marktandev

1. Introduction

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you access or use any mobile application ("App" or "Apps") developed and published by Mark Tan ("we", "us", or "our"), a Singapore-based software developer. This Policy is intended to help you understand your rights and our obligations under the Personal Data Protection Act 2012 of Singapore (PDPA), and, to the extent applicable, the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant privacy regulations if applicable to our jurisdiction.

By downloading, installing, or using any of our Apps, you agree to the collection and use of your personal data in accordance with this Privacy Policy. If you do not agree with the terms set forth herein, you must refrain from using our Apps.

This Policy applies uniformly to all current and future Apps published by Mark Tan and linked to this document.

2. Definitions

Unless otherwise specified, the terms used in this Policy have the meanings set out below:

• "Personal Data" refers to data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access.
• "User", "you", or "your" refers to any individual who downloads, installs, or uses our Apps.
• "Processing" means any operation performed on Personal Data, including collection, use, disclosure, storage, or deletion.
• "Store(s)" refers to Apple App Store and Google Play Store.
• "Third-Party Services" includes external platforms, SDKs, or APIs integrated into the App (such as RevenueCat or analytics tools).

3. Information We Collect

Some of our apps may not collect any personal data. Data collection only occurs in apps where such features are explicitly implemented. The specific types of Personal Data collected by each individual App, if any, will be clearly detailed on its respective product page on the Apple App Store or Google Play Store, in accordance with their disclosure requirements. We do not collect sensitive personal information unless clearly stated and with your consent.

The general categories of data we may collect, depending on the App's functionality, include, but are not limited to, the following:

• Personal Information: name, email address, birthday or login credentials (if account registration is implemented)
• Device Information: device type, operating system, unique device identifiers, language, region
• Usage Data: in-app activity, time spent, feature interaction
• Subscription Data: purchase receipts, subscription status, payment confirmations (via RevenueCat)
• User-Submitted Inputs: questions or messages submitted by users for AI-generated outputs

4. How We Collect Data

We may collect Personal Data in the following ways:

• Directly from you: when you register for an account, contact support, or input text into the App
• Automatically: through your use of the App, including logs, preferences, and performance metrics
• Via Third-Party Services (which may include, but are not limited to):
  • RevenueCat: used to manage and verify in-app subscriptions
  • Analytics or crash reporting SDKs (e.g., Firebase, Mixpanel, Sentry)
  • AI APIs (e.g., OpenAI, Claude, Gemini) for user-input processing

We will notify you of any significant changes to our collection methods and seek appropriate consent where required.

5. Use of Personal Data

We use your Personal Data for the following purposes:

• To operate and maintain the functionality of our Apps
• To enable and manage in-app subscriptions and purchases
• To deliver personalized or AI-driven responses where applicable
• To analyze performance and improve features and usability
• To provide customer support and respond to inquiries
• To enforce legal terms, prevent fraud, and ensure compliance with law

We only process Personal Data where there is a lawful basis, such as your consent, contractual necessity, or our legitimate interests, as further outlined below.

6. Legal Bases for Processing

We rely on the following legal bases to collect and process your Personal Data:

• Consent: When you voluntarily provide Personal Data (e.g., account registration, support queries, or enabling permissions)
• Contractual Necessity: For delivering paid features or subscriptions you have agreed to
• Legitimate Interests: For improving our services, ensuring security, and preventing misuse
• Legal Obligation: Where processing is required by applicable laws or regulatory authorities

For users located in jurisdictions such as the European Union or California, additional rights and obligations may apply as set out in later sections.

7. User Consent and Withdrawal

By using our Apps, you consent to the collection, use, and disclosure of your Personal Data as described in this Privacy Policy.

Where your consent is required under applicable law:

• We will obtain it explicitly before collecting data
• You may withdraw your consent at any time by contacting us at support@marktandev.com

Withdrawal of consent may affect your ability to access certain features or services within the App. Your request will be honored in accordance with applicable legal timelines and subject to verification.

8. Third-Party Services and SDKs

We may integrate third-party services into our Apps to enable core functionality, manage subscriptions, analyze performance, or facilitate specific features.

Examples of third-party services that may be used include:

• RevenueCat: used for subscription verification, entitlement tracking, and in-app purchase validation
• Analytics & crash reporting tools (e.g., Firebase, Sentry)
• AI APIs (e.g., OpenAI, Claude, Gemini) that process user-submitted text to generate responses or content

Not all apps will use all these services; integrations vary by app and feature set. Use of such services is subject to their individual privacy policies. We do not control how these third parties handle your data once transmitted.

9. Data Sharing and Disclosure

We do not sell, rent, or trade your Personal Data.

