to use our app, we will ask you to provide access to your photo library or separate photos and to specify your gender. We will also automatically collect from your device IP address, language settings, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, other unique identifiers (such as IDFA, IDFV, UUID), information about your interactions with the app and crashes. We need this data to provide and improve our services, analyze how our customers use the app and to measure ads.

For improving the app and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Apple, Amplitude, Apple Push Notification, Appsflyer,Crashlytics, Facebook, Firebase, Tableau, TikTok, Zendesk, Sentry, BackgroundRemoval, RemoteConfigService, Lottie, Moya, Nuke and Statscream. This enables us to (1) provide certain services; (2) analyze different interactions (how often users make purchases, what products our users viewed); (3) serve and measure ads (and show them only to a particular group of users, for example, only to those who have made a purchase).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6), and who will be the data controller (Section 1).

If you are a California resident, please review our California Notice at Collection and see the applicable state-specific section (Section 10) below. If you reside in a state with a comprehensive U.S. privacy law (for example, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia), please also see Section 10 for information about your privacy rights under applicable state law. If any questions remain unanswered, please contact us at hongdt2@gmail.com.

PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the Pixup mobile application (the “App”), the services and products provided through it (together with the App, the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU) AND (III) ACCEPT OUR DATA COLLECTION AND PROCESSING PRACTICES DESCRIBED BELOW. If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time; and (c) delete the App from your devices.

Any translation from the English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy, and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states of the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

• PERSONAL DATA CONTROLLER

• CATEGORIES OF PERSONAL DATA WE COLLECT

• FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

• UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

• WITH WHOM WE SHARE YOUR PERSONAL DATA

• HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

• AGE LIMITATION

• INTERNATIONAL DATA TRANSFERS

• CHANGES TO THIS PRIVACY POLICY

• U.S. STATES PRIVACY NOTICE

• DATA RETENTION

• CHANGE LOG

• CONTACT US

1. PERSONAL DATA CONTROLLER

VCTeam AI, will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

To edit photos, the app needs access to your photo library and your camera. The app requires that you expressly allow this access, through a request appearing on your mobile device.

We also collect some data automatically (for example, your advertising identifiers).

2.1. Data we receive directly from you

2.1.1. Personal Characteristics and Media Access

You provide us with information about yourself when using the Service. This information includes your gender and access to photo libraries or separate photos.

2.1.2. Face Data

The Service utilises advanced photo-editing artificial intelligence capabilities to process the photographs and images you provide. When content contains faces, we process certain information about them, such as information that estimates the location of parts and areas of the faces (“Face Data”)

We use Face Data only to create the AI images you requested based on the images containing faces you shared.

While Face Data may be considered biometric data in some jurisdictions and states outside of Europe, the Service does not and is not capable of conducting the identification or authentication of individuals depicted in the photos and images based on Face Data or otherwise. We do not use your pictures or Face Data to improve our photo editing features or train our photo editor algorithms.

Any photographs and images along with Face Data used in creating AI-driven content, and the resulting AI-generated images, are retained by us for a maximum duration of one (1) month following your most recent upload or interaction with our AI functionalities, irrespective of your subscription status. Upon reaching the specified retention limit, all such data, including photographs, images, Face Data, and AI-generated content, is deleted from our servers.

Face Data is shared with third parties solely for the purpose of processing user AI requests, specifically:

+ Processing and Storing Face Data (Hosting): Face Data is stored on our servers, provided by Vultr, Amazon Web Services (AWS), Google Cloud. The transfer is for data storage (hosting) purposes only.

+ Specialized AI Processing: We share images and/or temporary Face Data with AI service providers such as Replicate.com and Hugging Face to use specific AI models to generate content requested by users. But we are sure that these 3rd parties are large suppliers and comply with data processing policies.

2.1.3. Purchase Data

When you make payments through the Service, you need to provide your billing data, such as your credit card number, to our payment service providers. We do not collect, store, or have access to full credit card number data, though we may receive some limited information, including credit card-related data (including a secure token reflecting your payment method), data about products or services purchased, date, time and amount of the purchase, the type of payment method used, limited digits of your card number.

2.1.4. Content

Our Service will access and store the content to enable the normal running of the Service.

2.1.5. Feedback/Communications

We may also process your email and other information provided by you to us through customer support and other communications.

2.2. Data we collect automatically:

2.2.1. Data about how you found us

We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

2.2.2. Device Data and Location Data

We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

2.2.3. Usage data

We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, how often you use the App, how long you are in the App, your subscription orders and crashes you experienced while using the Service.

