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Privacy Policy

 

Privacy Policy for PDF Editor & Scan: DocKit

 

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

Nadezhda Belozerova (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”)explains ourdata protection policy and describes the types of information we may process when you install and/or use PDF Editor & Scan: DocKit software application(s) designed for mobile devices (the “App”). The title of the App may vary in countries and is subject to change withoutspecific notice.When we refer to personal data (or personal information) we mean anyinformation of any kind relating to a natural person who can beidentified, directly or indirectly, in particular by reference tosuch data.It is a natural person who can be identified directly or indirectly,in particular by reference to an identification number or to one ormore factors specific to his or her physical, physiological, mental,economic, cultural or social status.Our Privacy policy applies to all users, and others who access theApp (“users”).PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDINGTHE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHENYOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, ANDAGREE TO BE BOUND BY THESE TERMS.IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWINGIMPORTANT NOTICEUnder the California Consumer Privacy Act of 2018 (CCPA) Californiaresidents shall have the right to request:

    • the categories of personal information that is processed;
    • the categories of sources from which personal information isobtained;
    • the purpose for processing of user personal data;
    • the list and categories of third parties with whom we may shareyour personal information;
    • the specific pieces of personal information that we might haveobtained about a particular user provided that the data given inthe request is reliable enough and allows to identify the user.

Please use the navigation links through this Privacy policy:PERSONAL INFORMATIONAll about the categories of information, its sources and purposes ofprocessingPlease mind that according to CCPA personal information does notinclude de-identified or aggregated consumer information.SHARINGHow your information can be sharedPlease note that all third parties that are engaged in processinguser data are service providers that use such information onthe basis of agreement and pursuant to business purpose.OPT-OUT OPTIONSIf you don’t want us to process your personal information any more please contact us byemail ksusha.kha.apps@gmail.com. In most cases thereis no way to maintain the App’s further operatingwithout functional information, therefore, you will be advised to remove the App from your device.If you don’t want us to share device advertising identifiers with service providers or if you want to manage,controlwhen and which apps on your device have access to your device location data, please check your device settingsto optout as described belowREQUESTSTo submit a verifiable consumer request for access, portability or deletion of personal data please contact usby email ksusha.kha.apps@gmail.com. Please include in thetext of your request the wording “Exercising data privacy rights in the state of California”.When submitting a verifiable request, you should be ready to:

