Privacy Policy

1. Who We Are

This Privacy Policy explains how CYBERTRON TECHNOLOGY LIMITED, a company incorporated under the laws of Hong Kong, with its registered office at 18TH FLOOR, 128 WELLINGTON STREET, CENTRAL, HONG KONG, operates the loveTide mobile application ("loveTide" or the "App") and the website at www.winkflix.com (together, the "Service").

CYBERTRON TECHNOLOGY LIMITED acts as the data controller responsible for your personal information collected through the Service. For privacy-related and support questions, you may contact us at [email protected].

loveTide is a streaming application that provides access to short drama series produced by or licensed to us. Some titles can be browsed and viewed without an account. On Android, signing in through Google Sign-In is required before you can purchase a membership subscription or virtual coins, and before premium content can be unlocked. On iOS, sign-in is performed with Apple or Google through Firebase Authentication; the current iOS release does not offer subscriptions, virtual coins or in-app purchases. Platform-specific differences are described throughout this Policy and summarized in Section 2.5.

loveTide is also distributed as a TikTok Mini Program under the name loveTide_tv. There you reach the same short drama catalogue from inside the TikTok app, and the identity you use is your TikTok account, authorized through TikTok's Mini Program platform; we do not create or store a separate loveTide password for that surface. The differences between the Android app, the iOS app and the TikTok Mini Program are described in Section 2.5.

2. Scope of This Policy

2.1 This Policy applies to all information accessed, collected, used, stored, shared or transmitted by the App and the Service, including information collected by third-party software development kits ("SDKs") and service providers integrated into the App.

2.2 By installing, opening, browsing or using the Service, you acknowledge that you have read and understood this Policy. The Service is intended for users aged 16 years or older. If you do not agree with this Policy, please do not use the Service.

2.3 This Policy describes only the loveTide Service. It does not apply to third-party websites, applications or services that you may reach through the Service; those parties handle information under their own privacy policies.

2.4 The commercial terms governing subscriptions, virtual coins, refunds and content access are described in our separate Terms of Service. Nothing in this Policy modifies those terms.

2.5 Platform-specific summary (Android app, iOS app and TikTok Mini Program)

Mobile-app measurement update: The Kochava disclosures in this Policy apply to the Android and iOS mobile-app versions that include Kochava, including iOS version 0.1.1. They do not change the historical iOS 0.1.0 description below or add Kochava to the TikTok Mini Program.

The loveTide App is distributed on two platforms, and the features available differ between them. Where this Policy describes a feature that exists on one platform only, the platform is named. The following summary applies to the current iOS release:

On Android (Google Play), the App additionally offers membership subscriptions and virtual coins processed through Google Play Billing, and viewing history, favorites and playback progress are synced to your account across devices. Where this Policy refers to subscriptions, virtual coins, Google Play Billing or cross-device sync, those statements apply to the Android version unless the iOS platform is explicitly named.

Unless a platform is named, this Policy applies to the Service on all three surfaces. Where a feature exists on only one platform, the platform is identified in the relevant section.

3. Information We Collect

We collect only the information reasonably necessary to operate, secure and improve the Service. The categories below match the disclosures completed in the Google Play Data safety section (Android) and the App Store privacy label (iOS), and are consistent across the two platforms.

3.1 Account and sign-in information

When you choose to sign in, you authenticate through a third-party identity provider. The provider depends on your platform:

• Android: you sign in through Google Sign-In. With your consent, Google provides us with your Google account email address, full name, profile picture, and a unique, stable Google account identifier (the OAuth sub identifier) used to recognize you across sign-ins.
• iOS: you sign in with Apple or Google through Firebase Authentication. We receive the authentication information and account identifiers needed to establish and secure the loveTide account: your email address (which may be a private relay address when you choose "Hide My Email" with Sign in with Apple), your name (when you choose to share it with Apple), and a stable user identifier issued by Firebase (the Firebase uid) together with the identity token from Apple or Google.
• TikTok Mini Program (loveTide_tv): you open the Mini Program inside TikTok and authorize it with your TikTok account. We receive a TikTok platform-scoped user identifier (open ID), your TikTok display name and avatar where you authorize their use, and the session credentials needed to keep you signed in. We do not receive your TikTok password or any other TikTok login credential.