2.2.4. Advertising IDs

We collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Universally Unique Identifier (“UUID”). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

3.1. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. To learn more, please visit AWS Privacy Notice

To monitor infrastructure and the App’s performance, we use Crashlytics, which is a monitoring service provided by Google. Here's its Data Collection Policy.

We share your data regarding your usage and consumption of purchased content with Apple, as part of our efforts to resolve refund requests. This information may include details about how you have accessed and interacted with the purchased content. The purpose of sharing this data is to help Apple make an informed decision regarding refund requests. Such data sharing is done in compliance with Apple's policies.To learn more, please visit Apple's Privacy Policy.

We also use Apple’s Keychain service to securely store authentication-related data on your device. Keychain allows us to save small pieces of information—such as your access token, refresh token, and user ID—in a secure, encrypted way. This helps us maintain your login session, reduce the need to re-enter credentials, and ensure a seamless user experience. To learn more about how Keychain works, please refer to Apple's Privacy Policy.

We use a variety of tools and frameworks to improve the performance, stability, and overall quality of our App. These include:

RemoteConfigService - a custom service built on top of Firebase Remote Config that enables us to segment users into groups for split testing purposes. This helps us evaluate the impact of different UI structures, texts, and features. We also use RemoteConfigService to remotely update UI components without releasing a new version of the App.To learn more, please visit Privacy Policy and Privacy and Security in Firebase.

Sentry - an error tracking and monitoring tool that helps us identify and fix bugs. In certain cases, Sentry may record screen activity (including a short screen capture before a crash) to better understand what led to the error. These recordings are anonymised and used solely for diagnostic purposes.

3.2. To customize your experience

We process your personal data, such as gender, to adjust the content of the Service and provide content tailored to your personal preferences.

3.3. To provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

3.4 To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications if you opt-in. These may include reminders and motivational messages encouraging you to enhance your photos, or other information about the App. To opt out of receiving push notifications, you need to change the settings on your device.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service's users, as well as when they interacted with it, such as by tapping on links included in the message.

We use Apple Push Notification service (“APNs”), that is a notifications service provided by Apple. APNs allow us to send information to iOS devices. Apple's privacy policy.

3.5. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy. Appsflyer allows you to Opt Out of having data from my device sent to Appsflyer's servers for apps usage collection.

To track and analyze behavior of our App's users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.

We also use Tableau, the analytics platform, to discover relevant metrics, surface automated analytics and to detect drivers, trends, contributors, and outliers for metrics we follow, flagging changes and summarizing insights (Privacy Notice).

Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.

We also use Firebase Analytics, which is an analytics service provided by Google and Firebase Crash Reporting to monitor the stability of our App by automatically collecting and reporting data about crashes and other performance issues. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google's Privacy Policy.

We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our App, how often users make purchases, and other interactions. Learn more about Facebook's approach to data from its Privacy Policy.

3.6. To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features available on the App. We may show you advertisements on our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device.

We use Zendesk ticketing system to handle customer inquiries. When you send us inquiries via contact form or via email, we will store the details provided by you via Zendesk ticketing system, which enables us to track, prioritize and quickly resolve your requests. To learn more, please visit this Privacy Policy.

3.7. To personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook's feed.

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.

Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative – http://optout.networkadvertising.org/

• Digital Advertising Alliance – http://optout.aboutads.info/

• Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices

• Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/

• DAA AppChoices page – http://www.aboutads.info/appchoices

We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

We use Facebook Sharing SDK and Facebook Ads Manager, which allows us to choose audiences that will see our ads on Facebook or other Facebook's products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, installed the App). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook's products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

We also use Facebook Pixel, a tool provided by Facebook that helps us understand the effectiveness of our advertising and how users interact with our App after seeing Facebook ads. Facebook Pixel allows us to track user actions such as page views, purchases, and other key events. This helps us measure ad performance, optimize ads, build targeted audiences for future ads, and retarget people who have already interacted with our App.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). To learn more, please visit TikTok's Privacy Policy.

3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

3.9. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

In this Section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This Section applies only to EEA-based users.

We process your personal data under the following legal bases:

4.1. your consent;

Under this legal basis we

• may communicate with you regarding your use of our Service, for example, by sending you push notification reminding you to use the App.

• process the images you upload and Face Data.

• collect your Apple Identifier for Advertising (“IDFA”).

4.2. to perform our contract with you;

Under this legal basis we:

• Provide our Service (in accordance with our Terms and Conditions of Use)

• Customize your experience

• Provide you with customer support

• Communicate with you regarding your use of our Service

• Process your payments.

4.3. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

We rely on legitimate interests:

• to research and analyze your use of the Service

Our legitimate interest for this purpose is our interest in improving our Service so that we understand users' preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).

• to send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.

