Privacy Policy

1. Types of Information Collected

We may gather the following categories of personal data:

1.1 User-Submitted Information

When engaging with our support services on FlashClean: Boost & Clear Junk, you may voluntarily provide:

• Contact details (including email address)
• Supporting materials related to your inquiry (text, images, or videos)
• Your account identifier and issue description for effective troubleshooting

We also maintain records of all communications when you reach out to us regarding:

• Service complaints
• Technical support requests
• Product feedback submissions

1.2 Data Collected Through Automated Means

Usage Analytics

We document user interactions within the platform, including but not limited to:

• Navigation patterns (clicks, follows, searches)
• Content preservation actions ("My List" additions)
• Viewing behaviors and transactional activities

This operational data enables personalized content curation by analyzing preferences and inferring interests.

Specific applications include:

• Tracking daily check-ins, subscription status, push notification preferences, and viewing duration for reward program calculations
• Displaying transactional histories and reward earnings on relevant platform interfaces

Device Specifications

Our systems may identify:

• Advertising identifiers (IDFA exclusive to iOS ecosystems)

This facilitates device authentication, service security enhancement, and browsing optimization.

Advertising Ecosystem Data

We analyze installed application portfolios on user devices to refine advertising relevance.

Local Data Retention

Application cache mechanisms may preserve information (including personal data) on your device.

Tracking Technologies

We employ multiple digital tracking solutions:

Cookies & Similar Technologies

Text-based cookies combined with advanced tracking methods (web beacons, flash cookies, etc.) enable:

• Usage metric analysis (content engagement, frequented pages)
• Experience personalization
• Platform improvements
• Targeted advertising delivery
• Campaign performance measurement

Cross-Platform Marketing

Our partners utilize these technologies for platform promotion across digital properties.

Pixel Technologies

Microscopic image embeddings (termed "pixel tags" or "clear GIFs") capture:

• Cookie data
• Temporal access patterns
• Contextual page information
• Device-specific parameters

For opt-out procedures regarding these technologies, please consult the "User Rights and Preferences" section.

1.3 Data Obtained from External Sources

We may acquire the categories of information specified in this Privacy Policy through the following channels:

Third-Party Authentication Data

Users may access FlashClean: Boost & Clear Junk services by authenticating through:

• Social media accounts (Facebook/Google)
• Apple ID credentials

When utilizing third-party login, we retrieve limited profile data including:

• Display name
• Associated email address
• Device-specific Apple ID (iOS ecosystem only)

This authentication data serves three primary purposes:

• Account provisioning and access management
• Delivery of registered user benefits
• Implementation of security protocols

Publicly Available Records

We may process information legally obtained from:

• Governmental disclosures
• Social media platforms (publicly accessible content)

Third-Party Disclosures

In limited circumstances, we may receive personal data when:

• You are referenced in communications addressed to us (DMs, complaints, appeals)
• An authorized third party provides your contact details

2. Utilization of Collected Data

We process the information we gather to fulfill the following objectives:

2.1 Service Delivery & Operations

• Execute and enforce contractual agreements with users
• Facilitate seamless provisioning, maintenance, and enhancement of our services
• Establish and manage user accounts and associated profiles

2.2 User Engagement

Initiate service-related communications regarding:

• Platform usage updates
• New feature announcements
• Version upgrade notifications

Provide dedicated support for user inquiries.

2.3 Promotional Activities

Distribute marketing communications and exclusive offers via:

• In-platform messaging systems (Opt-out available during registration or subsequently via designated channels)

Implement intelligent advertising solutions including:

• Behavioral targeting systems
• Campaign performance analytics
• Integrated e-commerce functionalities

2.4 Experience Enhancement

Deploy intelligent content curation systems that:

• Analyze user preferences
• Surface relevant content recommendations
• Optimize interface rendering for cross-device compatibility and personalized display settings

2.5 Security Infrastructure

Implement advanced threat detection for:

• Fraud prevention
• Spam mitigation
• Illicit activity monitoring

Maintain comprehensive protection systems covering:

• Account security protocols
• Platform stability measures
• Service reliability standards

2.6 Regulatory Compliance

Adhere to multinational legal requirements including:

• Cross-border litigation responses
• Corporate transaction support (M&A, asset transfers)
• Financial restructuring procedures

2.7 Innovation Development

Advance core technologies through:

• Machine learning optimization
• Algorithmic refinement

Conduct analytical research to:

• Measure platform engagement metrics
• Drive product evolution

3. How We Share Your Information

We will not share your personal information unless explicitly stated in this Privacy Policy. Your personal information may be shared under one or more of the following circumstances:

3.1 Sharing With Your Consent

We may share information with third parties when we have obtained your consent or at your direction.