  • Provide sufficient information that allows us to reasonably verifyyou are the person about whom we collected personal information oran authorized representative, which may include: name, address,city, state, zip code and email address. We may use thisinformation to surface a series of security questions to you toverify your identity. If you are making a request through anauthorized agent acting on your behalf, such authorized agent mustprovide written authorization confirming or a power of attorney,signed by you.
  • Describe your request with sufficient detail that allows us toproperly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you withpersonal information if we cannot: (i) verify your identity orauthority to make the request; or (ii) confirm that the personalinformation relates to you. We may ask you for additionalinformation or documents to verify your identity. We may also carryout checks, including with third party identity verificationservices, to verify your identity before taking any action with yourpersonal information. This is regarded as a safeguard measure toprevent disclosure of your personal information under a fake or scamrequest.We ensure that personal information provided in a verifiableconsumer request will be used only to verify the requestor’sidentity or authority to make the request and not for any otherpurpose. We will keep it for the adequate term reasonably needed forthe purpose described above and delete after the purpose isfulfilled.We try to respond to a verifiable consumer request within forty-five(45) days of its receipt. If we require more time, we will informyou of the reason and extension period in writing. Please note thatwe are only required to respond to two requests per customer eachyear.EQUAL RIGHTSNothing in the way we deal with your request shall be interpreted asdiscrimination, which means that we will not set up differentpricing or products, or different level or quality of services foryou, if you choose to exercise your rights. However, in somecircumstances, we may not be able to provide services if you chooseto delete your personal information from our records.SALE OF DATAWe do not sell any of your personal data to third parties.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.Functional InformationWe ask for and process the following personal information when youuse the App. This information is necessary for the adequateperformance of the contract between you and us.Without such information it is impossible to provide completefunctionality of the App and perform the requested services.Permissions for Camera, Photos and videos, Files. After you grant us the relevant permission,we mayhave technical access to your Camera that is required to be able to scan documents via the App and/or to takephotosyouwant to add to your documents. Additionally, if you try to upload any image, photo or file from your PhotoLibrary/Gallery or Files to the App, the relevant technical access of the App to your Photos and videos orFiles isrequired. The technical access you provide to your Photos and videos (either limited or full), Files isnecessary forussolely to enable you to upload photos, images, files from your device to the App, use them to create and editdocumentsin the App, i.e. to operate the App Services and provide you with the App functionality. You can manage,change accesspermissions to your Camera, Photos and videos, Files at any time via the Settings app on your device. Read this Googlehelp article or this Apple support article(depending on which App (for iOS or Android devices) you use) for moredetails and instructions on how you can manage app permissions.Authorization data related to registration in the App. Your email address isrecorded if you already have an account or if you choose to createa new account within the App (Sign Up for a new account). Havingan account within the App (“User Account”)allows you to be registered within the App to use the full scopeof its functions, inter alia, to use the cloud storagefunctionality, to store and manage documents associated with yourUser Account, sync and access them anytime from any device or platform (iOS, Android, Web).You can create a User Account by providing your email address(“Enter email” option on the Sign Up screen), setting andconfirming the password and going through a verification process.You may also choose to sign in to the App with your Apple, Googleor Facebook account using the “Continue with Apple”, “Continuewith Google” or “Continue with Facebook” button on the Sign Upscreen. In this case you may use the information related to your AppleID/Google account credentials/Facebook account credentials to sign in to your User Account.When you create or log in to your User Account through a third-party service (Apple, Google or Facebook), you voluntarily direct this service to provide us with access to some of your basic profile information in accordance with the authorization procedures determined by such service. Among all potentially available basic profile information from a third-party service you use for authorization we access and record only your name and email address, which are processed and stored for the purpose of your User Account creation and maintenance.Inter alia, if you register in the App (Sign Up for a new User Account) or Sign in to your existing User Account using the “Continue with Google” option, Google will provide you with system notifications and require your authorization to give our App some access to your Google account data. If you decide to share such access, you will need to sign in to your Google account. In this case the App requests some access to your Google account data solely to enable you to create a new User Account and/or perform authorization to your existing User Account. When you use the “Continue with Google” option in the App, Google will give you a notification that you authorize us to access your basic Google profile information: name, email address, language preference, and profile picture. However, among all this basic profile information that you provide access to only your name and email address are collected and recorded by us for the purposes of your User Account creation and maintenance. You can review and manage the connection between the App and your Google account at any time via your Google account’s third-party connections page.Similarly, if you choose to register or sign in to your User Account via the “Continue with Apple” or “Continue with Facebook” option, you’ll be required to give Apple or Facebook permission to share some categories of your basic profile information (email, name, profile picture) to be linked with your User Account. You’ll have an opportunity to limit or control the permissions you give to Apple or Facebook both initially at the authorization stage and subsequently through the Apple or Facebook privacy and security settings.Note that you are solely responsible for maintaining theconfidentiality of your password used for logging in to yourUser Account. You are also responsible for all activities thatoccur under your User Account. You acknowledge and agree thatwe are not liable for any damages and/or losses that may occur asa result of someone else using your credentials to access yourUser Account (and/or data, files associated with your UserAccount) without your knowledge and express consent. You agree tonotify us immediately if you become aware of any unauthorized useof your User Account credentials, any other breach of securityrelating to your User Account or if you suspect anyunauthorized access and/or breach of security.Email address. Your email address may also be recorded and processed if you choose to provideitdirectly in the App’s Settings in order to use email functionality options.Files associated with your User Account. If you are signed in to your activeUser Account and use cloud storagefunctionality, you’ll be able to store, manage and synchronize on any device or platform (iOS, Android, Web)scannedfiles and documents you received using the App and/or other images, documents, files that you choose tocreate, import,upload to the App (hereinafter collectively referred to as “Files associated with your UserAccount”). All Filesassociated with your User Account are stored using the services of our cloud storage provider (Amazon Web Services,Inc.). Files associated with your User Account will be synchronized on any device orplatform (iOS, Android, Web)you might use for accessing such User Account. Note that if you choose