Privacy Policy

PRIVACY POLICY OF Inspiro

Policy Update Date: August 15, 2026

This Privacy Policy ("Policy") governs the collection, use, storage, processing, and protection of personal data of users ("User," "You," "Your") when using the Inspiro application and website ("Application," "We," "Our," "Us").

We recognize the importance of protecting personal information and are committed to processing it in strict compliance with international standards. This Policy has been developed in accordance with the General Data Protection Regulation (GDPR) of the European Union and the California Consumer Privacy Act (CCPA). It defines the types of personal data collected, how they are used, shared with third parties, protected, and stored.

By using the Application, the User acknowledges and agrees to the terms of this Policy. If the User does not accept the terms of this Policy, they must stop using the Application.

If the User has any questions regarding the processing of personal data, they may contact us using the contact details provided in this Policy.

1. USER CONSENT FOR DATA COLLECTION AND PROCESSING

1.1. Consent to Personal Data Processing. By using the Inspiro Application, the User confirms that they have read and agree to the terms of this Privacy Policy.

1.1.1. When installing and using the mobile application, or when visiting the website, the User grants consent for the collection and processing of their personal data, if required for the operation of the service.

1.1.2. If data processing is based on consent (e.g., for marketing notifications), the User may withdraw their consent at any time.

1.1.3. Withdrawal of consent does not affect the legality of processing carried out before the withdrawal (in accordance with Article 7(3) GDPR).

1.2. Mandatory Data Processing for Application Functionality. Certain types of data are processed not based on consent but due to contractual necessity or legitimate interests:

1.2.1. Technical data (IP address, device information, operating system) are collected automatically for the proper functioning of the Application.

1.2.2. Subscription data is transferred to Google Play and App Store and cannot be disabled without canceling the subscription.

1.2.3. Customer support inquiries require processing of the information provided by the User.

1.3. If the User does not agree with the processing of personal data, they must stop using the Application and delete it from their device.

2. DATA WE COLLECT

2.1. We collect and process various categories of data to ensure the functionality of the Application, comply with legal obligations, improve the user experience, and provide personalized content. Data may be provided by the User, collected automatically, or obtained from third-party services.

2.2. Data Provided by the User. Certain data is requested from the User when using the Application:

2.2.1. Account Information (if registration is introduced in future versions): name, email address, profile picture.

2.2.2. Subscription and Payment Data: details about purchased subscriptions and payment history, processed via Apple App Store and Google Play. We do not store or process payment data directly.

2.2.3. Customer Support Requests: information provided by the User when submitting support requests.

2.3. Automatically Collected Data. When using the Application, the following data is automatically processed:

2.3.1. Device Information: device type, model, operating system version, unique device identifiers.

2.3.2. Usage Data: interaction with application features, browsing history, frequency of use, errors, and crashes.

2.3.3. Log Files and Technical Reports: crash reports, performance, and diagnostic data (collected through Firebase and other analytics services).

2.4. Data from Third-Party Services. We use third-party services that may process User data in accordance with their privacy policies:

2.4.1. Google Analytics and Firebase – user behavior analysis, technical reports, crash data collection.

2.4.2. Apple and Google Payment Systems – subscription management and payment processing.

2.4.3. AppsFlyer Analytics – user behavior analysis, technical reports, crash data collection.

2.4.4. PostHog Analytics – user behavior tracking, feature usage analysis, and product improvement insights.

2.4.5. Meta – analytics, attribution, and advertising. The Meta software development kit records application events and, subject to Section 2.4.9, the device advertising identifier.

2.4.6. Airbridge and Singular – mobile measurement and marketing attribution, namely determining which marketing campaign led to an installation of the Application and recording subsequent application events, including subscription purchases. The software development kits of these providers are included in the Application but are activated remotely by Us, and either or both may be inactive at any given time. Where active, they process the data described in Section 2.3 and, subject to Section 2.4.9, the device advertising identifier.

2.4.7. The following additional providers process data on Our behalf:

2.4.7.1. Firebase Crashlytics – crash and non-fatal error reporting.

2.4.7.2. Firebase Remote Config – remote configuration of features.

2.4.7.3. Firebase App Check – verification that requests originate from a genuine installation of the Application.

2.4.7.4. Firebase Cloud Messaging – delivery of push notifications.

2.4.7.5. Firebase Installations – a technical identifier of the installation of the Application on the device.

2.4.7.6. Cloud Firestore – records of promotional code redemption.

2.4.7.7. Google Cloud Functions and Google Workspace (Gmail) – processing and delivery of support enquiries and of website contact form submissions.

2.4.8. Links to the privacy policies of third-party services are provided in the "Data Sharing with Third Parties" section.

2.4.9. Consent for advertising identifiers. On iOS, collection of the device advertising identifier by Our attribution and advertising partners takes place only where the User has permitted tracking in response to the system prompt shown by the operating system. On Android, the corresponding collection by the Meta software development kit is presently enabled by default. A User who does not wish it to occur may disable advertising personalisation in their device settings, or may object as provided in Section 8.4.4.

2.5. Uploaded Files and Multimedia Data. If the User uploads files (images, stickers, fonts) into the Application, the following data processing rules apply:

2.5.1. Access to photographs. To allow the User to choose an image to edit, the Application opens the photo selection interface provided by the User's operating system. On iOS that interface runs outside the Application and hands Us only the single file the User selects. The Application does not browse, read, index, or scan the User's photo library. On Android the Application requires permission to read image media where required by the operating system, and that permission may be revoked at any time in device settings. To save an Exported image, the Application requests write-only ("add only") access to the photo library on iOS, which allows it to add an image but not to read existing ones. Access to files, where offered, is requested only as necessary for the User-selected import operation and remains subject to the permissions and controls provided by the operating system.

2.5.2. Processing of imported files. The User may import their own photographs into the Application and apply presets, colour correction tools (including HSL adjustments), text, stickers, crops, and other editing features. Imported images, working copies of them, Compositions, Projects, thumbnails, Imported Assets, and Exported images are stored and processed on the User's device. Presets and adjustments are computed on the device by the Application itself. As at the date of this Policy the Application performs no server-side image processing and uploads no images to Us. The categories of information that do leave the device are described in Section 2.5.8.

2.5.3. Local Projects. The Application may allow the User to save edited photos and designs as local "Projects" within the Application. These projects are stored only on the User's device and are not synchronized with or backed up to Our servers.

2.5.4. Public Content Sharing (if enabled in the future) - uploading content to publicly available sections of the Application requires separate consent.

2.5.5. Deletion of uploaded content – the User can delete files from the device's storage as well as from public sections of the Application (if such functionality is available).

2.5.6. The Application does not analyze, transfer, or use uploaded files without the User's consent and does not request access to files without explicit permission.

2.5.7. Imported Assets. The User may import their own font files for use as custom fonts and their own images for use as custom stickers. These are copied into the Application's local storage on the device and are not transferred to Us. Copies managed by the Application are removed from the Application's local storage when the User removes the corresponding Imported Asset through the functionality provided by the Application. Removing the Application from the device removes its locally stored application data, subject to any device or platform backup controlled by the User or their platform provider.

2.5.8. What leaves the device. As at the date of this Policy, nothing described in Sections 2.5.2, 2.5.3, and 2.5.7 leaves the User's device except in the following cases:

2.5.8.1. Analytics events recording that a feature was used, which contain identifiers, counts, and predefined labels only, and which are not designed to carry image content, file names, or the text of a search query.

2.5.8.2. Crash and diagnostic reports, which contain technical error information only.

2.5.8.3. Files that the User themselves attaches to a support enquiry, which are transmitted to Us together with that enquiry as described in Section 2.8.

2.5.8.4. Screen recordings of the Application generated by Our product analytics provider, PostHog, which are used to diagnose usability problems. As at the date of this Policy, session replay is configured to mask text and images on the device before the recording is transmitted to PostHog. This is intended to prevent photographs displayed on the editing canvas, Imported Assets, and text entered by the User from appearing in session recordings, while allowing Us to understand screen layout and the sequence of User interactions. These recordings are transmitted to and stored by PostHog, presently on servers within the European Union, and are retained for the period stated in Section 3.8.3. A User who does not wish their sessions to be recorded may object as provided in Section 8.4.4.

2.5.8.5. An Exported image that the User themselves transfers to another application or platform using their own device. Such an image is not transmitted to Us at all.

2.5.9. Metadata in photographs. Photographs may carry embedded metadata such as the date and time of capture, the camera model and, if the User's camera records it, the geographic coordinates of the place where the photograph was taken. The Application does not read, interpret, or transmit this metadata, does not request access to photograph location data, and does not determine the User's location from a photograph. Where a photograph is re-encoded on import, its metadata is discarded. Where the photograph is used as it is, the copy stored by the Application as part of the relevant Project may still contain the original metadata. That Project-managed copy is removed from the Application's local storage when the corresponding Project is deleted. Images Exported from the Application are newly generated and are not intended to carry over metadata from the source photograph. The User should nevertheless be aware that publishing a photograph elsewhere may disclose where it was taken.

2.5.10. No facial or biometric processing and no generative artificial intelligence. As at the date of this Policy, the Application does not perform face detection, face recognition, face matching, or any other biometric identification or categorisation, creates no biometric template, and contains no generative artificial-intelligence feature: every element of a Composition is placed and adjusted by the User. Accordingly, Our processing of photographs does not at present involve special categories of personal data.

2.6. Compliance with GDPR and CCPA. We ensure transparency in data collection and processing in accordance with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Users have the right to:

2.6.1. Request access to their data.

2.6.2. Correct or delete their personal data.

2.6.3. Restrict the processing of their data within the legal framework.

2.6.4. Requests for access, modification, or deletion of data can be submitted to our support team via support@inspiroapp.com.

2.7. Methods of Collecting Personal Data. We collect personal data through the following methods:

2.7.1. Automatically when using the Application – interaction data (session duration, clicks, errors), technical data (device, OS, IP address) collected via Firebase Analytics, Google Analytics, AppsFlyer Analytics, PostHog Analytics, Meta Analytics.

2.7.2. During registration or subscription purchase – if this function is available, we receive contact details (email, name) through Apple ID, Google Account, or payment services (RevenueCat, App Store, Google Play).

2.7.3. Through the Application's functionality – content that the User imports (images, fonts, stickers) is processed locally on the device, in accordance with Sections 2.5.2 and 2.5.8.

2.7.4. Through cookies and tracking technologies – details on their use are described in Section 8 (Cookies and Tracking Technologies).

2.7.5. Through customer support requests – if the User contacts us via email or a support form, we receive the information they provide, as described in Section 2.8.

