Privacy Policy.

This Privacy Policy describes how Swell Games, TOO ("we", "us", or "our") collects, uses, and protects your information when you use the Flash7X mobile application and visit www.flash7x.app. We are committed to protecting your privacy and handling your data transparently.

1. Data We Collect In the App

Flash7X processes all image and photo data exclusively on your device using native Metal shaders. We do not upload, transmit, or store your photographs on any external servers.

We collect the following limited technical data:

• — Camera access: Used solely to display the live viewfinder and capture photos. Images are processed on-device and saved to your Photo Library only with your permission.
• — Photo Library access: Only accessed if you choose to save a captured image or import a photo for processing. We do not read your existing library.
• — Anonymous crash diagnostics: Collected via Firebase Crashlytics to improve application stability. These reports contain no personally identifiable information and no image data.
• — Anonymized usage analytics: Collected via Firebase Analytics (linked to Google Analytics 4). This includes session duration, feature interactions, and device type. No photos or personal identifiers are included.
• — Purchase history: Subscription status is managed securely by Apple StoreKit. We receive only anonymized confirmation of active subscription status — never your payment card details.
• — App Tracking Transparency (ATT): Flash7X does not use the Apple Advertising Identifier (IDFA) and does not display an ATT prompt. We do not track you across third-party apps or websites for advertising purposes.

2. Data Collected via the Website & Payments

When you visit www.flash7x.app:

• — Analytics cookies: We use Google Analytics 4 (GA4) via Firebase to understand how visitors interact with the site. This data is anonymized and aggregated. EU visitors will be prompted for cookie consent.
• — Email address: If you contact our support team, your email is used solely to respond to your inquiry.

Web purchases, if offered, are processed by Paddle.com, our Merchant of Record. Paddle collects your name, email, billing address, and payment information directly. We receive only limited purchase metadata (order ID, country, amount) — never your card details. For details on how Paddle handles your payment data, please review Paddle's Privacy Policy.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your data on the following lawful bases:

• — Contract performance: To provide the Flash7X application and subscription service you have purchased.
• — Legitimate interest: To analyze usage patterns and improve application stability via anonymized analytics and crash reports.
• — Consent: For optional analytics cookies on the website. You may withdraw consent at any time.

4. Third-Party Services

We use the following third-party services. Each operates under its own privacy policy:

• — Firebase / Google Analytics: Analytics, crash reporting, and performance monitoring. Firebase Privacy
• — Apple StoreKit: In-app subscription management and purchase validation.
• — Paddle: Web payment processing and Merchant of Record for web purchases.

We do not sell your personal information to any third parties. We do not use your data for advertising profiling.

5. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• — Access: Request a copy of the personal data we hold about you.
• — Correction: Request correction of inaccurate data.
• — Deletion: Request deletion of your personal data ("right to be forgotten").
• — Restriction: Request that we limit processing of your data.
• — Portability: Request your data in a structured, machine-readable format.
• — Objection: Object to processing based on legitimate interest.
• — California residents (CCPA): You have the right to know, delete, and opt out of the sale of personal information. We do not sell personal information.

To exercise any of these rights, contact us at support@swell.kz.

6. Data Retention

Anonymized analytics and crash data is retained for up to 14 months in accordance with Google Analytics default settings. Support correspondence is retained for up to 3 years. Purchase records are retained as required by applicable tax law. Since photos are processed entirely on your device, we retain no image data whatsoever.

7. Children

Flash7X is not directed at children under the age of 13 (or under 16 in the EEA). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately at support@swell.kz.

8. Security

We implement appropriate technical and organizational measures to protect your data. All data transmitted between the app and third-party services uses TLS encryption. On-device image processing means your photos never leave your device through our systems.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last updated" date at the top of this page. Continued use of Flash7X after any changes constitutes acceptance of the updated policy.