3.2 Sharing With Business Partners

You understand and agree that some of our services will be provided by or jointly with our business partners.

To comply with this Privacy Policy, you agree that we may share necessary personal information with the following partners:

Social Networks

If you choose to register using your social media account, we will share certain information (including nickname and profile picture) with the relevant social network.

Service Providers

We engage third-party companies to provide services for the purposes described in this Privacy Policy, including:

• Data analysis
• IT and related services
• Email delivery and customer support
• Security and fraud detection

These service providers may access your personal information while performing services for us.

Advertising Partners

For example, we share the list of applications installed on your device with AdMob for advertising and marketing purposes.

Third-Party SDK Providers

FlashClean: Boost & Clear Junk may integrate third-party SDKs or similar applications. By using these third-party services, you agree to their direct collection and processing of your information (e.g., through embedded code or widgets). Such providers' data practices are governed by their own privacy policies, not this Privacy Policy. However, we will:

• Strictly review third-party qualifications
• Impose legal, compliant, and secure requirements

To maximize the protection of your information security, we strongly recommend that you:

• Carefully review third-party privacy policies before use
• Discontinue use and contact us immediately if you identify any risks

Below is information about our primary third-party SDK providers:

1. Facebook SDK
   Link: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
   Usage: Used for user login
2. Google SDK
   Link: https://firebase.google.com/support/privacy
   Usage: Used for push messages, collect and analyze application crashes, collect and analyze application logs, and Google login used to log in users
3. MAX (AdMob, Facebook, Liftoff, IronSource, Unity, Chartboost, DT Exchange, Mintegral) SDK
   Link: https://www.applovin.com/privacy/
   Usage: Used for commercial monetization
4. adjust SDK
   Adjust GmbH.
   Link: https://www.adjust.com/terms/privacy-policy
   Usage: Used to analyze the effectiveness of product placements

3.3 Sharing in Business Transactions

We may transfer your personal information to another entity in the context of business transactions including but not limited to:

• Mergers & acquisitions
• Financing arrangements
• Corporate restructuring
• Bankruptcy proceedings
• Asset transfers
• Similar corporate transactions

In such events, we will:

• Provide notice regarding the information transfer
• Require the new data holder to fully assume and comply with all obligations under this Privacy Policy

3.4 Legal Compliance Disclosures

We may disclose your personal information when legally required to:

• Law enforcement agencies
• Government regulators
• Judicial authorities
• Other public institutions

Such disclosures may occur when reasonably necessary to:

• Fulfill legal or regulatory obligations
• Respond to official requests or inquiries
• Enforce our Terms of Service and other agreements
• Investigate potential policy violations
• Exercise or defend legal rights
• Address security, fraud, or technical issues
• Protect the rights, property, or safety of our organization, our user community, third parties, or the general public

4. Data Storage and Protection Measures

4.1 Data Storage Practices

4.1.1 Storage Locations

Currently, servers storing your personal information related to FlashClean: Boost & Clear Junk are located in Singapore. You acknowledge and agree that we may transfer and store your data on these servers in compliance with applicable laws and regulations. While data protection standards may differ between the server location and your jurisdiction, we will implement stricter safeguards to:

• Maximize protection of your personal information
• Prevent unauthorized information disclosure

As outlined in this Privacy Policy, we may share your information with third parties located outside Singapore. We will not transfer your personal information across borders without first complying with all applicable cross-border data transfer regulations.

