App Privacy Policy

1. Scope of This Policy

This Privacy Policy applies to the mobile applications published by Turn Global (Pvt) Ltd ("we", "us", "our") under our developer accounts on the Apple App Store and Google Play (the "Apps"). It explains what data our Apps do and do not handle.

Our Apps are utility applications. We have designed them to work without requiring you to create an account or provide personal information to us.

2. We Do Not Collect Personal Data

We do not collect, sell, or share personally identifiable information. Our Apps do not ask for your phone number, contacts, precise location, or other personal identifiers in order to function.

If you choose to connect your Google account for Google Drive backup or sync, Google Sign-In shares your basic profile information (name and email address) with the App, as described in the Google Drive section below.

In Apps that show ads, the advertising software (SDKs) from Google AdMob and its mediation partners, built into those Apps, may collect certain device data directly. This is described in the Advertising sections below.

• No account or sign-up is required to use the core features of our Apps.
• We do not maintain user profiles or build advertising identities from your activity.
• We do not sell or rent any data to third parties.

3. On-Device Data and Google Drive

Most data our Apps work with, such as your settings, preferences, content, and files, is stored locally on your device and stays under your control. We do not have access to this data, and it is not transmitted to our servers.

Removing an App, or using your device or operating system controls, deletes the data associated with it on that device.

Where an App offers it, you may choose to back up, sync, or restore your App data using your own Google Drive account. This is optional and initiated by you. To connect, you sign in with Google, which shares your Google account's basic profile information (name and email address) with the App so it can show which account is connected and authorize access. The App accesses only the files it creates or that you select, and only to perform the backup, sync, or restore you request. This data is stored by Google in your Google Drive account, not on our servers, and we do not have access to it. Data stored in Google Drive is subject to the Google Terms of Service, the Google Drive Additional Terms of Service, and the Google Privacy Policy (https://policies.google.com/privacy). You can revoke an App's access to Google Drive at any time from your Google Account settings.

4. Device-to-Device Communication and Encryption

Where an App lets you communicate or share data between devices, it may use a server relay to pass that data along when a direct connection is not available. In most cases this data is end-to-end encrypted (E2EE), meaning it is encrypted on the sending device and can only be decrypted on the receiving device.

Because such relayed content is end-to-end encrypted, we cannot read it, and we do not retain it beyond what is necessary to deliver it between devices.

5. In-App Purchases

Some Apps offer in-app purchases, including premium upgrades and subscriptions. All purchases are processed entirely by the Apple App Store or Google Play. We do not receive or store your payment card details, billing address, or other payment information.

Purchases are tied to your Apple or Google account, so you can restore eligible purchases on your devices through the store's standard restore mechanism. Billing, renewals, and refunds are governed by the policies of the respective app store.

6. Advertising (Google AdMob)

Some Apps are free and supported by advertising. These Apps use Google AdMob, an advertising service provided by Google LLC, to display ads. AdMob mediation may also serve ads from third-party advertising networks, such as Unity Ads and others ("ad partners").

Ads are delivered by the Google Mobile Ads SDK and ad partner SDKs built into the App. These SDKs collect and process data directly under their own privacy policies; we do not receive data that identifies you personally, and we do not combine ad data with any other information about you.

Google's use of this data is described in the Google Privacy Policy (https://policies.google.com/privacy) and in "How Google uses information from sites or apps that use our services" (https://policies.google.com/technologies/partner-sites). Unity's practices are described in the Unity Game Player and App User Privacy Policy (https://unity.com/legal/game-player-and-app-user-privacy-policy). More information about AdMob is available at https://support.google.com/admob/answer/6128543.

7. Data Collected by Ad Partners

To serve, measure, and improve ads and to prevent fraud, Google and our ad partners may collect the following data from Apps that show ads:

• Device and advertising identifiers, such as the Android Advertising ID, App Set ID, Apple's Identifier for Advertisers (IDFA, only if you allow tracking), and Identifier for Vendors (IDFV).
• IP address, which may be used to estimate your general (not precise) location.
• Device information, such as device model, operating system version, language, screen size, and network type.
• Ad interactions, such as ad impressions, taps, video views, and App launches.
• Diagnostic data, such as crash logs and SDK performance data.

8. Personalized Ads and Your Choices

Ads may be personalized based on your device's advertising identifier and activity, or non-personalized, meaning they are based on general context such as the App and your approximate location rather than your past behavior. Non-personalized ads still use data for purposes such as frequency capping, aggregated reporting, and fraud prevention.

• iOS: Apps ask for your permission through Apple's App Tracking Transparency prompt before the IDFA is used for tracking. You can change this at any time in Settings > Privacy & Security > Tracking.
• Android: you can delete or reset your advertising ID, or opt out of ad personalization, in your device's Settings (usually under Google > Ads or Privacy > Ads).
• Google account: you can manage the ads Google shows you at https://myadcenter.google.com.
• Remove ads: you can stop all advertising by upgrading to the premium (ad-free) version of an App where it is offered.

9. Consent and Regional Privacy Rights

European Economic Area, United Kingdom, and Switzerland: before personalized ads are shown or ad data is stored on or accessed from your device, Apps ask for your consent through Google's User Messaging Platform, a consent management platform certified under the IAB Transparency and Consent Framework. You can accept or decline, and you can change or withdraw your choice at any time through the privacy settings option in the App. If you do not consent, you may still see non-personalized or limited ads.

United States: under some U.S. state privacy laws (such as the California Consumer Privacy Act), sharing device identifiers with ad partners for personalized advertising may be considered a "sale" or "sharing" of personal information. We do not sell personal information for money. You can opt out of personalized advertising using the device settings described above, through the App's privacy settings where offered, or by contacting us.

Depending on where you live, you may have the right to access, correct, delete, or restrict the processing of your personal information. Because we do not hold personal data about you, requests about ad data are best directed to Google or the relevant ad partner, but you are welcome to contact us and we will help where we can.

10. Analytics

We do not use analytics to identify you personally. Any analytics that occur are limited to aggregated or anonymized diagnostics, or are performed by our advertising partners under their own policies as described above. Platform-level crash and performance reporting may also be provided by Apple or Google under their respective terms.

11. Children's Privacy

Our Apps are not directed to children under the age of 13 (or the minimum age required in your jurisdiction), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can address it.

Ads in our Apps are not intended to be personalized for children. Where we know or are told that a user is a child, ad requests are configured so that Google and our ad partners treat them as child-directed and do not serve personalized ads.

12. Data Security

We apply reasonable technical measures appropriate to utility apps, including on-device storage and end-to-end encryption for relayed communications where applicable. No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date above. Continued use of an App after changes take effect constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this App Privacy Policy, contact:

• Email: support@turn.global
• Mail: Turn Global (Pvt) Ltd, 37 Main Street, Battaramulla, Colombo, Sri Lanka.