Privacy Policy

1. Who we are

The App is developed and published by GLANRA COMPANY LIMITED (“GLANRA”, “we”, “us”, “our”), located at 37/2/6 Street No 12, Quarter 3, An Khanh Ward, Ho Chi Minh City, Vietnam. For the purposes of data protection laws such as the EU/UK General Data Protection Regulation (GDPR), we are the controller of the personal data described in this policy, except where a third party acts as an independent controller (see Section 9).

This notice is the App-specific privacy notice referred to in the GLANRA Privacy Policy, which applies to all of our apps. For this App, this notice is the complete description of our practices; where the two differ, this notice applies.

You can reach us at any time at [email protected].

2. Information we collect

2.1 Content you create and add

To make cards, videos and effects, you can add photos, videos, text, music, voice recordings, and an optional profile name and avatar. This content is stored locally in the App’s storage on your device. It is not uploaded to us, except for content you put into a Link Card (see Section 4).

• Photos and videos are chosen through the system photo picker, which gives the App access only to the items you select. When you save a creation, the App asks for permission to add it to your photo library.
• Music files you import from your device stay on your device. If you add music by entering a web address, the App downloads the file directly from that address, so the website you enter will receive a standard request from your device (such as your IP address).
• Sharing: when you share a creation using your device’s share options, it goes to the app or person you choose, under their own terms and privacy policies.

2.2 Information you send us

If you contact us (for example with “Send Feedback”), we receive your email address, your message and any attachments, plus the details the App pre-fills in the email: operating system version, country or region setting, and App version. We use this only to respond and to improve the App.

2.3 Information collected automatically

When you use the App, we and our service providers (listed in Section 9) automatically collect:

• Device and app information: device model, operating system and version, App version, language, country or region, time zone, screen size, network type, and similar technical data.
• Identifiers: your device’s advertising identifier (the IDFA on iOS, only if you allow tracking; the Advertising ID on Android, unless you have deleted it), the identifier for vendor (IDFV) on iOS, app instance and installation IDs generated by Firebase and AppsFlyer, push notification tokens, and IDs generated by advertising SDKs.
• Usage data: which screens and features you use, buttons you tap, templates and effects you view or use, session start and length, and events such as “card exported” or “link created”.
• Advertising data: which ads were requested, shown and clicked, estimated ad revenue, and attribution data (for example, which ad campaign led to the App being installed).
• Diagnostics: crash reports, error logs and performance data.
• Approximate location: a coarse location (such as country, region or city) derived from your IP address. It is used to show the right consent message, to serve and measure ads, and for aggregated analytics. The App does not request or use your precise (GPS) location.
• Content delivery data: templates, videos, music and effect packs are downloaded from our content servers. Those servers receive standard request data (such as IP address and device and App information) that is needed to deliver the content.
• Purchase information: see Section 7.

2.4 What we do not collect

The App does not access your contacts, calendars, health or fitness data, or precise location, and it does not use face recognition to identify anyone.

3. Camera, microphone and face/hand tracking

• Camera. Used only while you use camera features, to show a live preview with interactive effects and to record videos you choose to make.
• Face and hand tracking. Some effects follow your face or hands. To do this, on-device machine-learning models (Google MediaPipe and, on Android, Google ML Kit) detect the position of your face or hands in each camera frame. This produces temporary position points that exist only in your device’s memory while the effect is running. We do not store or upload these points or the camera frames, we do not share them with anyone, and we do not use them to identify you, for advertising, for marketing, or for data mining.
• Microphone. Used to record sound with the videos you create and, if you choose, to record a voice message inside the Link Card editor. Recordings stay on your device unless you add them to a Link Card.

These permissions are optional. You can turn them off at any time in your device settings, but some features will not work without them.

4. Link Cards (shared online cards)

A Link Card is an online card you create inside the App and share with a link or QR code.

