Privacy Policy

1. Who we are

This Privacy Policy is issued by ADEPT LABS TECHNOLOGY COMPANY LIMITED (“ADEPT Labs”, “we”, “us”, “our”), a company organized under the laws of Vietnam. We are the data controller responsible for your personal data processed through our products.

If you have any question about this policy or your data, contact us at [email protected].

2. Scope of this policy

We build a range of products — mobile apps, games, AI features, and cloud services. Different products collect different data depending on their features. This policy describes the full set of data we may process; any individual app only processes the subset needed for its actual functionality, as shown on that app’s App Store or Google Play privacy label. Where an app collects data not described here, it will provide its own supplementary privacy notice.

3. Data we collect and why

Depending on the app and the features you use, we may collect the following categories of data. For each, we state the purpose and, for users in the EEA/UK, the legal basis under the GDPR.

• Usage & analytics data — how you interact with an app (screens viewed, features used, session length), in aggregated or pseudonymized form. Purpose: to understand and improve our products. Legal basis: your consent where required, otherwise our legitimate interest in improving the service.
• Diagnostic & crash data — device model, operating-system version, and technical logs generated when an app crashes or errors. Purpose: to keep our apps stable and secure. Legal basis: legitimate interest.
• Purchase & subscription data — records of in-app purchases and subscription status. Payments are processed by Apple or Google; we do not receive or store your full payment-card details. Purpose: to deliver paid content, manage subscriptions, and meet tax and accounting obligations. Legal basis: performance of a contract and legal obligation.
• Account data — if an app offers an account, this may include your email address or a Sign in with Apple identifier, and settings you choose. Purpose: to create and secure your account and sync your data. Legal basis: performance of a contract.
• User content — content you create, upload, or submit within an app (for example files, text, or images), where a feature requires it. Purpose: to provide that feature. Legal basis: performance of a contract.
• Device & advertising identifiers — only if a specific app shows ads or measures advertising. Where this involves tracking across other companies’ apps or websites, we will first request your permission through Apple’s App Tracking Transparency prompt and, in the EEA/UK, your separate opt-in consent. You can decline, and app functionality will not depend on it. Legal basis: consent.

We practice data minimization: an app only requests access to data relevant to its core functionality, and we do not collect data we do not need.

4. How we share data

We do not sell your personal data. We share data only with the following categories of recipients, and only as needed:

• Platform providers — Apple and Google, who process payments, deliver apps, and provide crash and analytics tooling.
• Service providers — analytics, crash-reporting, cloud-hosting, and infrastructure vendors that process data on our behalf under contract.
• Legal & safety — authorities or advisors, where required by law or to protect our rights, users, and the public.

Any third party with whom we share user data is required to provide the same or equal protection of that data as stated in this policy and required by applicable app-store guidelines and law.

5. Data retention and deletion

We keep personal data only as long as necessary for the purposes described above, or as required by law (for example, purchase records kept for tax and accounting periods). We then delete or anonymize it.

If an app offers an account, you can request deletion of your account and associated data from within the app. You may also contact us at [email protected] to request deletion or to withdraw a consent you previously gave.

6. Your privacy rights

Depending on where you live, you may have some or all of the following rights over your personal data:

• EEA / UK (GDPR): access, rectification, erasure, restriction, data portability, objection, and the right to withdraw consent at any time. You also have the right to lodge a complaint with your local data-protection supervisory authority.
• California (CCPA/CPRA): the right to know, delete, and correct your personal information, to opt out of sale or sharing, to limit use of sensitive personal information, and to non-discrimination for exercising these rights. We do not sell or share personal information as those terms are defined under California law.

To exercise any of these rights, contact us at [email protected]. We will respond within the time required by applicable law.

7. International data transfers

We are based in Vietnam and serve users worldwide. Where we process data of users in the EEA, UK, or other regions, that data may be transferred to and processed in countries outside your own. We take steps to ensure such transfers are protected by appropriate safeguards as required by applicable law.

8. Security

We use reasonable technical and organizational measures to protect your data against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, but we work to protect your information and to limit access to those who need it.

9. Children's privacy

Most of our apps are intended for a general audience and are not directed to children under 13 (or the minimum age of digital consent in your country, which may be up to 16 in the EEA). We do not knowingly collect personal data from children under this age without verifiable parental consent. If we learn that we have collected such data without the required consent, we will delete it as soon as reasonably possible.

Where an app is specifically designed for children (for example, an app in Apple's Kids Category), that app does not include third-party advertising or third-party analytics that identify the child, does not use advertising identifiers, and follows the applicable children's-privacy rules (such as COPPA). Such an app will carry its own child-directed privacy notice. If you believe a child has provided us personal data, contact [email protected].

10. Changes to this policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top reflects the latest version. For material changes that affect how we use your personal data, we will provide a more prominent notice (for example, an in-app message) and, where required by law, ask for your renewed consent. We encourage you to review this page periodically.

11. Contact us

For any privacy question or request, contact ADEPT LABS TECHNOLOGY COMPANY LIMITED at [email protected].