Privacy Policy

Application: SoulPoetry

Service Provider: New Version Limited

Effective Date: September 29, 2025

Last Updated: September 29, 2025

This privacy policy governs your use of the software application SoulPoetry for mobile devices that was created by New Version Limited. The Application is a Freemium mobile application that generates AI-powered poetry using advanced artificial intelligence.

What Information Does the Application Obtain and How Is It Used

User Provided Information

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

When you register with us and use the Application, you generally provide:

- Your Apple ID information when using Sign in with Apple

- Name and email address optional, as provided by Apple

- Personal context for poetry customization Premium users only

- Author name for poem signatures Premium users only

- Poetry preferences and favorites

- Font and background theme preferences

The Service Provider may also use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.

Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to:

- The type of mobile device you use

- Your mobile devices unique device ID

- The IP address of your mobile device

- Your mobile operating system

- The type of mobile Internet browsers you use

- Usage analytics and patterns

- Application performance data

- Crash reports and error logs

Support and Contact Information

When you contact us for support through the Application, we automatically include the following technical information in your support request to help us provide better assistance:

- App version and build number

- Device model and type

- iOS version

- Subscription status

- User account status

- Usage statistics such as daily and total poem counts

- User identifier for account-related inquiries

This information is collected only when you initiate contact with support and is used solely for troubleshooting and providing technical assistance.

Location Information: This Application does not gather precise information about the location of your mobile device.

Does the Application Collect Precise Real Time Location Information of the Device

This Application does not collect precise information about the location of your mobile device.

Do Third Parties See and Have Access to Information Obtained by the Application

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

- As required by law, such as to comply with a subpoena, or similar legal process

- 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

- With our trusted services providers who work on our 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

Third-Party Services We Use

AI Services: The Application uses third-party artificial intelligence services to generate poetry. When you request a poem, we send anonymous prompts to our AI provider without any personally identifiable information. Our AI service provider processes this data according to their privacy policy and may retain it for up to 30 days for abuse monitoring purposes. Our AI service provider is located in the United States.

Apple Services: The Application integrates with several Apple services:

- Sign in with Apple: For secure authentication

- CloudKit: For data synchronization across your devices

- StoreKit: For subscription and purchase management

- App Store Connect: For analytics and crash reporting

- iOS Analytics: Basic app performance data collected by Apple

Analytics and Advertising: We do not use third-party analytics services beyond Apple first-party analytics. We do not display advertisements. We do not share data with advertising networks. All usage data is processed internally or through Apple privacy-compliant first-party analytics only.

No Sale of Personal Information: We do not sell, rent, or lease your personal information to any third parties for any purpose.

What Are My Opt-Out Rights

You can stop all collection of information by the Application easily by uninstalling the Application. 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.

Additional Opt-Out Options:

- Sign out: Remove your account from the device while keeping the app

- Disable CloudKit sync: Use the app entirely offline

- Revoke permissions: Through iOS Settings and then Privacy and Security

- Cancel subscriptions: Through iOS Settings and then Subscriptions

Data Retention Policy

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you would like us to delete User Provided Data that you have provided via the Application, please contact us at soulpoetry.ios@gmail.com and we will respond in a reasonable time.

Specific Retention Periods:

- Account Information: Retained while account is active, plus 30 days after deletion

- Usage Statistics: 24 months maximum, then aggregated anonymously

- Favorite Poems: Until manually deleted by user

- Cache Data: Maximum 7 days, automatically purged

- API Logs: 30 days maximum for debugging purposes

Children and Age Requirements

SoulPoetry is rated 14+ and is suitable for all ages. We do not knowingly collect personal information from anyone under the age of 13 without parental consent.

The Application generates poetry content that is appropriate for general audiences. By using this Application, if you are under 13, your parent or guardian must provide consent for your use of the app.

