Privacy Policy

1. OVERVIEW

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you download, install, or use the Speaker Test - Tone Generator mobile application (the“App”). The App is intended for individuals aged 18 or older. We do not knowingly collect personal data from anyone under 18. If you are under 18, please do not use the App or provide any personal data. If we discover that we have unintentionally collected such data, we will delete it promptly. Except where otherwise noted, we act as the data controller under the General Data

Protection Regulation (GDPR).

2.Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

• We (referred to as either "We", "Us" or "Our" in this Agreement) refers to the app developer team, Changsha Zhilan Technology Co., Ltd.

• Application means the software program provided by Us downloaded by You on any electronic device, named Speaker Test - Tone Generator.

• Service refers to the Application.

• Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an Account to use the Service.

• Personal Data is any information that relates to an identified or identifiable individual.

• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

I want to inform you that whenever you use my Service, in the case of an error in the app I collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing my Service, the time and date of your use of the Service, and other statistics.

3. INFORMATION WE PROCESS

We and our partners may use cookies, SDKs, or similar technologies (e.g., Firebase SDK,Adjust, RevenueCat) to collect this data for analytics, crash reporting, and advertising purposes. These tools may involve automatic profiling to deliver personalized content or ads.

4. PURPOSES OF PROCESSING

We use the information described above to:

1. Provide, operate, maintain, and improve the App and its sound-based water-ejection

features.

2. Personalize your experience, remember preferences, and test new functions.

3. Send technical notices, updates, security alerts, and respond to your inquiries.

4. Show contextual or interest-based ads (where permitted) and measure their

performance.

5. Detect, prevent, and investigate fraud or misuse and to comply with legal obligations.

If we intend to use your data for any other purpose, we will ask for your consent where

required by law.

5. DATA SHARING

We do not sell your personal data. We may share limited information with:

• Analytics & Performance Partners – e.g., Firebase (Google LLC)

These partners process data under their own privacy policies and may be located outside your country. We require them to implement appropriate safeguards, but we cannot control their independent data handling.

We may also disclose data (a) when required by law, (b) to protect users or enforce our rights, or (c) in connection with a merger, acquisition, or asset sale (you will be notified of any change of ownership).

6. DATA RETENTION

We keep personal data only as long as necessary for the purposes outlined above and to meet legal, accounting, or reporting requirements. When data is no longer needed, we delete or anonymize it. You may request deletion at any time (see Section 9).

7. INTERNATIONAL TRANSFERS

Your information may be transferred to—and processed on—servers outside your country, where privacy laws may differ. By using the App, you consent to this transfer. We rely on standard contractual clauses and other safeguards to protect your data in such cases.

8. DATA SECURITY

We employ administrative, technical, and physical measures (including encryption in transit, secure hosting, and access controls) to protect your data. No system is completely secure; however, if we identify a breach affecting your data, we will notify you as required by law.

9. YOUR RIGHTS AND CHOICES

If you are in the EEA or the UK, you have the right to:

• Access, correct, or port your personal data.

• Request deletion or restrict processing.

• Object to automated profiling or direct marketing.

California residents have analogous rights under the CCPA, including the right to access or delete personal data and the right to non-discrimination for exercising these rights.

For EU: GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process personal data under the following conditions:

• Consent: You have given your consent for processing personal data for one or more specific purposes.

• Performance of a contract: Provision of personal data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which We are subject.

• Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.

• Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in ourselves.

• Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by Us.

In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

We undertake to respect the confidentiality of your Personal Data and to guarantee You can exercise your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to your personal data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of your personal data directly within your Account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the personal data We hold about You.

• Request correction of the personal data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of your personal data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes You want to object to Our processing of your personal data on this ground. You also have the right to object where We are processing your personal data for direct marketing purposes

• Request erasure of your personal data. You have the right to ask Us to delete or remove personal data when there is no good reason for Us to continue processing it.

• Request the transfer of your personal data. We will provide to You, or to a third-party You have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw your consent. You have the right to withdraw your consent on using your personal data. If You withdraw your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of your personal data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

For California: CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of personal data are being collected and the purposes for which the personal data is being used.

• The right to access / the right to request. The CCPA permits You to request and obtain from us the information regarding the disclosure of your personal data that has been collected in the past 12 months by us or its subsidiaries to a third-party for the third party's direct marketing purposes.

• The right to say no to the sale of personal data. You also have the right to ask us not to sell your personal data to third parties. You can submit such a request by visiting Our "Do Not Sell My Personal Data" section. We do NOT sell any personal data.

• The right to know about your personal data. You have the right to request and obtain from us the information regarding the disclosure of the following:

·The categories of personal data collected

·The sources from which the personal data was collected

·The business or commercial purpose for collecting or selling the personal data

·Categories of third parties with whom We share personal data

·The specific pieces of personal data We collected about You

• The right to delete personal data. You also have the right to request the deletion of your personal data that have been collected in the past 12 months.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:

·Denying goods or services to You

·Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

·Providing a different level or quality of goods or services to You

·Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if You are a California resident, You can email or call Us or visit Our "Do Not Sell My Personal Data" section or web page.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will post the revised version in the App and update the “Last updated” date. Material changes may also be announced via push notification or in-app message.

11.User Consent for Data Processing Related to Refund Requests

In accordance with the App Store’s refund policy, when a user initiates a refund request, our server will receive a notification (CONSUMPTION_REQUEST) from Apple. In such cases, we will provide Apple with data related to the user’s subscription to assist Apple in making a decision regarding the refund request.

Please note that the data provided is strictly limited to subscription-related consumption information and does not include any personal or sensitive data. We are committed to complying with Apple’s requirements and ensuring that all data processing activities fully adhere to privacy protection laws and regulations.

By using this app, you consent to the transmission of your subscription consumption data to Apple, as required for processing refund requests, in compliance with the App Store’s refund policies.

12. CONTACT

If you have questions about this Privacy Policy or our privacy practices, please contact:admin@wiseflowtech.com.