Privacy Policy.

This Privacy Notice for Replr ("we", "us", or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://www.replr.app or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Replr), or any other application of ours that links to this Privacy Notice
• Use Replr. Replr is an AI-powered keyboard app that generates reply suggestions from screenshots of your chats and dating conversations, and from emails you paste.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not ask for it. But the screenshots you capture and the email text you paste can contain it, for example a dating conversation that reveals someone's sexual orientation, and in some jurisdictions the content of private messages and emails counts as sensitive personal information in itself. We use that content only to generate your replies and a one-line summary of the conversation. Our servers do not store the screenshot or email text after the replies are returned; the app keeps a small thumbnail of each screenshot on your device (see "Do we offer artificial intelligence-based products?").

Do we collect any information from third parties? Yes, in a few cases. We receive Apple's signed records of your App Store purchases (the app passes them to us) and Apple's notifications when your subscription changes and, if you used Sign in with Apple in an earlier version of the app, the name and email address you chose to share through Apple. The AI provider returns the replies and one-line summary it generated and the contact's name it read from the conversation.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? You can delete your account in the app at Settings > Account > Delete account. For anything else, visit https://replr.app/support or email us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we offer artificial intelligence-based products?
6. Is your information transferred internationally?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for Do-Not-Track features
12. Do United States residents have specific privacy rights?
13. Do other regions have specific privacy rights?
14. Do we make updates to this notice?
15. How can you contact us about this notice?
16. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: Replr does not ask you to register or to give us your name or email address. We receive the content you choose to send for a reply, any reply you report, and anything you send us yourself.

• Content you choose to capture. When you generate replies, the app sends the screenshot you captured or, in Email mode, the email text you pasted. It also sends the tone you picked, any note you typed in the message field before generating (the keyboard reads that text and clears the field at that moment), your optional "About you" text, your local time and time zone, for screenshots a language hint (your keyboard's language or your iPhone's language), and, when memory applies, recent summaries for that contact. When you regenerate, it also sends the replies already shown, so the AI can avoid repeating them. Section 5 explains what happens to this content.
• Reported replies. If you long-press a suggested reply and tap Report, the app sends us the reply text and the mode (chat, dating or email), and we store them, linked to your account when this device has one, so we can review the report.
• Sign in with Apple (earlier versions only). The current app has no sign-in screen. If you signed in with Apple in an earlier version, that account also holds your Apple user identifier and the name and email address Apple shared with us, which may be a private relay address.
• Messages to support. If you email us, we receive your email address and whatever your message contains.

Sensitive Information. We do not ask for sensitive information. Screenshots and email text you send can contain it, for example details in a dating conversation that reveal someone's sexual orientation or health. We use that content only to generate your replies and a one-line summary of the conversation, and our servers do not store the screenshot or email text after the replies are returned.

Payment Data. We do not receive your card or other payment details. Purchases and subscriptions are handled by Apple through the App Store, under Apple's privacy policy: https://www.apple.com/legal/privacy/. The purchase records we do receive are described under "Information automatically collected" below.

Application Data. The app asks for these permissions, which you can change at any time in your iPhone's Settings:

• Photos. With your permission, the app and keyboard check for your most recent screenshot and read that screenshot only when you use it to generate replies. The Replr Capture shortcut (Action Button or Back Tap) passes the screenshot to Replr directly and does not use your photo library. In Settings > Screenshots you can have the app delete the screenshots it used for replies from your photo library; iOS asks you to confirm, and the app never deletes any other photos.
• Keyboard Full Access. The Replr keyboard needs Full Access to reach the internet and to share data with the Replr app through storage on your device. The keyboard does not log or send what you type, apart from the note described above, which is sent with that request and saved with that capture in your History.

Information automatically collected

In Short: The app creates an account for your device, and we keep your subscription status and usage events against it. Your IP address is used as the key for short-lived counters that limit abuse, and is not stored in our database. Our attribution provider, AppsFlyer, collects device and network information to measure advertising.

