Privacy Policy

Last updated: 2025-05-28

This Privacy Policy explains how 11089439 Canada Corporation (“we”, “us”, or “our”) collects, uses, and protects your information when you use our mobile applications available on the Apple App Store (the “Apps”). This policy complies with applicable privacy laws including PIPEDA (Canada), GDPR (EU), and CCPA (California).

1. What Information We Collect

We collect the following categories of information:

• Apple ID purchase receipts - Transaction data from in-app purchases and subscriptions
• In-app usage & crash logs - App Store Connect Analytics data including app performance metrics
• Support email content - Communications when you contact us for help
• Device & OS version - Technical information for compatibility and debugging
• Account information - Name and email address if you create an account
• App usage data - Features used, time spent, and interactions within the app

2. Why We Collect This Information (Lawful Basis)

We collect and process your information to deliver our services, diagnose technical issues, respond to support requests, and comply with legal and tax obligations. Our lawful bases for processing include: contract performance (to provide the Apps), legitimate interests (to improve our services), legal obligations (tax and regulatory compliance), and consent (where applicable).

3. Sharing with Third Parties

We share your information only with the following trusted service providers under data processing agreements:

• Apple Inc. - For in-app purchases, crash logs, and App Store distribution
• AWS Canada - Cloud infrastructure hosting
• Firebase (Google) - Analytics and app performance monitoring

We never sell your personal data to third parties. All processors are contractually bound to protect your information.

4. International Data Transfers

Some of our service providers operate in the United States. When we transfer data internationally, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Contractual safeguards ensuring adequate protection
• Your explicit consent where required by law

5. Data Retention Periods

We retain your information for the following periods:

• Crash logs: 24 months
• Purchase invoices: 7 years (tax requirements)
• Support tickets: 2 years
• Account data: Until account deletion + 30 days
• Analytics data: 14 months

6. Security Measures

We protect your information using industry-standard security measures:

• TLS 1.3 encryption for data in transit
• AES-256 encryption for data at rest
• Least-privilege access controls
• Annual penetration testing
• Regular security audits and updates

7. Your Privacy Rights

Your rights depend on your location. To exercise any rights, contact privacy@appalect.com:

8. Children's Privacy

Our Apps and website are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn we have collected such information, we will delete it promptly.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of our Apps after changes constitutes acceptance of the updated policy. We will notify you of material changes through the App or by email.

10. Additional Provisions

10.1 AI and Machine Learning

Our Apps use artificial intelligence to enhance your experience. Where possible, AI processing occurs on your device. When cloud processing is necessary, we use aggregated or anonymized data.

10.2 Regional Specific Information

EU Users: Our legal bases under GDPR are contract performance, legitimate interests, legal obligations, and consent. EU Representative details will be provided if required.

US Users: We do not respond to Do Not Track signals. California residents may request information about third-party disclosures under the Shine the Light law.

11. Contact Us

For privacy questions or to exercise your rights, contact: