Legal Document

Privacy Policy & Global Compliance Declaration

Effective Date: January 1, 2026 Last Updated: January 1, 2026 Version: 3.0

This Privacy Policy and Global Compliance Declaration ("Policy") is published by CatFunTool.com ("Company," "we," "us," "our"), registered at No. 288 Guoyuan Road, Huaishang District, Bengbu, Anhui, China (Bengbu Tongren Intelligent IoT/IT Park). It applies to all mobile applications, websites, and digital services published under the CatFunTool brand ("Services"). Please read this Policy carefully before using our Services. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree, please discontinue use of the Services immediately.

→ Terms of Service Contact / Data Requests

Part 1: Privacy Policy

1.1 Data Collection — What We Collect and Why

We collect the minimum data necessary to operate, improve, and monetize our Services while respecting your privacy. The following categories describe the data we may collect and their purposes:

1.1.1 Device Identification Data

  • IDFA (Identifier for Advertisers, iOS): Apple's advertising identifier, collected only after you have explicitly granted consent via Apple's App Tracking Transparency (ATT) prompt. Used for personalized advertising, ad fraud detection, and attribution measurement.
  • GAID (Google Advertising ID, Android): Google's resettable advertising identifier, collected in accordance with Google Play policies. Used for ad targeting, frequency capping, and attribution. You may reset or delete this ID at any time in Android device settings.
  • OAID (Open Anonymous Device Identifier): An anonymous, resettable identifier provided by device manufacturers in certain regions (including China) as a privacy-preserving alternative to GAID. Used for attribution and ad analytics in applicable markets.
  • Device Hardware Attributes: Device model, OS version, screen resolution, locale, language, and time zone — used for app compatibility, UX personalization, and aggregate analytics. These are not used for fingerprinting in isolation but may be processed in combination by third-party attribution SDKs.

1.1.2 Network and Connection Data

  • IP Address: Collected passively for security monitoring, geographic routing, compliance jurisdiction determination, and aggregate analytics. IP addresses are truncated or anonymized where required by applicable law (e.g., GDPR). We do not store full IP addresses in persistent user profiles.
  • Mobile Carrier and Network Type: Carrier name (e.g., AT&T, Vodafone), connection type (WiFi/4G/5G), and MNC/MCC codes — used for ad performance analytics and to optimize content delivery.
  • WiFi Network SSID (where permitted): Collected only if you have granted location/network permission and only for relevant functionality within the app. Not transmitted to advertising networks.

1.1.3 Behavioral and Usage Data

  • In-App Ad Interaction Behavior (IAA): Whether you viewed, skipped, or completed an ad; ad impression and click timestamps; rewarded ad completion status; and ad format interactions (banner, interstitial, rewarded video, splash/app-open). This data is processed by our ad mediation partners (see Section 1.2) for targeting, fraud detection, and revenue optimization.
  • App Logic and Feature Usage: Which features you access, session duration, in-app navigation patterns, crash logs and performance metrics. This data is processed in aggregate or pseudonymized form. We use it to improve product design and fix technical issues. Crash logs may be collected via Firebase Crashlytics or equivalent platform services.
  • App Open/Close Events: Timestamps of app sessions for retention analytics and to optimize onboarding and re-engagement strategies.

1.1.4 In-App Purchase and Financial Transaction Data

  • Scope: All in-app purchases (IAP), including one-time purchases and auto-renewable subscription transactions, are processed exclusively through Apple's App Store payment infrastructure (iOS) or Google Play Billing (Android). CatFunTool does not collect, store, process, or transmit your payment card numbers, bank account details, or full financial credentials.
  • Transaction Records We Receive: We receive only the following from Apple/Google: a transaction receipt/token indicating purchase completion, the product identifier, the purchase timestamp, the transaction ID, and the subscription status (active/expired/refunded). These are used to unlock purchased features, verify entitlements, and detect subscription fraud.
  • Refund Handling: Refund requests and payment disputes are managed directly by Apple Inc. or Google LLC under their respective refund policies. We may receive refund status notifications to revoke entitlements where applicable.

1.1.5 Data We Do NOT Collect

Unless explicitly stated in a specific app's privacy disclosure, we do NOT collect: real name, national ID, passport number, social security number, financial account credentials, health records, biometric raw data, precise real-time GPS location, contact lists, photos, or messages.

1.2 Third-Party Data Sharing Architecture

We engage the following categories of third-party service providers. Each receives only the data required for their specific function. All partners have executed Data Processing Agreements (DPAs) where required by applicable law.

1.2.1 Ad Mediation Platforms

The following platforms may serve advertisements within our apps. Each collects device-level data as described in their respective privacy policies:

  • AppLovin MAX (AppLovin Corporation): Mediation platform, demand-side advertising, and anti-fraud analytics. Collects IDFA/GAID/OAID, device attributes, IP address, and behavioral signals. Privacy policy: https://www.applovin.com/privacy/
  • Google AdMob (Google LLC): Ad mediation and direct demand. Subject to Google's advertising policies. Collects device identifiers, IP address, app usage signals, and location (city-level). Privacy policy: https://policies.google.com/privacy
  • Unity LevelPlay / IronSource (Unity Technologies): Mediation, rewarded video, and interstitial. Collects device identifiers, behavioral data, and fraud signals. Privacy policy: https://unity.com/legal/privacy-policy
  • Meta Audience Network (Meta Platforms, Inc.): Display and video ad delivery. Collects IDFA/GAID, behavioral signals, and hashed identifiers where applicable. Privacy policy: https://www.facebook.com/privacy/policy/
  • Vungle / Liftoff (Liftoff Mobile, Inc.): Rewarded video and interstitial advertising. Privacy policy: https://liftoff.io/privacy-policy/
  • Mintegral (Mobvista Inc.): Programmatic advertising network. Privacy policy: https://www.mintegral.com/en/privacy/
  • InMobi (InMobi Pte. Ltd.): Ad network and demand. Privacy policy: https://www.inmobi.com/privacy-policy/
  • Pangle (ByteDance / TikTok For Business): Ad network. Collects device identifiers and behavioral data consistent with TikTok for Business policies. Privacy policy: https://www.pangleglobal.com/privacy
  • Digital Turbine (Digital Turbine, Inc.): Ad delivery and content distribution. Privacy policy: https://www.digitalturbine.com/privacy-policy/
Ad Consent Architecture: On iOS, advertising identifiers and behavioral data sharing with all of the above platforms is subject to user consent via Apple's ATT framework. If you decline ATT, contextual (non-personalized) ads will be displayed. No behavioral tracking data will be shared without ATT consent. On Android, you may limit ad personalization via Android Settings → Privacy → Ads.

1.2.2 Mobile Measurement Partners (MMP) / Attribution Platforms

We use the following platforms for install attribution, campaign analytics, and anti-fraud measurement:

  • AppsFlyer (AppsFlyer Ltd.): Install attribution, in-app event tracking, fraud prevention (Protect360). Processes IDFA/GAID/OAID, IP address, click/impression data. Privacy policy: https://www.appsflyer.com/legal/privacy-policy/
  • Adjust (Adjust GmbH, a subsidiary of AppLovin): Attribution, cohort analytics, and fraud detection. Processes device identifiers, IP address, and install signals. Privacy policy: https://www.adjust.com/terms/privacy-policy/
  • Singular (Singular Labs, Inc.): Marketing analytics, attribution, and ROI measurement. Processes device identifiers, campaign data, and aggregate behavioral data. Privacy policy: https://www.singular.net/privacy-policy/

Attribution data is used solely for: (a) measuring which marketing campaigns result in app installs; (b) detecting and blocking fraudulent installs; (c) aggregate campaign performance analytics. Attribution data is never sold to third parties for unrelated purposes.

1.2.3 Payment Processors

  • Apple Inc.: Processes all iOS App Store purchases. We receive only transaction receipts and entitlement signals.
  • Google LLC: Processes all Google Play purchases. We receive only purchase tokens and subscription status.

CatFunTool is not a payment processor and does not maintain PCI-DSS scope for cardholder data.

1.2.4 Technical Infrastructure Partners

We may use Firebase (Google LLC) for crash reporting, performance monitoring, and anonymous analytics. Firebase Analytics events are logged in anonymized or pseudonymized form. Firebase's data practices are governed by Google's Privacy Policy.