• Device account. The first time you open the app, it creates a random key, keeps it in your iPhone's Keychain (where it stays if you delete and reinstall the app, and does not sync to your other devices), and exchanges it with our server for an account. The account holds that key, a random account ID, your balance of free replies with a record of each grant, use and refund, and sign-in tokens that stop working 30 days after they were last used. We give each device its free replies once, and a device whose account was deleted is normally not given them again. The app also creates a separate random app ID, which it sends with reply requests and usage events.
• Accounts linked to a purchase. If a subscription is registered before this device has an account (for example after you deleted your account, or in an earlier version of the app), the account is identified by that purchase's App Store original transaction ID, and restoring the purchase on another device reaches the same account.
• Purchase and subscription records. When you start a trial, subscribe or restore, the app sends us Apple's signed record of the transaction, and Apple's servers notify ours when your subscription changes, for example when it renews, is cancelled, expires or is refunded. We keep the original transaction ID, the product, the purchase and expiry dates, whether it is a free trial, its status and whether it was a real or test purchase, together with a log of those subscription events, a record of when the paywall was shown and when a purchase was made, and a count of your usage for fair use. When the app has one, it attaches to the purchase a token derived from your account ID, so Apple's signed record can be matched to your account.
• Usage events. The app records named events, such as that onboarding was completed, the keyboard was added, Full Access or Photos access was granted, the paywall was shown, a reply was inserted, or a purchase completed or failed, with a timestamp and small details such as the mode, the onboarding step or the product. Our server records some events itself, such as that a reply was generated or failed, with the mode and AI model, and for each reply generated it records the AI model and quality setting used, the number of tokens and the cost. Events are stored against the random app ID and, once this device has an account, your account ID. Each event also records the two-letter code of the country your connection came from, which Cloudflare, the network our server runs on, works out from the connection; we store that country code only. Events never include your messages, contact names or screenshots, and they do not include your IP address.
• Abuse protection. Every request to our servers carries your IP address, as all internet requests do. Our server uses it as the key for daily counters that limit how many requests, free reply grants, reports and events can come from one network. Cloudflare also uses it, as the request arrives, to work out the country recorded with usage events (see above). It is used for nothing else apart from the diagnostic log messages described below. Each counter is named after the kind of request, the IP address and the day, holds only a count, is kept in Cloudflare's key-value store, and expires 24 hours after it was last updated. We never write your IP address to our database or attach it to your account, your usage events or your content.
• Install attribution (AppsFlyer). The app includes AppsFlyer's software development kit to measure which advertising campaigns lead to installs, trials and subscriptions. It sends AppsFlyer the identifier Apple assigns to our app on your device (the IDFV), device and network information such as device model, operating system version and IP address (from which AppsFlyer can work out an approximate location), app opens, one-time setup milestones (such as keyboard added, Full Access granted, onboarding completed and Photos access granted), and App Store purchases with the price, currency and product. AppsFlyer also assigns its own install ID, the SDK can collect Apple's attribution token for Apple Search Ads so AppsFlyer can record which Apple Search Ads campaign led to the install, and the SDK may send AppsFlyer its own performance statistics and error reports. Apple also sends AppsFlyer copies of its privacy-preserving install attribution reports (SKAdNetwork and AdAttributionKit). We use AppsFlyer's "Strict" version, which contains no code to read your advertising identifier (IDFA). The app does not ask to track you, and we do not give AppsFlyer your Replr account ID, your messages or your contact names.

We do not collect your browser type, referring URLs, device name, precise location, contacts, or a record of the web pages, files or searches you view.

Our hosting provider. Our servers run on Cloudflare, which processes every request on our behalf and may keep its own short-term operational logs at its network edge, including IP addresses, as hosting and network providers do. When a daily limit on free reply grants is reached, or when our key-value store fails while one of these counters is being checked, our server also writes the IP address involved into a diagnostic log message at Cloudflare. That processing is governed by Cloudflare's terms, and we do not use those logs to analyse or profile individual users.

Our website. replr.app does not set cookies of its own and runs no analytics. It loads its fonts from Google Fonts, so your browser connects to Google's servers, which receive your IP address.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To run your account. We process your device account, any account linked to a purchase or to Sign in with Apple, and your subscription records to give a new device its free replies, keep your Premium access in step with Apple, and restore purchases.
• To generate replies. We send the content of each reply request to an AI provider and return the replies to you.
• To respond to user inquiries/offer support to users. We use what you send us to answer your questions and solve problems you report.
• To review reported replies. We read reported replies so we can adjust how the AI behaves.
• To protect our Services. We use daily counters keyed by IP address or account to limit abuse of our servers and of the free replies.
• To identify usage trends. We use usage events and per-reply cost records to understand how the app is used and to manage cost and capacity, so we can improve it.
• To measure advertising. We use AppsFlyer to learn which advertising campaigns lead to installs, trials and subscriptions.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Diagnose problems and/or prevent fraudulent activities
  • Limit abuse of our servers and of the free replies
  • Measure which advertising campaigns lead to installs, trials and subscriptions
  • Review reported replies and improve how the AI behaves
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Service providers. We share personal information with the service providers below, only for the purpose given. Each of them processes it under its own terms and privacy policy.

