Privacy Policy — Number on Photos (사진에 숫자 입력)
Effective date: 13 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. The following data may be collected automatically:
| Category | Examples |
|---|---|
| Device identifiers | IDFV; IDFA (only when you consent via App Tracking Transparency) |
| Device & environment | OS version, device model, app version, locale |
| Approximate location | Country/region derived from IP address |
| Usage data | In-app events, screens viewed, feature interactions |
| Diagnostic data | Crash logs, performance metrics |
| Advertising data | Ad impressions, clicks, SKAdNetwork attribution |
| Photos | Read locally on device to perform the numbering feature — never uploaded to any server we control |
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 |
| Legal compliance | Art. 6(1)(c) — legal obligation |
4. Recipients / Processors
| Processor | Purpose | Country |
|---|---|---|
| Google LLC (Firebase Analytics, Crashlytics) | Analytics, crash diagnostics | United States |
| Google LLC (AdMob) | Advertising | 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 |
|---|---|
| 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)
- iOS Settings → Privacy & Security → Apple Advertising → reset advertising identifier
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