Privacy Policy - XConfessions App

Data Controller

LUST PRODUCTIONS, S.L.

C/ Diputació 185, Ppal 2

08011 Barcelona, Spain

Email: [email protected]

1. Scope

This Privacy Policy applies to personal information collected through the App, related customer support communications, and other interactions you may have with us in connection with the Service.

The App is intended only for adults. It is not directed to children under 18, and we do not knowingly collect personal information from children under 18.

2. Information We Collect

Depending on how you use the App, we may collect the following categories of personal information:

a. Information you provide directly

Email address when you create an account, contact us, or choose to receive communications from us

Profile photo(s) that you upload for profile-picture purposes

Information you provide in messages to us or through support requests

Any other information you voluntarily submit through the App

b. Information collected automatically

When you use the App, we may automatically collect certain technical and usage information, such as:

device type

operating system

app version

approximate usage and interaction data

crash, diagnostics, and performance-related information

app event data and analytics information collected through Google Analytics for Firebase

Google states that Firebase Analytics automatically collects certain event and usage data and also provides controls over analytics data collection and use.

c. Payment and transaction information

If you purchase paid features, payment processing is handled by third-party providers, such as:

Apple App Store In-App Purchases

SegPay

We do not store full payment card details when payments are processed by these third parties. We may receive limited transaction-related information, such as confirmation that a purchase was completed, a transaction identifier, product type, country, or related billing status information, as made available by the payment provider.

For SegPay transactions, SegPay's own privacy policy applies to the personal data it processes.

3. How We Use Personal Information

We may use personal information for the following purposes:

to create and manage user accounts

to provide and operate the App and its features

to display and manage profile pictures

to process or verify purchases and premium access

to communicate with you about your account, purchases, support requests, or important service notices

to send you promotional or marketing emails only where permitted by law and according to your choices

to allow you to opt in or opt out of marketing communications

to analyze usage, improve performance, troubleshoot issues, and develop new features

to protect the security and integrity of the App

to comply with legal obligations and enforce our Terms

4. Legal Bases for Processing (GDPR)

If the GDPR applies to our processing of your personal data, we rely on one or more of the following legal bases:

Performance of a contract: where processing is necessary to provide the App and related services to you

Consent: where you have given us consent, such as for optional marketing emails or where consent is otherwise required

Legitimate interests: where processing is necessary for our legitimate interests, such as improving the App, preventing fraud, maintaining security, and understanding user engagement, provided those interests are not overridden by your rights

Legal obligation: where processing is necessary for compliance with applicable law

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

5. Profile Photos

If you upload a photo to use as a profile picture, we will process that photo for profile display and account-related purposes within the App. You are responsible for ensuring that you have the right to upload any image you submit and that it does not violate applicable law or the rights of others.

6. Analytics

We use Google Analytics for Firebase to help us understand how users interact with the App, measure app performance, and improve the Service. This may include collection of app-instance data, device-related data, event data, and similar analytics information.

We do not use remarketing services, and we do not use your personal information for cross-context behavioral advertising or similar targeted advertising activities. We also state that we do not show ads in the App. Google's Firebase documentation describes Analytics as a service for understanding how users use Apple, Android, and web apps, and explains that analytics collection can be configured by the developer.

7. Marketing Communications

We may send emails to users who have opted in to receive marketing or promotional communications, where applicable law permits.

You can opt out of marketing emails at any time by:

using the unsubscribe link included in the message, where available

changing your settings in the App, where available

contacting us at [email protected]

Even if you opt out of marketing emails, we may still send you non-promotional communications, such as transactional messages, account notices, purchase confirmations, and important updates about the Service.

8. How We Share Personal Information

We may share personal information with:

service providers and vendors that help us operate the App, such as hosting, analytics, customer support, and technical service providers

payment processors and platform providers, such as Apple and SegPay, to enable purchases and payment-related operations

professional advisors, auditors, or legal counsel where reasonably necessary

competent authorities, courts, regulators, or law enforcement where required by law or to protect rights, safety, and security

a buyer, investor, or successor entity in connection with a merger, acquisition, financing, corporate reorganization, or sale of assets

We do not sell personal information.

