Privacy Policy for Riky

1. Scope of Application

This Privacy Policy applies to all users of the Riky App worldwide, excluding users located in the People's Republic of China. The App is strictly intended for individuals aged 18 years or older. If you are under 18 years of age, you are prohibited from using the App (including making in-app purchases), and we will not collect or process any personal data from minors.

2. Compliance with GDPR

2.1 Data Subject Rights (EEA Users)

For users residing in the EEA, we fully comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). You have the following rights regarding your personal data (including in-app purchase data):

• The right to access: You may request a copy of the personal data we hold about you (including in-app purchase history).
• The right to rectification: You may request correction of inaccurate or incomplete personal data (e.g., billing-related information).
• The right to erasure ("right to be forgotten"): You may request deletion of your personal data where we no longer have a lawful basis to process it (subject to retention requirements for financial records).
• The right to restriction of processing: You may request that we restrict processing of your personal data in certain circumstances (e.g., while verifying the accuracy of the data).
• The right to data portability: You may request transfer of your personal data (including purchase history) to another controller in a structured, commonly used, and machine-readable format.
• The right to object: You may object to processing of your personal data for direct marketing purposes or based on our legitimate interests, subject to legitimate grounds for processing.
• The right to withdraw consent: If you have provided consent for processing, you may withdraw it at any time, without affecting the lawfulness of processing based on consent before withdrawal.

2.2 Lawful Bases for Processing (GDPR)

We process personal data (including in-app purchase data) only where we have a lawful basis under GDPR, including:

• Consent: Where you have explicitly consented to processing for a specific purpose (e.g., marketing communications about in-app purchases).
• Performance of a contract: To fulfill our obligations under a contract with you (e.g., processing in-app purchases, delivering digital goods/services).
• Legitimate interests: For our legitimate business interests that do not override your fundamental rights and freedoms (e.g., improving App functionality, preventing fraudulent in-app purchases).
• Compliance with legal obligations: To comply with applicable laws and regulations (e.g., tax and financial record-keeping requirements).

2.3 GDPR-Related Inquiries

For GDPR-related inquiries or to exercise your data subject rights (including inquiries about in-app purchase data), please contact us at support@rikylab.com. We will respond to your request within one month of receipt, and may extend this period by two additional months if the request is complex or numerous.

3. User-Generated Content (UGC) Policy

3.1 Definition of UGC

User-Generated Content (UGC) refers to any content (including but not limited to text, images, videos, audio, comments, links, and other materials) that you post, upload, share, transmit, or otherwise make available through the App (collectively, "UGC"). This includes UGC associated with in-app purchased features (e.g., premium content sharing). You retain ownership of your UGC, but by posting UGC on the App, you grant us a non-exclusive, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, modify, adapt, publish, distribute, display, and translate such UGC for the purpose of operating, promoting, and improving the App (including premium features).

3.2 Prohibited UGC Content

You are strictly prohibited from posting, uploading, sharing, or transmitting any UGC that falls into the following categories. This prohibition applies to all UGC, including content posted using in-app purchased features. We reserve the right to remove any prohibited UGC, revoke access to in-app purchased features, suspend/terminate your account, and report violations to relevant authorities:

• Adult/Obscene Content: Any content depicting or promoting pornography, sexual exploitation, nudity (except in non-sexual, artistic, or educational contexts), sexual acts, or any material that is sexually explicit or obscene. This includes UGC shared through premium/paid features of the App.
• Disturbing/Offensive Content: Content that depicts or promotes violence, self-harm, gore, torture, abuse (including child abuse, animal abuse), or any material that is likely to cause severe emotional distress, discomfort, or revulsion to reasonable users.
• Gambling-Related Content: Content that promotes, facilitates, or advertises illegal gambling, sports betting, online casinos, poker rooms, or any form of wagering (including fantasy sports with monetary stakes) where such activities are prohibited by applicable law. This includes content that links to gambling services or solicits bets, even if posted through paid features.
• Drug-Related Content: Content that promotes, sells, distributes, or facilitates the use of illegal drugs, controlled substances, drug paraphernalia, or prescription drugs without a valid prescription. This includes but is not limited to cannabis (where illegal), cocaine, heroin, methamphetamine, and synthetic drugs.
• Political Content: Content that promotes or opposes any political party, candidate, government entity, or political ideology; content that incites political unrest, civil disobedience, or violence against political figures; or content that contains false or misleading political information (disinformation). This prohibition applies regardless of whether the content is posted through free or paid features.
• Discriminatory/Hateful Content: Content that promotes or incites discrimination, hatred, or violence based on race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, disability, age, or any other protected characteristic under applicable anti-discrimination laws (including GDPR, ECHR, and local anti-hate speech laws).
• Other Prohibited Content: Content that is illegal, fraudulent, infringing of third-party rights (e.g., copyright, trademark, privacy), or violates any applicable local, national, or international law (including anti-money laundering, anti-terrorism, and consumer protection laws). This includes content that promotes or facilitates fraudulent in-app purchases or unauthorized access to paid features.