1.3 Global Regional Privacy Rights and Legal Declarations

🇪🇺 European Union — GDPR (General Data Protection Regulation) and UK-GDPR

Legal Basis for Processing: We process personal data of EU/EEA and UK residents on the following legal bases under Article 6 GDPR:

  • Consent (Article 6(1)(a)): For IDFA/advertising identifier collection on iOS (via ATT), for personalized advertising, and for any non-essential analytics. You may withdraw consent at any time without affecting the lawfulness of prior processing.
  • Performance of a Contract (Article 6(1)(b)): For processing transaction data to deliver purchased features and subscriptions.
  • Legitimate Interests (Article 6(1)(f)): For app security, fraud detection, crash analytics, and aggregate usage analytics. We have conducted Legitimate Interest Assessments (LIAs) where this basis is relied upon.
  • Legal Obligation (Article 6(1)(c)): For retaining records required by applicable law.

EU Representative: As a company based outside the EU processing EU residents' data, we are in the process of designating an EU GDPR representative pursuant to Article 27. Until designation is complete, EU residents may direct inquiries to support@CatFunTool.com.

Your Rights Under GDPR/UK-GDPR: EU and UK residents have the following rights, exercisable by contacting us at support@CatFunTool.com:

  • Right to Access (Article 15): Request confirmation of whether we process your personal data and obtain a copy.
  • Right to Rectification (Article 16): Request correction of inaccurate or incomplete personal data.
  • Right to Erasure / "Right to Be Forgotten" (Article 17): Request deletion of your personal data where no overriding legal basis exists.
  • Right to Restriction of Processing (Article 18): Request that we restrict processing of your data in certain circumstances.
  • Right to Data Portability (Article 20): Receive your personal data in a structured, machine-readable format and transmit it to another controller.
  • Right to Object (Article 21): Object to processing based on legitimate interests, including profiling for advertising.
  • Right to Withdraw Consent: Withdraw consent for consent-based processing at any time.
  • Right to Lodge a Complaint: Lodge a complaint with your national Data Protection Authority (DPA) if you believe your rights have been violated.

Response Timeline: We will respond to verified rights requests within 30 days. Extensions of up to 60 additional days may apply for complex requests; we will notify you of any extension.

International Data Transfers: We transfer EU/UK personal data to third countries (including the United States and China) using appropriate safeguards including Standard Contractual Clauses (SCCs) adopted by the European Commission (Decision 2021/914), supplementary technical measures including end-to-end encryption, and — where available — adequacy decisions.

EU Digital Services Act (DSA) Compliance: As a provider of online intermediary services, where applicable, we maintain transparency about algorithmic content recommendations, provide mechanisms for users to flag illegal content, and publish annual transparency reports in accordance with DSA requirements. See Section 2.5 for detailed content moderation procedures.

Data Retention: We retain personal data only as long as necessary for the stated purpose or as required by law. Advertising identifiers and behavioral data are purged within 13 months. Transaction records are retained for up to 7 years for tax and legal compliance.

🇺🇸 United States — CCPA, CPRA, VCDPA, TDPSA, and Additional State Laws

California — CCPA / CPRA (California Consumer Privacy Act / California Privacy Rights Act):

CatFunTool does not sell your personal information as defined by the CCPA. We may share personal information with our advertising partners for cross-context behavioral advertising purposes, which constitutes "sharing" under CPRA. California residents have the right to opt out of such sharing.

  • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected, the business or commercial purposes for collection, and the categories of third parties with whom we share data.
  • Right to Delete: You may request deletion of personal information we hold about you, subject to certain legal exceptions.
  • Right to Correct: You may request correction of inaccurate personal information.
  • Right to Opt-Out of Sharing: You may opt out of sharing of personal information for targeted advertising by contacting us at support@CatFunTool.com or by using the "Do Not Sell or Share My Personal Information" mechanism in applicable app settings.
  • Right to Limit Use of Sensitive Personal Information: To the extent we process sensitive personal information as defined by CPRA, you have the right to limit our use to that which is necessary to perform the Services.
  • Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
  • Response Timeline: We will acknowledge your request within 10 business days and respond substantively within 45 calendar days, with a possible 45-day extension for complex requests.
  • Authorized Agents: You may designate an authorized agent to submit requests on your behalf, subject to our verification procedures.

Virginia — VCDPA (Virginia Consumer Data Protection Act): Virginia residents have the rights to access, correct, delete, and obtain a portable copy of their personal data; the right to opt out of processing for targeted advertising, sale, or profiling with significant effects; and the right to appeal our decisions. We will respond to verified requests within 45 days.

Texas — TDPSA (Texas Data Privacy and Security Act): Texas consumers have rights to access, correct, delete, and obtain a copy of their personal data; to opt out of processing for targeted advertising or the sale of personal data; and to appeal denials. Response within 45 days.

