Effective date: October 26, 2026

iClasser LLC ("iClasser," "we," "us," or "our") develops and publishes mobile applications ("Apps"), including education, creative, and utility Apps. This policy explains why and how iClasser processes personal data when you use those Apps.

Some of these Apps are directed at children. Some are for a general audience. Not every App uses every feature described below. We process a category of data only when that App includes the feature, or when someone chooses to provide the information. Use of the Apps is also covered by our User Agreement.

Our website and educational platform are covered by a separate Privacy Policy. Our mobile games are covered by a separate Games Privacy Policy.

An App that is not directed at children, and that lets you create an account, is intended for people 18 or older. Creating an account on that App confirms that you are at least 18. Section 2 explains Apps that are directed at children.

For privacy questions and requests, email support@iclasser.com. iClasser LLC is the controller of personal data described in this policy.

1. How do we process your data in our Apps?

When you install and use an App, we process the information needed to operate that App. Some Apps also include analytics, advertising, attribution, bot checks, sign-in, a server-side backend, or an AI feature. Those practices apply only to Apps that include them.

1.1. What information do we collect about you?

Information you provide for a feature. When an App needs it to work, we may ask for a name, email address, phone number, address, or location. Device location is collected only after permission is granted. We use this information to provide the feature, operate an account, and respond to support requests. We do not sell a name, email, phone number, or street address, and we do not send a phone number or street address to advertisers. An App directed at children does not ask the child for a phone number, street address, or precise location. Section 2 describes those Apps.

Account and sign-in, when the App offers them. You may sign in with Apple, Google, or an email or phone account. We receive the identifier and email address needed to secure the account, including an Apple private relay address if you choose one. We use that information to create and protect your account and to provide the service.

Backend, when the App has one. Account data and the information required for the feature may be stored on iClasser servers. An App without a backend keeps that data on your device, aside from data collected by a third-party SDK the App includes.

Learning progress, on an education App. An education App may store progress, such as lessons opened or completed, on the device or, when the App has a backend, on our servers. We use that information to operate the App and show progress.

Attribution, when the App includes Adjust. Adjust receives advertising identifiers, app-instance identifiers, app events, IP address, and campaign data to measure installs and advertising campaigns and to detect fraud.

Analytics, when the App includes it. We use analytics services, such as Google Analytics, to understand how an App is used and to improve it. They receive app usage, device and technical data, and country-level location inferred from the IP address. On an App directed at children, we use analytics to operate and improve the App. We do not use a child's information to build an advertising profile.

Captcha, when the App includes a bot check. The captcha provider may receive your IP address, device data, and interaction data to tell a person from an automated request.

Advertising, when the App includes it. Third-party advertising partners, such as Google AdMob, receive advertising identifiers such as IDFA or GAID, ad interactions, device and technical data, and consent choices, so advertisements can be shown and measured. Personalized advertising follows consent and device settings. An App directed at children does not use a child's personal information for personalized or behavioral advertising.

Payments, when the App charges a fee. Card payments are collected by Stripe or PayPal, or by Apple or Google for a purchase in an app store. Those providers receive the payment details. We receive a transaction record, such as a transaction identifier, payment status, and the email connected to the payment. We do not store the full payment card number.

AI and image features, when the App includes them. Some Apps display material that was generated with AI, such as lessons or images prepared for the App. Using that material does not, by itself, send a user's identity to an AI provider. When a feature converts an image you upload, or generates a result from a prompt or other content you submit, we send that image, prompt, or content to the provider that runs the feature so it can return the result. Depending on the App, that provider is fal.ai or OpenRouter. OpenRouter routes a request to a model provider. Those providers process the content under their own privacy policies, which describe their retention and whether a model provider may use inputs. We do not send a payment card number to these providers.

1.2. Why and on what legal bases do we process your data?

The following table explains why we process this data and the legal bases for doing so. A row applies only when the App includes that feature or you provide that information.