Age Requirements by Region:

- App Store Rating: 14+ globally

- United States: 13 years or older (COPPA compliance)

- European Union: 16 years or older or age of digital consent in your country whichever is higher

- Other regions: 13 years or older or age of digital consent as defined by local law whichever is higher

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at soulpoetry.ios@gmail.com. We will delete such information from our files within a reasonable time.

Parental Controls: We encourage parents to monitor their children online activities and consider using parental control tools available through iOS Screen Time and other family safety applications.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application.

Technical Security Measures:

- Encryption: All data is encrypted in transit and at rest using industry-standard encryption

- Authentication: Secure Sign in with Apple with two-factor authentication support

- Access Control: Least-privilege access principles for all systems

- Regular Security Audits: Quarterly security assessments and penetration testing

- Secure Development: Security-by-design principles in all development processes

Data Processing Security:

- AI Integration: Anonymous API calls with no personal identifiers

- CloudKit: Apple enterprise-grade security and encryption

- Local Storage: iOS Keychain and Secure Enclave protection

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via the Application. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

Notification Methods:

- In-App Notification: Prominent banner when policy changes

- Email Notice: If you have provided an email address for material changes

- Version Update: Policy version clearly marked with change date

- Grace Period: 30 days notice for material changes affecting your rights

What Constitutes Material Changes:

- Changes to data collection practices

- New third-party data sharing

- Changes to your rights or opt-out procedures

- Changes to data retention periods

- New uses of personal information

Your Rights Under International Privacy Laws

Rights Under GDPR European Union

If you are located in the European Union, you have the following rights:

- Right of Access: Request a copy of your personal data

- Right to Rectification: Correct inaccurate personal data

- Right to Erasure: Request deletion of your personal data right to be forgotten

- Right to Restrict Processing: Limit how we process your data

- Right to Data Portability: Receive your data in a structured format

- Right to Object: Object to processing based on legitimate interests

- Right to Withdraw Consent: Withdraw consent for processing at any time

Rights Under CCPA California

If you are a California resident, you have the following rights:

- Right to Know: What personal information we collect and how it is used

- Right to Delete: Request deletion of personal information

- Right to Opt-Out: Opt-out of the sale of personal information Note: We do not sell personal information

- Right to Non-Discrimination: Not to be discriminated against for exercising these rights

Rights Under Other Privacy Laws

Canada PIPEDA: Access, correction, and complaint rights

Australia Privacy Act: Access, correction, and complaint rights

Brazil LGPD: Similar rights to GDPR

Other Jurisdictions: Rights as provided by applicable local privacy laws

How to Exercise Your Rights

To exercise any of these rights, contact us at soulpoetry.ios@gmail.com with:

- Your name and contact information

- Specific right you wish to exercise

- Sufficient information to verify your identity

- Clear description of your request

We will respond within 30 days or as required by applicable law.

Legal Basis for Processing GDPR

For users in the European Union, we process personal data based on the following legal grounds:

Consent Article 6 1 a

- Marketing communications where applicable

- Optional data collection email, name

Performance of Contract Article 6 1 b

- Providing AI poetry generation services

- Account management and authentication

- Subscription service delivery

Legitimate Interests Article 6 1 f

- App improvement and development

- Security and fraud prevention

- Customer support

- Anonymous usage analytics

Legal Obligation Article 6 1 c

- Compliance with applicable laws

- Tax and accounting requirements

You may withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.

International Data Transfers

Data Transfer Mechanisms

United States AI Services: We transfer limited, anonymized data to our AI service provider for AI processing. This transfer is based on:

- Necessity for performance of contract

- Adequate safeguards through contractual clauses

- No personal identifiers included in transfers

Apple CloudKit: Data may be stored in Apple data centers globally, protected by Apple privacy commitments and certifications.

