This Privacy Policy is a general template aligned with common requirements. It is not legal advice. A qualified attorney should review it for your actual data practices, SDKs, and jurisdictions.
1. Scope & children
This Policy applies to the App and related support communications you have with us at the contact email below. It does not apply to third-party sites or services that we do not control.
The App is not directed to children under 13 (or the higher age required in your jurisdiction for valid consent without parental authorization). We do not knowingly collect personal information from children in violation of applicable law. If you believe we have done so, contact us and we will take appropriate steps.
2. Information we collect
What we collect depends on how you use the App, your device settings, and whether optional features (analytics, advertising, accounts, cloud sync) are enabled in your build.
| Category | Examples |
|---|---|
| Identifiers & device data | Device type, OS version, language/region, app version, coarse IP-derived location (often at city/country level via network or analytics vendors), advertising or device identifiers if tracking/analytics SDKs are used and permitted. |
| Usage diagnostics | Crash logs, performance metrics, feature usage events—typically in aggregate or pseudonymous form when collected by analytics tools. |
| Content you choose to provide | Photos or other media you import for display in the App; recordings or exports you create locally on your device. Such content may remain on-device unless a feature explicitly uploads it. |
| Purchase records | Transactions are processed by Apple (or other platforms); we may receive limited transaction or entitlement information from the platform to validate purchases. |
| Communications | Email address and message content if you email us for support. |
Sensitive categories: We do not intend to collect sensitive categories (e.g., health, biometric templates for identification) as defined under CCPA/CPRA for the core App experience. If a future feature requires such data, we will disclose it clearly and obtain any required consent.
3. How we use information
- Provide, maintain, and improve the App (including interactive visuals, themes, recording/export where available).
- Process in-app purchases and restore entitlements.
- Respond to support requests and secure communications.
- Monitor crashes, abuse, fraud, and security incidents.
- Comply with law, enforce our User Agreement, and protect rights and safety.
- With appropriate notice and consent where required: analytics, personalization, or advertising consistent with platform settings (e.g., Apple’s App Tracking Transparency).
4. Legal bases (EEA, UK, Switzerland)
If GDPR or similar law applies, we rely on one or more of: contract (necessary to provide the App), legitimate interests (security, improvement, aggregated analytics, provided they are not overridden by your rights), consent (where required, e.g., certain cookies or marketing), and legal obligation.
5. Sharing & processors
We do not sell your personal information for money. We may share information with:
- Service providers who assist us (e.g., hosting, analytics, crash reporting, customer support tools), subject to confidentiality and processing terms.
- Platform providers such as Apple for distribution, payments, and OS-level privacy controls.
- Authorities when required by law or to protect rights, safety, and integrity.
- Business transfers in connection with a merger, acquisition, or asset sale, with notice where required.
6. International transfers
We or our processors may process information in countries other than where you live (including the United States). Where required, we use appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms, in addition to technical and organizational measures.
7. Retention
We retain information only as long as needed for the purposes above, unless a longer period is required by law. Support emails may be retained for a limited period. On-device content is controlled by you and your device settings (e.g., deleting the App may remove local data).
8. Security
We implement reasonable technical and organizational measures designed to protect personal information. No method of transmission or storage is 100% secure; we encourage you to keep your device OS updated and use platform security features.
9. Your rights & choices
Depending on your location, you may have rights to access, correct, delete, port, or restrict processing of your personal information, and to object to certain processing or withdraw consent. You may also have the right to lodge a complaint with a supervisory authority.
How to exercise rights: Email fulecyl@163.com with your request and region. We may need to verify your identity. You can also use iOS Settings to reset advertising identifiers, limit tracking, and manage app permissions (Photos, Microphone, Camera, etc.).
We will not discriminate against you for exercising privacy rights where such a guarantee is required by law.
10. California residents (CCPA / CPRA)
California consumers may have the rights to know, delete, correct, and opt out of certain “sharing” for cross-context behavioral advertising, and to limit use of sensitive personal information, as applicable.
Categories collected (last 12 months, illustrative): identifiers, device/network information, usage data, commercial information (purchases), and communications you send us. Purposes: operate the App, analytics/security, support, and transactions. Disclosures: to service providers and platform partners as described above.
We do not “sell” personal information in the traditional sense. If we engage in activities that constitute “sale” or “sharing” under California law, we will provide a “Do Not Sell or Share My Personal Information” link or equivalent control as required.
You may designate an authorized agent where permitted by law; we may require signed permission and identity verification.
11. Canada
Subject to applicable Canadian law (including PIPEDA or substantially similar provincial statutes), we will obtain consent where required, limit collection to what is appropriate, allow access to your personal information subject to exceptions, and maintain reasonable safeguards. Contact us to access or correct information or to raise concerns.
12. Singapore (PDPA)
We aim to collect, use, and disclose personal data in accordance with the PDPA, including consent and notification obligations where they apply, reasonable security arrangements, and access/correction pathways via our contact email unless an exception applies.
13. Australia
Where the Australian Privacy Act 1988 (Cth) applies, we aim to handle personal information in line with the APPs, including transparency, access/correction, overseas disclosure safeguards where relevant, and notification of eligible data breaches when required.
14. Cookies & similar technologies
The mobile App generally does not use browser cookies. Comparable technologies may include SDKs for analytics or ads. You can manage many of these through device and App permissions and platform settings.
15. Changes & contact
We may update this Policy from time to time. We will post the new effective date and, where required, provide additional notice. If you disagree with material changes, stop using the App and contact us.
Privacy contact: fulecyl@163.com