We do not create a separate password-based account and we do not ask you to choose an account password inside the App. We do not request access to your Google contacts, Gmail messages, calendar or Drive, and we do not request access to iCloud, your iOS contacts, photos, microphone or camera for sign-in purposes. In the TikTok Mini Program we do not request access to your TikTok direct messages, contacts, camera, microphone or photo library.

3.2 Subscription, purchase and virtual coin information (Android app only)

On Android, all payments inside the App are processed by Google Play Billing. We receive and store the following entitlement and transaction records; we do not receive or store your credit card number, bank account number, billing address or other payment instrument details:

• Google Play purchase order / purchase token and transaction identifier;
• Subscription plan, subscription status, renewal state, purchase date and expiration date;
• Virtual coin balance, coin purchase records and records of which episodes or titles were unlocked with coins;
• Refund, cancellation or dispute status reported through Google Play.

On iOS (version 0.1.0, build 1086), the App does not offer in-app purchases, subscriptions or virtual coins, and no purchase or entitlement records are collected. If in-app purchases are introduced in a future iOS release, this Policy, the in-app disclosure and the App Store privacy label will be updated before collection begins.

In the TikTok Mini Program (loveTide_tv), the current version offers no subscriptions, virtual coins or in-app purchases, so no purchase or entitlement records are collected there. If paid features are introduced in the Mini Program later, payment would be handled by the payment capabilities of the TikTok platform, we would still not receive or store your card or bank details, and this Policy together with the platform's developer disclosures would be updated before the feature went live.

3.3 Viewing and usage information

• Watch history: the titles and episodes you have viewed;
• Favorites / watchlist: the titles you have saved to your favorites or watchlist;
• Playback progress: the position at which you stopped viewing an episode, used to resume playback.

On Android, watch history, favorites / watchlist and playback progress are associated with your signed-in account and synced across devices. On iOS (version 0.1.0), recent viewing history and playback progress are stored only locally on your device; they are not transmitted to our servers and cross-device synchronization is not offered. Clearing the App or uninstalling it removes this local data.

In the TikTok Mini Program (loveTide_tv), recent viewing and playback state are kept in the Mini Program's local storage on the TikTok client and are not synced with the Android or iOS apps. The three surfaces keep separate viewing state, so progress made in one does not appear in the others.

3.4 Technical information automatically collected to operate the Service

To deliver video streaming, maintain service stability, detect abuse and protect accounts, we and our hosting provider automatically receive limited technical information:

• Internet protocol (IP) address and network type (Wi-Fi / mobile network);
• Device model, operating system version and App version;
• App language setting and country region detected from your Google Play store region (used only for content availability and entitlement rules, not for precise location tracking);
• Crash, error and diagnostic events generated by the App itself, recorded to identify defects and security incidents. On Android, Kochava measurement is described in Section 3.6; no third-party crash reporting SDK is integrated. On iOS, the app includes Firebase Crashlytics, but crash-report collection is disabled for the current release (version 0.1.0, build 1086), so no crash or diagnostic events are transmitted to Crashlytics in this build. If crash reporting is enabled in a future iOS release, this Policy, the in-app disclosure and the App Store privacy label will be updated before collection begins.
• In the TikTok Mini Program, technical and runtime events are handled by the TikTok Mini Program platform and are subject to TikTok's privacy policy. We do not integrate a separate analytics or crash reporting SDK into the Mini Program, and we do not receive TikTok's platform-level measurement data.

3.5 Information we do not collect

Consistent with the current design of the App, we do not collect the following categories of data:

• Precise location from device location services; Kochava may derive a general location from the IP address described in Section 3.6;
• Phone contacts, address book, SMS or call logs;
• Microphone or camera data;
• Persistent hardware identifiers such as IMEI, IMSI or SIM serial number, linked to your personal account;
• Health data, financial account numbers or government identification numbers.

If any of these categories are introduced in a future version of the App, this Policy, the in-app disclosure and the Google Play Data safety section will be updated before collection begins.

3.6 Advertising measurement and shared links (mobile apps only)

Kochava may receive device and app identifiers, IP address, device model, operating system and app version, installation and session information, and shared-link information. Sharing events include the action, Copy Link or system share channel, public content identifier and content type, and system-reported completion; they do not establish that another person received or watched the content.