We may share or disclose your data in the following limited circumstances:

• With service providers and processors who assist in delivering app functionality (e.g., RevenueCat)
• To comply with legal obligations or respond to lawful requests from authorities
• To enforce our Terms and Conditions, protect our rights, or investigate fraud or abuse
• In the context of a merger, acquisition, or asset sale, where permitted by law

We will not disclose your Personal Data outside these purposes unless we obtain your explicit consent or are otherwise permitted by law.

10. Data Retention

We retain Personal Data only for as long as is necessary to fulfill the purposes outlined in this Policy, or as required by applicable laws or contractual obligations.

• Account and subscription data may be retained for the duration of your usage and a reasonable period thereafter to maintain records or resolve disputes.
• Trial and anonymous usage data may be retained for analytical purposes in a de-identified form.
• AI interaction content is not stored unless explicitly needed for functionality and disclosed as such.

When data is no longer required, we will securely delete or anonymize it in accordance with best practices.

11. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

However, no transmission of data over the internet or storage system can be guaranteed to be 100% secure. You acknowledge and accept that any information you transmit is done at your own risk.

We encourage you to use strong passwords, avoid sharing credentials, and report any security concerns to support@marktandev.com immediately.

12. User Rights under PDPA (Singapore)

As a user located in Singapore, you have the following rights under the Personal Data Protection Act 2012:

• Right to Access: Request access to the Personal Data we hold about you.
• Right to Correction: Request correction of inaccurate or incomplete data.
• Right to Withdraw Consent: Revoke your consent to continued use or disclosure of your data.

To exercise your rights, please contact us at support@marktandev.com with sufficient detail to allow us to verify your identity and respond appropriately.

13. Rights under GDPR and CCPA (If and When Applicable)

If you are a resident of the European Union or California, and access our Apps despite our non-targeting of such regions, you may be entitled to additional rights:

Under GDPR:

• Right to Erasure ("Right to be Forgotten")
• Right to Data Portability
• Right to Restriction of Processing
• Right to Object to Processing
• Right to Lodge a Complaint with a supervisory authority

Under CCPA (California):

• Right to Know what categories of data we collect and disclose
• Right to Access your data
• Right to Deletion
• Right to Opt-Out of the sale of personal data (we do not sell data)
• Right to Non-Discrimination for exercising your rights

You may submit requests via support@marktandev.com. Verification procedures may apply.

14. Cross-Border Data Transfers

Our Apps and third-party services may process or store data on servers located outside your country of residence, including in jurisdictions that may not provide the same level of data protection as your home country.

Where applicable, we ensure that such transfers comply with Singapore's Transfer Limitation Obligation under the PDPA and, where required, rely on:

• Contractual clauses
• User consent
• Other legally recognized safeguards

By using our Apps, you expressly consent to such cross-border transfers of your Personal Data.

15. Children's Privacy

Our Apps are intended for general audiences but may include content with minimum age designations (for example, 12+ or 18+) as specified in their respective App Store listings. We do not knowingly collect Personal Data from children under the age of thirteen (13), or any age threshold requiring parental consent under applicable law.

If we become aware that we have collected Personal Data from a child without the necessary consent, we will take steps to delete such information promptly. Parents or legal guardians who believe that their child has provided Personal Data without consent may contact us at support@marktandev.com.

16. AI Processing and Disclaimers

Certain Apps may enable users to submit text-based content for processing by artificial intelligence systems. These features are intended for entertainment, educational, or functional purposes and may generate automated responses.

We do not:

• Store user input or generated content beyond the duration needed to fulfill the request, unless explicitly stated otherwise
• Use such content for training or profiling purposes
• Make decisions based solely on automated processing that produces legal or significant effects

Users acknowledge that AI-generated outputs may be inaccurate, inappropriate, or misleading. You agree to use such features responsibly and understand that the outputs do not constitute advice or factual information.

17. App Store and Google Play Compliance

To comply with Apple and Google developer policies, we:

• Provide clear notice of what data is collected, how it is used, and whether it is shared with third parties
• Disclose all required permissions and data use in our App Store listings
• Offer links to this Privacy Policy within our App and Store pages
• Adhere to platform-specific user privacy and transparency requirements

Failure to accept this Policy or the relevant Store permissions may prevent access to certain features of the App.

18. Your Responsibilities

You are responsible for:

• Keeping any login credentials secure, if account creation is enabled
• Ensuring that any information you provide is accurate and up to date
• Not submitting Personal Data of others without their consent
• Complying with applicable laws and App terms when using our services

Any misuse of the App that violates this Privacy Policy or applicable law may result in termination of your access and reporting to authorities where necessary.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal obligations, data practices, or service enhancements. When we make material changes, we will:

• Update the "Effective Date" at the top of this document
• Provide in-App or Store-based notification where required

Your continued use of the App following the posting of an updated version constitutes your acceptance of the revised Policy.

20. Contact Us

If you have any questions about this Privacy Policy, your data rights, or wish to file a complaint, you may contact us at:

• Email: support@marktandev.com
• Developer: Mark Tan
• Jurisdiction: Singapore