2.8. Support Enquiries. When the User contacts Us through the Application, We receive the name, email address, and message they provide, any file the User chooses to attach, and, in order to help Us reproduce the problem reported, the Application version, operating system version, device language, store country, and the subscription and attribution identifiers associated with that installation of the Application. Enquiries are transmitted and held as electronic mail in Our corporate mailbox and are retained in accordance with Section 3.8.4. Attachments may contain photographs or videos, and the User is advised to attach only what is necessary to explain the problem.

2.9. Promotional Codes. Where the User redeems a promotional code, We record in Our database that the code has been used and associate that record with a technical identifier of the installation of the Application on the User's device, so that the same code cannot be redeemed twice. This identifier is not linked to a name, an email address, or an account.

2.10. The Website. Where the User submits the contact form on the website, We receive the name, email address, and message they enter and transmit them to Our corporate mailbox by electronic mail. The submission is also recorded in Our hosting provider's technical logs. The website uses analytics only where the User accepts them in the consent banner presented on first visit. That choice is stored in the User's browser and may be changed at any time from the website footer. As at the date of this Policy the website sets no advertising cookies. The website does not provide the Editor and does not process photographs.

3. HOW WE USE DATA

3.1. We process Users' personal data to ensure the functionality of the Application, fulfill legal obligations, and enhance the user experience. All data processing operations comply with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

3.2. Main Purposes of Data Processing. We collect and analyze information exclusively for the following purposes:

3.2.1. Application Functionality and Performance: Managing subscriptions, granting access to premium content, enabling Users to import and edit their own photographs (including applying presets, colour correction tools such as HSL, and other effects), enabling Users to place text and stickers on a canvas, save the result as a local Project, and export it to their device photo library, as well as processing imported images, custom fonts, and stickers locally on the User's device. This purpose also covers optimizing interface performance, troubleshooting, and adapting functionality for different devices.

3.2.2. Personalized User Experience: Adjusting the Application based on user preferences, interactions with content, and selected settings. Allowing Users to save font, sticker, and template usage history for quick access.

3.2.3. Security and Data Protection: Detecting suspicious activity and preventing fraud. Controlling access to user accounts and preventing unauthorized use.

3.2.4. Support and Maintenance: Responding to User inquiries and resolving technical issues. Improving customer support based on analysis of common problems and inquiries.

3.2.5. Analytics and Application Development: Analyzing anonymized data to understand which features are most in demand and how Users interact with the Application. Using those insights to enhance the interface, make content more relevant, and introduce new features.

3.2.6. Legal Compliance: Processing data to comply with GDPR and CCPA requirements, including handling User requests for data deletion or exercising their rights.

3.3. Each of these processes is implemented in strict accordance with the principle of data minimization—we collect only the information that is truly necessary for the operation of the Application.

3.4. Automated Processing and Decision-Making. Some processes within the Application are automated, but no automated decisions produce legally significant consequences for the User without human oversight. Automated processing includes:

3.4.1. Personalized Interface and Content. The Application analyzes which fonts and stickers are most frequently used by the User and suggests quick access to them. Based on User preferences, new or relevant content may be recommended.

3.4.2. Error Detection. The Application automatically logs crashes and sends diagnostic reports to Firebase Crashlytics to improve stability.

3.4.3. Security Measures. If suspicious activity is detected, such as an attempt to log in from an unrecognized device, the system may temporarily block the account and request identity verification.

3.5. We apply a "human review" principle, meaning that the User can always request clarification if an automated system restricts access or suggests personalized content.

3.6. Marketing Communications and Push Notifications

3.6.1. We do not sell personal data to advertisers or share it with third parties for marketing purposes without User consent.

3.6.2. If the User has agreed to receive notifications, we may send personalized offers within the Application.

3.6.3. The User can disable notifications at any time in their device settings.

3.6.4. We maintain transparency, ensuring that the User can see what data is used for marketing and can opt out entirely.

3.7. Use of Anonymized Data. We may use anonymized and aggregated data for analytics, trend research, and new feature development. These data sets contain no personally identifiable information and do not allow for User identification.

3.8. Data Retention Periods. We retain personal data only for as long as necessary to fulfill the processing purposes, after which it is securely deleted or anonymized.

3.8.1. Account Data – stored until the User deletes their account or requests data deletion. Upon deletion, data is removed within 30 days, unless legal requirements mandate continued retention.

3.8.2. Subscription and Payment Data – records of subscription status and entitlement are stored for one year after subscription cancellation in accordance with Apple App Store and Google Play policies. Accounting and tax records evidencing a transaction are retained for the longer period stated in Section 3.8.5, as required by law.

3.8.3. Activity Logs, Analytics, and Session Recordings (Application Usage Data) – stored for up to 12 months, after which they are deleted or anonymized.

3.8.4. Customer Support Data, including any attachments – stored for up to 6 months after the resolution of the inquiry, unless required otherwise by law.

3.8.5. Financial and accounting records – may be retained for up to 5 years to comply with accounting and tax regulations.

3.8.6. Promotional code redemption records – retained for as long as the promotional campaign remains capable of being audited, and in any event no longer than 3 years.

3.8.7. This Section 3.8 is the single retention schedule applicable under this Policy. Section 5.4 restates it for convenience. In the event of any discrepancy, this Section 3.8 prevails.

3.9. After expiration of the retention period, the data is permanently deleted without the possibility of recovery unless further storage is legally required.

