Privacy Policy

Last Amended: June 11, 2025

This Privacy Policy (“Privacy Policy”) governs the processing and transfer of personal data collected or processed by using or accessing any of our mobile applications (“App” or “Apps”). This Privacy Policy is an integral part of our End User License Agreement (“EULA”).

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data, where applicable, as required by the EU General Data Protection Regulation (“GDPR”), the Brazilian General Data Protection Law (“LGPD”), the California Consumer Privacy Act (“CCPA”), and other applicable regulations.

If you have any questions regarding this Privacy Policy or our data practices, please contact us at: gxdm990@gmail.com

TABLE OF CONTENTS

I. PRIVACY NOTICE

  A. Policy Amendments

  B. Contact Information

  C. Data Sets We Collect and For What Purpose

  D. How We Collect Your Information

  E. SDK & Tracking Technologies

  F. Data Sharing

  G. Data Retention

  H. Security Measures

  I. International Data Transfer

  J. User Rights

  K. Opt Out Options

  L. Eligibility and Children Privacy

II. JURISDICTION-SPECIFIC NOTICES

  A. California Residents

  B. Colorado Residents

  C. Virginia Residents

  D. Connecticut Residents

  E. Utah Residents

  F. Nevada Residents

I. PRIVACY NOTICE

A. POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted within the App or on our associated website. The updated date will be reflected in the “Last Amended” heading.


We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments will become effective within 30 days upon display of the modified Policy. We recommend reviewing this Policy periodically to ensure you understand our most current privacy practices.

B. CONTACT INFORMATION

For any privacy-related inquiries, requests, or complaints, please contact us:

  • By Email: gxdm990@gmail.com

Representative for data subjects in the EU and UK: We have appointed a privacy representative as a point of contact for EU/UK data subjects. Please reach out to us at the email above and we will provide you with the necessary contact details.

C. DATA SETS WE COLLECT AND FOR WHAT PURPOSE

Non-Personal Data

We may collect aggregated, non-personal, non-identifiable information during your use of our Apps. This may include: device type and operating system, language preference, time and date stamps, country-level location, and general usage statistics.

Personal Data

We may also collect individually identifiable information (“Personal Data”) as described below. We do not knowingly collect Special Categories of Personal Data (e.g., health, biometric, racial/ethnic origin, or religious data).

The following categories of Personal Data may be collected depending on the features of the specific App you use:

Registration Information

If registration is required, we collect information such as your name and email address to set up your account and provide our Services. We may also use this data for relevant marketing communications, which you may opt out of at any time by contacting us.

Lawful Basis: Contract performance; legitimate interest (marketing).

Contact Information

If you contact us, we collect your name, email address, and any information you voluntarily provide, solely to respond to your inquiry.

Lawful Basis: Legitimate interest.

GPS / Location Information

Certain App features may request access to your device location (fine or coarse). Where used, this data is processed solely on your device to provide the relevant feature and is not stored on our servers. You may revoke this permission at any time via your device settings.

Lawful Basis: Your explicit consent via in-app permissions.

Push Notifications

We may store a device notification token (e.g., Firebase Cloud Messaging token) to send you push notifications. You may disable notifications at any time via your device settings.

Lawful Basis: As the token is non-personal data, no specific lawful basis is required.

In-App Payment Information

All in-app purchases are processed entirely by the relevant app store provider (Google Play or Apple App Store). We do not store or process any payment card or billing details. We only receive a non-identifiable order reference number.

Lawful Basis: Contract performance.

Log Data and Unique Identifiers

In the event of an error, we may collect crash/log data through third-party providers, which may include your device IP address, device name, OS version, App configuration, timestamps, and usage statistics. We treat this as Personal Data out of caution.

Lawful Basis: Legitimate interest (improving App stability and security).

List of Installed Apps

Certain Apps may request a list of installed applications on your device to support, improve, or protect our Services.

Lawful Basis: Your consent via in-app permissions.

Profiling / Advertising Data

We may work with advertising partners who place SDKs in our Apps to display relevant ads. These SDKs may collect device identifiers and behavioral data for interest-based advertising. You may opt out via your device’s privacy/ads settings.

Lawful Basis: Your consent where required by jurisdiction.

Photos, Images, and Videos

If an App includes a photo or video editing feature, we will request access to your media for that purpose only. Processing occurs on your device and we do not store your photos or videos on our servers.

Lawful Basis: Consent; contract performance.

Microphone and Audio

Where an App includes voice or dialer functionality, we may request microphone access. Audio is used solely to provide the feature and is not stored on our servers.

Lawful Basis: Consent; contract performance.

Call Log and Contacts

Where an App includes dialer functionality, we may request access to your call log and contacts to provide caller identification features. This data is processed on-device and not stored on our servers.

Lawful Basis: Consent; contract performance.

Bluetooth and Network

We may collect information about nearby Bluetooth devices and Wi-Fi networks to deliver certain App features (e.g., network scanning). This data is used solely to provide the requested functionality.

Lawful Basis: Consent; contract performance.

Calendar

Some Apps may require calendar access to apply design themes or display contextual features. Calendar data is processed on-device and not stored on our servers.

Lawful Basis: Consent; contract performance.

Health Data

Where an App includes health-related features, health data is processed solely on your device and is never transmitted to our servers.

Lawful Basis: Consent; contract performance.

D. HOW WE COLLECT YOUR INFORMATION

We collect information in the following ways:

  • Automatically, through your use of the App (subject to permissions you grant).
  • Voluntarily, when you contact us or provide information directly.
  • From third-party service providers and partners as described in this Policy.