4.1.2 Retention Periods

We retain your personal information until:

• Your account is terminated, or
• The information is no longer required for its original purpose

Additional retention may occur when necessary to:

• Comply with legal obligations
• Enforce our agreements
• Resolve disputes

Retention duration varies based on:

• Information category
• Purpose of use
• Legal retention requirements

Upon expiration of retention periods, we will either:

• Delete your information, or
• Anonymize the data (unless otherwise required by law)

4.2 Information Protection Framework

We implement appropriate technical and organizational measures including:

• Data encryption
• De-identification techniques

These safeguards are regularly reviewed and enhanced to improve overall system security. While we are committed to protecting your information, please note that:

• No electronic transmission or storage method is 100% secure
• We cannot guarantee absolute security

If you do not accept these inherent risks, you must discontinue using our services.

4.2.1 Technical Safeguards

• Transport layer security protocols to prevent interception
• Data classification and tiered storage systems
• Multi-factor authentication access controls
• Comprehensive data processing monitoring
• Full lifecycle auditing of all data operations

5. Your Rights and Choices

Under applicable laws and regulations, you possess certain rights regarding your personal information, including but not limited to:

• Right of Access: To request access to your personal information
• Right to Rectification: To correct or modify your personal information
• Right to Erasure: To request deletion of your personal information
• Right to Withdraw Consent: To revoke previously given consent
• Right to Opt-Out: To unsubscribe from notifications/marketing communications
• Right to Content Preferences: To choose personalized content settings
• Right to Data Portability: To obtain a copy of your data in a structured format
• Right to Restrict Processing: To limit or object to processing of your information

To exercise these rights or if you encounter difficulties in doing so, please contact us using the provided contact details. We will:

• Verify your identity
• Respond within a reasonable timeframe, or the period required by your jurisdiction's laws

If you disagree with our decision regarding your request, you may appeal following the instructions in our response notice.

Additional jurisdiction-specific rights may apply as outlined in the Supplemental Terms - Jurisdiction-Specific Provisions section, in accordance with applicable local laws.

6. Handling of Minors' Information

Our services are not directed at individuals below the age of 13 or the legal minimum age in your jurisdiction (as defined in the Supplemental Terms - Jurisdiction-Specific Provisions). We do not knowingly collect personal data from users under this age threshold. If you are below the minimum age, please refrain from using FlashClean: Boost & Clear Junk or submitting any personal information. Should we become aware that we have inadvertently collected data from an underage user, we will promptly delete such information and deactivate the associated account.

For users above the minimum age but still legally considered minors, parental or guardian oversight is required. By using our services, you (and your parent/guardian) acknowledge and consent to this Privacy Policy. Minors must review these terms with a parent or legal guardian and obtain approval before sharing any personal data.

7. Cross-Border Data Transfers

To deliver our services, your personal information may be processed in or transferred to jurisdictions outside your own, including to affiliated entities or third-party partners. These regions may have differing data protection standards— some offering less stringent safeguards than your local laws. Regardless, we adhere to applicable regulations and implement appropriate measures to secure your data in alignment with this Privacy Policy.

8. Policy Updates & Notifications

We may periodically revise this Privacy Policy to reflect legal, operational, or technological changes. Updates will be marked with a revised "Last Updated" date, and material modifications will be communicated via prominent notices (e.g., in-app alerts, emails, or website banners). Where mandated by law, we will seek your explicit consent before enforcing changes affecting your rights. For your benefit, we recommend reviewing this policy regularly to stay informed.

9. Contact Us

If you have any questions, comments, complaints, requests, or suggestions regarding this Privacy Policy or any privacy-related matters, you may:

• Submit feedback directly within the app via ["Profile" - "Help & Feedback"];
• Email us at: connect@Dialect.com
• Refer to the "Supplemental Terms - Jurisdiction-Specific Provisions" section below to check if there is a local representative or contact in your country/region.

Upon receiving your inquiry or request, we will respond within the timeframe required by applicable laws after verifying your identity. While we strive to address all requests promptly, this does not affect your right to lodge a complaint with the relevant data protection authority (where applicable).

10. Language

This Privacy Policy is originally written in English and may be translated into other languages. In case of any discrepancy, conflict, or ambiguity between the English version and a translated version, the English version shall prevail.

11. Governing Law & Dispute Resolution

This Privacy Policy is governed by and construed in accordance with the laws of Singapore, without regard to its conflict of laws principles. Any disputes arising under this policy shall be resolved in accordance with the Terms of Service.