3.10. How We Ensure Data Confidentiality. We implement comprehensive data protection measures, including:

3.10.1. Encryption of data in transit and at rest (TLS 1.2+, AES-256).

3.10.2. Access restrictions – only authorized employees can handle personal data.

3.10.3. Data minimization – collecting only the necessary information.

3.10.4. Security monitoring – continuous tracking of suspicious activity in the system.

3.11. The User may at any time exercise the rights set out in Section 7, including requesting deletion of their data, and may object to analytics collection as provided in Section 8.4.4. Content held only on the User's device remains under the User's own control at all times, as described in Section 7.3.

3.12. Legal Basis for Data Processing. We process personal data only on lawful grounds as defined in Article 6 of the GDPR. Depending on the situation, we rely on one or more of the following legal bases:

3.12.1. User Consent (Art. 6(1)(a) GDPR) – data may be processed if the User has explicitly consented (e.g., for receiving marketing notifications or analytics).

3.12.2. Contract Performance (Art. 6(1)(b) GDPR) – when processing is necessary to provide access to the Application, complete payment transactions, or support functionality.

3.12.3. Legitimate Interests (Art. 6(1)(f) GDPR) – data may be processed to protect our interests, such as fraud prevention, account security, and investigating violations.

3.12.4. Legal Obligations (Art. 6(1)(c) GDPR) – if data processing is required for compliance with legal regulations (e.g., retaining financial transaction records for tax purposes).

3.13. We do not use personal data for automated decision-making that produces legal effects for the User (Article 22 GDPR) without their explicit consent.

3.14. Who Is Responsible for Data Processing? In compliance with Article 37 GDPR, we appoint a Data Protection Officer (DPO) responsible for overseeing data protection practices.

3.14.1. If you have questions regarding data protection, you may contact our DPO at support@inspiroapp.com.

3.14.2. Data Controller: Individual entrepreneur Hrinchenko Polina Volodymyrivna, registered in Ukraine.

3.14.3. Jurisdiction: EU (for GDPR compliance), California (for CCPA compliance).

4. DATA SHARING WITH THIRD PARTIES

4.1. We value the privacy of our Users and do not share personal data with third parties without a legal basis. Access to information is granted only in cases necessary for the operation of the Application, payment processing, security measures, or compliance with legal obligations. This section explains when data may be shared with third parties and what protective measures are applied in such cases.

4.2. When Data May Be Shared with Third Parties. We share personal data only in the following circumstances:

4.2.1. For the Functionality of Essential Application Services

4.2.1.1. Data is shared with services that analyze user behavior (Google Analytics, Firebase, AppsFlyer, PostHog, Meta Analytics) for diagnostics, technical issue resolution, and data storage.

4.2.1.2. To process subscriptions and payments, information is transmitted to Apple App Store and Google Play. We do not store payment details, and all transactions are handled exclusively by these platforms.

4.2.1.3. To deliver the sticker catalogue and font preview images shown in the Application, the Application requests those assets from Our content service. As at the date of this Policy these are download requests, and no image, Composition, Project, or other User Content is sent with them. If third-party APIs are used in future (for example, for cloud content storage or content generation), only the minimum necessary information will be shared and this Policy will be updated accordingly.

4.2.2. For Legal Compliance

4.2.2.1. We may share personal data with government authorities or law enforcement agencies upon official request if required by law.

4.2.2.2. Data may be shared in the course of fraud investigations, intellectual property rights violations, or other legal proceedings.

4.2.3. In the Event of Business Reorganization

4.2.3.1. If we are involved in a merger, acquisition, or sale of assets, User data may be transferred to the new owner, provided that confidentiality is maintained.

4.2.4. We do not sell or transfer personal data to advertisers or marketing companies without the User's explicit consent.

4.3. International Data Transfers. Since our servers and partner services may be located in different countries, User data may sometimes be transferred outside their country of residence.

4.3.1. If data is transferred outside the European Economic Area (EEA), we ensure an adequate level of protection by using the Standard Contractual Clauses (SCCs) approved by the European Commission.

4.3.2. If data is transferred to jurisdictions that do not provide an adequate level of data protection, we apply additional security measures such as encryption and access restrictions.

4.4. Security Measures for Data Transfers. Personal data is transferred only when appropriate security mechanisms are in place, including:

4.4.1. Encryption during transmission (SSL/TLS) to prevent unauthorized interception by third parties.

4.4.2. Access control mechanisms, restricting data usage only to the services that require it.

4.4.3. Data Processing Agreements (DPAs) with third parties to ensure compliance with GDPR and CCPA regulations.

4.5. User Rights Regarding Data Sharing. Each User has the right to:

4.5.1. Request information on what data has been shared with third parties and on what legal basis.

4.5.2. Restrict data sharing, if it does not affect the Application's functionality.

4.5.3. Withdraw consent for data processing and sharing in certain cases.

4.6. All requests related to data sharing can be submitted to our support team at support@inspiroapp.com.

5. DATA STORAGE AND PROTECTION

5.1. We recognize that protecting personal data is a priority for our Users and take all necessary measures to ensure its security. This section explains where and how data is stored, what security mechanisms are applied, and what actions are taken in the event of data privacy incidents.

5.2. Where Data Is Stored. The storage of data depends on its type and the functionality of the Application:

5.2.1. User personal data, including account information, subscription details, and payments, is stored on cloud servers certified under international security standards (ISO/IEC 27001, GDPR, CCPA). We use third-party infrastructure providers such as Google Cloud (hosting), Firebase (analytics, crash reports), AppsFlyer (analytics, crash reports), PostHog (analytics, product insights), Meta (analytics), and RevenueCat (subscription management), located in the EU and the US. These providers operate in accordance with recognized international security standards (such as ISO/IEC 27001) and apply strong encryption and access control to ensure data protection and compliance with the GDPR and CCPA.

