Currently in effect: 2026-05-30 (direct link to this version)
Previous versions / Archive:
Privacy Policy — Number on Photos (사진에 숫자 입력)
Effective date: 30 May 2026
This Privacy Policy describes how personal data is processed in the mobile application “Number on Photos / 사진에 숫자 입력” (the “App”), developed by Jitae Kim (“we”, “us”). It is written to satisfy the requirements of the EU General Data Protection Regulation (GDPR) as a global baseline, with a dedicated section for California residents (CCPA/CPRA).
1. Data Controller
Jitae Kim Email: wlxo0401@gmail.com
(No Data Protection Officer is appointed; the controller may be contacted directly at the email above.)
2. Categories of Personal Data Processed
The App does not require an account, and we do not directly ask you to provide personal information. There is data you create/store on your device, and data collected automatically by third-party SDKs.
2-1. Data you create/store on your device (on-device only)
- Photos — photos you select are processed only on your device to perform the numbering feature and are never uploaded to any server we control. Saving the result to your camera roll (Photos app) is your choice.
- Work history — a record of your numbering actions: creation date, image name (reference), input mode. Stored only in on-device SwiftData and never transmitted.
2-2. Data collected automatically (by third-party SDKs / system)
This data is not collected or stored directly by us; it is collected and processed automatically by the third-party SDKs integrated into the App, each for its own purpose. We do not store this data in a directly identifiable form and only see aggregated/anonymized results.
| Category | Examples | Collected by |
|---|---|---|
| Device identifiers | IDFV | Firebase Analytics, Firebase Crashlytics, Google AdMob |
| Advertising identifier | IDFA (only when you consent via App Tracking Transparency) | Google AdMob |
| Device & environment | OS version, device model, app version, locale | Firebase Analytics, Firebase Crashlytics, Google AdMob |
| Approximate location | Country/region derived from IP address | Firebase Analytics, Google AdMob |
| Usage data | In-app events, screens viewed, feature interactions | Firebase Analytics |
| Diagnostic / crash data | Crash logs, performance metrics | Firebase Crashlytics |
| Advertising data | Ad impressions, clicks | Google AdMob |
| Advertising attribution | App install/conversion attribution | Apple SKAdNetwork |
3. Purposes and Legal Bases (Art. 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Providing the core photo-numbering feature | Art. 6(1)(b) — performance of a contract |
| Analytics & service improvement (Firebase Analytics) | Art. 6(1)(f) — legitimate interest |
| Crash diagnostics (Firebase Crashlytics) | Art. 6(1)(f) — legitimate interest |
| Personalized advertising (AdMob, IDFA) | Art. 6(1)(a) — consent (via ATT) |
| Non-personalized advertising | Art. 6(1)(f) — legitimate interest |
| Obtaining & managing advertising/tracking consent (Google UMP) | Art. 6(1)(c) — legal obligation / Art. 6(1)(f) — legitimate interest |
| Legal compliance | Art. 6(1)(c) — legal obligation |
4. Recipients / Processors
We do not share the photos or work history you create on your device with any third party. Only the automatically collected data above is processed by the following providers:
| Processor | Purpose | Country |
|---|---|---|
| Google LLC (Firebase Analytics, Crashlytics) | Analytics, crash diagnostics | United States |
| Google LLC (AdMob / UMP) | Advertising; advertising/tracking consent management | United States |
| Apple Inc. (SKAdNetwork) | Ad attribution | United States |
Each provider’s own privacy practices:
- Google: https://policies.google.com/privacy
- Google Ads: https://policies.google.com/technologies/ads
- Apple: https://www.apple.com/legal/privacy/
5. International Transfers
Personal data may be transferred to the United States via our processors. Such transfers rely on the EU-US Data Privacy Framework where applicable, and/or Standard Contractual Clauses (SCCs).
6. Retention
| Item | Retention |
|---|---|
| Work history | On-device only — retained until you delete it in the App or uninstall the App |
| Analytics data | up to 14 months |
| Crash logs | up to 90 days |
| Advertising identifiers / data | per Google AdMob and Apple SKAdNetwork policies |
| Photos | not retained — processed on-device only |
7. Your Rights under GDPR (Arts. 15–22)
You have the right to:
- Access (Art. 15)
- Rectification (Art. 16)
- Erasure (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interests (Art. 21)
- Withdraw consent at any time (without affecting prior lawful processing)
- Lodge a complaint with your local supervisory authority
To exercise any right, contact wlxo0401@gmail.com.
8. California Residents (CCPA / CPRA)
If you are a California resident, in addition to the rights above you have the right to:
- Know what personal information is collected and how it is used
- Delete personal information collected from you
- Correct inaccurate personal information
- Opt out of “sharing” of personal information for cross-context behavioral advertising (under CPRA, advertising identifiers passed to AdMob may qualify as “sharing”)
- Limit the use of sensitive personal information (we do not collect sensitive PI as defined by CPRA)
- Non-discrimination for exercising your rights
We do not “sell” personal information for monetary consideration. To opt out of tracking-based advertising, decline the App Tracking Transparency prompt or disable tracking in iOS Settings.
To submit a CCPA/CPRA request, email wlxo0401@gmail.com. We will verify your identity using reasonable methods before fulfilling the request.
9. Withdrawing Tracking / Consent
- iOS Settings → Privacy & Security → Tracking → Number on Photos (toggle off)
- In-app Google UMP consent form — when prompted, you can change your advertising/tracking consent choices
- iOS Settings → Privacy & Security → Apple Advertising → reset advertising identifier
- iOS Settings → Privacy & Security → Photos → Number on Photos (change access)
- Uninstalling the App removes all on-device local data (work history, settings)
10. Automated Decision-Making
The App does not perform automated decision-making or profiling that produces legal or similarly significant effects under Art. 22 GDPR.
11. Children
The App is not directed to children under 16, and we do not knowingly collect personal data from children under 16 (under 13 in jurisdictions where COPPA applies). If you believe a child has provided us with personal data, contact us and we will delete it.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be announced in-app or at the published URL. All prior versions are retained in the same repository, organized by effective date.
13. Contact
Jitae Kim — wlxo0401@gmail.com