and apply theoption “Delete Account” in thesettings of the App, all Files associated with your User Account stored in thecloud will bedeleted and you’ll no longer have an opportunity to restore them. After deletion of your User Account youwill onlyhave access to files kept locally on your device (i.e. to files not associated with your deleted Useraccount).Note that we do not access the contents of the Files associated with your User Account,you are the only person whocan exercise control over such files. In some exceptional cases we may carry out a check of your filesmetadata uponyour request (without access to the contents of files), if it is necessary for legitimate aims, such asidentifyingerrors, bug investigation, providing you with the technical support for the App services.Please also bear in mind that if you don’t have an active User Account, are not signed into your active UserAccount and, accordingly, don’t use the cloud storage functionality, all files that you upload, edit, savein the Appare stored locally on your device and inaccessible to us. This means that such files will not be stored in thecloudand/or on any of our cloud service provider servers, will not be synchronized on any device or platform asthey arenot associated with your User Account.Other User Account Details. In addition to your name, email address the following data related toyour User Account may beprocessed: your current cloud storage capacity, the amount of cloud storage space actually used, date ofUserAccount registration, subscription ID. All this information is kept in the App’s administration panel andprocessed forthe purposes of maintenance of your User Account and subscription (if applicable),providing you with high-qualitytechnical support, dispute settlement.Automatic deletion of inactive User Accounts with all associated data. In order to ensure the integrity of user base and provide the highest level of security, we have implemented an automatic account deletion approach with respect to inactive User Accounts. Your User Account is regarded inactive if the following two conditions are met simultaneously: (a) you have not signed in to your User Account for a continuous period of 12 (twelve) months; (b) you don’t have an active subscription and, consequently, free cloud storage is used. If your User Account is classified as inactive according to the above criteria, we will initiate the process of account deletion in accordance with our security protocols. To ensure that you are aware of this action, we will send you the corresponding notification via email at least 7 (seven) days before the scheduled User Account deletion. This email notification will serve as a reminder of your User Account deletion due to inactivity and provide you with an opportunity to sign in and secure your User Account and associated data. If you do not take any required action after receiving notification about scheduled User Account deletion within the prescribed period, your inactive User Account will be automatically deleted along with all Files associated with your User Account and other related data. Once deleted, all this information will be permanently removed from our systems with no possibility of restoring.Information about the files that the user stores in Google Drive service (processing is relevant and applicable only if the App supports the “Import files from Google Drive” function). If the corresponding functionality is available, you may choose to import your files from Google Drive directly to the App. To use this function, you’ll be required to activate connection of the App with Google Drive service. When you try to enable this connection within the App, you’ll be prompted to enter your Google account sign-in credentials and be asked for permission to see and download your Google Drive files. Once you grant this permission, the App will have access to the up-to-date list of files that you store in Google Drive service. The App access and processing of information about the list of files you store in Google Drive service is necessary solely for the purpose of providing you with the “Import files from Google Drive” function, i.e. in order to enable you to select and import your files from Google Drive service directly to the App. Bear in mind that the above-described App access to the up-to-date list of files that you store in Google Drive service does not include human access to the content of such files, which means that you are the only person who can manage and exercise full control over them. You may enable or disable the connection of the App with Google Drive service at any time via the App. If you disconnect Google Drive in the App, you won’t be able to import files from your Google Drive directly to the App. Additionally, you can always review and manage connection of the App with Google Drive service via your Google Account’s third-party connections page.User Content related to the AI features. If you use AI-powered features available within the App, certain content may be shared with our AI service providers for the sole purpose of providing and maintaining these features. Our AI service providers do not use your content for training, improvement or development of their models. Content is typically retained for a limited period (usually up to 30 days) for service provision and abuse identification purposes, after which it is removed from the provider’s systems, unless legally required to be retained longer.Note that it is strictly prohibited to enter, provide, generate via the App, use, distribute or otherwiseexploit any content in a way that compromises or violates the privacy of others. Youare solely responsible for non-infringement of third party rights when you use the App or AI-powered features.Data that may be sent to conversion services. In some cases in order to support document conversion functions in the App (for example, to convert DOC to JPG/PDF, XLS to JPG/PDF, PPT to JPG/PDF), we may use third party conversion services. When such services are used for conversion of your files, such files are transiently processed using automated methods only for the purposes of rendering conversion services. Service providers do not access the contents of your files while such files are processed and no persistent storage is utilized. All your files processed via conversion services are deleted automatically in service provider systems right after or within a reasonable time after the conversion is completed.Contact Information (i.e. name, e-mail address, as well as any other content included in theemail) which you may fillin by yourself when you contact us via email. We collect, store and process yourContactInformation using the services of our cloud storage provider (Amazon Web Services, Inc.). We may use suchinformationsolely in order to respond effectively to your inquiry, fulfill your requests, send you communications thatyou requestand perform the requested services.Information That Is Processed AutomaticallyIf you use the App designed for iOS devices, at the first launch of such App you’ll be asked forpermission toaccess your Identifier for Advertisers (IDFA) for tracking purposes via special App Tracking Transparency(ATT) alertdemonstrated to you. Then you’ll have an opportunity to turn off or turn on permission to track your activityacrossother companies’ apps and websites at any time via Privacy & Security settings on your device (check Section VIII ofthis Privacy policy for more details).Additionally, when you use the App, some information about your device and your user behavior may beprocessedautomatically on the grounds of our legitimate interests in improving our App and giving ourusers the best experience.All this information is generally non-personal, i.e. it does not, on its own, permit direct association withanyspecific individual, and we may access it only in aggregated form. We use third-party automatic dataprocessingtechnologies (advertising and/or analytics tools) to analyze all this information sent by your device via theApp. Someintegrated advertising and/or analytics tools launch automatedprocessingof your personal data, including profiling, which means any form of automated processing of personal data usedtoevaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning yourpersonalpreferences, interests, behavior, location or movements.The following list describes the categories of data that may be processed automatically and shared withthird-party advertising and/or analytics tools as described above:

  • Device Details. When you use a mobile deviceto access the App, some detailsabout your device are reported, including “device identifiers”.Device identifiers are small data files or similar data structuresstored on or associated with your mobile device, which uniquelyidentify your mobile device (but not your personality). Deviceidentifier enables generalized reporting or personalized contentand ads by the third parties.

What data can be processed:

  • ➜Information about the device itself: type of your device, typeof operating system and its version, model and manufacturer,screen size, screen density, orientation, audio volume andbattery, device memory usage.
  • Information about the applications. Name, API key(identifier for application), version, properties of the App canbe reported for automated processing and analysis. Some servicesalso record the list of applications and/or processes which areinstalled or run on your device.
  • Cookies and similar technologies. When you usethe App, cookies and similar technologies may be used (pixels, webbeacons, scripts). A cookie is a text file containing smallamounts of information which is downloaded to your device when youaccess the App. The text file is then sent back to the server eachtime you use the App. This enables us to operate the App moreeffectively. For example, we will know how many users accessspecific areas or features within our App and which links or adsthey clicked on. We use this aggregated information to understandand optimize how our App is used, improve our marketing efforts,and provide content and features that are of interest to you. Wemay ask advertisers or other partners to serve ads or services tothe App, which may use cookies or similar technologies.
  • Log file information. Log file information isautomatically reported each time you make a request to access theApp. It can also be provided when the App is installed on yourdevice. When you use our App, analytics tools automatically recordcertain log file information, including time and date when youstart and stop using the App, and how you interact with the App.
  • Ad-related information. The following data mightbe reported about the ads you can view: the date and time aparticular ad is served; a record if that ad was “clicked” or ifit was shown as a “conversion” event; what the ad offer is about;what type of ad it is (e.g., text, image, or video); which adplacement is involved (where the ad offer is displayed within theApp); whether you respond to the ad.
  • In-app events. When you use our App, analyticstools automatically record your activity information (taps,scrolls, screens you visited in the App, tutorial steps, levelingup, payments, in-app purchases, custom events, progression events,method of limiting the processing of user data).
  • Subscription details: information about yoursubscriptions in the App (subscription ID, subscription start date, its duration,payment receipts); information about the User Accounts that you createwhen you get registered (email, date of registration, etc.); loginhistory (sorted by dates and devices) and the number of currentlyconnected active devices; information about promo codes that youused for accessing premium features of the App.