• to personalize our ads

The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

• to enforce our Terms and Conditions of Use and to prevent and combat fraud

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.

• to investigate and respond to any comments or complaints that you may send us.

• In the event of a merger or acquisition of our business and/or all or any portion of its assets, your information may be disclosed to the prospective purchaser, our advisers, and any other prospective purchaser's advisers and will be one of the assets that is transferred to a new owner; and

• in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with government agency requests, legal process or litigation)

Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. In such cases, we will cease processing information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. To exercise your right to object, please see Section 6 of this Privacy Policy.

4.4. to comply with legal obligations, including, but not limited to, responding to requests by government or law enforcement authorities conducting an investigation.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

5.1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers (Amazon)

• authentication and secure storage provider (Apple)

• data analytics providers (Firebase, Appsflyer, Amplitude, Crashlytics, Tableau)

• technology partners (Sentry)

• communication service providers (Apple, Zendesk)

• marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, TikTok)

5.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

5.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

5.4. Affiliates

We may share your personal information with our partner organizations that are part of our corporate group - these are companies that are owned by, own, or are jointly owned with us. These partner organizations will use the information in ways that align with this Privacy Policy.

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the App.

Deleting your personal data. You can request erasure of your personal data as permitted by law.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof..

Additional information for EEA-based users:

If you are based in the EEA, you have the following rights in addition to the above:

The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below.

To exercise any of your privacy rights, please send a request to hongdt2@gmail.com.

7. AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you are under 16, do not use or provide any information to or on this App or through any of its features.

If you learn that anyone younger than 16 has provided us with personal data, please contact us, and we will work to delete that information from our databases.

We are not liable for any damages that may result from a visitor’s misrepresentation of age.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

For a detailed summary of key updates, please refer to the Change Log available at Section 11. It provides an overview of all recent modifications and helps you track updates over time.

10. U.S. STATES PRIVACY NOTICE

Applicability

If you reside in a state that has enacted consumer privacy laws, this section applies to you. This U.S. States Privacy Notice ("Notice") supplements our Privacy Policy and provides disclosures required by laws in states such as, for example, California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

This Notice is designed to supplement our Privacy Policy to ensure compliance with state-specific laws and applies to the collection, use, and sharing of your Personal Information through our websites, mobile applications, and other online or offline services (collectively, the "Services").

For California residents, this also serves as our California Notice at Collection.

The definition of "Personal Information" may vary by state law. Generally, it refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

10.1. Categories of Personal Information We Collect and For What Purposes

The table below outlines the categories of Personal Information we collect, along with purposes of such collection. For more details, refer to other sections of our Privacy Policy.

Category

Examples of Personal Information in this Category

Purpose of collection

Identifiers and Personal Characteristics

Gender, email address.

• To provide and maintain our Services.

• To serve and measure ads

• To communicate with users, including customer support, service updates, and promotional offers.

Sensitive Information

When we process sensitive personal information (as defined by State Privacy Laws), such as s, we do so only for legally permitted purposes and do not use such data to infer characteristics about you or uniquely identify you.

• To provide and maintain our Services.

Commercial Information

• Purchase history

• Content provided during your use of the Service

• Any information you may share during conversations with our support agents, including your feedback, complaints, etc.

• Your photo library or a separate photo (we do not use such data to infer characteristics about you or uniquely identify you)

• To provide and maintain our Services.

• To improve user experience through personalized content, recommendations, and service customization.

• To serve and measure ads.

• To process payments, subscriptions, and transactions

• To conduct analytics and research for product development and service enhancements.

Geolocation

Internet protocol (IP) address, country, and/or region

• To provide and maintain our Services.

• To improve user experience through personalized content, recommendations, and service customization.

Internet or other electronic network activity information

Information regarding a consumer’s interaction with an application or advertisement (Usage Data).

• To improve user experience through personalized content, recommendations, and service customization.

• To serve and measure ads.

• To process payments, subscriptions, and transactions.

• To conduct analytics and research for product development and service enhancements.

Inferences drawn from any of the above information categories

We may collect data and draw inferences based on that data; however, these inferences are used solely to determine which features you use more or less and are not used to deduce other specific personal characteristics.

• To improve user experience through personalized content, recommendations, and service customization.

For additional details on the purposes of processing and third parties with whom data is shared for each specific purpose, please refer to Section 3 of this Privacy Policy.

We may also process de-identified data, ensuring it cannot reasonably be linked back to you. We commit to maintaining and using de-identified data responsibly and will not attempt to re-identify such data unless required to validate our de-identification measures.