3.3 UGC Moderation

We employ automated tools and human moderators to review UGC (including UGC from premium users) for compliance with this policy. However, we do not guarantee that all prohibited UGC will be identified or removed immediately. You may report any UGC that violates this policy (including UGC from paid features) by contacting us at support@rikylab.com. We will review reported content promptly and take appropriate action (including refunding in-app purchases in cases where paid features were used to post prohibited content, at our discretion).

3.4 Liability for UGC

You are solely responsible for your UGC (including UGC posted using in-app purchased features) and any consequences of posting or sharing it. We are not liable for any UGC posted by users, but we reserve the right to remove or disable access to any UGC, revoke paid features, or refund in-app purchases at our discretion, without notice, for any reason (including violation of this policy). We may also disclose UGC to law enforcement or third parties if required by law or to protect our rights, property, or safety, or the rights, property, or safety of others.

4. Collection and Use of Personal Data (Including In-App Purchases)

4.1 Types of Data Collected

We may collect the following personal data from you, including data related to in-app purchases:

• Account information: Email address, username, password (hashed), and profile information (e.g., name, profile photo).
• Usage data: Information about how you use the App (e.g., features accessed, content viewed, time spent on the App, device information, IP address, location data (if you grant permission), and usage of in-app purchased features).
• UGC data: Any content you post or share through the App (including UGC from paid features, as outlined in Section 3).
• Payment data: We do not store your full payment card information. Payment processing for in-app purchases is handled by Apple App Store, and we only receive anonymized transaction data (e.g., purchase amount, date, product ID) to confirm purchase completion and deliver digital goods/services.
• Transaction data: In-app purchase history (e.g., products purchased, purchase date, transaction ID, refund status) for accounting, tax, and customer support purposes.
• Communication data: Messages sent through the App, customer support inquiries (including inquiries about in-app purchases), and feedback.

4.2 Purpose of Data Collection

We use your personal data (including purchase data) for the following purposes:

• To provide and maintain the App's functionality (e.g., account management, UGC sharing, processing in-app purchases, delivering premium features, issuing refunds).
• To improve and personalize the App (e.g., analyzing usage patterns of free/paid features, tailoring content to your preferences, developing new premium features).
• To ensure compliance with applicable laws and policies (e.g., moderating UGC, preventing fraudulent in-app purchases, maintaining financial records for tax purposes).
• To communicate with you (e.g., responding to inquiries about in-app purchases, sending important updates about paid features, marketing communications (with your consent)).

5. Data Storage and Transfer (Including Purchase Data)

Your personal data (including in-app purchase history) is stored on secure servers located in the European Union (EU) and the United States (US). We may transfer your personal data to third-party service providers (e.g., cloud hosting providers, analytics services, payment processors) located in countries outside the EEA. For EEA users, we ensure that such transfers comply with GDPR, including using Standard Contractual Clauses (SCCs) approved by the European Commission, or relying on adequacy decisions by the European Commission (e.g., for transfers to the US under the EU-US Data Privacy Framework).

We retain your personal data (including purchase history) only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable law (e.g., tax laws may require retention of financial records for 5-7 years). Once your data is no longer needed, we will securely delete or anonymize it (except for financial records required by law).

6. Third-Party Services (Including Payment Processors)

The App may contain links to third-party websites or services (e.g., social media platforms). We are not responsible for the privacy practices or content of these third parties. For in-app purchases, payment processing is handled by Apple App Store, which has its own privacy policy governing the collection and use of your payment data. We encourage you to review Apple's Privacy Policy (https://www.apple.com/legal/privacy/en-ww/) and the privacy policies of any other third-party services you access through the App.

7. Refunds and Data Retention for In-App Purchases

Refunds for in-app purchases are processed in accordance with Apple App Store's refund policy. If you request a refund, we may retain your transaction data for a reasonable period to process the refund and comply with tax/legal requirements. We will not use your data for marketing purposes after a refund unless you have explicitly consented.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments (including changes to in-app purchase features). We will notify you of any material changes by posting the updated Privacy Policy on the App, sending you an email notification, or displaying a prominent notice within the App. The updated Privacy Policy will take effect on the effective date stated at the top of this document. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data (including purchase data).