Information provided automatically to advertising or analytics toolsdoes not generally come to our control, therefore we cannot beresponsible for processing such information. Please mind that someservices are engaged in personal data profiling and may obtaininformation related to your personality and/or your device by usingtechnologies that do not belong to our scope of responsibility. Incase when your user ID is linked to your Facebook / Google / Appleaccount, Facebook / Google / Apple may use your device informationin association with categorized data that were already recorded inits databases (e.g. your age, gender or other demographicindication). We do not control, supervise or stand surety for howthe third parties process your personal data, that might becollected by their own means (not through our App). Any informationrequest regarding the disclosure of your personal information shouldbe directed to such third parties (see Section IV).Payment InformationIf you purchase a subscription in the App (for iOS or Android devices), the respective AppStore(Apple App Store or Google Play Store) is responsible for billing, processing and charging for all your In-AppPurchases, handles your payment information and keeps it absolutely safe and secure. This payment informationisprocessed by the corresponding App Store as part of the performance of the contract between you and us. Wecannot accessor use your credit or debit card information when you purchase a subscription in the App.You mayaccess the applicable In-App Purchase rules and policies directly from the App Stores.Information that you may submit for improving the Algorithms of the App

  • User Photos for improving machine learning (ML) algorithms. For the purpose of analyzingthe scope of certain technicalparameters we suggest you help us with the reference material so that the processing technologies of our Appcould bereformed, smartened and smoothed. Your collaboration is crucial for us when we aspire to enhance our methodsand improvethe services. In this regard you have an option to allow us to use your in-app photos to improve ourdetection and recognition algorithms. To grant us the relevant permission, set the “Improve AITools”/”Improverecognition” or analogous option in the Settings of the App to the “on” position. Once the relevantpermission isgranted, your in-app photos that you send us for improving ML algorithms will be stored on the servermaintained by ourcloud storage provider. These photos will be used for training purposes only and are deleted after thepurpose ofprocessing (improving ML algorithms) is fulfilled. You can always enable or disable the collection andprocessing ofyour in-app photos for improving ML algorithms in the App’s Settings.

Email communicationsIf you already have an active User Account or if you choose to create a new User Account in the App, we may use the email address associated with your User Account and some other accompanying data to send you the following types of email communications:

    • operational/transactional email messages;
    • marketing email messages.