10.2. What Personal Information We Share

Certain state privacy laws, such as those in California, require us to disclose the categories of Personal Information that we have shared with third parties for business purposes over the past 12 months. During this period, we have disclosed all categories of Personal Information outlined in the "Categories of Personal Information We Collect" section for business purposes. For example, we may share IP addresses and device identifiers with service providers that assist us with crash monitoring and reporting.

Some U.S. states grant residents the right to opt out of sharing their Personal Information with third parties in exchange for valuable consideration (which may be classified as a “sale” or “share” under state privacy laws, even if no monetary transaction occurs). If you reside in one of these states and would like to limit the disclosure of your Personal Information to third parties for advertising or marketing purposes, please refer to Section 10.4. below.

For details regarding the categories of third parties with whom we share Personal Information, please refer to Section 3 and Section 5 of this Privacy Policy.

10.3. Your Privacy Rights Under State Laws

Certain U.S. state privacy laws grant residents specific rights regarding their personal information. If you reside in a state with such laws, you may have the following rights:

Your Right

Description

Right to Know

You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for business purposes in the 12 months preceding your request.

Right to Access

You have the right to request access to the specific pieces of personal information we have collected about you in the 12 months preceding your request.

Right to Delete

You have the right to request that we delete the personal information we have collected from you. We will use commercially reasonable efforts to fulfill your request, subject to applicable laws. However, we may be required to retain certain information for legitimate business purposes or as required by law.

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

Right to Opt-Out of Sales, Sharing, and Targeted Advertising

You may have the right to opt out of certain uses of your personal information, including:

• The "sale" or "sharing" of your personal information as defined under state privacy laws.

• The use of your personal information for targeted advertising.

Right to Data Portability

You can request a copy of your personal data in a structured, portable format.

Right to Non-Discrimination

You have the right to exercise your privacy rights without fear of discrimination.

Right to Withdraw Consent

Where applicable, you have the right to withdraw your consent for data collection and sharing.

Right to Limit the Use of Sensitive Personal Information

Certain states provide the right to restrict how businesses use sensitive personal information. In order to opt-out, please contact us at hongdt2@gmail.com with the subject line "Limit the Use of Sensitive Personal Information." We will process such requests in accordance with applicable laws.

To exercise any of these rights, submit a request to our customer support team via email: hongdt2@gmail.com

Verification

To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request, this may include your email, date of subscription purchase, date of last activity or some other Service use data that will reasonably identify you. We may also ask you for additional proof of identity, if necessary.

Right to Appeal

If we deny your request, you may have the right to appeal our decision. To do so, please contact us and explain your concerns. If you are dissatisfied with the result of the appeal, you may escalate the matter by contacting the Attorney General's office in your state of residence.

Authorized Agents

f you are an authorized agent acting on behalf of a consumer, you may submit an opt-out, access, deletion, or correction request by contacting us. If you are making a request on behalf of a California resident, you may be required to submit proof of authorization, such as:

• A valid power of attorney

• Written permission signed by the consumer, along with identity verification from the consumer

California “Shine the Light” Law

California's Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to hongdt2@gmail.com, which includes "Request for California Privacy Information" on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

Retention of Personal Information

We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

10.4. Sales, Sharing, and Targeted Advertising

Privacy laws in some U.S. states broadly define the term "sale" to include sharing of information via cookies, pixels, and similar tracking technologies for certain targeted advertising activities. We do not sell Personal Information for monetary compensation. However, when you visit our app, we and our advertising partners may collect device data and behavioral insights through tracking technologies, which could be interpreted as a “sale” or "sharing" under state laws, even if no money is exchanged.

We do not knowingly engage in sales, sharing, or targeted advertising using the personal information of individuals under 18.
More information about our data-sharing practices is available in the table below.

Category of Personal Information Disclosed

Category of Third-Party Recipient

• Identifiers (such as IDFA).

• Internet or other electronic network activity information (such as links you click or pages you visit on our app or your interactions with the Service).

• Commercial information (such as whether you bought a subscription).

• Advertising networks.

• Social networks.

Opt-Out Rights

You may opt out of sales, sharing, or targeted advertising by contacting us at hongdt2@gmail.com

Your opt-out settings apply per device and browser. If you switch devices, clear cookies, or use a different browser, you may need to reapply your opt-out settings.

11. DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you, complying with our legal obligations, and enforcing Terms of Use and our other agreements). For example, to prevent abuse of trials, introductory offers, or discounts, we will retain records that you have previously initiated such trials as long as these offers remain available in our Service.
Please note that personal information may be retained for longer if it becomes the subject of a legal claim or is somehow relevant for litigation or other proceedings.

12. CHANGE LOG

Here you can find a summary of key updates to this Privacy Policy.

13. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your personal data please contact us at hongdt2@gmail.com.

Effective as of: 31 October 2025