• What is uploaded. The Link Card editor is a web page that opens inside the App. The content you add to it, such as messages, names, photos, voice recordings and the template you choose, is uploaded to and stored on servers run by us or our cloud hosting provider (Google Firebase / Google Cloud) so a unique link and QR code can be created. The editor may use browser storage or cookies that it needs to work.
• Who can see it. Anyone who has the link can view the card. Only share it with people you trust, and do not include information you would not want others to see. A recipient can forward the link, or save and share screenshots, and we cannot control that.
• How long it stays online. Each link is valid for a limited time, which the App shows you (48 hours by default). When the link expires, the card content is deleted from our servers.
• History on your device. The App keeps a list of the links you created (link, template, creation and expiry time) on your device only. Removing a link from “My Links” deletes it from your device. It does not delete the online card before it expires. If you want a card taken down sooner, email us the link and we will delete it.
• Other people’s information. If your card includes someone else’s photo, name or voice, make sure you have their permission.

5. How we use information

We use information for the purposes below. If you are in the European Economic Area (EEA), the United Kingdom or Switzerland, the table also shows our legal basis under the GDPR.

We do not sell your personal information for money. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you.

6. Advertising and tracking

The App shows banner, native, interstitial, app-open and rewarded ads from Google AdMob. AdMob can fill ads through other ad networks (“mediation”), which are listed in Section 9. These partners may collect the data described in Section 2.3 to serve ads, limit how often you see the same ad, measure performance, and detect fraud. If you have allowed it, they may also use this data to show ads that are personalized to your interests.

• iOS – App Tracking Transparency. The App asks for your permission before your data is used to track you across apps and websites owned by other companies. If you choose “Ask App Not to Track”, the IDFA is not shared, and you will still see ads, but they will be less relevant. You can change this at any time in Settings › Privacy & Security › Tracking.
• Android – Advertising ID. You can reset or delete your Advertising ID in your device settings (usually Settings › Privacy › Ads, or Settings › Google › Ads).
• Consent in the EEA, UK, Switzerland and some U.S. states. Where required, the App shows a consent message powered by Google’s User Messaging Platform (which uses the IAB Transparency & Consent Framework in the EEA/UK) before personalized ads are served. You can review or change your choices through the privacy settings option in the App, where available, or by contacting us.
• Ad-free options. Where offered, you can remove ads with an in-app purchase.

Ads are provided by third parties. We do not control their content or the websites and apps they link to, and those have their own privacy policies.

7. In-app purchases and subscriptions

Purchases and subscriptions are processed by the Apple App Store or Google Play, under their terms and privacy policies. We do not receive or store your payment card, bank account or billing address details. The store tells us what you bought (product, price and currency, transaction and receipt identifiers, purchase and expiry dates, and subscription status). We use this to unlock and restore features, confirm your subscription, prevent fraud, and meet legal obligations. Purchase events may also be shared with our analytics and attribution partners (such as Google Analytics for Firebase and AppsFlyer) so we can measure revenue and the performance of our marketing.

8. How we share information

We share information only as described in this policy:

• Service providers that host content and Link Cards, provide analytics, crash reporting, push notifications, remote configuration, attribution and consent management. They process data on our behalf and under our instructions.
• Advertising partners that serve and measure ads in the App. Some of them act as independent controllers of the data they collect under their own privacy policies.
• Apple and Google, for app distribution, payments and platform features (for example SKAdNetwork/AdAttributionKit ad measurement on iOS and the Install Referrer on Android).
• People you choose: people who have your Link Card link, and the apps and contacts you share your creations with.
• Legal and safety reasons: when we believe in good faith that it is required by law or legal process, or that it is needed to protect the rights, property or safety of our users, the public or us.
• Business transfers: if we are involved in a merger, acquisition or sale of assets, information may be transferred as part of that deal, and it will remain subject to this policy or one that is at least as protective.

We work only with third parties that commit to protecting personal data with the same or equal protection as described in this Privacy Policy and as required by applicable law, the Apple App Store Review Guidelines and Google Play policies. We also require them to use the data only for the purposes for which it was shared.