1.3. Who do we share your data with?

We share personal data with the recipients below only when the App uses that service or when the law requires it. Where required, we apply contractual, technical, and organizational safeguards.

• Service providers: Hosting, support, and infrastructure providers that operate an App, including a backend when the App has one.
• Analytics providers, such as Google Analytics, when the App includes them, so we can understand how the App is used and improve it. Where the law requires consent before this analytics runs, we ask for it first.
• Adjust, when the App includes it, for install and campaign attribution and fraud checks. Adjust may act as our service provider or as an independent controller, depending on the service and the applicable law.
• Advertising partners, such as Google AdMob, when the App includes third-party advertising, to display and measure advertisements. They act as independent controllers for the advertising they deliver. You can opt out of personalized advertising in the App where a control is available, in your iOS or Android advertising settings, or by emailing support@iclasser.com. An App directed at children does not use a child's personal information for personalized or behavioral advertising.
• Captcha providers, when the App includes a bot check, to tell a person from an automated request.
• AI providers, when the App converts an image you upload or generates a result from content you submit. Depending on the App, we use fal.ai or OpenRouter. They receive the image, prompt, or other content needed to return the result, and they process it under their own privacy policies. OpenRouter may route that request to a model provider.
• Stripe and PayPal, when the App takes a card payment through them. They collect the payment details and act as independent controllers for that payment. Their privacy policies are at stripe.com/privacy and paypal.com/legalhub/privacy-full. We receive the transaction record described above and do not store the full card number.
• Apple and Google, when you sign in or make a purchase through an app store. They act as independent controllers for authentication and payment. We receive the identifier, email or private relay address, and tokens needed to secure the account, and transaction identifiers when a purchase is made.
• Legal and regulatory authorities, when we must comply with a legal obligation.

1.4. How long do we keep your data?

We keep personal data only for as long as needed for the feature that collected it, or for as long as a legal duty requires.

2. Children's privacy

Some Apps are directed at children, including school and curriculum Apps. The children's rules in this section apply when an App is directed at children. An App that is not directed at children follows the general rules.

On an App directed at children, we collect what the learning or creative feature needs. That can include learning progress and, if the feature asks for it, an image or prompt the child submits. We do not ask the child for a phone number, street address, or precise location. We do not sell a child's personal information. We do not use it for personalized or behavioral advertising, and we do not use it to build an advertising profile.

Where the law requires a parent or guardian to consent before we collect personal information from a child, we collect it with that consent. If we cannot obtain the consent the law requires, we do not collect personal information that needs it.

In the European Economic Area, consent-based processing for an information-society service offered directly to a child requires a parent or guardian's consent when the child is under 16, unless the child's country of residence sets a lower age. That age will not be below 13. In the United Kingdom, the age is 13. In the United States, an App directed to children under 13 follows the Children's Online Privacy Protection Act, including verifiable parental consent before we collect personal information that the Act covers.

A parent or guardian may email support@iclasser.com to review the child's information, correct it, delete it, or refuse further collection. We will delete it. The same address is how a parent withdraws consent.

An App that is not directed at children is not a children's service. If that App offers an account, the account is for a person 18 or older. We do not knowingly collect personal information from a child on that App. If a child has used it, or an account was created for a child, email support@iclasser.com. A parent, guardian, or the user may make that request. We will delete the information.

3. How is your data protected when transferred internationally?

iClasser is based in the United States. Some of our partners and service providers may be located outside the European Economic Area, the United Kingdom, or Switzerland, including in the United States.

When we transfer personal data internationally, we do so under applicable data protection law, including the GDPR, the UK GDPR, and Swiss data protection law where they apply. Safeguards are chosen for the transfer. They may include an adequacy decision, the European Commission's standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, a Swiss-recognized transfer tool, or certification under the EU-U.S. Data Privacy Framework, and a UK or Swiss extension, where the recipient is certified.

4. What are your rights and how can you exercise them?

Wherever you live, you can email support@iclasser.com to ask a question or exercise a right. We will handle the request with care.