Colorado — CPA; Connecticut — CTDPA; Washington — My Health MY Data Act: Residents of these states have similar rights to access, correct, delete, portability, and opt-out of targeted advertising and sale. We comply with all applicable state privacy laws. Contact support@CatFunTool.com to exercise any state privacy right.

Do Not Track: Our Services do not currently respond to browser-level Do Not Track (DNT) signals, as no uniform industry standard exists. For meaningful opt-out, please use the app-level opt-out or contact us directly.

🇧🇷 Brazil — LGPD (Lei Geral de Proteção de Dados)

For Brazilian residents, we process personal data under the following legal bases defined by the LGPD:

  • Consent (Article 7, I): For advertising tracking identifiers and personalized advertising. Consent is obtained through the ATT framework on iOS and through explicit in-app consent dialogs on Android.
  • Legitimate Interest (Article 7, IX): For fraud detection, security monitoring, and aggregate analytics.
  • Contract Performance (Article 7, V): For processing IAP transaction data to deliver purchased features.

Your Rights Under LGPD: Brazilian residents have the right to confirm the existence of and access to their personal data; to correct incomplete, inaccurate, or outdated data; to anonymize, block, or delete unnecessary or excessive data; to portability; to information about public and private entities with which we have shared data; to information about the possibility of denying consent and the consequences thereof; and to revoke consent.

Data Protection Officer (DPO): Requests from Brazilian residents may be directed to support@CatFunTool.com with the subject line "LGPD — Data Request." We aim to respond within 15 business days.

Cross-Border Transfers: We transfer personal data from Brazil to international service providers. Such transfers are conducted under data transfer agreements ensuring adequate protection standards equivalent to those of the LGPD, in accordance with Chapter V of the LGPD.

🇨🇳 China — PIPL (Personal Information Protection Law) and Data Security Law (DSL)

For users of our Services in mainland China, we comply with the Personal Information Protection Law (PIPL, effective November 1, 2021) and the Data Security Law (DSL, effective September 1, 2021).

Consent Requirements: Processing of personal information of individuals located in China requires separate, voluntary, explicit, and informed consent. We obtain separate consent for each category of sensitive personal information processed. You may withdraw consent at any time without affecting prior lawful processing.

Data Localization: Personal information of Chinese residents collected through our Services in China is stored on servers located within the People's Republic of China to the extent required by PIPL and sector-specific regulations. Where we transfer personal information outside of China (e.g., to our international advertising partners), we conduct security assessments as required by the Cyberspace Administration of China (CAC) and obtain user consent for such cross-border transfers in accordance with the Regulations on the Standard Contract for the Outbound Transfer of Personal Information.

Regulatory Oversight: We cooperate with the Ministry of Industry and Information Technology (MIIT), the Cyberspace Administration of China (CAC), and other relevant authorities as required by Chinese law.

Your Rights Under PIPL: Users in China have the right to know about and decide on the processing of their personal information; to restrict or refuse processing; to access and copy their personal information; to correct inaccurate information; to delete personal information in specified circumstances; to request explanations of processing rules; and to transfer their personal information to a designated third party. Contact support@CatFunTool.com to exercise these rights.

🇮🇳 India — DPDP Act (Digital Personal Data Protection Act, 2023)

For data principals (users) located in India, we comply with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and any rules notified thereunder.

Consent: We process digital personal data of Indian residents based on free, specific, informed, unconditional, and unambiguous consent. Consent is sought in plain language, separately for each purpose. A consent manager mechanism will be implemented as required when the relevant provisions are notified by the Government of India.

Data Fiduciary Obligations: We maintain a record of consents, implement appropriate technical and organizational security safeguards, and provide mechanisms for data principals to exercise their rights. We will notify the Data Protection Board of India and affected data principals of any personal data breach within such time as required by applicable rules.

Your Rights Under the DPDP Act: You have the right to access a summary of your personal data we process; to correct or erase your personal data; to obtain redress for violations of your rights under the Act; and to nominate a person to exercise your rights in the event of your death or incapacity.

Cross-Border Transfers: We transfer personal data of Indian residents to countries notified by the Central Government as permissible transfer destinations, or as otherwise permitted by the Central Government. Until such notification is issued, we process cross-border transfers under appropriate safeguards.

Data Protection Officer: Contact support@CatFunTool.com for DPDP-related inquiries. We will appoint a DPO for India as required by applicable rules.