5.2.2. Payment data is not stored on our servers. All financial transactions are processed exclusively through Apple App Store and Google Play, which comply with the Payment Card Industry Data Security Standard (PCI DSS).

5.2.3. Local storage: photographs imported for editing, working copies of them, Compositions, Projects, thumbnails, Imported Assets, and Exported images are stored and processed locally on the User's device. Such data is not transferred to Our servers, save as described in Section 2.5.8, and is fully under the User's control on their device. Depending on the User's own device and operating system settings, the Application's storage may be included in a device backup operated by the User's platform provider, such as iCloud Backup. Such backups are controlled by the User and that provider, and not by Us.

5.2.4. Cross-border data transfers are conducted only under internationally recognized protection mechanisms, such as the Standard Contractual Clauses (SCCs) approved by the European Commission.

5.3. How We Protect Data. To prevent breaches, unauthorized access, and other security threats, we employ a combination of protection measures, including:

5.3.1. Encryption at all levels:

5.3.1.1. Data in transit is secured using TLS 1.2+.

5.3.1.2. Stored data is encrypted with the AES-256 standard.

5.3.2. Access control system:

5.3.2.1. Access to data is restricted to authorized employees only, who undergo verification and operate under strict access levels.

5.3.2.2. All changes in the database are recorded in security logs.

5.3.3. Monitoring and response:

5.3.3.1. An automated system detects and responds to suspicious activity.

5.3.3.2. Any detected anomalies are analyzed immediately, and corrective measures are taken if necessary.

5.3.3.3. We conduct regular security audits and penetration testing to ensure compliance with modern data protection standards.

5.4. Data Retention Periods. The retention schedule is set out in Section 3.8 and is restated below for convenience. In the event of any discrepancy, Section 3.8 prevails. We retain personal data only for as long as necessary to achieve the purposes of processing, after which it is deleted or anonymized:

5.4.1. Account data – stored until the User deletes their account, after which it is permanently erased within 30 days.

5.4.2. Activity logs and analytics – stored for up to 12 months, after which they are deleted or anonymized.

5.4.3. Subscription and payment data – retained for 1 year after subscription cancellation to comply with tax and financial reporting requirements.

5.4.4. Customer support inquiries – stored for up to 6 months after resolving the request.

5.4.5. Financial and accounting records – may be retained for up to 5 years in accordance with legal requirements.

5.5. After the retention period expires, data is automatically deleted or anonymized unless further storage is required by law.

5.6. Data Breach and User Notification. In the event of a data breach or unauthorized access, we follow these key principles:

5.6.1. Immediate incident assessment – upon detection, we evaluate the nature of the breach, the volume of affected data, and potential risks.

5.6.2. Corrective measures – we take actions to prevent recurrence, including blocking unauthorized access and strengthening security protocols.

5.6.3. User and regulatory notifications – if personal data is affected, we notify the competent authorities within the timeframe required by GDPR and CCPA, and inform affected Users through official communication channels.

5.7. We are committed to minimizing the likelihood of such incidents and continuously improving our security infrastructure.

6. USER-GENERATED CONTENT MANAGEMENT

6.1. The Inspiro Application provides Users with tools for creating and editing content, including uploading images, fonts, and stickers. This section explains how uploaded files are processed, where they are stored, what rights Users retain over their content, and how data deletion works.

6.2. Uploaded Files and Content Created in the Application. When using the Application, Users may upload and edit files (such as images, stickers, and fonts). It is important to note that:

6.2.1. All imported files, including photos and other images edited in the Application, custom fonts, and custom stickers, are processed locally on the User's device. We do not transfer or store such files, Compositions, or local Projects on Our servers, save as described in Section 2.5.8.

6.2.2. The Application may request access to the device's storage or photo library where necessary for importing or exporting content. Such access is subject to the permissions and controls provided by the User's operating system and may be revoked through device settings where supported.

6.2.3. If the functionality allows for public access, the User independently decides whether to share content in publicly accessible sections.

6.2.4. We do not analyze, index, or use uploaded files without the User's consent.

6.3. User Rights to Uploaded and Created Content. The User retains full ownership rights over uploaded and created files. However, if content is published in publicly accessible sections of the Application, the following policies apply:

6.3.1. Private Content – remains accessible only to the User.

6.3.2. Public Content – if the User shares content in public sections, they grant a non-exclusive license for other Users to use it within the functionality of the Application.

6.3.3. Commercial Use – content created in the Application may be used for commercial purposes (e.g., in design projects or social media) unless restricted by a specific license.

6.3.4. We do not claim ownership rights over User-generated content unless it is explicitly published for public access.

6.4. Deleting Uploaded Files and Content. Users may delete their created content at any time, with the following conditions:

6.4.1. Locally stored files and Projects (including edited photos saved within the Application) are deleted directly from the User's device. We do not have access to such local content and cannot delete it remotely.

6.4.2. If content was uploaded to a public section, its deletion does not affect previously granted licenses or downloaded copies.

6.4.3. Automatic deletion – content that violates the Application's rules or legal requirements may be removed without prior notice.

6.4.4. Full data deletion requests can be submitted to our support team for review.

6.5. User Responsibility for Content. The User agrees not to upload content that:

6.5.1. Infringes on third-party intellectual property rights (e.g., unlicensed images or fonts).

6.5.2. Contains illegal materials prohibited under international law.

6.5.3. Is misleading or intended for disinformation.

6.5.4. Depicts an identifiable person without that person's consent to the editing, publication and, where applicable, commercial use of the depiction, or depicts a minor without the consent of that minor's parent or legal guardian.

