Privacy Policy

Effective Date: July 21st, 2026

This Privacy Policy applies to [APP Name] (hereinafter referred to as the "Application"). It strictly complies with Apple App Store Review Guideline 5.1.1, iOS Privacy Manifest specifications, and App Tracking Transparency (ATT) authorization rules. Meanwhile, it conforms to global data compliance requirements including the Personal Information Protection Law of China, Cybersecurity Law of China, EU General Data Protection Regulation (GDPR), and California Consumer Privacy Act (CCPA).

This policy clearly and transparently explains how we collect, use, store, share, and protect your personal information, as well as all your legal rights to inquire, correct, delete your personal information and deregister your account. This policy is publicly accessible without login and fully meets the review standards for App Store release.

1. Scope of Application and Data Controller Information

Contact Address: renoh@wolskiassociates.pics

2. Data Collection Rules (Fully Aligned with App Store Privacy Labels)

We undertake to only collect the minimum data necessary for product functions, refrain from compulsorily collecting non-essential information, obtain explicit user authorization for all data collection activities, and comply with the iOS minimum permission principle. All collected data is completely consistent with the App Store Connect privacy questionnaire, privacy manifest file, and SDK privacy statements without any discrepancy.

2.1 Mandatory Collected Data (Essential for Core Functions)

We may collect the following data based on the actual functions of the Application, solely to ensure the normal operation of the Application:

1. Device Basic Information: Device model, system version, unique device identifier, network type, device language, and time zone information (used for device adaptation, crash fixing, and application compatibility optimization).

2. Log Data: Application operation logs, crash logs, and error reports (used for fault troubleshooting, function optimization, and user experience improvement).

3. Account Information (if account function is available): Username, phone number, login records, and account status information (used for account registration, login, identity verification, and account security management).

2.2 Optional Collected Data (User-Authorized and Revocable Anytime)

Such data is only collected with your active authorization. Disabling relevant permissions will immediately stop data collection without affecting the use of core functions:

1. Album/Photo Permission: Only used for users to actively upload avatars, screenshots and publish works. We will not automatically scan or upload album contents.

2. Microphone/Camera Permission: Only used for user-initiated scenarios such as voice interaction, code scanning, and material shooting.

3. Location Information (if applicable): Only used for localized service functions. Users may disable location permission in system settings at any time.

4. Identifier for Advertising (IDFA): Only used for targeted advertising and data analysis. In strict accordance with the iOS ATT framework, IDFA will only be obtained after user pop-up authorization, and users may reject or disable tracking permission at any time.

2.3 No Data Collection Statement (for Minimalist Applications)

If this Application is a pure tool-based minimalist application without accounts, network access or advertisements, this Application does not collect, store or upload any user personal information, and conducts no user data tracking behaviors, fully complying with Apple’s specifications for no-data-collection applications.

3. Purposes of Data Use (Mandatory Disclosure for App Store Review)

All user data we collect is only used for the following legitimate purposes without excessive use:

1. Ensuring the normal operation of the Application’s core functions and providing basic services to users;

2. Fixing application faults, optimizing product experience and iterating functions;

3. Conducting security risk control to prevent abnormal account activities, cheating, infringement and illegal use;

4. Responding to user consultations, after-sales requests, permission appeals and data rights protection demands;

5. Complying with laws, regulations, Apple Developer Agreement and platform regulatory requirements;

6. Other purposes with separate user authorization.

4. Data Sharing and Third-Party SDK Disclosure (2026 Latest Compliance Requirements)

We will not sell, rent or trade any user personal information to irrelevant third parties. Data sharing is only conducted in the following compliant scenarios, and all third parties have completed privacy compliance filing:

1. Compliant Third-Party Service SDKs: This Application may access SDKs for statistics, pop-up displays, payment and advertising. All data collection behaviors of such SDKs are recorded in the privacy manifest, fully consistent with App Store privacy labels, and only used for corresponding functional services.

2. Legal Mandatory Scenarios: We will provide data in accordance with regulations when judicial authorities or regulatory departments request data disclosure by law.

3. Explicit User Consent: Third-party data sharing behaviors actively authorized or initiated by users.

All third-party partners are required to sign data confidentiality agreements to strictly control user data and prevent data leakage and abuse.

5. Data Storage and Security Protection

1. Storage Region: User personal information is stored on compliant servers in [Chinese Mainland / Compliant Region], with no illegal cross-border data transmission.

2. Storage Period: Data is only retained for the shortest period required for service provision. All user data will be completely deleted after account cancellation or data deletion requests take effect (except log data required to be retained by laws and regulations).

3. Security Measures: We adopt technical means including encrypted transmission, data desensitization, permission control and server security protection to prevent data leakage, tampering, loss and unauthorized access.

4. Data Monitoring: We establish a regular data security inspection mechanism to timely eliminate potential security risks and protect user information security.

6. Core User Rights (Key App Store Review Item)

You enjoy full free and threshold-free rights to inquire, correct, delete your personal information, revoke authorization, deregister your account and refuse tracking:

1. Information Inquiry and Correction: You may view your personal information in the application settings and correct erroneous information independently.

2. Authorization Revocation: You may disable all permissions of the Application including album, camera, location and tracking in your mobile system settings at any time, and we will immediately stop corresponding data collection.

3. Account Deletion (Apple Mandatory Requirement since June 2023): You may independently delete your account and all associated personal data via [Settings - Account Security - Delete Account], or apply for manual cancellation through the official email. All user data will be completely and irreversibly cleared within 7 working days after account cancellation.

4. Data Tracking Refusal: Strictly compliant with the iOS ATT framework, a tracking authorization pop-up will be displayed on the first launch. If you choose to refuse tracking, we will not collect IDFA or user behavior tracking data.

5. Data Deletion Request: You may apply for deletion of all your personal data at any time, and we will process and respond within the statutory time limit.

7. Minor Protection

This Application is available for all age groups. We will not actively collect personal information of users under the age of 18. If you are a minor, please use this Application with the accompaniment and authorization of your guardian. Guardians may contact us to delete minor personal information if unauthorized collection is found.

8. Cross-Border Data Transmission Statement

This Application will not actively transmit user personal information to overseas servers. If cross-border data transmission occurs due to service iteration, we will strictly abide by domestic and foreign cross-border data compliance laws and regulations, obtain separate user authorization, implement data security guarantee measures, and complete relevant filing procedures.

9. Policy Updates and Notifications

We may update this Privacy Policy in accordance with laws, regulations, platform rules and product function iterations. Updated versions will be notified via in-app pop-ups, announcements or privacy page updates. Your continued use of the Application after the update constitutes recognition of the revised policy. Major privacy changes will require explicit user re-authorization.

10. Dispute Resolution

Disputes arising from this Privacy Policy shall be settled through negotiation in the first instance. If negotiation fails, disputes shall be submitted to the people’s court where the operator is located for litigation resolution.

11. Compliance Statement

This Privacy Policy fully complies with Apple App Store privacy review specifications, iOS privacy manifest requirements, ATT tracking authorization rules and mandatory account deletion requirements. The actual data behaviors, privacy manifest and App Store privacy labels of the Application are completely consistent with the contents of this policy, without false disclosure, illegal data collection or privacy inconsistency, which is fully applicable for App Store review and release.

Privacy Support Email: renoh@wolskiassociates.pics