We also measure successful sign-ins and searches, actual video viewing, the first locally measured video view, sessions with more than five minutes of active playback, checkout starts, and confirmed purchase, subscription or free-trial conversions where the feature and reliable evidence are available. These events contain activity categories and, where applicable, active viewing duration and verified transaction amounts and currencies. We do not include search text, private viewing titles or episode identifiers, business account identifiers, original order numbers, sign-in credentials or payment credentials in these events. The SDK may associate events with device or app-install identifiers.

4. How We Use Your Information

We use the information described above for the following purposes:

1. Providing the Service: authenticating your account, delivering drama titles, and maintaining your favorites and watchlist. On Android, watch history and playback progress are synced across devices; on iOS (version 0.1.0) this data stays on your device;
2. Processing purchases and entitlements (Android only): verifying Google Play subscriptions and coin purchases, unlocking paid episodes or membership features, and maintaining your entitlement records. The current iOS release has no in-app purchases;
3. Customer support: responding to account, subscription, coin and playback support requests, and investigating reported problems;
4. Security and fraud prevention: detecting unauthorized access, abuse, payment fraud, content piracy and violations of our Terms of Service;
5. Service maintenance and stability: diagnosing crashes, performance issues and compatibility problems on device and operating system combinations;
6. Legal compliance: complying with applicable accounting, tax, record-keeping and legal obligations, and responding to valid legal requests;
7. Aggregate statistics: producing aggregated or de-identified statistics about usage of the Service that cannot reasonably be used to identify you personally, using data held on our own servers. Mobile-app measurement through Kochava is described in Section 3.6.

The App currently displays no advertising. We use Kochava in the mobile apps to measure promotion of loveTide, installations, shared-link activity and the activity and conversion events described in Section 3.6. These events may be associated with device or app-install identifiers; they are not necessarily anonymous. Advertising measurement is subject to the permissions and choices described in Sections 10 and 14.2. If a new SDK is added in a future version, this Policy, a separate in-app disclosure and the Data safety section will be updated before collection begins, and you will be asked for any consent required by Google Play policies and applicable law.

5. Legal Bases for Processing (EEA and United Kingdom)

For users in the European Economic Area ("EEA") and the United Kingdom, we rely on the following legal bases under the General Data Protection Regulation ("GDPR") and the UK GDPR to process personal information:

6. Sharing of Information

We share information in the circumstances described below. Kochava Free App Analytics terms permit use of measurement data, combination with other data and creation of derived data. Depending on the processing and applicable law, these arrangements may constitute a sale or sharing of personal information, including under the CCPA/CPRA. Your choices are described in Section 10.

6.1 Service providers and processors

Except for the Kochava Free App Analytics arrangement described above, we share the minimum information necessary with the following service providers, which perform functions on our behalf under data processing arrangements that require them to protect the information and use it only for the services they provide to us. We currently do not use a third-party customer support SDK:

• Kochava Measurement; Kochava Tracking on iOS (mobile apps only) — advertising measurement, installation attribution, shared-link measurement and activity/conversion measurement using the data described in Section 3.6;
• Google Play Billing (Android only) — processes subscriptions, coin purchases, renewals and refunds; provides purchase and entitlement status back to us;
• Google Sign-In (Android) and Firebase Authentication (iOS, Google and Apple providers) — verifies sign-in identity under Google's / Apple's authentication services and establishes the loveTide account session;
• Apple — Sign in with Apple (iOS only) — authenticates users who choose to sign in with Apple, including optional "Hide My Email" private relay addresses;
• Firebase Crashlytics (iOS build only) — crash reporting SDK is present in the iOS build but collection is disabled in release 0.1.0; no crash or diagnostic data is currently transmitted to it;
• TikTok Mini Program platform (loveTide_tv only) — distributes the Mini Program, provides its runtime and the TikTok account authorization flow, and processes data about your TikTok account and your use of the Mini Program under TikTok's own privacy policy; we receive only the platform-scoped identifiers and profile information you authorize;
• Amazon Web Services (AWS), Hong Kong region (ap-east-1) — hosts our backend, account records, video content and App assets, and delivers streaming traffic on our behalf.

6.2 Legal and regulatory sharing

We may disclose your information where we reasonably believe disclosure is required to:

• Comply with applicable law, regulation, legal process or a valid governmental request;
• Enforce our Terms of Service, investigate or defend against claims or violations, including fraud and payment abuse;
• Protect the rights, property or safety of our users, our business or the public;
• Transfer information in connection with a merger, acquisition, financing or sale of business assets, subject to this Policy and applicable law, with notice to you where required.