🇸🇦 Saudi Arabia — PDPL (Personal Data Protection Law)

For users located in the Kingdom of Saudi Arabia, we comply with the Personal Data Protection Law ("PDPL"), its implementing regulations, and guidelines issued by the National Data Management Office (NDMO) / Saudi Data and Artificial Intelligence Authority (SDAIA).

Processing Basis: Personal data of Saudi residents is processed based on explicit consent, contract performance, or legitimate interest as defined under the PDPL. We obtain explicit consent before processing sensitive personal data.

Data Localization: Where required by the PDPL or sector-specific regulations, personal data of Saudi residents is processed and stored within the Kingdom of Saudi Arabia. Cross-border transfers are conducted only with authorization from SDAIA or where permitted under applicable regulations.

Your Rights: Saudi residents have the right to access their personal data, request correction, request deletion (right to be forgotten), object to processing, and lodge a complaint with SDAIA/NDMO. Requests may be directed to support@CatFunTool.com.

🇨🇦 Canada — PIPEDA and Provincial Laws

For Canadian residents, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation (including PIPA Alberta, PIPA British Columbia, and Quebec Law 25 / Law 64 as applicable).

Accountability: CatFunTool is accountable for all personal information under its control and has designated support@CatFunTool.com as the contact for privacy inquiries.

Consent: We obtain meaningful consent for the collection, use, and disclosure of personal information, with the form of consent varying based on sensitivity. Implied consent is used for non-sensitive purposes clearly connected to an obvious transaction; express consent is required for sensitive data.

Your Rights: Canadian residents may access their personal information held by us and request correction of inaccurate information. Contact support@CatFunTool.com to exercise these rights. We will respond within 30 days.

Breach Reporting: We comply with PIPEDA's mandatory breach reporting and notification requirements, reporting breaches to the Office of the Privacy Commissioner of Canada and affected individuals where there is a real risk of significant harm.

🇯🇵 Japan — APPI (Act on Protection of Personal Information)

For users in Japan, we comply with the Act on Protection of Personal Information (APPI) as amended, including 2022 amendments introducing enhanced opt-out, pseudonymized information handling, and foreign transfer disclosure requirements.

Third-Party Provision: We disclose personal information to the third-party advertising and analytics partners listed in Section 1.2 of this Policy. For transfers to foreign third parties, we identify the destination country and the relevant personal information protection system in that country.

Your Rights: Japanese residents have the right to request disclosure, correction, addition, deletion, suspension of use, elimination, and suspension of third-party provision of their personal information. Contact support@CatFunTool.com with subject line "APPI Request."

1.4 Auto-Renewal Subscription Policy

Certain apps published by CatFunTool offer auto-renewable subscription services. The following terms apply to all such subscriptions in addition to any app-specific subscription terms presented at the point of purchase:

  • Subscription Transparency: The subscription price, billing interval (e.g., weekly, monthly, annual), and included features are clearly disclosed on the app's product page and in the in-app purchase prompt before any transaction is initiated. No subscription will begin without your explicit confirmation.
  • Free Trial Terms: Where a free trial is offered, the trial period, the price that will be charged upon trial expiration, and the billing date are disclosed clearly. Charges will not apply during a free trial period. If you cancel before the end of the free trial, you will not be charged. Only one free trial per subscription product per Apple ID or Google Account will be honored.
  • Billing Reminder: Subscription renewals will be processed automatically unless you cancel at least 24 hours before the end of the current billing period. Apple will send a renewal receipt notification to your Apple ID email. You are responsible for monitoring your subscription status.
  • Price Changes: If we change subscription pricing, we will provide advance notice through the App Store/Google Play prior to the change taking effect. Your continued subscription after the price change takes effect constitutes acceptance of the new price.
  • How to Cancel:
    • iOS: Open iOS Settings → tap your Apple ID → Subscriptions → select the app → Cancel Subscription.
    • Android: Open Google Play Store → tap your profile → Payments and subscriptions → Subscriptions → select the app → Cancel subscription.
    Cancellation takes effect at the end of the current billing period. You will retain access to subscription features until the period expires.
  • Refunds: Refund requests for subscriptions are handled by Apple Inc. or Google LLC respectively. CatFunTool does not process subscription refunds directly. Please use the appropriate platform refund request system. CatFunTool has no ability to override platform refund decisions.
  • Subscription Fraud: Attempts to manipulate subscription billing, share subscription credentials, reverse-engineer entitlement validation, or misuse free trial offers constitute a material breach of our Terms of Service and may result in account suspension and permanent revocation of subscription access without refund.

