Privacy Policy

1. Who we are

The operator of the Cluo App is the data controller for personal information described in this policy, unless a different controller is required by law in your jurisdiction. For privacy requests, contact us at cluocyl@163.com.

2. Information we may collect or process

Depending on how you use the App, the following categories may apply:

2.1 Information you provide

• Photos and media: Images or media you import or capture for use inside the App’s spatial scenes, previews, or editing flows.
• Support communications: If you email us, we receive your message content and contact details you include.

2.2 Information collected automatically

• Device and App diagnostics: Limited technical data may be processed on-device or by Apple (for example crash logs if you opt in to sharing analytics with developers through Apple’s mechanisms).
• App Tracking Transparency (ATT): On supported iOS versions, Apple may require permission before certain cross-app tracking. Your choice is managed through the system prompt and iOS Settings.

2.3 In-app purchases

Purchases are handled by Apple. We do not receive your full payment card number. Apple may provide us transaction identifiers or product information necessary to deliver virtual currency or entitlements inside the App.

3. How we use information

We use information to:

• Provide, maintain, and improve the App’s features (including 3D presentation, previews, and capture-related functionality).
• Process virtual currency and entitlements associated with your Apple account transactions.
• Respond to support requests and communicate about security or policy updates.
• Comply with legal obligations and protect rights, safety, and integrity of users and the App.

We do not sell your personal information for money as that term is commonly understood under the CCPA/CPRA. We do not use your photos to train third-party AI models unless we clearly disclose a separate program and obtain any required consent.

4. Legal bases (where applicable)

Depending on your region, we may rely on one or more of the following: performance of a contract (providing the App), legitimate interests (security, product improvement compatible with your rights), consent where required (for example certain permissions or marketing where offered), or legal obligation.

5. Sharing and disclosure

We may share information with:

• Apple: As needed for App Store distribution, in-app purchases, and platform services under Apple’s privacy policies.
• Service providers: Vendors who assist us with hosting, analytics, or email delivery, bound by confidentiality and processing terms.
• Legal and safety: When required by law, legal process, or to protect rights and safety.

We do not sell personal information to data brokers for unrelated advertising without appropriate notice and, where required, consent.

6. Retention

We retain information only as long as necessary for the purposes above, including to resolve disputes and comply with law. User Content processed primarily on your device remains under your control; when stored or backed up by Apple (for example in iCloud according to your settings), Apple’s terms may apply.

7. Security

We implement reasonable technical and organizational measures appropriate to the nature of the App. No method of transmission or storage is completely secure; we encourage you to keep your device updated and use device passcodes or biometrics.

8. Your privacy rights by region

Depending on where you live, you may have rights to access, correct, delete, or restrict processing of personal information, or to object to certain processing. You may also have the right to appeal our response where applicable law provides an appeal process.

8.1 California, USA (CCPA/CPRA)

California residents may have the rights to know, delete, and correct personal information, to opt out of certain sharing (including “sale” or “sharing” as defined by California law), and not to receive discriminatory treatment for exercising rights. You may submit requests by emailing cluocyl@163.com. We will verify requests as required by law. You may use an authorized agent where permitted, subject to verification.

Categories collected (illustrative): identifiers (such as device or transaction identifiers), commercial information (in-app purchases), visual information (photos you choose to process in the App), and internet or electronic network activity (App interactions), as applicable.

8.2 Canada (PIPEDA and provincial laws)

Canadian users may request access to their personal information and challenge accuracy and completeness. We will respond in accordance with applicable federal or provincial privacy legislation.

8.3 Singapore (PDPA)

Individuals in Singapore may have rights to access and correct personal data, and to withdraw consent where processing is consent-based, subject to exceptions under the PDPA.

8.4 Australia (Privacy Act & APPs)

Australian users may access personal information we hold and request correction. If you believe we have mishandled a complaint, you may contact the Office of the Australian Information Commissioner (OAIC) after first contacting us.

8.5 Summary table

9. Children

The App is not directed to children under the age required by applicable law to consent to data collection without parental authorization. If you believe we have collected information from a child inappropriately, contact us and we will take appropriate steps.

10. International transfers

If personal information is transferred across borders (for example between your region and the United States or other locations where we or our service providers operate), we use appropriate safeguards as required by applicable law, such as contractual clauses or other lawful mechanisms.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will post the revised policy with an updated effective date. Where required by law, we will provide additional notice.

12. Related documents

Our User Agreement describes terms of use for the App and works together with this Privacy Policy.

13. Contact