Privacy Notice for Apps

This Privacy Notice explains how Full Time Enterprise S.L. (“Full Time Enterprise”, “we”, “us”, or “our”) processes personal data in connection with the mobile applications published under our Apple Developer account and the services and features available within those applications.

This Privacy Notice applies when you download, install, access, or use any of our mobile applications, interact with features within the apps, contact us, or otherwise use our services.

Please note that not all of our applications process the same categories of personal data. Certain data processing activities described in this Privacy Notice apply only to specific applications or specific features within the applications. Where this is the case, it is indicated in the relevant sections below.

This Privacy Notice describes:

• what personal data we collect,
• how we collect it,
• for what purposes we use it,
• the legal bases for processing,
• how long we retain it,
• with whom we share it,
• whether we transfer it internationally,
• and your rights under applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

By using our applications, you acknowledge that your personal data may be processed as described in this Privacy Notice.

1) PURPOSES OF PROCESSING PERSONAL DATA

We process personal data for the following purposes:

a) Provision and operation of the applications and services

To provide, operate, maintain, and improve our mobile applications and their functionalities, including enabling app features, ensuring the proper functioning of the services, and maintaining app performance.

b) Technical support and user communications

To receive, manage, and respond to support requests, bug reports, technical issues, or other communications sent by users.

c) Maintenance, updates, and security

To maintain, update, troubleshoot, secure, and monitor our applications and services, including the detection, prevention, and resolution of technical incidents, fraud, misuse, or security issues.

d) Analytics and service improvement

To generate aggregated and anonymous statistical reports regarding the use of the applications, user activity, performance, and usage patterns, in order to improve our services, features, and user experience.

e) Device features access (such as camera or microphone)

Certain features within our applications may require access to device functionalities such as the camera, photo library, or microphone. Access to these features is always subject to your device permission settings, and you may grant or deny such permissions at any time through your device settings.

f) Compliance with legal obligations

To comply with applicable legal and regulatory obligations, respond to lawful requests from public authorities, and protect our legal rights.

g) Advertising, attribution, and campaign measurement

To support advertising-based monetization in certain applications, including the delivery of ads, measurement of ad performance, attribution of app installs or campaigns, fraud prevention, and related advertising or marketing analytics, where applicable and in accordance with your device settings, consent choices, and applicable law.

2) CATEGORIES OF PERSONAL DATA WE PROCESS

Depending on the application you use and the features you interact with, we may process the following categories of personal data:

a) Contact and communications data

Information you provide when you contact us, submit a support request, report a problem, respond to a survey or otherwise communicate with us, such as your name, email address, and the content of your message, where applicable.

b) User content and files provided through the app

Content you choose to upload, create, import, capture, edit, or otherwise submit through the application, including images, photos, prompts, text inputs, and other content processed through app features.

c) Images and face, or body, related visual data

In certain applications, including image editing or AI-powered creativity apps, we may process images that contain human faces, facial features, hairstyles, skin features, body shape, body proportions, clothing, tattoos, or other visual characteristics appearing in the content you upload, capture, or generate through the app. We process this visual data only to provide the relevant image editing, transformation, generation, enhancement, retouching, avatar, styling, or similar functionality requested by the user through the app.

d) Device and technical data

Information about the device and software used to access the application, such as IP address, device model, operating system, app version, language, time zone, crash reports, diagnostic data, and similar technical information.

e) Usage data

Information about how you interact with the application, such as app activity, feature usage, session information, screens viewed, interactions with in-app content, and similar usage events.

f) Location data

In some applications, we may process approximate location data or other location-related information where this is enabled by the relevant app feature, the device settings, or associated SDKs. Not all applications process location data.

g) Advertising and identifiers data

In some applications, particularly ad-supported apps, we may process advertising-related data and identifiers, such as advertising IDs, device identifiers, campaign attribution data, and information related to ad interactions, measurement, or anti-fraud activities. Not all applications use advertising or tracking technologies.

h) Purchase and transaction-related data

Where users purchase subscriptions or digital features through the Apple App Store or other authorized app marketplaces, we may process limited transaction-related information, such as subscription status, purchase validation data, entitlement status, and similar purchase-related records. We do not collect or store full payment card details.

i) Network and connectivity data

Information relating to your network connection and service environment, such as mobile carrier, network type, and signal-related information, where relevant for app functionality, diagnostics, or service performance.

j) Permissions-based access data

Where a feature requires access to device capabilities such as the camera, microphone, or photo library, we may process the related content or technical access events only to the extent necessary to provide that feature and subject to your device permission settings.