4.1. Who can you contact regarding your privacy?

Email support@iclasser.com. We respond to privacy requests by email.

4.2. What are your rights in the EEA, the UK, and Switzerland?

If you live in the European Economic Area, the United Kingdom, or Switzerland, the GDPR, the UK GDPR, or Swiss data protection law may apply. iClasser LLC is the controller. Contact us at support@iclasser.com. The purposes, categories of data, and legal bases are in section 1.2. The recipients are in section 1.3. Retention is in section 1.4. International transfers are in section 3.

Where European or UK law requires consent before analytics, advertising, or attribution software runs, we ask for that consent before it runs. You can refuse it, and the App remains available for the features that do not need it. You can withdraw consent later by emailing support@iclasser.com or, where the App provides a control, in the App.

You have the following rights:

• Access and portability: You can ask for a copy of your personal data. Where the law requires it and it is technically feasible, we provide that copy in a structured, commonly used, machine-readable format.
• Rectification: You can ask us to correct inaccurate or incomplete data.
• Erasure: You can ask us to delete your data, unless the law requires us to keep it or we need it to establish, exercise, or defend a legal claim.
• Restriction: You can ask us to limit processing in the cases the law provides.
• Objection: You can object to processing based on legitimate interests, on grounds related to your situation. You can object to processing for direct marketing at any time.
• Withdraw consent: Where we rely on consent, you can withdraw it at any time. Withdrawal does not affect processing that was lawful before the withdrawal.
• Automated decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significant effects. Generating a lesson, image, or other result with AI is not that kind of decision.
• Complaint: You can lodge a complaint with a supervisory authority in your country of residence, place of work, or the place of the alleged infringement. In the UK, that authority is the Information Commissioner's Office.

A parent or guardian may exercise these rights for a child, as described in section 2. We may ask for information needed to confirm the requester's identity and, where the request is about a child, the requester's authority. We respond within the time the applicable law requires.

4.3. What are your rights in the United States?

This section applies to residents of U.S. states whose privacy laws grant consumer rights, including California. Depending on your state, you may have some or all of the rights below.

In the preceding twelve months, the categories we may have collected, depending on the App, are identifiers (such as an email address, phone number, account identifier, advertising identifier, or IP address), commercial information if you make a purchase, internet or other electronic network activity (such as app usage and ad interactions), geolocation when you grant permission or enter an address, content you submit to an AI or image feature, and, on an education App, learning progress.

We disclose those categories to the service providers and partners in section 1.3 when the App uses them. Where an App includes third-party advertising or Adjust, disclosing advertising identifiers and related device data for personalized advertising or measurement may be a "sale," "sharing," or "targeted advertising" under some state laws. We do not sell your name, email, phone number, or street address. We do not sell or share the personal information of a child, and we do not use it for targeted advertising.

• Access, know, and portability: You may ask whether we process your personal data, for a copy of it, and for information about how we use and disclose it.
• Correction and deletion: You may ask us to correct inaccurate personal data or to delete personal data, subject to legal exceptions.
• Opt out of sale, sharing, and targeted advertising: Where an App includes advertising or Adjust, you may opt out in the App where a control is available, in your iOS or Android advertising settings, or by emailing support@iclasser.com.
• Non-discrimination: We will not discriminate against you for exercising a privacy right.
• Appeal: If we deny a request, you may reply to our response or email support@iclasser.com with "Privacy Appeal" in the subject line.

4.4. How to manage your preferences

You can also use:

• In-app controls, where the App provides them, to manage advertising choices or request deletion.
• Device settings to turn off location permission, reset or limit your advertising identifier, and manage iOS App Tracking Transparency or Android ad personalization.

Email support@iclasser.com for a request you cannot complete in the App.

5. How do we update this policy?

We may update this policy when our Apps or the law changes. The date of the current version is at the top of this page. Email support@iclasser.com if you would like a previous version.