CHARME Privacy Policy

(A) Who are we

We are ASTRONEX JOINT STOCK COMPANY (ASTRONEX), a publishing company delivering apps for mobile devices. ASTRONEX is the controller of your personal information and is responsible for your data. All references in this policy to “ASTRONEX”, “our”, “us” or “we” refer to ASTRONEX, or our group companies, as appropriate. All references in this policy to “apps” refer to our apps that are available to download on mobile devices, including the Charme photo editor app on iOS.

(B) Our values and what this policy is for

We value your privacy and aim to be accountable and transparent in how we collect and use your personal information. This privacy policy outlines what you can expect from us regarding your data and informs you about your rights.

We’ve organised this policy in a clear structure so that you can find the information most relevant to your relationship with us.

If you have feedback or questions about this policy, please contact us using the information in section 10.

(C) Who does this policy apply to

This policy applies to:

• Users of the Charme app on iOS
• Individuals who contact our support team

(D) What does this policy contain

This privacy policy describes the following important topics:

1. Collection of your personal information and how we use it
2. Our legal basis for using your personal information
3. How and why we share your personal information with others
4. How long do we store your personal information
5. Your rights
6. Children
7. Where we may transfer your personal information
8. Risks and how we keep your personal information secure
9. Changes to this privacy policy
10. Further questions and how to make a complaint

(E) Your rights to object

You have various rights to the use of your personal information, especially the right to:

1. Ask us to stop using your personal information for direct marketing purposes.
2. Raise valid objections to our processing based on legitimate interests.

You can find more details in Section 5.

(F) What you need to do and your confirmation to us

Please read this privacy policy carefully to understand how we handle your personal information. By downloading and using the Charme app, you confirm that you have read and understood this privacy policy as it applies to you.

The Detail – The Key Information You Should Be Aware Of

1. Collection of your personal information and how we use it

1.1 What personal information do we collect

We may collect the following information:

• Device identifiers, such as Identifier for Advertising (IDFA) and general location data, if you consent to personalised ads.
• Email address and any other personal data you provide when contacting our customer support.
• App usage data, such as time spent on features, filters used, and crashes (collected via analytics tools like Firebase).
• Interaction with ads, for example, whether an ad was viewed, clicked, or ignored.

1.2 How we use your personal information

We use your information for the following purposes:

• To deliver personalised advertisements in the app (with your consent).
• To manage and remember your preferences related to marketing and advertising.
• To provide customer support and respond to inquiries.
• To analyse app performance, stability, and engagement (via analytics tools).
• To fulfil any legal obligations that apply to us.

1.3 Other uses of your personal information

Additionally, we may use your data:

• To respond to legal claims or requests.
• To carry out internal operations, such as audits or business analysis.
• To detect fraud or security issues.
• To improve our products and user experience.

We will not use your data in any way that is incompatible with the original purposes described above.

2. Legal basis for use of your personal information

We rely on the following legal grounds:

• Consent: For delivering personalised ads and collecting certain types of data.
• Contract performance: To provide access to the app and its functionalities.
• Legitimate interest: To improve our services, support users, secure our app, and generate revenue through advertising.

Where legitimate interests are relied upon, we will assess that our interests do not override your fundamental rights.

3. How and why we share your personal information with others

3.1 Third-party advertising and analytics

We work with third-party advertising and analytics providers who may collect and use your data to help us serve ads and understand app usage. These include:

• Admob (Google Inc.)
• AppLovin
• Facebook (Meta)
• Unity Ads (Unity Technologies Finland Oy)
• Bytedance Ltd.
• Firebase & Google Analytics (Google Inc.)

These companies may use cookies or tracking tools embedded in the app. The information shared includes:

• Device type and identifier
• IP address and approximate location
• In-app activity (e.g., ad interactions)

These third parties may also use this data for their purposes, including cross-platform ad targeting. You may opt out of this by withdrawing your consent in the app settings.

3.2 Other third parties

We may also share your data with:

• Apple Inc. for processing in-app purchases and subscription billing.
• Cloud storage providers, such as BigQuery, are used for data storage and support purposes.
• ASTRONEX affiliates, for internal support or compliance.
• Legal authorities, in compliance with laws or defence of legal rights.
• Third parties involved in a merger, acquisition, or asset sale involving ASTRONEX.

We will never sell your data without your consent.

4. How long do we store your personal information

We retain your personal information only as long as necessary to fulfil the purposes described in this policy, or as required by applicable law. After that, your data will be deleted or anonymized.

5. Your rights

You have the following rights:

• Access your personal information.
• Correct inaccurate or outdated data.
• Delete your information in specific situations.
• Restrict or object to data processing.
• Withdraw consent at any time.
• Port your data to another service provider (where applicable).

To exercise these rights, contact us at: aso.astronex@gmail.com

We will respond within 30 days or notify you if more time is needed.

6. Children

Our app is not directed at children under the age of 16. We do not knowingly collect personal information from anyone under this age. If we become aware that we have inadvertently collected such data, we will delete it.

If you believe a child has provided us with data, contact us at aso.astronex@gmail.com.

7. Where we may transfer your personal information

Your personal information may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States.

We ensure adequate protection through:

• Standard contractual clauses approved by the European Commission
• Third parties certified under frameworks like the EU-U.S. Data Privacy Framework

You may request further details by contacting us.

8. Risks and how we keep your personal information secure

We take appropriate technical and organisational measures to protect your data from unauthorised access, use, or loss. These include:

• Data encryption
  Access controls
• Secure cloud infrastructure
• Internal training and audits

Despite our efforts, no transmission over the internet is entirely secure. Use of our services is at your own risk.

9. Changes to this privacy policy

We may update this policy periodically. Changes will be posted in the app and may also be notified to you directly. Please check back regularly to stay informed.

10. Further questions and how to make a complaint

If you have any questions, requests, or complaints regarding your personal information, please contact:

• Email: aso.astronex@gmail.com
• Website: https://astronex.ai