1.5 AI-Generated Content Declaration

Certain features within CatFunTool's apps may incorporate AI-generated or AI-assisted content, including but not limited to algorithmic suggestions, procedurally generated audio or visual content, and AI-powered analytical outputs.

  • Labeling: Where AI-generated content is presented as information or recommendation, we will clearly label such content as AI-generated or algorithmically produced to the extent technically feasible and required by applicable law, including the EU AI Act (where applicable) and emerging domestic AI content labeling regulations.
  • Data Use for AI: Unless you have provided explicit consent, we do not use your personal behavioral data to train external AI models. Aggregate, de-identified data may be used to improve on-device algorithm performance.
  • Accuracy and Liability: AI-generated content may be inaccurate, incomplete, or inappropriate. We disclaim liability for reliance on AI-generated content to the maximum extent permitted by applicable law. You should independently verify important AI-generated outputs before acting on them.
  • Prohibited AI Uses: You may not use AI-generated content from our Services to create synthetic media that deceives, defames, or harms other individuals, or in violation of any applicable law.
  • Regulatory Compliance: We monitor regulatory developments regarding AI governance (including the EU AI Act, China's Generative AI Service regulations, and US federal/state AI bills) and will update our practices and disclosures as requirements take effect.

Part 2: 2026 Technical Compliance Guide

This section documents our technical compliance posture across major distribution platforms and data residency frameworks, current as of January 2026. This section is provided for transparency and for the benefit of our users, partners, and regulators.

2.1 Apple App Store Technical Compliance

App Privacy Nutrition Labels

All CatFunTool apps on the App Store maintain accurate App Privacy labels in App Store Connect, disclosing all data categories collected under the "Data Linked to User" and "Data Used to Track You" sections. Labels are reviewed and updated with every major SDK update or feature change that affects data collection scope. We disclose at minimum: Device ID (advertising identifiers), Usage Data (app interactions), Diagnostics (crash data), and Purchase History.

App Tracking Transparency (ATT) Framework

  • Mandatory Prompt: All apps that collect IDFA or link behavioral data across apps for advertising purposes present Apple's requestTrackingAuthorization() prompt before any advertising SDK initialization that requires user-level tracking.
  • No ATT Bypass: We do not use any technical methods to circumvent ATT, including fingerprinting, IP-based probabilistic matching for advertising purposes, CAID, or any other ATT bypass technique prohibited by Apple's App Store Review Guidelines.
  • iOS 18 Single-Prompt Compliance: In accordance with iOS 18 policies, apps present ATT prompt only once per install, without repeated re-prompting after user denial. ATT status is checked at app launch and respected persistently.
  • SKAdNetwork: For attribution measurement without IDFA, we support Apple's SKAdNetwork framework for privacy-preserving install attribution in accordance with Apple's guidelines.
  • Privacy Manifests: All app targets and third-party SDKs that access required reason APIs include privacy manifest files (PrivacyInfo.xcprivacy) specifying the reason codes for API usage, in compliance with Apple's requirements effective May 2024 onward.

Subscription and IAP Technical Compliance

We implement StoreKit 2 (or StoreKit 1 where compatibility requires) for all IAP and subscription transactions. Transaction verification uses App Store server-side receipt validation or signed transaction verification. We do not cache or store raw receipts on our servers beyond what is needed for entitlement verification. We implement Transaction.currentEntitlements to accurately reflect subscription status across devices.

2.2 Google Play Android Technical Compliance

Data Safety Form

All CatFunTool apps on Google Play maintain accurate and current Data Safety section declarations in the Google Play Console, disclosing all data types collected, whether data is shared with third parties, whether data is encrypted in transit, and whether users can request data deletion. Forms are reviewed and updated with each SDK update, new data collection, or policy change.

Encryption and Security Standards

  • Storage Encryption: All locally stored user data is encrypted using AES-256. Sensitive data (transaction records, identifiers) stored in Android Keystore-backed secure storage.
  • Transmission Encryption: All network communications use TLS 1.2 or higher with certificate pinning for sensitive endpoints. Cleartext traffic (HTTP) is disabled for all production domains in the Network Security Configuration.
  • Third-Party SDK Transparency: All SDKs integrated into our Android apps must support Android 14+ Privacy Sandbox APIs. We do not integrate SDKs that bypass Android privacy controls or access data through undocumented methods.