2.1 SPECIFIC NOTICE FOR IMAGES, USER CONTENT AND FACE-RELATED VISUAL DATA

Certain applications or features made available under our Apple Developer account allow users to upload, import, capture, create, edit, transform, enhance, or generate image-based content.

Where you use these features, we may process:

• images or photos that you upload from your device or capture using your camera,
• generated or edited image outputs,
• prompts, styling selections, editing instructions, or similar feature inputs,
• and visual information contained in the images, including faces, facial features, hairstyles, skin features, body shape, body proportions, clothing, tattoos, or other visible characteristics appearing in the content.

We process this content solely for the purpose of providing the functionality requested by the user within the relevant application or feature, such as image editing, enhancement, retouching, avatar creation, style transformation, body-related visual editing, or other AI-powered or image-based creative features available in the app.

We do not require users to upload images containing personal data of third parties. If a user chooses to upload such content, the user is responsible for ensuring that they have the necessary rights, permissions, or legal basis to do so.

This type of processing does not apply to all of our applications. It only applies to those applications or features that allow image-based content uploads, image generation, or similar visual editing functionality.

Such content may be processed temporarily as necessary to provide the requested functionality, maintain the service, troubleshoot technical issues, protect the security and integrity of the application, or comply with legal obligations. Retention of such content is governed by the retention principles described in the “Data Retention” section of this Privacy Notice.

Where required for service delivery, maintenance, hosting, storage, technical support, security, analytics, or other operational purposes, this data may be processed by service providers acting on our behalf and under appropriate contractual and data protection safeguards.

3) DATA WE DO NOT INTENTIONALLY COLLECT DIRECTLY

We generally do not require users to provide direct personal identifiers such as their full name, postal address, phone number, or password in order to use our mobile applications.

Our applications are typically designed to function without requiring account registration or direct personal identification data, unless a specific feature explicitly requires it (for example, contacting support or responding to a survey).

Payment information

All payments, subscriptions, and digital purchases made within our applications are processed by the Apple App Store or other authorized app marketplace providers. We do not collect, store, or have direct access to your full payment card details or banking information. We may receive limited transaction-related information such as subscription status, purchase confirmation, or transaction identifiers in order to manage app entitlements and subscriptions.

Sensitive personal data

We do not intentionally request or require users to provide sensitive personal data such as health data, political opinions, religious beliefs, or similar categories of sensitive data through our applications. However, users should avoid uploading or submitting sensitive personal data within images, text prompts, or other user-generated content.

User responsibility regarding third-party data

If a user uploads content that contains personal data of third parties (for example, images of other people), the user is responsible for ensuring that they have the necessary rights or permissions to use and upload that content.

4) LEGAL BASES FOR PROCESSING

We process personal data on the following legal bases, depending on the relevant application, feature, and processing activity:

a) Performance of a contract

We process personal data where this is necessary to provide the application, perform the requested service, enable app functionalities, validate purchases or subscriptions, process user-submitted content through app features, and otherwise fulfill our obligations in connection with the use of the application.

This legal basis applies, for example, to:

• operating the app and its core features,
• enabling image editing, generation, enhancement, retouching, avatar, styling, or similar functionalities requested by the user,
• managing subscriptions, entitlements, and service access,
• and handling user support requests directly related to the service.

b) Consent

We rely on your consent where required under applicable law, including where a feature requires access to device permissions or where consent is required for certain analytics, advertising, tracking, or location-related processing.

This may apply, for example, to:

• access to the camera, microphone, or photo library,
• the use of advertising or tracking technologies where consent is legally required,
• location access where requested by the application or the operating system,
• and other optional features based on your device settings or privacy choices.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

c) Legitimate interests

We may process personal data where this is necessary for our legitimate interests, provided that those interests are not overridden by your fundamental rights and freedoms.