6.3 No social or public profile data

loveTide currently provides no comments, reviews, public profiles, private messaging or other user-to-user public features. Accordingly, we do not publish or share your personal information with other users.

Inside the TikTok Mini Program, activity that the TikTok platform itself records may be visible to TikTok under your TikTok privacy settings. We do not post to your TikTok profile, publish your viewing activity or message your TikTok contacts on your behalf.

7. Third-Party SDKs and Services

The third-party code and services currently integrated into the App are listed below. Each provider processes data under its own privacy policy. This table must be kept consistent with the Google Play Data safety section, the App Store privacy label and the TikTok Mini Program developer disclosures at all times. Kochava receives the mobile-app measurement data described in Section 3.6. We currently do not integrate a customer support SDK.

8. Data Retention and Deletion

8.1 Active account information. Account profile data, viewing history, favorites, watchlist, playback progress and entitlement records are retained for as long as your account remains active, or as needed to provide the Service.

8.2 Transaction and subscription records. Operational purchase, subscription and coin entitlement records are retained for thirty (30) days after purchase for customer support, entitlement verification and dispute handling. Where applicable tax, accounting, audit or consumer protection law requires us to keep a record for a longer period, we retain that specific record for the period required by law and delete it afterwards; such legally retained records remain protected under this Policy.

8.3 Technical and diagnostic logs. Crash, error, performance and security logs are retained for thirty (30) days, after which they are deleted or aggregated.

8.4 Deleted accounts. When you request account deletion under Section 11, your account profile and associated personal viewing data are deleted within thirty (30) days of confirming the deletion, except for records we are legally required to retain, which continue to be protected under this Policy and are deleted when the retention period expires.

8.5 Guest sessions. When you browse free content without signing in, any temporary playback state held locally on your device is removed when you clear the App data or uninstall the App; we do not maintain a separate guest account on our servers.

8.6 Identity-provider records (iOS app and TikTok Mini Program). Your loveTide business account profile is deleted on request under Section 11. The Firebase Authentication user record and the underlying Apple ID / Google identity are held by Apple, Google and Firebase respectively; the precise retention and deletion responsibilities for these records are being aligned with our backend configuration. Until that alignment is complete, account deletion removes the loveTide account profile and the viewing/entitlement data we control; you may also independently revoke Sign in with Apple through iOS Settings → [your Apple ID] → Sign-In with Apple → loveTide → Stop Using Apple ID, and request deletion of the Firebase user record by emailing [email protected]. Likewise, deleting your loveTide account does not delete your TikTok account or the records TikTok holds about your use of the Mini Program; those are managed by TikTok under its own policies and settings.

8.7 Kochava measurement records. The thirty-day periods above do not specify Kochava's retention period. Kochava records are subject to the applicable service terms, retention settings and legal requirements; account deletion does not automatically remove records already received by Kochava. You may request help with access or deletion through Section 10.5. Local duplicate-prevention records contain hashed markers rather than original order numbers: transaction markers expire ninety (90) days after the transaction and are removed on a subsequent valid update; the first-view marker remains until App data is cleared or the App is uninstalled.

9. Data Security

9.1 We apply reasonable technical and organizational measures designed to protect your personal information against unauthorized access, loss, misuse, alteration or disclosure. These measures include:

• Encryption of data in transit using modern transport security (HTTPS / TLS) between the App, our servers and service providers;
• Role-based access controls: only authorized personnel who need the information to perform their duties may access account records, and only under confidentiality obligations;
• Restricted access to production systems, with activity logging for sensitive operations;
• Never publicly displaying subscription details, purchase records or payment-related identifiers in the App or elsewhere.

9.2 No method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially reasonable measures to protect your information, we cannot guarantee absolute security. If we become aware of a personal data breach affecting your information, we will evaluate it under applicable law and notify affected users and regulators where notification is required.

9.3 You are responsible for keeping your Google or Apple account credentials secure; sign-in to loveTide is handled through those providers (and through Firebase Authentication on iOS), and we never ask you for your Google or Apple account password inside the App.

10. Your Privacy Rights

Depending on where you live, you have the rights described below. To exercise any of these rights, contact us at [email protected]. We verify the request before acting and respond within the timeframe required by applicable law, normally within thirty (30) days.

10.1 Users in the EEA and the United Kingdom (GDPR / UK GDPR)

You have the following rights with respect to your personal information:

• Right of access: obtain a copy of the personal information we hold about you;
• Right to rectification: correct inaccurate or incomplete information;
• Right to erasure: request deletion of your personal information, where no legal obligation or legitimate ground for retention applies;
• Right to restriction of processing: request that we suspend processing of your information in certain circumstances;
• Right to data portability: receive the information you provided to us in a structured, commonly used, machine-readable format;
• Right to object: object to processing based on our legitimate interests, subject to our overriding grounds for continuing the processing;
• Right to withdraw consent: withdraw consent given for sign-in or optional processing at any time;
• Right to lodge a complaint: with the data protection authority of your EU member state or, for UK residents, the Information Commissioner's Office.

10.2 California residents (CCPA / CPRA)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act:

• Right to know: request the categories, specific pieces, sources, purposes and recipients of the personal information we collected about you over the prior twelve (12) months;
• Right to delete: request deletion of personal information we collected from you, subject to legal exemptions;
• Right to correct: request correction of inaccurate personal information;
• Right to limit the use of sensitive personal information: where sensitive personal information were to be processed, you could request that its use be limited;
• Right to opt out of sale or sharing: you may request that we stop any processing that constitutes sale or sharing under applicable law by contacting [email protected] with the subject "Do Not Sell or Share My Personal Information". Device tracking controls and Kochava privacy requests are described in Section 10.5;
• Right to non-discrimination: we will not discriminate against you for exercising any of these rights.

You may authorize an agent to submit a request on your behalf; we may require verification of both you and the agent.

10.3 Hong Kong residents (Personal Data (Privacy) Ordinance, Cap. 486)

Under the Personal Data (Privacy) Ordinance of Hong Kong, you are entitled to:

• Request access to the personal data we hold about you;
• Request correction of personal data that is inaccurate;
• Request that we not retain your personal data longer than necessary for the purpose of collection.

Access or correction requests should be sent to [email protected]; we will respond within the timeframe required by the Ordinance. If you are dissatisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong.

10.4 Other jurisdictions

Residents of other countries may have similar rights under local law. Please contact us at [email protected] to identify and exercise the rights available to you.

10.5 Mobile-app tracking choices and Kochava requests

On iOS, you can decline the ATT prompt or withdraw permission in Settings > Privacy & Security > Tracking. On Android, you can use the advertising-identifier privacy controls provided by your device. Withdrawing tracking permission does not by itself delete information already collected. For access, deletion or questions about Kochava measurement data, contact [email protected] or use Kochava's privacy request options. Accepting the Terms of Service or acknowledging this Policy does not grant tracking permission.

11. Account Deletion

App platform policies (Google Play, the Apple App Store and the TikTok Mini Program platform) require that users be able to request deletion of their account and associated data both inside the App and through an external web channel. The following process applies.

11.1 Deletion inside the App

You may delete your loveTide account at any time from the App:

1. Sign in to the account you wish to delete;
2. Open Profile → Settings;
3. Select Delete Account and follow the on-screen confirmation steps.

11.2 Deletion through the web / email channel

If you cannot access the App, send an account deletion request from the email address registered to your loveTide account to [email protected] with the subject line "Account Deletion Request". Include your registered sign-in email (Google or Apple, including any Apple private-relay address) or, for the TikTok Mini Program, the TikTok account name or open ID you used, so we can verify the request.

11.3 What happens when your account is deleted

Upon verified deletion, we permanently delete the loveTide business account profile and the viewing and entitlement records associated with it that are held on our servers. The following items are handled separately:

• Identity-provider records: deleting the loveTide account does not automatically delete your Apple ID, your Google account, or the Firebase Authentication user record. To revoke Sign in with Apple, use iOS Settings → [your Apple ID] → Sign-In with Apple → loveTide → Stop Using Apple ID. To request removal of the Firebase Authentication user record, email [email protected]; we are aligning this deletion flow with our backend and will update this section once it is fully automated.
• TikTok account records (loveTide_tv): deleting your loveTide account does not delete your TikTok account, and does not remove records TikTok holds about your use of the Mini Program. Those remain under TikTok's own policies and are managed through TikTok's account settings.
• Active subscriptions (Android only): before deleting the account, cancel any recurring membership subscription in Google Play Store → Subscriptions, so that no further renewal charge occurs; account deletion itself does not automatically cancel a Google Play subscription. The current iOS release has no subscriptions.
• Remaining virtual coins and unlocked entitlements (Android only): once the account is deleted, unused coins, episode unlocks and membership entitlements cannot be restored. Refund eligibility for recent purchases follows Google Play refund policy and our separate purchase terms. The current iOS release has no coins or in-app purchases.
• Local iOS viewing data: on iOS, watch history and playback progress are stored on the device (Section 3.3); uninstalling the App removes that local data.
• Required retention records: transaction and billing records we must retain under applicable law remain protected and inaccessible for account-related operations, and are deleted at the end of the applicable retention period described in Section 8.2.