6.5.5. Falls within any of the categories of prohibited material listed in Section 14.2.5 of the Terms of Use, including any sexual or sexualized depiction of a minor, any intimate depiction of a real person created without their consent, and any image impersonating a real person, brand, authority, or news organisation.

6.5.6. Is an Imported Asset, including a font file, that the User is not licensed to use.

6.6. We reserve the right to block or remove content that violates these terms, to the extent that content is within Our control. Content held only on the User's device is not within Our control, and the measures available to Us in respect of it are described in Section 11.6.4 of the Terms of Use. Reports may be submitted to support@inspiroapp.com as provided in Section 11.6.3 of the Terms of Use.

6.7. Public Access and Content Usage by Other Users. If the Application allows content publication, the User acknowledges that:

6.7.1. Publicly shared content may be used by other Users within the Application's functionality.

6.7.2. Content deletion does not revoke existing licenses – if content has been downloaded or used, its removal does not cancel previously granted rights.

6.7.3. We are not responsible for how third parties use publicly shared content outside of the Application.

7. USER RIGHTS

7.1. We respect the rights of Users regarding their personal data and ensure their enforcement in accordance with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). This section details the rights Users have and how they can exercise them.

7.2. Key Rights Under GDPR and CCPA. Users of the Application are entitled to the following rights:

7.2.1. Right to Access Data (Art. 15 GDPR, §1798.110 CCPA) – Users can request information about what data we collect, how it is used, and to whom it is disclosed.

7.2.2. Right to Rectification (Art. 16 GDPR, §1798.106 CCPA) – If any personal data is outdated, incorrect, or incomplete, Users can request its correction.

7.2.3. Right to Deletion ("Right to Be Forgotten") (Art. 17 GDPR, §1798.105 CCPA) – Users may request the deletion of their personal data, provided there are no legal grounds for its continued processing.

7.2.4. Right to Restriction of Processing (Art. 18 GDPR) – Users may temporarily restrict the processing of their data, for example, while verifying its accuracy.

7.2.5. Right to Data Portability (Art. 20 GDPR) – Users can request a copy of their data in a machine-readable format (e.g., JSON, CSV) and transfer it to another service provider.

7.2.6. Right to Object to Automated Decision-Making (Art. 22 GDPR) – If a decision affecting User rights (e.g., account suspension) is made automatically, the User can request a review involving human intervention.

7.2.7. Right to Opt-Out of Data Sales (CCPA, §1798.120) – California residents can prohibit the transfer of their personal data to third parties for commercial purposes.

7.3. Content held only on the User's device. We ensure the implementation of these rights in compliance with applicable legal requirements. To avoid any doubt, Projects, Compositions, Imported Assets, working copies of imported images, and Exported images are held in the Application's storage on the User's device or in the device photo library, and, save as described in Section 2.5.8, We do not receive them and may not be technically able to retrieve, correct, export, or delete them in response to a request under Section 7.2. The User controls this content directly:

7.3.1. A Project may be deleted in the Application's project list.

7.3.2. An Imported Asset, such as a custom font or custom sticker, may be removed in the screen from which it was imported.

7.3.3. Deleting the Application from the device erases all Projects, Imported Assets, and working copies of imported images. This is irreversible, and We are not able to restore them.

7.3.4. An Exported image is deleted in the device's own photo library.

7.3.5. Requests under Section 7.2 in respect of data that We do hold, namely analytics and crash identifiers, session recordings, subscription records, promotional code records, and support correspondence, are handled as described in Section 7.4.

7.4. How Users Can Exercise Their Rights. Users can submit a request to exercise their rights in the following ways:

7.4.1. By sending an inquiry to support@inspiroapp.com.

7.4.2. In the case of analytics data and session recordings, by written request as provided in Section 8.4.4. On the website, analytics may also be declined or later withdrawn in the consent banner and from the website footer.

7.4.3. We are committed to:

7.4.3.1. Responding to requests within 30 days (or within 45 days for California residents under CCPA).

7.4.3.2. Notifying Users if an extension is needed (e.g., for further verification) and providing reasons for any delays.

7.4.3.3. Providing a clear explanation if a request cannot be fulfilled due to legal or technical constraints.

7.4.3.4. Delivering requested data in a structured and machine-readable format (such as JSON, CSV, or similar).

7.4.3.5. Implementing identity verification measures (e.g., email verification) to prevent unauthorized access to personal data.

7.5. Limitations on the Exercise of Rights. Some requests may be denied under the following circumstances:

7.5.1. Legal Obligations – If data cannot be deleted due to legal requirements (e.g., retention of financial transaction records for a set period).

7.5.2. Abuse of Rights – If a request is excessive, repetitive without valid reason, or made in bad faith.

7.5.3. Protection of Third-Party Rights – If fulfilling a request would infringe on the rights of other Users or organizations (e.g., during legal proceedings).

7.6. If a request is denied, the User will receive an explanation and possible further actions they can take.

7.7. Right to File a Complaint. If a User believes their rights have been violated, they may:

7.7.1. Contact customer support to resolve the issue.

7.7.2. File a complaint with a data protection authority in their country:

7.7.2.1. For European Union residents – with their national data protection authority or the European Data Protection Board (EDPB).

