PRIVACY POLICY

Last modified: March 2025

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

Appenvision LTD (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use our apps software application for mobile devices (the “App”, “our App”).

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more 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 our apps or website (“Users”).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE OUR APPS OR WEBSITE YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:

the categories of personal information that is processed;
the categories of sources from which personal information is obtained;
the purpose for processing of user personal data;
the list and categories of third parties with whom we may share your personal information;
the specific pieces of personal information that we might have obtained about a particular user provided that the data provided in the request is reliable enough and allows to identify the user.

Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

OPT-OUT OPTIONS

If you don’t want us to process your personal information any more please contact us support@appenvisions.com In most cases there is no way to maintain the App’s further operating without functional data therefore you will be advised to remove the Apps from your device.

If you don’t want us to share device identifiers and geolocation data with service providers please check your device settings to opt out.

REQUESTS

To submit a verifiable consumer request for access, portability or deletion of personal data please contact us support@appenvisions.com. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California”.

When submitting a verifiable request, you should be ready to:

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

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

EQUAL RIGHTS

Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

SALE OF DATA

We 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 Information

We ask for and process the following information when you use the Apps. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the Apps and perform the requested services.

User Content (i.e. the text you enter into the message field, PDF-files you attach and send to the Apps, as well as any text, other content generated by AI via the Apps).
Contact Information (name, e-mail address, as well as any other content included in the email).
Face Data: When using our AI Avatar App, you may upload up to 10 photos of yourself. We do not collect or retain any face data; instead, these photos are securely transmitted to the Astria service for processing. Your uploaded photos will be stored on our servers for a period of 30 days after upload and then deleted.

Information That Is Processed Automatically

On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our Apps (Identity For Advertisers).

Payment Information

Our e-commerce provider (Apple/Google) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our Apps and provide you with new experiences. As part of this mission, we use your information for the following purposes:

To make our service available.
To improve, test and monitor the effectiveness of our Apps.
To provide you with interest-based (behavioral) advertising or other targeted content.
To communicate with you.
To prevent fraud and spam, to enforce the law.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.

Entity name	Services performed	Entity location	Link to Privacy Policy
AdJust	Analytics service provider	U.S.A.	Privacy Policy
Applovin	Ad management/analytics service provider	U.S.A.	Privacy Policy
AppsFlyer Inc.	Analytics service provider	U.S.A.	Privacy Policy
Firebase (Google LLC)	User authentication, analytics and marketing service provider	U.S.A.	Privacy Policy
OpenAI, L.L.C.	AI-generated content provider	U.S.A.	Privacy Policy
Astria, Inc.	Fine-tuning API provider	U.S.A.	Privacy Policy

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our Apps to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for our Apps or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the Apps and to comply with our legal obligations.

VII. EXERCISING YOUR RIGHTS

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

Data Access and Portability.
Change or Correct Data.
Data Retention and Deletion.
Restriction of Processing.
Exercising the right to know about data sharing.
Lodge a complaint.

VIII. HOW TO OPT OUT

Opt-out of marketing tracking

You can manage your activity tracking permissions. Inter alia, if you do not want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:

For Apple: Go to Settings > Privacy & Security (or “Privacy” in earlier versions of iOS) > Tracking, then tap to turn off or turn on permission to track for a specific app.
For Google: Go to Settings > Privacy > Ads, then you can choose either to “Reset advertising ID” or to ”Delete advertising ID”.

IX. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

X. CHILDREN’S PRIVACY

Our Apps is not intended for children under the age of eighteen (18). Therefore, we do not knowingly collect or solicit any personal information from children under eighteen (18).

XI. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

XII. HOW TO CONTACT US

If you have any questions about this Privacy policy, please feel free to contact us support@appenvisions.com.