Privacy Policy

Last updated: June 2, 2026

This Privacy Notice applies to Luo Yu (individual developer) ("we," "us," or "our") and explains how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Questions or concerns? Reading this notice will help you understand your privacy rights and choices. We are responsible for decisions about how we process your personal information. If you do not agree with our policies and practices, please do not use our Services. Contact us at divisionfinks@hotmail.com.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find more details in the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more in Personal information you disclose to us.

Do we process sensitive personal information? We do not process sensitive personal information.

Do we collect information from third parties? We do not collect information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason. Learn more in How we process your information.

When and with whom do we share personal information? We may share information in specific situations described in this notice. Learn more in When and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission or storage technology can be guaranteed 100% secure. Learn more in How we keep your information safe.

What are your rights? Depending on where you live, applicable privacy law may give you certain rights regarding your personal information. Learn more in Your privacy rights.

How do you exercise your rights? The easiest way is to email us at divisionfinks@hotmail.com. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more? Review the full notice.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on?
4. When and with whom do we share personal information?
5. How long do we keep your information?
6. How do we keep your information safe?
7. What are your privacy rights?
8. Controls for do-not-track features
9. Do US residents have specific privacy rights?
10. Do we make updates to this notice?
11. How can you contact us about this notice?
12. How can you review, update, or delete data we collect?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you contact us, participate in activities on the Services, or otherwise interact with us.

Sensitive Information. We do not process sensitive information.

Payment Data. If you make purchases, payment data may be processed by Apple. See https://www.apple.com/legal/privacy/. All in-app purchases and subscriptions use Apple StoreKit. Apple processes and stores payment information; we cannot access or store your payment details. Manage subscriptions in device Settings.

Application Data. If you use our app, we may collect the following when you grant permissions:
We do not integrate third-party advertising or analytics SDKs. Information above is used to operate the app, troubleshoot issues, and support voluntary feedback.

2. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We may process your personal information when necessary to protect vital interests, such as to prevent harm.

3. What legal bases do we rely on?

In short: We process personal information only where we have a valid legal basis under applicable law, such as consent, legal obligations, or vital interests.

If you are in the EEA or UK, we may rely on consent, legal obligations, or vital interests. You may withdraw consent by contacting us (see Contact us).

If you are in Canada, we may process information with your consent or as permitted by law. You may withdraw consent at any time.

4. When and with whom do we share personal information?

In short: We may share information in specific situations, such as business transfers.

5. How long do we keep your information?

We keep personal information only as long as needed for the purposes in this notice, unless a longer period is required by law. When no longer needed, we delete or anonymize it, or securely isolate it until deletion is possible.

6. How do we keep your information safe?

We use appropriate technical and organizational measures designed to protect personal information. However, no method of transmission or storage is 100% secure. Use our Services in a secure environment.

7. What are your privacy rights?

Depending on your location (EEA, UK, Switzerland, Canada, or certain US states), you may have rights to access, correct, delete, or restrict processing of your personal information. Contact us using the details in section 11. EEA/UK residents may lodge a complaint with a supervisory authority.

Withdrawing consent: Where we rely on consent, you may withdraw it at any time by contacting us.

8. Controls for do-not-track features

Most browsers and mobile systems offer a Do-Not-Track (DNT) setting. There is no uniform standard for recognizing DNT signals; we do not currently respond to DNT browser signals.

9. Do US residents have specific privacy rights?

In short: Residents of certain US states may have rights to know, access, correct, delete, and opt out of certain processing. See section 11 to exercise rights.

Categories of personal information we collect

In the past 12 months we have not collected categories of personal information listed under US state privacy laws for this app (identifiers, commercial information, internet activity, geolocation, etc.). Payment data is handled by Apple, not stored by us.

We have not sold or shared personal information for cross-context behavioral advertising in the past 12 months.

10. Do we make updates to this notice?

In short: Yes, we will update this notice as needed to stay compliant with relevant laws. The updated version will be indicated by a revised date at the top.

11. How can you contact us about this notice?

Email: divisionfinks@hotmail.com

Luo Yu (individual developer)
Lane 58, Lvxiao Road
Room 801, Building 9
Shanghai, Shanghai 201203
China

12. How can you review, update, or delete data we collect?

Depending on applicable laws, you may request access, correction, or deletion of personal information we maintain. Email divisionfinks@hotmail.com to submit a request.