Android 14 and Android 15 Compliance

  • Privacy Sandbox on Android: We participate in the Privacy Sandbox on Android transition, adopting Topics API, Protected Audience API, and Attribution Reporting API as these become viable and as our SDK partners support them.
  • Android 15 OTP and Screen Sharing: In compliance with Android 15 requirements, our apps do not request accessibility permissions or device admin privileges for purposes unrelated to accessibility. We implement the Android 15 screen-sharing content indicator in any feature involving screen recording or sharing.
  • 64-bit Requirement: All CatFunTool Android apps are compiled as 64-bit binaries (ARM64-v8a) in compliance with Google Play's mandatory 64-bit requirement.

Google Play Billing

All in-app purchases use the Google Play Billing Library (latest stable version). We implement the PurchasesUpdatedListener for real-time purchase updates, verify all purchases server-side using the Google Play Developer API before granting entitlements, and handle all billing response codes correctly including ITEM_ALREADY_OWNED and USER_CANCELED.

2.3 2026 Global Data Residency Compliance

The following table summarizes our data residency posture for major jurisdictions:

China (PRC)

Personal information of users in mainland China is processed and stored within the PRC unless a lawful cross-border transfer mechanism is in place (security assessment, standard contract, or certification). We cooperate with required CAC security assessments for large-scale data exports. PIPL-required consent is obtained before any cross-border data transfer.

India

We comply with data localization requirements under the DPDP Act as they take effect pursuant to government notification. Financial payment data processed through Google Play Billing is subject to RBI data localization requirements, which are satisfied through Google's compliant infrastructure.

Saudi Arabia

Personal data of Saudi residents is processed in accordance with NDMO/SDAIA data residency guidelines. Cloud infrastructure serving Saudi users routes data through regions authorized for Saudi data. Cross-border transfers require SDAIA authorization or fall within PDPL permitted exceptions.

Brazil

International transfers of Brazilian personal data are conducted under Standard Contractual Clauses or equivalent mechanisms pursuant to LGPD Chapter V. We monitor ANPD guidance on approved transfer mechanisms and update our practices accordingly.

European Union

EU personal data transfers to third countries are conducted under Standard Contractual Clauses (SCCs, Commission Decision 2021/914) with supplementary measures including encryption, pseudonymization, and access controls. Where adequacy decisions exist (e.g., for US entities under the EU-US Data Privacy Framework), we verify partner certification status annually.

Canada

Transfers of Canadian personal data to third parties outside Canada are conducted under contractual protections ensuring comparable levels of privacy protection as required by PIPEDA and applicable provincial laws. Quebec Law 25 assessment requirements are applied for transfers from Quebec.

United States Cloud Act

We acknowledge that certain data stored on US-based cloud infrastructure may be subject to US government access requests under the CLOUD Act. We will challenge overly broad requests to the extent permitted by law and will notify affected users of data disclosure requests where legally permitted to do so.

2.4 Transparency UX Design Standards

We implement the following UX standards across our app portfolio to ensure informed consent and transparent user experiences:

  • Privacy Policy Placement: Our Privacy Policy is accessible in three locations for every app: (1) the App Store / Google Play product page; (2) the app's splash/onboarding screen (with a direct link before any data collection begins); and (3) the app's Settings or About menu for ongoing reference.
  • IAP Confirmation: All in-app purchases are subject to a confirmation prompt. For purchases above USD $50.00 (or equivalent), an additional double-confirmation step is implemented to prevent accidental purchases.
  • Permission Request Clarity: System permission dialogs (notifications, tracking, location) are preceded by a plain-language "pre-permission" screen explaining exactly why the permission is needed and what will happen if denied — before any system dialog is shown.
  • Rewarded Ad Skip: Where technically permitted by the ad network, a skip or close option is made available for rewarded ad formats after 5 seconds of viewing. The reward is granted only upon completion of the full ad view as required by the advertiser.
  • Complaint Channels: Every app provides a clearly accessible in-app feedback / report mechanism and links to support@CatFunTool.com for complaints, abuse reports, and content moderation requests.
  • Android 15 Screen Share Indicator: In any feature utilizing screen capture or sharing, we implement the Android 15 required visual indicator notifying users that screen sharing is active.