12. Supplemental Terms - Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms - Jurisdiction-Specific applicable to your jurisdiction from which you access or use the services, and the rest of the Privacy Policy, the relevant jurisdictions' Supplemental Terms - Jurisdiction-Specific shall prevail.

12.1 Additional Notice for California Residents

This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").

12.1.1 How we collect and disclose your personal information

Over the past 12 months, we have collected and disclosed your personal information as mentioned in the "What Information We Collect" and "How We Share Your Information" sections, for purposes set out in the "How We Use Your Information" section. Please refer to these sections to see details.

The category of the above information is reiterated with terms specified in CCPA as follows:

Category Defined in CCPA	Source
Identifiers, including your email address and account name.	Information from other sources and information you provide.
Commercial information, including your transaction history, reward coins history and consumption records.	Automatically collected information.
Internet or other electronic network activity information, including your clicking and following records, collection, searching and browsing history, and information regarding your interaction with us.	Automatically collected information.
Audio, electronic, visual, thermal, olfactory, or similar information. This may be contained in the information you provide when contacting us.	Information you provide.
Sensitive personal information. Account log-in, in combination with any required security or access code, password, or credentials allowing access to an account.	Information from other sources.
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics and other attributes.	We may make inferences from information obtained directly from you or automatically collected during your use.

We do not knowingly collect any information about anyone under the age of 16.

12.1.2 Do we sell or share your personal information

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of "sold" and "shared" in the CCPA. We will not sell or share your personal information without providing you with notice and an opportunity to opt-out of such sale and sharing.

12.1.3 Your California rights

Depending on your residency, you have the following rights with respect to your personal information:

• The right to know. You have the right to request to know what personal information about you we have collected, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected.
• The right to delete. You have the right to request us to delete your personal information, subject to certain exceptions.
• The right to correct. You have the right to request us to correct inaccurate personal information that we maintain about you. Note that correction requests are subject to certain limitations, and we may choose to delete rather than correct your personal information in some circumstances.
• The right to opt-out. You have the right to opt-out of the sale or sharing of your information under CCPA. However, as aforesaid, we do not sell or share your personal information in the context of CCPA. Therefore, we do not have an opt-out. We will not sell or share your personal information without providing you with notice and an opportunity to opt-out of such sale and sharing.
• The right to limit. You have the right to request us to limit the use and disclosure of sensitive personal information in accordance with CCPA, subject to certain limitations.
• The right to non-discrimination. We will not discriminate against you for your exercise of privacy rights conferred by the CCPA.

12.1.4 How you exercise your rights

Method. You may exercise your rights by using methods described in the "What Are Your Rights and Choices" section. You may only make a verifiable consumer request for your "right to know" twice within a 12-month period.

Verifying your request. We only respond to your requests when we can verify your request. In order to verify your request, we may need additional information. If we cannot verify your identity, we will let you know.

Range of our response. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If we cannot comply with any portion of a request, the response we provide will also explain the reason, if applicable.

Authorized agent. If you choose to use an authorized agent to submit your request, we may require your agent to provide proof that you have given signed permission to submit the request. We may also require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with us. We will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4121 to 4130. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf or from an agent that does not meet the requirements for authorized agents under the CCPA.

Fees and charges. We do not ordinarily charge a fee for our response to your requests. However, where a request is excessive, repetitive, or manifestly unfounded, we may determine to charge a reasonable fee to comply with your request.

Response timing. We will use good faith efforts to respond to your request within 45 days of receipt of such a request. Where an extension (up to a total of 90 days) is necessary, we will inform you of the reason and the needed extension period in writing. We will comply with your request to limit within 15 business days from the date of our receipt of your request.

12.2 Additional Notice for European Economic Area ("EEA") Residents

This section applies to residents in EEA covered by the General Data Protection Regulation ("GDPR").