7.7.2.2. For California residents – with the California Attorney General.

7.8. We are committed to cooperating with regulatory authorities and taking necessary measures to address any violations.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1. To ensure the stable operation of the Application, personalize the user experience, and conduct analytics, we use cookies and other tracking technologies. This section explains which technologies are used, how they work, and what settings are available to Users.

8.2. What Are Cookies and Tracking Technologies? Cookies are small text files stored on the User's device that help us remember their preferences, enhance the Application's usability, and analyze behavior. In addition to cookies, we also use:

8.2.1. Local Storage – Allows the storage of settings and data for quick access.

8.2.2. Pixels and Tags – Small pieces of code used to analyze interaction with the Application.

8.2.3. Device Identifiers (Device IDs) – Help analyze Application usage across different platforms.

8.3. What Cookies and Technologies Do We Use? We use several types of cookies and similar technologies:

8.3.1. Functional Cookies – Ensure the basic operation of the Application (e.g., remembering User preferences and account settings). Without them, some features may not work correctly.

8.3.2. Analytical Cookies – Help us collect anonymized information about how Users interact with the Application. We use:

8.3.2.1. Google Analytics – To analyze User behavior and improve functionality.

8.3.2.2. Firebase Analytics – To monitor errors and Application performance.

8.3.2.3. AppsFlyer Analytics – To monitor errors and Application performance.

8.3.2.4. PostHog Analytics – To track feature usage and gather product improvement insights.

8.3.2.5. Meta Analytics – To analyze User behavior and marketing campaign performance.

8.3.3. Marketing Cookies – If the User has provided consent, these may be used for personalized recommendations and push notifications within the Application.

8.3.4. Security and Protection Technologies – Used to prevent fraud and secure accounts.

8.4. How Can Users Manage Cookies and Tracking? We respect Users' rights to control their data. They can:

8.4.1. Disable or restrict cookies in their device or browser settings.

8.4.2. Revoke the Application's access to photographs and notifications at any time in device settings.

8.4.3. Disable push notifications for the Application at any time in device settings.

8.4.4. Object to the processing of their analytics data, including session recordings, or withdraw any consent given for it, by writing to support@inspiroapp.com. We will consider and give effect to such requests to the extent required by applicable data protection law.

8.4.5. Use the privacy management tools published by Our analytics providers, namely Google (Google Analytics and Firebase), AppsFlyer, PostHog, and Meta. Links to their privacy policies are given in Section 8.6.

8.4.6. On the website, accept or decline analytics in the consent banner presented on first visit, and change that choice at any time from the website footer. Where analytics are declined, they are not loaded. As at the date of this Policy the website sets no advertising cookies.

8.5. Some cookies are necessary for the Application to function properly, and disabling them may limit certain features.

8.6. Data Sharing with Third Parties. Cookies and analytics technologies may transmit anonymized data to third parties if allowed under their policies:

8.6.1. Google (Google Analytics, Firebase) – Google Privacy Policy: https://policies.google.com/privacy

8.6.2. AppsFlyer - AppsFlyer Privacy Policy: https://www.appsflyer.com/legal/privacy-policy/

8.6.3. PostHog - PostHog Privacy Policy: https://posthog.com/privacy

8.6.4. Meta - Meta Privacy Policy: https://www.facebook.com/privacy/policy/

8.6.5. Airbridge - Airbridge Privacy Policy: https://www.airbridge.io/privacy-policy

8.6.6. Singular - Singular Privacy Policy: https://www.singular.net/privacy-policy/

8.6.7. Apple (App Store Analytics) – Apple Privacy Policy: https://www.apple.com/legal/privacy/en-ww/

8.7. We do not share personally identifiable User data with third parties without explicit User consent.

9. AGE RESTRICTIONS AND CHILD DATA PROTECTION

9.1. Age Restrictions. The use of the Application is permitted only for Users who meet the established minimum age requirements:

9.1.1. For Users in the EU – The minimum age is regulated under Article 8 of the GDPR. The applicable thresholds are those set out in the table in Section 3.3 of the Terms of Use, which is the single controlling list, namely: Germany 16, Netherlands 16, Poland 16, Ireland 16, France 15, Czech Republic 15, Spain 14, Italy 14, Austria 14, and Sweden, Belgium, Denmark, Finland and Portugal 13. Other EU countries – 13 years old, unless a higher age is specified by local law.

9.1.2. For Users in the United States – In compliance with COPPA (Children's Online Privacy Protection Act), the minimum age for independent use is 13 years old.

9.2. If a User has not reached the required minimum age, they may use the Application only with written consent from a parent or legal guardian. Where a User transfers an image created in the Application to a social network or other platform, that platform's own minimum age requirements and terms apply in addition to those set out here, and the User is responsible for complying with them.

9.3. How We Protect the Data of Minors. We do not knowingly collect or process personal data from children under 13 years old without parental or guardian consent. If we discover that an account belongs to a child who registered without parental approval, we reserve the right to:

9.3.1. Restrict or block access to the Application.

9.3.2. Delete the minor's personal data as soon as possible.

9.3.3. Request proof of age or parental consent if necessary to continue using the Application.

9.4. Parental Controls and Rights of Parents/Guardians. Parents or legal guardians have the right to:

9.4.1. Request the deletion of their child's data – If they believe that personal data was collected without their consent.

9.4.2. Restrict access to certain features – If such options are available through device settings or platform controls (Google Play, Apple App Store).

9.4.3. Contact us with any concerns regarding the protection of children's data via support@inspiroapp.com.

9.5. Advertising and Tracking Policy for Minors

9.5.1. We do not display personalized ads to Users under 18 years old and do not share their data with advertising services.

