Privacy Policy

1. Information We Collect

Information You Provide to Us

We may collect information that you voluntarily provide, including:

• Contact information — such as your name and email address, when you contact us for support, submit feedback, or communicate with us
• Communication data — the content of messages you send to us, including support requests and feedback

Information Collected Automatically

When you use the Services, certain information is collected automatically, including:

• Device information — device type and model, operating system and version, app version, unique device identifiers, and device settings
• Usage data — features used, screens viewed, user interactions, timestamps, session duration, and in-app events
• Subscription and transaction data — subscription status, purchase history, transaction identifiers, and billing period information (payment processing is handled by the applicable platform provider)
• Advertising identifiers — such as Apple's Identifier for Advertisers (IDFA), where permitted by your device settings and applicable law
• Network and connection data — IP address, internet service provider, browser type (for website visits), and general network information
• Approximate location — derived from your IP address (we do not collect precise GPS location)
• Performance and diagnostic data — crash reports, error logs, performance metrics, and diagnostic information

Information from Third Parties

We may receive information about you from third parties, including:

• Platform providers — such as Apple, regarding your subscription status and app installation
• Advertising and attribution partners — conversion data, campaign performance metrics, and attribution information related to how you discovered or installed the app
• Analytics providers — aggregated or de-identified usage statistics and performance metrics

2. On-Device Processing

We want to be transparent about what stays on your device and never reaches our servers:

• Your photos and videos are never accessed, viewed, collected, uploaded, or transmitted by us
• Your photo library metadata (dates, locations, faces, captions, or other EXIF data) is not collected or transmitted by us
• Your organizational decisions (e.g., keep or delete) are stored locally on your device only
• Photo analysis features — including duplicate detection, similarity grouping, and related processing — are performed entirely on your device
• We do not use facial recognition or process biometric data

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and maintain the Services — deliver core functionality, manage your subscription, and ensure the Services operate correctly
• Improve and develop the Services — analyze usage patterns, identify trends, and develop new features and functionality
• Advertising measurement and attribution — measure the effectiveness of our advertising campaigns and understand how users discover and install the app
• Personalization — tailor your experience, including the timing and presentation of subscription offers
• Diagnostics and performance — identify and fix crashes, bugs, and technical issues
• Communications — respond to your inquiries, provide support, and send service-related notifications
• Safety and security — detect and prevent fraud, abuse, and other harmful activity
• Legal compliance — comply with applicable laws, regulations, legal processes, or governmental requests

Legal Bases for Processing (EEA/UK Users)

If you are in the European Economic Area or United Kingdom, our legal bases for processing your information include:

• Contract — processing necessary to perform our contract with you (providing the Services)
• Legitimate interests — processing necessary for our legitimate business interests, such as improving the Services, preventing fraud, and measuring advertising effectiveness, where those interests are not overridden by your rights
• Consent — where you have given consent for specific processing activities (e.g., advertising identifier collection), which you may withdraw at any time
• Legal obligation — processing necessary to comply with applicable laws

4. How We Share Your Information

We may share your information in the following circumstances:

• Service providers — we share information with third-party service providers who perform services on our behalf, including subscription management, analytics, crash reporting, and infrastructure hosting. These providers are contractually obligated to use your information only for the purposes of providing services to us.
• Advertising and attribution partners — we may share device identifiers, advertising IDs, and conversion event data with advertising and attribution partners to measure the effectiveness of our advertising campaigns and understand user acquisition channels.
• Platform providers — information necessary for subscription processing and app distribution is shared with platform providers (e.g., Apple).
• Legal requirements — we may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, the safety of others, investigate fraud, or respond to a government request.
• Business transfers — in connection with, or during negotiations of, any merger, acquisition, sale of assets, financing, bankruptcy, or transition of all or a portion of our business, your information may be transferred or disclosed as part of such transaction.
• With your consent — we may share your information with third parties when you have given us explicit consent to do so.
• Aggregated or de-identified data — we may share aggregated or de-identified information that cannot reasonably be used to identify you.

5. Advertising and Attribution

We work with third-party advertising and attribution partners to measure the effectiveness of our advertising campaigns and to understand how users discover and install our app. These partners may collect or receive certain information, including:

• Device identifiers and advertising identifiers (e.g., IDFA)
• App installation and first-open events
• In-app conversion events (e.g., subscription starts)
• Campaign and ad interaction data
• IP address and approximate location

This information is used to attribute app installations to specific advertising campaigns, optimize ad delivery, and measure return on advertising spend. We also participate in Apple's SKAdNetwork for privacy-preserving ad attribution. Our advertising and attribution partners process this information in accordance with their own privacy policies.

You can limit ad tracking by adjusting your device settings. On iOS, go to Settings > Privacy & Security > Tracking and disable “Allow Apps to Request to Track.” You may also reset your advertising identifier in Settings > Privacy & Security > Apple Advertising.

6. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to collect information about your browsing activity. These technologies help us analyze website traffic, personalize content, and improve your experience.

Types of cookies we may use include:

• Essential cookies — required for the website to function properly
• Analytics cookies — help us understand how visitors interact with our website
• Advertising cookies — used to deliver relevant advertising and measure campaign effectiveness

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality. We honor “Do Not Track” (DNT) signals and Global Privacy Control (GPC) signals where required by applicable law.

7. Data Retention

We retain your information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

• On-device data — all locally stored data (decisions, preferences, cached content) is deleted immediately when you uninstall the app
• Support communications — retained for as long as necessary to resolve your inquiry and for a reasonable period thereafter for quality assurance and legal compliance
• Analytics and usage data — retained in identifiable form for no longer than 24 months, after which it is aggregated or deleted
• Third-party service providers — may retain data in accordance with their own data retention policies

We may retain certain information for longer periods where required by law, for legitimate business purposes (such as fraud prevention), or to resolve disputes.

8. Data Security

We implement commercially reasonable technical and organizational measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular security assessments.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You acknowledge that you provide your information at your own risk.

9. International Data Transfers

Your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that differ from those of your country of residence.

Where required by applicable law, we ensure that appropriate safeguards are in place for international data transfers, including standard contractual clauses approved by the European Commission or other mechanisms recognized under applicable data protection law. By using the Services, you acknowledge and consent to the transfer of your information as described in this section.

10. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. We are committed to honoring these rights in accordance with applicable law.

All Users

• Right to request access to information we hold about you
• Right to request correction of inaccurate information
• Right to request deletion of your information
• Right to withdraw consent where processing is based on consent

California Residents (CCPA/CPRA)

• Right to know what personal information is collected, used, shared, or sold
• Right to request deletion of personal information
• Right to correct inaccurate personal information
• Right to opt-out of the sale or sharing of personal information (we do not sell personal information)
• Right to limit the use and disclosure of sensitive personal information
• Right to non-discrimination for exercising your privacy rights

European Economic Area and United Kingdom Residents (GDPR/UK GDPR)

• Right of access to your personal data
• Right to rectification of inaccurate personal data
• Right to erasure (“right to be forgotten”)
• Right to restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interests
• Rights related to automated decision-making and profiling
• Right to lodge a complaint with your local data protection authority

Australian Residents

• Rights under the Privacy Act 1988 and the Australian Privacy Principles (APPs)
• Right to access personal information we hold about you (APP 12)
• Right to request correction of personal information (APP 13)
• Right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC)

Other U.S. State Residents

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with consumer privacy laws may have additional rights, including the right to access, correct, delete, and obtain a copy of personal data, as well as the right to opt out of targeted advertising, sale of personal data, and profiling. We honor these rights as required by applicable law.

How to Exercise Your Rights

To exercise any of these rights, contact us at sweep@ferrixlabs.com with the subject line “Privacy Request.” We will verify your identity and respond within the timeframe required by applicable law (typically 30-45 days). You may also designate an authorized agent to make a request on your behalf. We will not discriminate against you for exercising any of your privacy rights.

11. Opt-Out of Targeted Advertising

You may opt out of targeted advertising and ad tracking through the following methods:

• iOS device settings — go to Settings > Privacy & Security > Tracking and disable “Allow Apps to Request to Track”
• Advertising identifier — reset or limit your advertising identifier in Settings > Privacy & Security > Apple Advertising
• Contact us — email sweep@ferrixlabs.com with the subject line “Opt-Out of Targeted Advertising”

We honor Global Privacy Control (GPC) signals and “Do Not Track” (DNT) signals where required by applicable law. Opting out of targeted advertising does not mean you will no longer see ads; it means the ads you see may be less relevant to your interests.

12. Children's Privacy

The Services are not directed at children under the age of 13 (or 16 in the European Economic Area and United Kingdom). We do not knowingly collect personal information from children under these ages. If we become aware that we have collected personal information from a child under the applicable age without verified parental consent, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at sweep@ferrixlabs.com.

13. Third-Party Links and Services

The Services may contain links to third-party websites, services, or applications that are not operated or controlled by us. This Privacy Policy does not apply to any third-party services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services that you access through or in connection with the Services.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. If we make material changes, we will provide notice through the Services, on our website, or by other appropriate means. Your continued use of the Services after any changes take effect constitutes your acceptance of the updated Privacy Policy. The “Last Updated” date at the top of this page indicates when this policy was last revised.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Ferrix Labs Inc.

Email: sweep@ferrixlabs.com

For privacy-related requests, please include “Privacy Request” in your subject line. We aim to respond to all requests within 30 days, or within the timeframe required by applicable law.