12. Children's Privacy

12.1 loveTide is intended for users aged 16 years or older and is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe a child under 13 has provided us with personal information, contact us at [email protected] and we will take steps to delete that information promptly.

12.2 For users aged 13 to 15, the Service is not intended or marketed; where applicable, parental consent rules under local law would be observed before any account creation.

12.3 We do not integrate SDKs that have not been approved for use in child-directed services, because the App does not target children.

13. International Data Transfers

13.1 Your information is stored and processed on our servers hosted on Amazon Web Services in the Hong Kong region (ap-east-1), Hong Kong SAR. On Android, Google Play Billing and Google Sign-In process authentication and payment data under Google's own systems. On iOS, Firebase Authentication (Google / Apple sign-in) processes authentication data under Google's Firebase infrastructure, and Sign in with Apple processes authentication data under Apple's own systems; Sign in with Apple does not share your profile email or name beyond the identity token we receive. In the TikTok Mini Program, TikTok and its infrastructure process the Mini Program runtime, the authorization flow and platform-level data under TikTok's own systems and policies; our own backend and account records remain in AWS Hong Kong. Kochava also processes the mobile-app measurement data described in Section 3.6 on its infrastructure and through its service providers, which may be outside your country and outside our AWS Hong Kong region. Applicable transfer safeguards are described in Section 13.2 and Kochava's data processing policy.

13.2 Where personal information originating in the EEA or the United Kingdom is transferred outside the EEA or the UK to Hong Kong or another third country, we rely on applicable transfer mechanisms, such as the European Commission Standard Contractual Clauses (and equivalent UK transfer mechanisms), and we require our service providers to apply appropriate safeguards consistent with this Policy.

13.3 Information collected within Hong Kong is handled under the Personal Data (Privacy) Ordinance, Cap. 486.

14. Cookies and Similar Technologies

14.1 The App uses local storage and cache on your device to maintain sign-in state, playback progress and preferences. Where our website is visited, it may use essential cookies required for basic site functionality.

14.2 The mobile apps use Kochava identifiers and, where available and permitted by device settings, advertising identifiers for the measurement purposes described in Section 3.6. On iOS, Kochava Tracking accesses Apple's identifier for advertisers (IDFA) only after authorization through Apple's App Tracking Transparency (ATT) prompt. Declining tracking permission does not restrict use of the App or direct sharing, but installation attribution or automatic restoration of a shared episode after installation may be unavailable. The App does not display advertising. We do not link account data to persistent hardware identifiers such as IMEI, IMSI or SIM serial number. Within the TikTok Mini Program, the TikTok platform may collect device and usage identifiers for its own purposes under TikTok's privacy policy; that processing is controlled by TikTok rather than by us, and we do not receive it for advertising.

15. Governing Law and Jurisdiction

15.1 Consistent with our Terms of Service, this Privacy Policy, and any dispute or claim arising out of the processing of your personal data, are governed by the laws of your jurisdiction of habitual residence where required by mandatory local data protection law (such as the GDPR in the EEA, the UK GDPR in the UK, the LGPD in Brazil, or the CCPA/CPRA in California).

15.2 For international cross-border operations and users in other service regions, data governance disputes are subject to the neutral dispute resolution procedures and governing law provisions set out in Section 16 of our Terms of Service. This does not limit your right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.

16. Changes to This Policy

16.1 We may update this Policy from time to time to reflect changes in the Service, legal requirements or third-party services. The "Last updated" date at the top of this page shows when the current version took effect.

16.2 For material changes, we will provide additional notice in the App, for example through an in-app notice before the changed processing begins. Your continued use of the Service after the effective date constitutes acceptance of the revised Policy; this does not replace any separate consent required for tracking or other optional processing.

17. Contact Us