• Cloudflare runs our servers, database and key-value store (which holds the daily abuse counters, the free reply marker described in section 7, and the two-minute copy of replies described in section 5), hosts our website, and forwards email sent to [email protected].
• AI providers: Google (Gemini API), OpenAI, Anthropic and xAI. Each reply request is sent to one of them to generate your replies (see section 5).
• AppsFlyer measures which advertising campaigns lead to installs, trials and subscriptions (see section 1).
• Discord hosts the private team channel where we receive a copy of each reported reply (the mode and up to 280 characters of the reply, but not your account ID) and operational alerts. Alerts contain no message content; a few include the first eight characters of an account ID or a purchase transaction ID.
• Google (Gmail) and Resend handle our support email: messages to [email protected] are delivered to a Gmail mailbox, and our replies are sent through Resend.
• Google Fonts serves the fonts on our website.

Apple handles your payments and subscriptions, and handled Sign in with Apple in earlier versions of the app, under Apple's own privacy policy. We do not sell your personal information.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"): Google (through the Gemini API), OpenAI, Anthropic and xAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "What legal bases do we rely on to process your personal information?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• Text analysis
• Text generation

What happens to your screenshots and conversations

The app asks for your permission before it first sends captured content to an AI provider, and sends nothing if you decline. After that, each time you generate replies, the app sends the request described in section 1 over an encrypted connection to our server. The server passes its content to one of the AI Service Providers named above, solely to generate reply suggestions, and returns to your device the replies, a one-line summary of the conversation, the contact's name and a few short notes from the AI, such as which app the chat is on and, when memory was used, which remembered details shaped the replies. We do not store your screenshots, email text, notes, About you text or memory summaries on our servers. Our server keeps a copy of that response in Cloudflare's key-value store for about two minutes, only so that a retried request is not charged twice. Apart from that copy and the text of any reply you report, we keep no copy of your conversations.

We use these providers' developer APIs, not their consumer chat apps. Each provider processes the content under its own API terms and privacy policy, which govern how long it may keep the content (for example, for abuse and safety monitoring) and how it may use it.

Conversation memory and history on your device

After each reply, the app saves a record of that capture in storage on your device that only Replr can use: a one-line summary of the conversation, the contact's name, the suggested replies, any note you typed, the tone, the app the chat was on, any memory summaries sent with the request, technical details such as the AI model used and, for screenshot captures, a small low-resolution thumbnail of the screenshot. It saves this whether or not Memory is on, and it is what you see in the History tab. The AI is instructed to write summaries using first names only and without surnames, email addresses, phone numbers, home addresses or financial details; this is an instruction to the AI, not a guarantee.

Memory is on by default. When it is on, and always in Dating mode, the app matches the conversation to a contact you have replied to before and sends that contact's most recent summaries with the request, so the replies can follow the conversation. Our server passes them to the AI provider and does not store them. Turning off Settings > Memory stops summaries being sent with chat and email requests. It does not change Dating mode, and it does not delete summaries already saved on your device.

To delete memory, go to the History tab: open a person and tap Delete contact to remove that contact with their replies and memory, or use Clear all history, which deletes every record and its memory but keeps your contacts' names until you delete each contact. Settings > Account > Delete account also clears this history and your contacts from your device. The full-size copy of your latest screenshot which the app keeps so the New button can make fresh replies from it, is deleted once it is more than an hour old, the next time you open the app or the keyboard. Deleting the Replr app removes this history, but not the random device key kept in your iPhone's Keychain, so reinstalling on the same iPhone reconnects to the same account unless you deleted that account.

How We Process Your Data Using AI

All personal information processed using our AI Products is handled as this Privacy Notice describes. The AI Service Providers process it under their own API terms, as set out above.

6. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers run on Cloudflare's global network, so a request is usually handled in a Cloudflare data centre near you, and our database and key-value store are also hosted by Cloudflare. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us and by the third parties with whom we share your personal information (see "When and with whom do we share your personal information?" above), including in the United States and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

Safeguards for international transfers

Where a service provider's data processing terms include the European Commission's Standard Contractual Clauses or the UK International Data Transfer Addendum, we rely on those terms for transfers of personal information from the EEA or UK. Contact us if you would like more information about transfers to a particular provider.

7. How long do we keep your information?

In Short: We keep account records until you delete your account, keep the content of your conversations on our servers for no more than about two minutes, and keep a few records that are not linked to your account for longer.

• Screenshots, email text, notes, About you text and memory summaries you send: not stored on our servers. The copy of the response (replies, one-line summary, contact name and the AI's short notes) expires after about two minutes.
• IP address counters: expire 24 hours after they were last updated.
• Your account, free replies, subscription records, and the usage events, per-reply cost records and reported replies linked to your account: kept until you delete your account. We do not currently delete them automatically while your account exists.
• Usage events and reported replies recorded before this device had an account: stored without a link to your account (usage events carry the random app ID and a country code), and kept after account deletion. When you delete your account, the country code is removed from the events we keep for this device, so they then carry the random app ID only.
• Free reply marker: when a device account is deleted, we try to keep a marker containing only that device's random key, with no expiry, so the device cannot claim its free replies again.
• Copies of reported replies in our team channel, and support emails: kept until we delete them.
• Data held by our service providers (for example the AI Service Providers, AppsFlyer, and Cloudflare's logs): kept under their own retention policies.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 16 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 16 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. Our Terms require you to be at least 16 to use Replr, and by using the Services you confirm that you are. If we learn that personal information from a user under 16 or the equivalent age as specified by law in your jurisdiction has been collected, we will delete the account and take reasonable measures to promptly delete such data from our records. Replr does not check your age, so if you become aware of any data we may have collected from children under age 16 or the equivalent age as specified by law in your jurisdiction, please contact us at [email protected].

10. What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section "How can you contact us about this notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "How can you contact us about this notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

You can delete your account at any time in the app: go to Settings > Account > Delete account. If you signed in with Apple in an earlier version and have since signed out of that account, email [email protected] and we will delete it.

Deleting your account removes from our database the account and its sign-in tokens, your free replies balance and its record, your subscription record and fair-use counts, your subscription and paywall event logs, and the usage events, per-reply cost records and reported replies linked to your account. On your iPhone, it also clears your history, memory summaries and contacts in the app.

Deleting your account does not:

• cancel your subscription with Apple, which you manage in your iPhone's Settings under your Apple ID > Subscriptions. If you later restore or buy a subscription, a new account is created for it;
• delete usage events or reported replies recorded before this device had an account, which are not linked to your account;
• delete the marker that stops a device claiming its free replies again, which contains only the device's random key;
• delete the copy of a reported reply posted to our team channel, which is not linked to your account, or emails you sent to support;
• delete data held by Apple, AppsFlyer, Cloudflare or the AI Service Providers under their own policies;
• remove your name and About you text or the random app ID from your iPhone (deleting the app removes these), or the random device key in your iPhone's Keychain (which stays even if you delete the app).

Deleted records can remain for a limited time in our database provider's automatic recovery backups. We may also retain some information where the law requires it.

If you have questions or comments about your privacy rights, you may email us at [email protected].

11. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: receiving help through our customer support channels; participation in customer surveys or contests; and facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Categories A, B, D and F: as long as you have an account with us, except as described in "How long do we keep your information?"
• Category G: your time zone is not stored by us; the country code is kept with usage events, and removed from the events we keep when you delete your account; approximate location is kept by AppsFlyer under its own retention policy
• Categories H and L: not stored on our servers after your replies are returned

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have additional rights (for example, to access categories of personal data being processed, to obtain a list of categories of third parties to which we have disclosed personal data, to limit use and disclosure of sensitive personal data, etc., as permitted by the applicable state privacy law).

How to exercise your rights

To exercise these rights, you can contact us by visiting https://replr.app/support, by emailing us at [email protected], or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided below.

13. Do other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular: offer you the products or services that you want; respond to or help with your requests; manage your account with us; confirm your identity and protect your account.

At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa) General enquiries: [email protected]
Complaints (complete POPIA/PAIA form 5): [email protected] & [email protected]

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you by prominently posting a notice of such changes or by showing a notice in the app. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at [email protected].

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To delete your account, go to Settings > Account > Delete account in the app; "What are your privacy rights?" explains what that removes. To request to review, update, or delete your personal information in any other way, please visit https://replr.app/support or email [email protected].