Operational/transactional email messages. Operational/transactional email messages are defined as email communications that are necessary and essential for the following purposes: a) the proper functioning of the App; b) the performance of our contractual and/or legal obligations to users; c) the completion of a transaction (if applicable). Examples of operational/transactional email messages that you may receive are the following: User Account setup confirmation; confirmation codes for User Account setup and password reset; notifications about upcoming User Account deletion (due to inactivity of User Account for over a year), important security notifications and alerts; legal and compliance notifications; purchase confirmations, receipts, invoices (may be applicable for transactions processed with our direct participation); other messages that may be crucial for our users. We rely on the following legal grounds for processing of your email address and other related data for the purpose of sending you operational/transactional messages: (a) contractual necessity; (b) our legitimate interests in providing our users with high-quality and secure products (App) that correspond to the declared functionality; (c) compliance with a legal obligation to which we are subject. Transactional/operational email messages are non-marketing in nature and are sent to you in order to provide essential information, confirmations, notifications or alerts related to your User Account, transactions, or your interaction with the App. For this very reason operational/transactional email messages that you may receive do not contain an unsubscribe link.Marketing email messages. Marketing email messages are understood as email communications that are promotional in nature and are designed to achieve the following goals: a) effective communication and providing more value to our users; b) sending timely email campaigns and boosting user retention; c) increasing user awareness about all available up-to-date features and functionalities of the App; d) learning more about our audience and their real needs. Examples of marketing email messages may include: newsletters that inform users about functionality changes, new features of the App; special promotional offers, including offers related to available subscription plans; useful notes, articles and other accompanying materials containing insights and tips on how to use the App effectively and with maximum benefits; surveys and feedback requests. To be able to send only those marketing email messages that are likely to be of interest to our users, more relevant to their needs and preferences, in addition to user’s email address we also process some additional categories of information, such as user’s User Account registration method, information about the version of the App used, the date of User Account registration, the current number of Files associated with user’s User Account, user’s subscription details (hereinafter collectively referred to as “User and Event Properties”). When we process a user’s email address as well as User and Event Properties for the purpose of sending marketing email messages, we rely on our legitimate interests in providing valuable up-to-date information about our products and increasing awareness about user needs.Opt out. All users who are subscribed to receiving marketing email messages have the opportunity to opt-out at any time by using the resignation link available in each message received. The unsubscribe request of each user is honored within a reasonable period of time. Each user will also have an opportunity to opt out of receiving marketing email messages in advance when they Sign Up for a new User Account by choosing the relevant option on the Sign Up screen.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you withnew experiences. As part of this mission, we use your informationfor the following purposes:(a) To make our service available. We use Functional Information and Information ThatIs Processed Automatically to provide you with all requested services.(b)To improve, test and monitor the effectiveness of ourApp. We use the Information That Is Processed Automatically to better understand user behaviorand trends, detect potential outages and technical issues, to operate, protect, improve, and optimize ourApp.(c)To provide you with interest-based (behavioral) advertising or other targeted content. Wemay use the Information That Is Processed Automatically for marketing purposes (to show ads that may be ofinterest to you based on your preferences). We provide personalized content and information to you, whichcan include online ads or other forms of marketing.(d) To communicate with you. We use your email and other information we have tocommunicate with you through different types of email communications, inter alia, to send you marketing notifications, receive your feedbackabout our App experience, and let you know about our policies and terms. We also use your information thatyou provide to us via email for the purposes of processing andresponding (if necessary) to your requests, receiving your comments or suggestions about the operation ofthe App or on other matters.(e)To prevent fraud and spam, to enforce the law. We really want our App to be free of spamand fraudulent content so that you feel safe and free. We may use your information to prevent, detect, andinvestigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarksand enforce our Terms of Use.If any new purposes for processing your personal data arise we will let you know we start to processinformation on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the waysthat are described in this Privacy policy. We adhere to the U.S.Digital Advertising Alliance’s Self-Regulatory Principles for theMobile Environment.Please note that while integrating external services we choose thirdparties that can assure they apply all necessary technical andorganizational measures to protect user personal data. However, wecannot guarantee the security of any information transmitted from usto any such third party. We are not responsible for any accidentalloss or unauthorized access to your personal data through a fault ofthird parties.We will not rent or sell your personal data to any third parties,but we may share your information from tools like log files,device identifiers and location data, with third-party organizationsthat provide automatic data processing technologies for the App. Wedo not control or influence these third parties’ trackingtechnologies or how they may be used.We may also share certain information such as cookie data withthird-party advertising partners. This information allowsthird-party ad networks, inter alia, to deliver targetedadvertisements that they believe will be of most interest to you.We may engage the following third-party service providers in orderto provide us with necessary infrastructure for delivery andimprovement of our services:

Entity name Services performed Entity location Link to Privacy Policy
Amazon.com, Inc., Amazon Web Services, Inc. and affiliated companies Cloud storage provider U.S.A./other entities (depending on entity) https://aws.amazon.com/privacy/
Apple Inc. Cloud storage provider (for iOS devices). Authorization tool U.S.A. https://www.apple.com/privacy/
Google LLC Authorization tool. Google Drive API services provider (may be used for support of “Import files from Google Drive” function, if such function is available) U.S.A. https://policies.google.com/privacy
Facebook (Meta Platforms, Inc.) Authorization tool U.S.A. https://www.facebook.com/privacy/explanation

In case you want to learn more about these services and theirprivacy options (including opt-out) please consult the correspondentwebsites and privacy policies. We are not responsible for any usageof your personal data by the abovementioned third parties inviolation of our instructions.The App may contain links to third-party websites / services or youmay access the App from a third-party site. We are not responsiblefor the privacy practices of these third-party sites or serviceslinked to or from our App, including the information or contentcontained within them.We may disclose your personal information if it is needed forobjective reasons, due to the public interest or in other unforeseencircumstances:

  • as required by law;
  • when we believe, in good faith, that disclosure is necessary toprotect our rights, protect your safety or the safety of others,investigate fraud, or respond to a government request;
  • if we are involved in a merger, acquisition, or sale of all or aportion of our assets, you will be notified via email and/or aprominent notice in our App of any change in ownership or yourpersonal information usage, as well as any choices you may haveregarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide the App to our usersaround the world.We and third-party organizations that provide automatic dataprocessing technologies for the App or our third-party advertisingpartners may transfer the automatically processed information acrossborders and from your country or jurisdiction to other countries orjurisdictions around the world.If you are located in the European Union or other regions with lawsgoverning data processing that may differ from laws in other jurisdictions, please notethat we may transfer information, including personal information, toa country and jurisdiction that does not have the same dataprotection laws as in your jurisdiction.This means that your personal information can be transferred to athird country, a territory or one or more specified sectors withinthat third country, or to the international organization where dataprotection and confidentiality regulations may not provide the samelevel of protection of personal data as your country does.We try to make sure that the recipient of any personal data providesa proper protection of the personal data received, in accordancewith the current legislation on the protection of such information.By using the App, you agree that we may transfer your personal datato any third country, a territory or one or more specified sectorswithin that third country, or to the international organization.For the purposes of data storage, we recourse to the services of thehosting organizations. We take your privacy seriously and,therefore, encrypt your personal data – if possible – before sendingit to the hosting organizations for the purposes of its storage.Please note that we cooperate only with those hosting organizationsthat have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as isnecessary for performing the functional service of the App and tocomply with our legal obligations. If you no longer want us to useyour information that we physically access and store, you canrequest that we erase your personal information and close yourUser Account.However, some data may still be stored for a certain time period(but no longer than the storage purpose requires) if information isnecessary to comply with legal obligation (taxation, accounting,audit) or in order to maintain safety and data backup settings,prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regardingyour personal information. You have the following options inrelation to your personal information that was collected:

  • Data Access and Portability. You can requestcopies of your personal information.

To exercise any of the rights described above, you can contact usby email ksusha.kha.apps@gmail.com. Please bear in mind that we ensurethe above mentioned rights only with respect to the information thatwe physically access and store.You also have the right to lodge a complaint with your local data protection or a supervisory authority if youreasonably believe that your rights under applicable data protection laws have been breached. Please note thatwhen you exercise your right to lodge a complaint with your local data protection or a supervisory authority,you may be required to provide additional information and support your complaint with sufficient objectiveevidence. By lodging a complaint you agree to provide sufficient explanation as to what you believe impairedyour rights. Additionally, in some cases prior to lodging a complaint with your local data protection or asupervisory authority, you may be required to send your initial claim directly to us and ask forclarifications if necessary.When your personal information is processed automatically you mayobject to such processing in some circumstances. Where your personalinformation is processed for direct marketing purposes, you may askto cease processing your data for these direct marketing purposes.In order to exercise your right please contact the third partyservices listed in the Section IV of this Privacy policy to learnhow you can object to processing your data. Most of them have clearinstructions on their privacy pages, functional API or otheroptions.If you are located in the European Union, you may address ourrepresentative when you have questions on privacy issues:Privacy Contact: ksusha.kha.apps@gmail.com

VIII. HOW TO OPT OUT

How to delete your User AccountIf you no longer want the Files associated with your User Account to be stored in thecloud storage of the App, you may choose to delete your User Account. For deletion ofyour User Account, please follow the instructions in the App settings.As a result, all the Files associated with your User Account willbe deleted permanently with no possibility of restoring.Opt-out of marketing trackingYou can manage your activity tracking permissions. Inter alia, if you don’t want third-party service providersto use the personalized ads on the basis of your interests please follow the instructions below:

  • For iOS, iPadOS devices: go to Settings > Privacy & Security (or “Privacy” in earlierversions of iOS, iPadOS) > Tracking, then tap to turn off or turn on permission to track for a specific app.

