**Effective date: August 22, 2026**
**Last updated: August 22, 2026**
### 1. About This Policy
Solumi (the “App”) is provided by **Noah Coleman**, an individual developer (“Developer,” “we,” “us,” or “our”). This Privacy Policy explains how we and our service providers process information relating to you when you use the App and describes your rights.
If you do not agree with this Policy, please stop using the App. Because the App is offered in multiple countries and regions, this Policy must be read together with applicable local data protection laws. Mandatory local law prevails where it provides greater protection.
### 2. Information We Process
We follow data-minimization principles. Registration is optional, and the App does not allow user-generated content. Depending on the features you choose and the third-party services actually enabled, the following information may be processed:
1. **Sign in with Apple information (only if you choose to sign in):** the unique user identifier supplied by Apple and any name or email address you choose to provide, including an Apple private relay address. We use it to create, identify, and secure your account and synchronize account-related entitlements.
2. **Subscription and transaction information:** subscription product, subscription status, expiration date, transaction identifiers, and purchase-validation results. Apple processes payments; we do not receive your full payment-card or payment-account details.
3. **Device and usage information:** we enable Firebase Analytics and AppsFlyer. They may process, on our behalf, device type, operating system and App version, language, IP address and approximate region derived from it, app-instance or installation identifiers (such as Firebase Installation ID, AppsFlyer ID, or IDFV), installation source, and in-App usage events for product analytics, install attribution, and marketing measurement. We do not enable Firebase Crashlytics or Firebase Performance Monitoring.
4. **Advertising identifier (IDFA) and tracking as defined by Apple:** AppsFlyer is configured to access IDFA after you grant permission, for install attribution and marketing measurement. Before accessing IDFA, the App requests permission through Apple’s App Tracking Transparency (ATT) framework. You may decline or later withdraw permission in iOS Settings without losing core learning features. Without ATT permission, AppsFlyer will not obtain your IDFA. We do not use IDFA to create profiles for targeted advertising; however, under Apple’s rules, processing IDFA through a third-party SDK for advertising measurement may be classified as “tracking.” AppsFlyer’s processing of relevant data remains subject to its policy, our configuration, and applicable platform rules.
5. **Support and rights-request information:** the email address, request details, and information reasonably needed to verify and handle your request when you contact us, request account deletion, or exercise privacy rights.
The App currently does not require precise location, contacts, photos, microphone recordings, camera content, health information, or user-generated content. If our features change, we will provide appropriate notice, obtain legally required permission before collection, and update this Policy and our App Store privacy disclosures.
### 3. Purposes and Legal Bases
We process information only to:
- provide Sign in with Apple, account features, learning functionality, and cross-device entitlements;
- validate purchases, deliver subscription content, restore purchases, and prevent transaction fraud;
- secure and maintain the App, diagnose crashes, and improve performance and user experience;
- measure installation sources and marketing effectiveness where AppsFlyer is enabled;
- respond to support, account-deletion, and privacy-rights requests; and
- comply with law, resolve disputes, and protect users, the Developer, or others.
Where applicable law requires a legal basis, we rely on performance of our contract with you, your consent, compliance with legal obligations, or our legitimate interests in securing and improving the service. You may withdraw consent at any time without affecting prior lawful processing.
### 4. Service Providers and Disclosure
We do not sell your personal information. We disclose information to, or permit processing by, the following providers only as reasonably necessary to operate and maintain the App:
- **Apple:** Sign in with Apple, App Store payments, subscription management, purchase validation, and related platform services;
- **Google Firebase Analytics:** App usage and event analytics; we do not enable Firebase Crashlytics or Performance Monitoring;
- **AppsFlyer:** installation attribution, marketing analytics, and fraud prevention.
These providers may process information under their applicable terms and privacy policies. We may also disclose information where required by law, necessary to protect legal rights, or in connection with a business transfer. Any recipient in a business transfer must continue to protect information under this Policy or standards no less protective.
Third-party policies:
- Apple Privacy Policy: https://www.apple.com/legal/privacy/
- Google Privacy Policy: https://policies.google.com/privacy
- Firebase Privacy and Security: https://firebase.google.com/support/privacy
- AppsFlyer Services Privacy Policy: https://www.appsflyer.com/legal/services-privacy-policy/
### 5. International Transfers
The App is offered globally. We and our providers may process information outside your country or region, including in the United States, European Economic Area, Israel, or other locations where providers operate. Data-protection rules there may differ. Where required, we use reasonable safeguards such as approved contractual clauses or other lawful transfer mechanisms.
### 6. Retention
We retain information only for as long as necessary for the purposes described here:
- account information is generally retained until account deletion and then deleted or anonymized within a reasonable period;
- subscription and transaction records may be retained longer as legally necessary for tax, accounting, fraud prevention, and dispute resolution;
- analytics, attribution, and diagnostic information is retained according to our configurations and provider retention settings; and
- support and rights-request records are kept as needed to handle requests, demonstrate compliance, and resolve disputes.
At the end of the retention period, we delete or anonymize information, or isolate and restrict it where immediate deletion is not feasible.
### 7. Security
We use reasonable technical and organizational safeguards appropriate to the nature and risk of the information, including access controls, transmission protections, and service-configuration management. No transmission or storage method is completely secure.
### 8. Children’s Privacy
The App Store “4+” age rating describes content suitability. It does not mean that we knowingly collect children’s personal information, and it is not the same as placement in Apple’s Kids Category. The App is not designed specifically for children.
Users who are below the age at which they may independently consent to personal-data processing or enter the relevant service contract in their location may use the App only after a parent or legal guardian has reviewed and agreed to this Policy and the relevant terms. We do not knowingly collect personal information from a child without required parental consent. If you believe a child provided information without appropriate consent, contact us at the address below so we can investigate and take appropriate action, including deletion.
### 9. Your Rights and Choices
Depending on your location, you may have rights to access, correct, delete, or obtain a copy of personal information; restrict or object to processing; withdraw consent; or complain to a local data protection authority. You may also:
- initiate account deletion in the App’s account settings;
- manage tracking, analytics, and other system permissions in iOS Settings;
- manage or cancel subscriptions in your Apple Account subscription settings; and
- submit a privacy request using the email below.
We may request reasonable information to verify your identity. We will not discriminate against you for exercising applicable privacy rights. Deleting your Solumi account does not automatically cancel a subscription purchased through Apple; cancel it separately in Apple’s subscription settings to avoid renewal.
### 10. Supplemental Notice for Residents of Certain U.S. States
Under applicable U.S. state privacy laws, device identifiers, internet activity, and approximate location may be personal information. We do not sell personal information for monetary consideration. If we later engage in processing considered a “sale,” “sharing,” or targeted advertising under applicable law, we will provide required notice and opt-out controls. You may exercise applicable rights through the email below and may use an authorized agent where permitted.
### 11. EEA, UK, and Swiss Users
For information whose purposes and means we determine, **Noah Coleman** is the data controller. You may request access, correction, deletion, restriction or objection, and data portability, and may complain to the data-protection authority where you live or work. Where processing relies on consent, you may withdraw it at any time.
### 12. Changes to This Policy
We may update this Policy when features, providers, or legal requirements change. We will notify you of material changes through an in-App notice, an updated page, or another legally required method, and update the date above. We will seek renewed consent where required.
### 13. Contact Us
Data controller/developer: **Noah Coleman**
Email: **18911497323@163.com**
Mailing address: **500 Yapa Dr Apt 8, Silverton, Oregon 97381, United States**