E. SDK & TRACKING TECHNOLOGIES

Our Apps and service providers may use software development kits (SDKs), cookies, or other tracking technologies to help provide and improve our Services, personalize your experience, and monitor performance.

Common SDKs we may use include:

  • Google Play – In-app billing (https://policies.google.com/privacy)
  • Firebase – Analytics, crash reporting, remote config, messaging (https://firebase.google.com/support/privacy)
  • Advertising Partners (AdMob, Meta Audience Network, AppLovin, and others) – Interest-based advertising. Each partner’s privacy policy is available on their respective websites.

The specific SDKs used may vary by App. You can opt out of interest-based advertising through your device settings or the Digital Advertising Alliance opt-out tools.

F. DATA SHARING

We may share your data with the following categories of recipients:

  • Advertising Partners: Online identifiers, for ad delivery and personalization.
  • Service Providers: All relevant data, for hosting, analytics, fraud prevention, and other operational purposes. These providers are contractually restricted to use your data only as directed by us.
  • Business Acquirers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity under the same privacy obligations.
  • Government Authorities: Where required by law, legal process, or to protect the rights, property, or safety of our users or the public.

G. DATA RETENTION

We retain Personal Data for as long as necessary for the purposes described in this Policy, or as required by applicable law. Retention periods may be extended where required for legal compliance, dispute resolution, or fraud prevention. We may delete data at any time unless legally required to retain it.

H. SECURITY MEASURES

We implement physical, technical, and administrative security measures designed to protect your Personal Data from unauthorized access, misuse, disclosure, or accidental loss. If you believe your privacy has been compromised, please contact us immediately at: gxdm990@gmail.com

I. INTERNATIONAL DATA TRANSFER

Your data may be processed in Israel, the EU, the US, or other countries. When transferring Personal Data from the EU/EEA to third countries, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission. Contact us for further information about these arrangements.

J. USER RIGHTS

Depending on your jurisdiction, you may have rights including:

  • Right to access and review your Personal Data.
  • Right to correct inaccurate Personal Data.
  • Right to delete your Personal Data.
  • Right to restrict or object to processing.
  • Right to data portability.
  • Right to withdraw consent at any time.
  • Right to lodge a complaint with a supervisory authority.

To exercise any of these rights, please contact us at: gxdm990@gmail.com

K. OPT-OUT OPTIONS

We do not sell your Personal Data. We may share data with third parties for personalized advertising purposes. To opt out of interest-based advertising:

  • Digital Advertising Alliance (US): https://www.aboutads.info/choices/
  • Digital Advertising Alliance (Canada): https://youradchoices.ca/en/tools
  • Digital Advertising Alliance (EU): https://www.youronlinechoices.com/
  • Network Advertising Initiative: https://optout.networkadvertising.org/
  • Adjust your device’s privacy/ad settings under Settings > Privacy > Advertising.

L. ELIGIBILITY AND CHILDREN’S PRIVACY

Our Apps are not intended for children. In the EEA, a “child” is anyone under 16; in the US, under 13. We do not knowingly collect Personal Data from children. If we become aware that a child has provided us with Personal Data, we will delete it immediately.

If you believe a child has shared data with us, please contact us at: gxdm990@gmail.com

II. JURISDICTION-SPECIFIC NOTICES

A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies to California residents under the California Consumer Privacy Act (CCPA), as amended by the CPRA effective January 1, 2023.

Categories of personal information collected, sources, purposes, and recipients are described in Sections I.C and I.F above. We do not sell your personal information. We may share personal information with third parties for cross-contextual advertising purposes; you may opt out as described in Section I.K.

California residents have the right to: know what personal information is collected; delete personal information; correct inaccurate personal information; opt out of sale/sharing; and non-discrimination for exercising these rights.

To exercise your rights, contact us at: gxdm990@gmail.com

B. ADDITIONAL NOTICE TO COLORADO RESIDENTS

Under the Colorado Privacy Act (CPA), Colorado residents (acting in an individual or household context) have the following rights: access, correction, deletion, portability, opt-out of targeted advertising/sale/profiling, and appeal.

We do not sell personal data and do not profile users. We may share data for personalized advertising; opt out as described in Section I.K.

To submit a request or appeal: gxdm990@gmail.com

If your appeal is denied, you may contact the Colorado Attorney General at https://coag.gov/file-complaint/

C. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act (VCDPA), Virginia residents (acting in an individual or household context) have rights to access, correct, delete, obtain a copy of, and opt out of the processing of their personal data for targeted advertising, sale, or profiling.

To submit a request or appeal: gxdm990@gmail.com

If your appeal is denied, you may contact the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

D. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act (CDPA), Connecticut residents (acting in an individual or household context) have rights to access, correct, delete, portability, and opt out of targeted advertising, sale, and profiling.

To submit a request or appeal: gxdm990@gmail.com

If your appeal is denied, contact the Connecticut Attorney General at https://www.dir.ct.gov/ag/complaint/

E. ADDITIONAL NOTICE TO UTAH RESIDENTS

Under the Utah Consumer Privacy Act (UCPA), Utah residents (acting in an individual or household context) have rights to access, delete, obtain a copy of, and opt out of the sale or use of their personal data for targeted advertising.

To submit a request: gxdm990@gmail.com

F. NOTICE TO NEVADA RESIDENTS

Nevada law allows residents to opt out of the sale of certain personal information. We do not currently sell personal information as defined under Nevada law. However, Nevada residents may submit a verified opt-out request and we will record your instructions for any future changes in our practices.

To submit a request: gxdm990@gmail.com