9.5.2. If a minor User has enabled push notifications, they can disable them at any time through their device settings.

10. LIMITATION OF LIABILITY

10.1. Disclaimer of Liability for Data Loss or Breach. We implement security measures to protect Users' personal data in compliance with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). However:

10.1.1. We are not responsible for data breaches or compromises resulting from cyberattacks, malware infections, server failures, or other technical incidents beyond our control.

10.1.2. We are not responsible for data loss caused by the User, including:

10.1.2.1. Use of weak passwords or sharing login credentials with third parties.

10.1.2.2. Unauthorized access to an account due to compromised or infected devices.

10.1.2.3. Intentional or accidental deletion of information by the User.

10.2. If a data breach occurs, we will take appropriate action under Article 33 of the GDPR, including:

10.2.1. Notifying regulatory authorities and affected Users of any potential risks.

10.2.2. Providing security guidance (e.g., password change, enabling two-factor authentication).

10.3. Disclaimer of Liability for Third-Party Actions. We may share Users' personal data with third-party service providers, including analytics, payment processors, marketing platforms, and technical service providers. However:

10.3.1. We do not control the privacy policies of third-party services (e.g., Google, Apple, Firebase, RevenueCat, AppsFlyer, PostHog, Meta).

10.3.2. We are not responsible for their errors, failures, or data breaches.

10.3.3. We are not responsible for the actions of App Store and Google Play, including subscription processing and payment handling.

10.4. Before using third-party services, the User must review and agree to their respective privacy policies and terms.

10.5. Liability for User-Uploaded Content. Inspiro allows Users to upload and use content, including fonts, stickers, and images. However:

10.5.1. We are not responsible for the copyright status of imported files, including photographs, other images, custom stickers, and custom font files, if the User uses unlicensed or unauthorized content, nor for the User obtaining the consent of any person depicted in an imported photograph.

10.5.2. We are not liable for any reputational or financial damages caused by the use of third-party content.

10.5.3. We reserve the right to remove content that violates the law or our policies.

10.5.4. If a User violates third-party rights (e.g., copyright, trademarks, intellectual property), they bear full legal responsibility for any resulting consequences.

11. CHANGES TO THE PRIVACY POLICY

11.1. We reserve the right to update this Privacy Policy to ensure compliance with legal changes (GDPR, CCPA), new platform requirements (Google Play, App Store), and improvements to the functionality of the Application.

11.2. When and Why Do We Update the Privacy Policy? Updates to this Policy may occur due to the following reasons:

11.2.1. Changes in Legislation – If new requirements arise under GDPR, CCPA, or other applicable laws, we will update the Policy accordingly.

11.2.2. Introduction of New Features – If we implement new functionalities involving the processing of personal data, such as additional authentication methods or integration with third-party services.

11.2.3. Enhancement of Security Measures – If we introduce new technologies to protect user data or change storage providers.

11.3. All changes aim to increase transparency and strengthen data protection.

11.4. How Will Users Be Notified of Changes? If significant changes are made to the Privacy Policy that affect Users' rights, we will notify them through:

11.4.1. In-App Notifications – A push notification or pop-up message summarizing the updates.

11.4.2. Email Communication – If we have the User's contact details (e.g., in case of account registration).

11.4.3. Publication of the Updated Policy – The revised version will be made available in the Application and on our official website.

11.5. Users are expected to review the updated Policy, and continued use of the Application after changes take effect constitutes acceptance of the new terms.

11.6. What If a User Does Not Agree with the Updates? If a User disagrees with the updated Policy, they may:

11.6.1. Limit the data collected about them by revoking the Application's permissions in device settings and by objecting to analytics collection as provided in Section 8.4.4.

11.6.2. Delete their account and data by contacting User Support.

11.6.3. Discontinue using the Application if the changes significantly alter the data processing terms.

11.7. For any inquiries regarding the changes, Users may contact us at support@inspiroapp.com for further clarification.

12. CONTACT INFORMATION

12.1. If you have any questions regarding this Privacy Policy, the processing of your personal data, or the exercise of your rights under GDPR and CCPA, you may contact us through the following channels.

12.2. How to Contact Us? You can reach us through the following means:

12.2.1. Email: support@inspiroapp.com – for any inquiries related to privacy, data deletion, or user rights.

12.2.2. Postal Address: Ukraine, 02121, Kyiv, Bratstva Tarasivtsiv Street, building 6, apartment 231 – for official written requests concerning data protection.

12.2.3. In-App Support: If available, you may submit a request through the "Privacy" section in the Application settings.

12.3. Response Timeframes

12.3.1. Acknowledgment of request: Within 5 business days.

12.3.2. Full response: Within 30 days (or up to 45 days for California residents under §1798.130 CCPA).

12.3.3. If additional time is required to process the request, we will notify you and explain the reason for the delay.

12.4. Contact Information for Data Protection Authorities

12.4.1. If you are a resident of the European Union and believe that we have violated your data protection rights, you may file a complaint with the data protection authority in your country or escalate the matter to the European Data Protection Board (EDPB).

12.4.2. For California residents, the appropriate regulatory body is the California Attorney General's Office.

12.5. Our Commitment to Transparency

12.5.1. We are committed to handling all user requests in a transparent and efficient manner, ensuring that you receive full information regarding your privacy rights and data protection.

12.5.2. If your request requires further clarification, we are always available to provide guidance and assistance in resolving any privacy-related concerns.