9. Third-party services we use

This list reflects the current versions of the App and may change as we add or remove partners. Not every partner is used on every platform.

10. Data retention and deletion

When data is no longer needed, we delete it or make it anonymous.

11. Your choices and controls

• Permissions: turn camera, microphone, photos and notifications on or off in your device settings.
• Tracking and ad personalization: see Section 6 (App Tracking Transparency on iOS, Advertising ID on Android, and the consent message where shown).
• Notifications: turn push notifications and reminders off in your device settings at any time, or turn reminders off in the App’s Settings screen.
• Local content: delete creations, recordings, music and links inside the App. Uninstalling the App removes all of its local data from your device.
• Link Cards: they expire automatically. To delete one sooner, email us the link.
• Withdraw consent: you can withdraw any consent at any time. This does not affect processing that already took place.

12. Your privacy rights

Depending on where you live, including under Vietnam’s Law on Personal Data Protection and its implementing regulations, the GDPR, the UK GDPR and U.S. state privacy laws, you may have the right to:

• access the personal data we hold about you and get a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to certain processing, including processing based on legitimate interests and direct marketing;
• receive your data in a portable format;
• withdraw consent at any time; and
• complain to your local data protection authority.

How to make a request. Email [email protected] with the subject “Privacy Request”. The App has no user accounts, so please include details that help us find your data, for example the Link Card link, or the email address and approximate date you contacted us. We may ask you to verify your request. We will respond within one month, or within the time required by the law that applies to you. Some data is held by our partners under identifiers that we cannot link to you. In that case, we will explain how to contact the partner directly, and you can also use the device controls in Section 11.

13. U.S. state privacy notice

This section applies to residents of California and other U.S. states with comprehensive privacy laws.

• Categories we collect: identifiers (such as advertising and device IDs); internet or other electronic network activity (App usage and ad interactions); approximate geolocation; commercial information (purchase records); audio and visual information (only the content you put into a Link Card, and your own local content that we do not receive); and inferences that advertising partners may draw about your interests. We collect these from you, from your device, and from our partners, for the purposes described in Section 5.
• “Sale” and “sharing”: we do not sell personal information for money. However, allowing ad partners to collect identifiers and usage data for personalized, cross-context behavioral advertising may count as a “sale” or “sharing” under some state laws. To opt out, decline personalized ads in the consent message where it is shown, choose “Ask App Not to Track” on iOS, delete your Advertising ID on Android, or email us with the subject “Do Not Sell or Share”.
• Sensitive information: we do not use or disclose sensitive personal information to infer characteristics about you.
• Your rights: you may request to know, access, correct and delete your personal information, and to opt out as described above. You may use an authorized agent. We will not discriminate against you for exercising your rights.
• Retention: see Section 10.

14. Children

The App is not directed to children under 13, or under the minimum age required in your country to consent to data processing (for example, 16 in some EEA countries). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

15. Security

We use reasonable technical and organizational measures to protect information, including encrypted connections (HTTPS) for Link Cards and reputable, secure cloud providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Remember that anyone with a Link Card link can view that card.

16. International transfers

We are based in Vietnam. We and our service providers may process information in countries other than the one where you live, including the United States and other countries where our providers operate. Where the law requires it, we rely on appropriate safeguards for these transfers, such as the European Commission’s Standard Contractual Clauses or equivalent mechanisms.

17. Changes to this policy

We may update this policy from time to time, for example when we add features or partners. We will change the “Last updated” date above and, when changes are significant, give you notice in the App or on this page. If you keep using the App after an update, the updated policy applies.

18. Contact us

If you have questions or requests about this policy or your data, contact:

GLANRA COMPANY LIMITED
37/2/6 Street No 12, Quarter 3, An Khanh Ward, Ho Chi Minh City, Vietnam
Email: [email protected]
Telephone: +84 348 635 424
Support: glanraltd.com/support