Part 3: Compliance Risk Control and Regular Review

3.1 Risk Control Measures

  • Pre-Launch Compliance Audit: Every app version undergoes a compliance review before submission to the App Store or Google Play, covering privacy labels accuracy, ATT implementation, Data Safety form completeness, IAP implementation, age-appropriateness checks, and legal document currency.
  • Third-Party Partner Management: Before integrating any new SDK or service provider, we conduct a privacy impact assessment covering data types collected, legal bases, sub-processor relationships, and any data residency implications. New partners must execute DPAs where required.
  • User Rights Request Handling: We maintain a designated inbox (support@CatFunTool.com) for data subject rights requests and privacy inquiries. All requests are logged, triaged within 3 business days, and responded to within the applicable statutory deadline. We maintain a record of all requests and responses for audit purposes.
  • Security Protection: We implement technical and organizational security measures proportionate to the risk, including: end-to-end encryption for sensitive data; access controls limiting data access to personnel with a need-to-know; regular security reviews of SDK dependencies; secure coding practices aligned with OWASP Mobile Top 10; and a documented incident response plan for data breaches.
  • Staff Training: All team members involved in product development, data handling, or user support receive annual training on applicable privacy laws, security best practices, and our internal policies.

3.2 Regular Review Requirements

We conduct a formal compliance review on a bi-annual (every 6 months) basis, covering the following checklist:

  • ☑ Privacy Policy and Terms of Service currency — reflect any new features, SDKs, or regulatory changes
  • ☑ App Store / Google Play compliance — Privacy Nutrition Labels, Data Safety Form, store metadata
  • ☑ SDK inventory audit — verify all integrated SDKs, update to latest compliance-ready versions
  • ☑ Data handling practices — confirm data minimization, retention schedules, and deletion procedures
  • ☑ Anti-fraud rule effectiveness — review fraud detection system performance, update penalty thresholds
  • ☑ User rights request log — review all requests received, ensure timely and accurate responses
  • ☑ Third-party DPAs — confirm all required data processing agreements are current and executed
  • ☑ Security vulnerability assessment — scan for known CVEs in dependencies, update as needed
  • ☑ Regulatory change monitoring — assess impact of new or amended laws across all target jurisdictions
  • ☑ Ad platform policy compliance — verify ongoing compliance with all ad network policies and guidelines

The results of each review are documented internally and trigger updates to this Policy and related documentation where required.

Part 4: General Provisions

4.1 Children's Privacy

Our Services are not directed to children under the age of 13 (or 16 in EU/UK jurisdictions, or such higher age as required by applicable local law). We do not knowingly collect personal information from children. If you believe we have inadvertently collected personal information from a child, please contact support@CatFunTool.com immediately and we will delete such information promptly.

Certain apps may be designed for family use. In such cases, separate in-app privacy disclosures for child users and parental consent mechanisms will be implemented as required by COPPA (US), the UK Children's Code (AADC), and equivalent regulations.

4.2 Data Security and Breach Notification

We implement industry-standard technical and organizational security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. In the event of a personal data breach that poses a risk to the rights and freedoms of individuals, we will:

  • Notify the relevant supervisory authority within 72 hours of becoming aware of the breach (GDPR/UK-GDPR standard), and within applicable timelines under other jurisdictions' breach notification laws.
  • Notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.
  • Document the breach, its effects, and remedial measures taken.

4.3 Changes to This Policy

We may update this Policy periodically to reflect changes in our practices, technology, legal requirements, or for other operational reasons. Material changes will be communicated through in-app notifications, prominently displayed notices at the top of this page, and/or email notification where required by applicable law. The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the Services following the effective date of any changes constitutes your acceptance of the revised Policy.

4.4 Governing Law and Dispute Resolution

This Policy is governed by the laws of the People's Republic of China, without prejudice to any mandatory provisions of consumer protection or privacy law in your jurisdiction of residence that cannot be excluded by contract. For EU/UK residents, nothing in this Policy limits your right to lodge a complaint with your national Data Protection Authority. For disputes arising from this Policy, the parties agree to first attempt good-faith resolution through direct communication before pursuing formal legal remedies.

4.5 Contact and Data Protection Inquiries

For all privacy-related inquiries, data subject rights requests, breach notifications, or regulatory correspondence, please contact:

CatFunTool — Privacy Team
Email: support@CatFunTool.com
Direct: luyiming@CatFunTool.com
Address: No. 288 Guoyuan Road, Huaishang District, Bengbu, Anhui, China
(Bengbu Tongren Intelligent IoT/IT Park)

Please include "Privacy Request" and your jurisdiction in the subject line for faster routing. See also our Terms of Service for additional policies governing use of our Services.