12.2.2 Legal Basis for Processing

We will only use your personal information where we have a lawful basis to do so. Under the General Data Protection Regulation (GDPR), we process personal data based on the following legal grounds:

• Your Consent — We may process your personal information when you provide explicit consent for specific purposes. You have the right to withdraw your consent at any time.
• Contractual Necessity — We process personal data when necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legitimate Interests — We may process personal data where necessary to pursue our or a third party's legitimate interests, provided these interests do not override your fundamental rights and freedoms. Our legitimate interests include:
  • Enhancing your user experience
  • Sending marketing communications, promotions, and advertisements related to our products/services
  • Developing, testing, and improving our offerings
  • Ensuring the security, confidentiality, and integrity of FlashClean: Boost & Clear Junk
  • Complying with non-EEA laws, regulations, or governmental requests
  • Protecting our and our customers' rights and property
  • Resolving disputes and enforcing agreements
• Legal Obligation — We process personal data when necessary to comply with a legal obligation, such as:
  • Responding to lawful requests from law enforcement, regulators, courts, or public authorities
  • Meeting disclosure requirements under applicable laws
• Public Interest — We may process personal data where necessary to perform a task carried out in the public interest, including:
  • Conducting research
  • Preventing and detecting crime
  • Protecting children and safeguarding public safety, security, and integrity as defined by applicable laws
• Vital Interests — We may process personal data when necessary to protect someone's life, physical integrity, or safety, such as:
  • Sharing information with emergency services in critical situations to preserve health or life

12.2.3 Your GDPR Rights

Your rights regarding your personal information in accordance with GDPR specifically include the following:

• The right of access. You have the right to request access to your personal information, which enables you to receive a copy of information undergoing processing.
• The right to rectification. You may request correction of inaccurate personal information without undue delay. You may also supplement any incomplete personal information, taking into account the purposes of the processing.
• The right to withdraw consent. Where your personal information is processed based on consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal.
• The right to erasure (right to be forgotten). You have the right to request erasure of your personal information under the following circumstances: (1) the personal information is no longer necessary for the purposes of processing, (2) you withdraw your consent if the processing is solely based on consent, (3) you object to the processing and we have no overriding legitimate grounds or you object to the processing for direct marketing purposes, (4) your personal information has been unlawfully processed, or (5) there is a legal obligation imposed on us to erase your personal information. However, where your personal information is necessary for specific purposes set forth in Article 17(3) of GDPR, the right to erasure shall not apply.
• The right to restriction. You have the right to restrict the processing of your personal information if (1) the accuracy of your personal information is contested by you, for the period in which we have to verify the accuracy of the personal information, (2) the processing is unlawful, and you oppose the deletion of your personal information and request restriction, (3) we no longer need your personal information for the purposes of processing, but your personal information is required by you for legal claims, (4) you have objected to the processing for the period in which we have to verify overriding legitimate grounds.
• The right to portability. You have the right to portability, where (1) the processing of your personal information is based on a legal basis of contractual necessity or consent, and (2) the processing is carried out by automated means. This means that you have the right to receive your personal information you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that information to another controller without hindrance from us.
• The right to object. You have the right to object to the processing of your personal information at any time. We will comply with your request, unless we have an overriding legitimate ground or we need to continue processing your personal information to establish, exercise, or defend a legal claim. Where you object to the processing of your personal information for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing, we will no longer process your personal information for these purposes.
• The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint about our processing of your personal information with your national data protection authority.

You may contact us via the contact information provided herein, if you wish to exercise all the above-mentioned rights or if you have any problems related to those rights. You will not usually have to pay a fee to exercise your rights. However, where your requests are manifestly unfounded, repetitive, or excessive, we may charge a reasonable fee. We may need to request specific information from you to help us confirm your identity and ensure your rights. Where a third party submits a request on your behalf, we may need to take reasonable measures to verify the authenticity of the request. In order to speed up our response, we may ask for further information in relation to your request.

12.2.4 Cross-Border Data Transfers

We may transfer your personal information outside the European Economic Area (EEA). When doing so, we implement the following safeguards:

• EU-Approved Countries: If the destination country has received an EU "adequacy decision," we transfer data directly.
• Standard Contractual Clauses (SCCs): For other countries, we use EU-approved SCCs to protect your data.
• Other Legal Mechanisms: When needed, we may use other GDPR-compliant transfer methods.

All transfers ensure your personal information receives protection equal to that provided in the EU.