This may include:

• maintaining, securing, and improving our applications and services,
• preventing fraud, abuse, misuse, and security incidents,
• generating aggregated analytics and service performance insights,
• troubleshooting technical issues,
• defending legal claims,
• and ensuring the proper administration of our business and app operations.

d) Compliance with legal obligations

We may process personal data where necessary to comply with applicable legal obligations, regulatory requirements, lawful requests from authorities, or obligations relating to the protection of our rights and the rights of others.

If you wish to exercise your rights or withdraw consent where consent is the applicable legal basis, you may contact us using the contact details provided in this Privacy Notice.

5) DATA RETENTION

We retain personal data only for as long as necessary for the purposes for which it was collected, including to provide the services, comply with legal obligations, resolve disputes, enforce agreements, and maintain the security and integrity of our applications.

Retention periods may vary depending on the type of data and the specific application or feature used.

In general, we apply the following retention criteria:

a) User content (such as images, photos, generated images, prompts, or other content submitted through the app)

User content is processed to provide the requested app functionality. Such content may be stored temporarily for processing, service delivery, technical troubleshooting, or user access to generated content, and may be deleted periodically or when it is no longer necessary for the service operation, unless a longer retention period is required for security, legal, or operational reasons.

b) Technical, usage, and analytics data

Technical logs, diagnostic data, crash reports, usage data, and analytics data may be retained for a limited period in order to maintain service performance, analyze app usage, improve functionality, and ensure system security.

c) Support and communications data

If you contact us for support or inquiries, we may retain the related communications and information for as long as necessary to handle the request and for a reasonable period thereafter for administrative, legal, or service improvement purposes.

d) Purchase and subscription data

Information related to purchases, subscriptions, and transaction validation may be retained for as long as necessary to manage subscriptions, provide customer support, comply with financial and tax obligations, and resolve disputes.

e) Legal and compliance data

We may retain certain information where necessary to comply with legal obligations, resolve disputes, enforce our agreements, or protect our legal rights.

In all cases, when personal data is no longer necessary for the purposes for which it was collected, it will be deleted, anonymized, or securely stored only for as long as required by applicable law.

6) WHO WE SHARE PERSONAL DATA WITH

We may share personal data with the following categories of recipients, depending on the application used and the relevant features:

a) Service providers and processors

We may share personal data with third-party service providers that process data on our behalf and under our instructions for purposes such as hosting, cloud storage, content processing, technical infrastructure, analytics, crash reporting, customer support, security, fraud prevention, subscription management, and other operational services necessary to operate and maintain our applications.

These service providers act as data processors and are contractually bound to process personal data only in accordance with our instructions and applicable data protection laws.

b) App store and platform providers

Our applications are distributed through app marketplaces such as the Apple App Store or other authorized platforms. These platform providers may independently process certain personal data in connection with app distribution, payments, subscriptions, analytics, fraud prevention, and platform operations, in accordance with their own privacy policies.

c) Analytics and advertising partners

In applications that include analytics, advertising, attribution, or similar services, certain technical data, device identifiers, usage data, or advertising-related data may be shared with analytics providers, advertising networks, attribution partners, or measurement providers for purposes such as app analytics, advertising delivery, campaign attribution, performance measurement, and fraud prevention. Not all applications use advertising or tracking technologies.

d) Legal and regulatory authorities

We may disclose personal data where required to comply with applicable law, legal obligations, court orders, regulatory requirements, or lawful requests from public authorities, or where necessary to protect our rights, property, or safety, or the rights, property, or safety of users or others.

e) Corporate transactions

In the event of a merger, acquisition, restructuring, sale of assets, financing, or similar corporate transaction, personal data may be transferred as part of the business assets, subject to appropriate confidentiality and data protection safeguards.

f) Group companies

Where necessary for internal administrative purposes, service operation, technical support, analytics, customer support, legal compliance, or business management, personal data may be shared within our corporate group, subject to appropriate data protection safeguards.

7) INTERNATIONAL DATA TRANSFERS

Some of the recipients of personal data described in this Privacy Notice may be located outside the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as the country in which you are located.

Where personal data is transferred outside the EEA, we will ensure that such transfers are carried out in accordance with applicable data protection laws and are subject to appropriate safeguards.

Depending on the circumstances, these safeguards may include:

• an adequacy decision issued by the European Commission,
• the European Commission’s Standard Contractual Clauses,
• or any other lawful transfer mechanism recognized under applicable data protection law.

