Privacy Policy

This privacy notice for Shutter Clique from Gallus Soft LLC ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use our mobile application (Shutter Clique), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at <privacy@gallussoft.com>.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with the Services. This may include personal information you provide to us, such as your name, email address, and password. If given permission, the app may also collect city-level location information, e.g., "San Francisco, CA".
• Do we process any sensitive personal information? We do not process sensitive personal information.
• Do we collect any information from third parties? We do not collect any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
• In what situations and with which parties do we share personal information? If you provide permission to include your current city name in your posts, we use a third-party geocoding service to translate your location into a city name. We do not share any other personal information with this service. We also use a third-party service (RevenueCat) to process subscription payments. We create an anonymized ID for you when communicating with that service.
• How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information, e.g., we use encryption protocols to transfer your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
• What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way to exercise your rights is by using the relevant features provided by the Shutter Clique application, or by contacting us at <privacy@gallussoft.com>. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full below.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Passwords

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. However, we do not gain access to or store your payment details such as credit card numbers or bank account numbers. Payment data is handled and stored by Apple. You may find their privacy notice here: https://www.apple.com/legal/privacy/data/en/app-store/. We also use a third-party service called RevenueCat to facilitate payments. You can find their privacy policy here: https://www.revenuecat.com/privacy/.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may derive city-level location information from your mobile device or IP address when you perform certain actions within the Services, such as uploading data to our servers. To generate a city name for your location, we may use a third-party geocoding service. In those cases, we do not share any personal identifiers, such as your name or email address, with that service. We do not continuously monitor your location and do not store location more accurately than a city name. You can choose to change the collection of geolocation information by using the device's Location Services settings and you can remove location information from any posts that you've already created. iOS also lets you turn off Precise Location so that only your approximate location is used by the app.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera and photo library. If you wish to change our access or permissions, you may do so in your device's settings, e.g, Settings > Shutter Clique on an iOS device.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings. You may also opt into receiving these notifications and control which specific notifications you receive by going to your account settings within the app.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with relevant laws. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We do not share your personal information, such as your name or email address, with third parties. Users that you specifically connect with may see personal information that you choose to share with them. Showing location information on your posts means sharing your IP address with a geocoding service.

We may need to share your personal information in the following situations:

• Other Users. When you share personal information (for example, by posting comments or other content to the Services) or provide information to facilitate connecting with other users (for example, providing your email address), such personal information may be viewed by the other users that you select. Similarly, those other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile. However, your personal information is not provided to users that you do not choose to connect with and this information is not made public outside the Services.
• Geolocation. If you provide permission to show your location on your posts, we may use a geocoding service to convert your location into a city name. No other personal information is shared with that service. If you disable access to location information from your device's Location Services settings, we do not call the geocoding service at all.
• Payments. If you pay for a subcription, we use a third-party payments service called RevenueCat to help process your payment. We generate an anonymized ID for your account when communicating with RevenueCat and we do not share any other personal information or identifiers with them.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. For example, we use encryption protocols when transferring your information and we use industry standard token authentication techniques to secure access to your account. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 17 years of age.

We do not knowingly collect, solicit data from, or market to children under 17 years of age. Nor do we knowingly sell such personal information. The Shutter Clique app is designated "17+" in the Apple App Store. By using the Services, you represent that you are at least 17 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 17 years of age has been collected without parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 17, please contact us at <privacy@gallussoft.com>.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information: If you would at any time like to review or change the information in your account, or terminate your account, you can do this by logging into your account in the Shutter Clique application.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized . As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

9. WHAT PRIVACY RIGHTS DO UNITED STATES RESIDENTS HAVE?

In Short: If you are a resident of California, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The following table presents categories of personal information and indicates, in the final column, which of these we have collected in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services, or for as long asyou have an account with us.

How We Use and Share Personal Information

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain U.S. state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at <privacy@gallussoft.com>.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by the "Last updated" date at the top of this privacy policy. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please log into the Shutter Clique application or email us at <privacy@gallussoft.com>. Within the app, the following actions are available, but not limited to:

• Update your name, email address, and password
• View and/or delete all posts that you've made with the Service
• Edit and/or delete the title you provided for your own posts
• Edit and/or delete comments that you added to your own posts or other users' posts
• Edit and/or delete reactions (emoji) that you added to other users' posts
• Control whether city-level location is captured for posts you make
• Remove any city-level location already captured for posts you make
• Save photos you take within the app to your device's Photos app
• Delete your account, causing all associated data to be deleted from the Service

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at <privacy@gallussoft.com>.