We do not share personal information for behavioral advertising or remarketing purposes.

Under California law, consumers may have rights related to the sale or sharing of personal information; because we do not do remarketing or targeted advertising and do not show ads, this policy reflects a "no sale / no sharing for cross-context behavioral advertising" position.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

maintaining your account

providing the Service

complying with legal, accounting, tax, or regulatory obligations

resolving disputes

enforcing our agreements

Retention periods may vary depending on the type of data and the reason we collected it.

10. International Data Transfers

Because some of our service providers may operate outside your country, your personal information may be transferred to and processed in countries other than the one in which you reside, including countries outside the European Economic Area.

Where required by applicable law, we will take appropriate steps to ensure that such transfers are subject to adequate safeguards, such as contractual protections or other lawful transfer mechanisms.

11. Security

We implement reasonable technical and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Your Rights Under the GDPR

If you are located in the European Economic Area, United Kingdom, or another jurisdiction with similar rights, you may have the right to:

request access to your personal data

request correction of inaccurate or incomplete data

request deletion of your data

request restriction of processing

object to certain processing

request data portability

withdraw consent where processing is based on consent

lodge a complaint with a competent supervisory authority

To exercise these rights, contact us at [email protected].

13. California Privacy Rights (CCPA/CPRA Notice)

If you are a California resident, and to the extent the CCPA as amended by the CPRA applies, you may have the following rights, subject to exceptions:

the right to know the categories of personal information we collect, use, disclose, and retain

the right to request access to specific pieces of personal information

the right to request deletion of personal information

the right to request correction of inaccurate personal information

the right to know the categories of sources from which personal information is collected

the right to know the business or commercial purposes for collecting, using, or disclosing personal information

the right to know the categories of third parties to whom personal information is disclosed

the right to opt out of the sale or sharing of personal information, if applicable

the right to limit the use and disclosure of sensitive personal information, where applicable

the right not to receive discriminatory treatment for exercising your privacy rights

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

To submit a California privacy request, contact us at [email protected]. We may need to verify your identity before responding to your request.

14. CalOPPA Notice

In accordance with the California Online Privacy Protection Act ("CalOPPA"), this Privacy Policy provides notice of:

the categories of personal information we collect

the categories of third parties with whom we may share personal information

how users can request changes to their personal information

how we will notify users of material changes to this Privacy Policy

California's online privacy rules require operators of online services to conspicuously post a privacy policy and include certain disclosures.

Do Not Track

Some web browsers may transmit "Do Not Track" ("DNT") signals. Because there is no universally accepted standard for how to interpret DNT signals across apps and services, our App does not currently respond to browser-based DNT signals.

However, we do not use the App to engage in third-party behavioral advertising or remarketing.

15. Children's Privacy

The App is intended for adults only. We do not knowingly collect personal information from children under the age of 18. If we learn that we have collected personal information from a child under 18 without appropriate authorization, we will take steps to delete that information.

If you believe that a child under 18 has provided us with personal information, please contact us at [email protected].

16. Third-Party Services

The App may integrate with or rely on third-party services, including app stores, analytics providers, hosting providers, and payment processors. Those third parties may process personal data in accordance with their own privacy notices and terms.

This includes, where applicable:

Apple App Store / Apple In-App Purchases

Google Firebase / Google Analytics for Firebase

SegPay

We are not responsible for the privacy practices of third parties except as required by applicable law.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version in the App or through another appropriate channel and update the "Effective date" above.

Your continued use of the App after the updated Privacy Policy becomes effective means that you acknowledge the updated policy, to the extent permitted by law.

18. Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, contact us at:

LUST PRODUCTIONS, S.L.

C/ Diputació 185, Ppal 2

08011 Barcelona, Spain

[email protected]

19. Digital Content and Withdrawal Right

To the extent applicable under Spanish consumer regulations, the right of withdrawal may not apply to the supply of digital content not provided on a tangible medium once performance has begun with the consumer's prior express consent and acknowledgment that the right of withdrawal is thereby lost.