Privacy Policy

This Privacy Policy describes how sumalab ("we", "us", or "our") handles personal data in the mobile application "Pilq" (the "App").

1. Data Controller

Name: sumalab
Contact: tamagosenbei0826@gmail.com

2. Personal Data We Collect

We may collect the following personal data:

(1) Device and Technical Information

• Device type and OS version

• IP address

• Advertising identifiers (IDFA / AAID)

(2) Location Data

• Approximate or precise location (only with user permission)

(3) User Content

• Pins, notes, images

• Stored locally on the user's device

(4) Advertising Data

We use third-party advertising services (Google AdMob), which may collect:

• Advertising identifiers

• Usage data

• IP address

3. Purpose of Use

We use personal data for:

• Providing app functionality

• Improving user experience

• Advertising delivery and optimization

• Security and fraud prevention

• Legal compliance

4. Legal Basis

For users in the EEA:

Purpose：Legal Basis

App functionality：Legitimate interest or consent

Location data：Consent

Personalized ads：Consent

Service improvement：Legitimate interest

Legal compliance：Legal obligation

5. Data Storage

• User content is stored locally on the device

• We do not store personal data on our servers

6. Third-Party Sharing

We may share data with:

• Google AdMob (advertising)

• Legal authorities when required

7. International Transfers

Data may be transferred outside the EEA (e.g., United States).
We rely on:

• Standard Contractual Clauses (SCC)

• Adequacy decisions

8. User Rights (GDPR)

Users in the EEA have the right to:

• Access

• Rectification

• Erasure

• Restriction

• Data portability

• Object

• Withdraw consent

9. Consent Management

We obtain explicit consent for:

• Personalized advertising

• Tracking

This includes:

• Advertising identifier usage

• Usage data collection

• Data sharing with third parties (e.g., Google AdMob)

Users can withdraw consent at any time.
If consent is not given, non-personalized ads may be shown.

10. Data Retention

• Local data: until deleted by user

• Advertising data: according to Google policies

11. Children

This App is not intended for children under 13 (or applicable minimum age).

12. Security

We take reasonable measures to protect personal data.

13. Changes

We may update this policy and notify users via app or website.

14. Contact

sumalab
tamagosenbei0826@gmail.com

15. Supervisory Authority

EEA users may lodge complaints with their local authority.

16. Governing Law

This policy is governed by Japanese law. GDPR applies where required.

Terms of Service

These Terms govern the use of the mobile application "Pilq" provided by sumalab.

1. Application

These Terms apply to all use of the App.

2. Service Description

The App allows users to create and manage notes, drawings, and pins on a map.

3. Prohibited Conduct

Users must not:

• Violate laws or public order

• Infringe rights of others

• Harass others

• Misuse the App

• Reverse engineer or modify the App

• Send excessive automated requests

• Perform any inappropriate conduct

4. User Content

Users are responsible for their content.
We are not liable for user content.
Users guarantee that their content is lawful and does not infringe third-party rights.

5. Data Storage

Data is stored locally and may be lost if the App is deleted.

6. Disclaimer

We do not guarantee accuracy or reliability.
We are not liable for damages.

7. Changes or Termination

We may modify or discontinue the App at any time.

8. Advertising

The App may display third-party advertisements.

9. Restrictions

We may restrict users who violate these Terms.

10. Changes to Terms

Terms may be updated and become effective upon notice.

11. Governing Law

Japanese law applies.
Tokyo District Court has exclusive jurisdiction.

12. Contact

sumalab
tamagosenbei0826@gmail.com