You can also control whether apps can ask for permission to track your activity. If you don’t want to beasked for your permission, or do not want apps to access your device’s Advertising Identifier, go toSettings > Privacy & Security (or “Privacy” in earlier versions of iOS, iPadOS) > Tracking and then disablethe “Allow Apps to Request to Track” switch. If you turn off “Allow Apps to Request to Track”, you won’t getprompts from apps that want to track your activity. Each app that asks for permission to track while thissetting is turned off will be treated as if you tapped “Ask App Not to Track”.Please find additional information here: https://support.apple.com/en-us/HT212025 or in theSettings > Privacy & Security (or “Privacy” in earlier versions of iOS, iPadOS) > Tracking section on yourdevice.If you want to disable Apple’s ad targeting, go to Settings > Privacy & Security (or “Privacy” in earlierversions of iOS, iPadOS) > Apple Advertising, then set the “Personalized Ads” switch to the “off” position.Please find additional information here: https://support.apple.com/en-us/HT202074

  • For Android devices: you can manage advertising preferences in your device settings. Go to Settings > Google > Ads, then you can opt out of ads personalization.

You can also visit https://youradchoices.com for the same purpose.Please mind that when you opt out of certain interest based advertising, you may still continue to receivecontextual ads based on other non-personal information, such as ads related to the content of other digitalproducts you are using.Opt-out of Location Data ProcessingYou can manage, control when and which apps on your device have access to your device location data. For thispurpose see the instructions below.

  • iOS, iPadOS devices: you can turn Location Services on or off for all apps on your device via the Settings >Privacy & Security (or “Privacy” in earlier versions of iOS, iPadOS) > Location Services. If you want toturn off or otherwise change access mode to Location Services data for a specific App, then go to theSettings > Privacy & Security (or “Privacy” in earlier versions of iOS, iPadOS) > Location Services > selectthe applicable app and set the preferred option with respect to “Allow location access” status (“Never”/”AskNext Time Or When I Share”/”While Using the App”/”Always”/other available option). Please see additionalinformation here: https://support.apple.com/en-us/102515
  • Android devices: you can control location permissions in your device settings. Go to Settings > Location, and manage which apps have access to your location.

IX. SECURITY

The security of your personal information is highly important to us.We follow generally accepted industry standards to protect thepersonal information submitted to us, both during transmission andonce we receive it.We take reasonable and appropriate measures to protect personalinformation from loss, misuse and unauthorized access, disclosure,alteration and destruction, taking into account the risks involvedin the processing and the nature of the personal information.We implement appropriate technical and organizational measures,which are designed to implement data-protection principles, such asdata minimization, in an effective manner and to integrate thenecessary safeguards into the processing. We seek your personal datato be encrypted with proper and strong encryption algorithms,including hashing where possible.Unfortunately, no method of transmission over the Internet, ormethod of electronic storage, is 100% secure. We do our best toprotect your personal data, nevertheless, we cannot guarantee itsabsolute security. In the event that your personal information iscompromised as a breach of security, we will promptly notify you incompliance with applicable law.If you have any questions about the security of our App, you can contact us by email ksusha.kha.apps@gmail.com.

X. CHILDREN’S PRIVACY

Our App is not intended for children. Therefore, we do not knowingly or intentionally collect or solicit anypersonal information from children. For the purposes of this Section X the terms “child” and/or “children” inthe context of data processing activities may be interpreted on a case-by-case basis as prescribed byapplicable data protection laws. No one who is considered a “child” under applicable data protection laws isallowed to directly provide any personal information to the App.As a general rule we consider a person under the age of sixteen (16) to be regarded as “a child” until we havelegal grounds to conclude that a person under sixteen (16) should be treated as an adult as per provisions oflocal data protection rules or based on the parent authorization provided to us directly.Solely the holders of parental responsibility are liable for preventing their children from providing personalinformation via the App without relevant verifiable parental consent. If we learn that we have collectedpersonal information from a child without verification of parental consent, we will erase that information asquickly as possible. If you reasonably believe that we might have any information from or about a child, or achild has directly provided us with personal information via the App without verifiable parental consent,please contact us.

XI. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.Whenever we change this Privacy policy, we will post those changesto this Privacy policy and other places that we considerappropriate. Additional forms of notice of modifications or updatesas appropriate under the circumstances may be provided to you.

XII. HOW TO CONTACT US

If you have any questions about this Privacy policy, please feel free to contact us by email ksusha.kha.apps@gmail.com.Developer: Nadezhda BelozerovaEmail: ksusha.kha.apps@gmail.comJurisdiction: ThailandCopyright © 2026 Nadezhda Belozerova