Cross-Border Data Protection

- Encryption: All data encrypted in transit and at rest

- Contractual Safeguards: Data processing agreements with all vendors

- Data Minimization: Only necessary data is transferred

- Regular Audits: Compliance monitoring of all data transfers

Data Breach Notification

In the unlikely event of a data breach that affects your personal information, we will:

User Notification within 72 hours

- Direct notification via email if provided

- In-app notification upon next app launch

- Clear explanation of what happened and what data was affected

Regulatory Notification

- Supervisory authorities notified within 72 hours GDPR requirement

- Relevant authorities in other jurisdictions as required by law

Breach Response Measures

- Immediate containment of the security incident

- Investigation to determine scope and cause

- Remediation to prevent future incidents

- Support for affected users

Cookies Tracking Technologies and Advertising

SoulPoetry does not use cookies, web beacons, or similar tracking technologies. The Application:

- No third-party trackers or analytics services beyond Apple first-party

- No advertising identifiers collection or use

- No cross-app tracking or profiling

- No targeted advertising or behavioral advertising

- No sharing of data with advertising networks

- Apple privacy-first analytics only when required for basic functionality

- No location tracking or geolocation services

- No access to contacts, photos, camera, or microphone unless explicitly requested

- No social media integration that shares your data

We do not participate in any advertising networks or data broker activities.

Artificial Intelligence and Automated Decision Making

AI Processing Transparency

- AI Language Models: Used solely for generating poetry

- No profiling: We do not create profiles for automated decision-making

- No bias monitoring: Regular review of AI outputs for fairness

- User control: You can always request human review of any AI-generated content

Data Used in AI Processing

- Input: Poem type, tone preference, length, optional topic context

- Processing: Anonymous prompt generation without personal identifiers

- Output: AI-generated poems with titles delivered to your device

- Local Storage: Author names and display preferences stored locally for premium users

- Image Generation: Font and background preferences used for local image creation

- Retention: No permanent storage of AI processing data on external servers

If you have any questions about this Privacy Policy, please email us at:

soulpoetry.ios@gmail.com

Regulatory Complaints

If you believe we have not resolved your privacy concern adequately, you have the right to lodge a complaint with:

- EU: Your local supervisory authority

- California: California Attorney General

- Canada: Privacy Commissioner of Canada

- Australia: Office of the Australian Information Commissioner

- Other jurisdictions: Relevant data protection authority

Consent and Acknowledgment

By downloading, installing, or using the SoulPoetry Application, you acknowledge that:

1. You have read and understood this Privacy Policy in its entirety

2. You consent to the collection and use of your information as described

3. You understand your rights under applicable privacy laws

4. You are of legal age to consent to data processing in your jurisdiction

5. You may withdraw consent at any time as described in this policy

Express Consent for Sensitive Operations

For certain data processing activities, we will seek your explicit consent:

- Marketing communications if implemented in future versions

- Sharing personal context with AI services for personalization

- Data transfers outside your region where required by law

Accessibility

This Privacy Policy is available in accessible formats. If you need this policy in an alternative format large print, audio, etc., please contact us at soulpoetry.ios@gmail.com.

Language Versions

This Privacy Policy is available in English. If translations are provided in other languages, the English version shall prevail in case of any discrepancies.

Definitions

Personal Data or Personal Information: Any information relating to an identified or identifiable individual, as defined by applicable privacy laws.

Processing: Any operation performed on personal data, including collection, use, storage, and deletion.

Data Controller: New Version Limited as the entity determining the purposes and means of processing personal data.

Data Processor: Third-party services that process data on our behalf.

Supervisory Authority: The regulatory body responsible for data protection in your jurisdiction.

Effective Date and Version Control

Effective Date: September 27, 2025

Last Reviewed: September 27, 2025

Next Review Date: September 27, 2026

Version History

- Version 1.0: Initial privacy policy

This Privacy Policy is legally binding. By continuing to use SoulPoetry after any changes to this Privacy Policy, you agree to be bound by the revised policy.

For the most current version of this Privacy Policy, please check within the Application or contact us at soulpoetry.ios@gmail.com.

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