Where required, we will also implement supplementary measures designed to protect personal data transferred internationally.

You may contact us using the details provided in this Privacy Notice if you would like further information about the safeguards applied to international data transfers.

8) YOUR DATA PROTECTION RIGHTS

Under applicable data protection law, including the GDPR where applicable, you may have the following rights in relation to your personal data:

a) Right of access

You may request confirmation as to whether we process your personal data and, where that is the case, request access to that personal data and to certain information about how it is processed.

b) Right to rectification

You may request that we correct inaccurate personal data concerning you and, where applicable, complete incomplete personal data.

c) Right to erasure

You may request that we delete your personal data in certain circumstances, including where the data is no longer necessary for the purposes for which it was collected, where consent has been withdrawn and no other legal basis applies, or where the processing is otherwise unlawful.

d) Right to restriction of processing

You may request that we restrict the processing of your personal data in certain circumstances, including where you contest the accuracy of the data or object to the processing.

e) Right to object

You may object to the processing of your personal data where such processing is based on our legitimate interests. Where applicable, you also have the right to object to processing for direct marketing purposes.

f) Right to data portability

Where processing is based on your consent or on a contract and is carried out by automated means, you may request to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.

g) Right to withdraw consent

Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

h) Right to lodge a complaint

You have the right to lodge a complaint with the competent data protection authority if you believe that the processing of your personal data infringes applicable data protection law.

To exercise your rights, you may contact us using the contact details provided in this Privacy Notice. We may request additional information to verify your identity before processing your request, where necessary.

9) DEVICE PERMISSIONS, ANALYTICS AND ADVERTISING CHOICES

Depending on the application you use and the features you enable, you may control certain privacy-related settings directly through your device, the application, or the relevant app marketplace account settings.

Device permissions

Some features may require access to device capabilities such as the camera, photo library, microphone, or location. You can manage these permissions at any time through your device settings. Please note that if you disable certain permissions, some features of the application may not function properly.

Analytics and advertising settings

In applications that use analytics, advertising, attribution, or tracking technologies, certain privacy choices may also be available through your device settings, operating system permissions, or app marketplace privacy controls.

For example, depending on your device and region, you may be able to:

• manage app tracking permissions,
• limit or disable access to certain device identifiers,
• manage advertising preferences,
• or adjust consent choices presented within the application, where applicable.

Please note that not all applications include advertising, analytics, or tracking technologies, and the available privacy choices may vary depending on the application, device, operating system, and jurisdiction.

10) SECURITY OF PERSONAL DATA

We implement appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

These measures may include, where appropriate:

• encryption of data in transit,
• access controls and authentication mechanisms,
• restricted access to personal data on a need-to-know basis,
• security monitoring and logging,
• system maintenance and updates,
• secure hosting environments,
• contractual security obligations imposed on service providers and processors,
• and procedures designed to prevent, detect, and respond to security incidents.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we take reasonable measures to protect personal data, we cannot guarantee absolute security.

11) MINORS

Our applications and services are not directed to children and are not intended to be used by individuals who are below the minimum age required to consent to data processing under applicable law in their country of residence.

We do not knowingly collect personal data directly from children without appropriate parental or legal guardian consent where such consent is required by applicable law.

If we become aware that personal data has been collected from a child without the required consent, we will take reasonable steps to delete such data as soon as possible.

If you are a parent or legal guardian and believe that a child has provided personal data through one of our applications, you may contact us using the contact details provided in this Privacy Notice.

12) WHO WE ARE

For the purposes of this Privacy Notice, the data controller is:

Full Time Enterprise S.L. Calle Malteses, 2, planta 2º, puerta B, Las Palmas de Gran Canaria, Spain.

Full Time Enterprise S.L. is responsible for determining the purposes and means of the processing of personal data described in this Privacy Notice.

13) CONTACT US

If you have any questions about this Privacy Notice, the processing of your personal data, or if you wish to exercise your data protection rights, you may contact our Data Protection Officer at:

Email: gdpr@newryglobal.com

14) CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes in our applications, services, data processing practices, legal requirements, or regulatory obligations.

When we make changes, we will publish the updated version through the relevant application, website, or other appropriate channel, and we will update the “Last Updated” date indicated below.

We encourage users to review this Privacy Notice periodically to stay informed about how personal data is processed.