PRIVACY POLICY

1Introduction

Zinance Inc. ("Company," "we," "us," or "our"), a corporation organized under the laws of Ontario, Canada, operates mobile applications (collectively, the "Services"). This Privacy Policy describes how we collect, use, disclose, and otherwise process personal information in connection with our Services, and explains the rights and choices available to individuals with respect to their personal information.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, you must not access or use our Services.

2Information We Collect

We are committed to data minimization and collect only the information necessary to provide and improve our Services. The categories of information we may collect include:

2.1 Information Collected Through Third-Party Services

• Apple Game Center: If you choose to use Game Center features, Apple may collect your Game Center display name, scores, and achievements. This information is processed by Apple Inc. in accordance with Apple's Privacy Policy.
• Apple App Analytics: We utilize Apple's built-in analytics services, which may collect aggregated usage data, crash reports, and performance metrics. This information is processed by Apple Inc. and provided to us in anonymized, aggregated form.

2.2 Advertising Information

Our Services may display advertisements provided by third-party advertising networks. If you consent through Apple's App Tracking Transparency framework, these networks may collect your Identifier for Advertisers (IDFA) and other device information to deliver personalized advertisements. You may withdraw this consent at any time through your device settings.

2.3 Information We Do Not Collect

We do not require account registration, and we do not collect names, email addresses, phone numbers, payment information, or other directly identifying personal information through our Services.

3Third-Party Services

Our Services integrate with the following third-party services, each of which maintains its own privacy policy governing the collection and use of your information:

• Apple Game Center: Apple Privacy Policy
• Apple App Analytics: Apple Privacy Policy
• Advertising Partners: Our advertising partners' privacy policies will be made available within the application or upon request.

4How We Use Information

We use the information collected through our Services for the following purposes:

• To operate, maintain, and provide the features and functionality of our Services;
• To enable leaderboard functionality and competitive features;
• To analyze usage patterns and improve our Services;
• To identify and resolve technical issues and bugs;
• To display advertisements, including personalized advertisements where consent has been provided;
• To comply with legal obligations and enforce our terms and policies.

5Advertising and Tracking Technologies

Our Services may display advertisements. We comply with Apple's App Tracking Transparency ("ATT") framework, which requires us to obtain your consent before tracking your activity across other companies' apps and websites.

Your Choices: You may control ad tracking through your device settings at any time by navigating to Settings → Privacy & Security → Tracking on your iOS device. If you opt out of tracking, you will still see advertisements, but they may be less relevant to your interests.

We do not use cookies or similar tracking technologies within our mobile applications.

6Children's Privacy

Our Services are designed for a general audience and are not specifically directed at children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children under 13.

In compliance with the Children's Online Privacy Protection Act ("COPPA") and similar laws:

• We do not require users to provide personal information to use our Services;
• We do not enable behavioral advertising for users who have not consented to tracking;
• If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete such information.

If you are a parent or guardian and believe that your child has provided personal information to us, please contact us immediately at the address provided below.

7Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information:

7.1 European Economic Area, United Kingdom, and Switzerland (GDPR)

If you are located in the EEA, UK, or Switzerland, you have the following rights under the General Data Protection Regulation:

• Right of Access: The right to obtain confirmation of whether we process your personal data and access to such data;
• Right to Rectification: The right to correct inaccurate personal data;
• Right to Erasure: The right to request deletion of your personal data;
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format;
• Right to Object: The right to object to processing of your personal data;
• Right to Withdraw Consent: The right to withdraw consent at any time.

7.2 Canada (PIPEDA)

If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act, including:

• The right to access your personal information held by us;
• The right to challenge the accuracy and completeness of your personal information;
• The right to withdraw consent to the collection, use, or disclosure of your personal information.

7.3 California (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act and California Privacy Rights Act:

• Right to Know: The right to know what personal information we collect, use, and disclose;
• Right to Delete: The right to request deletion of your personal information;
• Right to Opt-Out: The right to opt-out of the "sale" or "sharing" of personal information. We do not sell personal information as defined by the CCPA.

To exercise any of these rights, please contact us using the information provided below.

8Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. As we rely primarily on Apple's services for data processing, retention periods for Game Center and analytics data are governed by Apple's data retention policies.

9Data Security

We implement appropriate technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

10International Data Transfers

Our Services are operated from Canada. If you are accessing our Services from outside Canada, please be aware that your information may be transferred to, stored, and processed in Canada or other countries where our service providers operate. By using our Services, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection rules.

11Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and, where required by applicable law, provide additional notice (such as through the Services or via email). Your continued use of our Services after any such changes constitutes your acceptance of the revised Privacy Policy.