Privacy Policy

I. Introduction. Regional Patterns (California)

EntertainTech Solutions LLC ("we," "us" or "our") takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you install and/or use "Cardtrove - Card Scanner" software application for mobile devices (the "App", "our App"). The App's title may vary in countries and is subject to change without specific notice.

Cardtrove lets you scan a trading card with your device camera to identify it, estimate its market value, and organize the cards you own into a collection. When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly.

Our Privacy policy applies to all users, and others who access the App ("Users"). For the purposes of the GDPR, we are the data controller, unless otherwise stated.

Please read this privacy policy carefully. By using the app you acknowledge that you have read, understood, and agree to be bound by these terms.

If you are a California resident, please read the following important notice.

Under the California Consumer Privacy Act of 2018 (CCPA), California residents may request:

• the categories of personal information that are processed;
• the categories of sources from which personal information is obtained;
• the purpose for processing personal data;
• the categories of third parties with whom we may share personal information;
• the specific pieces of personal information we may have obtained about a particular user, provided the request is reliable enough to identify the user.

What this Privacy Policy covers

Personal Information. Categories of information, its sources, and purposes of processing. Under CCPA, personal information does not include de-identified or aggregated consumer information.

Sharing. How your information can be shared. Third parties engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

Opt-out options. If you do not want us to process your personal information anymore, contact us at support@blowy.tech. In most cases, the App cannot continue operating without functional data, so you may be advised to remove the App from your device. If you do not want us to share device identifiers with service providers, please check your device settings to opt out.

Requests. To submit a verifiable consumer request for access, portability, or deletion of personal data, contact us at support@blowy.tech and include the wording "Your rights to maintain confidentiality in the state of California".

When submitting a verifiable request, you should be ready to:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include name, address, city, state, zip code, and email address;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may ask for additional information or documents to verify your identity before taking any action with your personal information. We ensure that personal information provided in a verifiable consumer request will be used only to verify identity or authority to make the request and not for any other purpose.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We are only required to respond to two requests per customer each year.

Equal Rights. We will not discriminate against you for exercising your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

Sale of Data. We do not sell any of your personal data to third parties.

II. Information We Process

There are several categories of information that can be processed.

Information processed automatically. On the basis of your permission, we use third-party automatic data processing technologies, such as advertising, attribution, or analytics tools, to analyze certain information sent by your device via our App. Some integrated tools may launch automated processing of your personal data, including profiling. Processing through these technologies starts automatically once you allow our App to track your activity. You can withdraw permission at any time by using the opt-out options described in this policy.

We may also process some information about your device and user behavior on the ground of our legitimate interest. This information is generally non-personal and may be accessed only in aggregated form to improve our App and user experience.

• Device details. Type of device, operating system and version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, and device memory usage.
• Internet connection details. Mobile carrier, network provider, network type, IP address, timestamps, session duration, speed, and browser.
• Location-related information. IP address, country code, region, state, and city associated with your SIM card or device, language setting, and time zone.
• Other device identifiers. Advertising and vendor identifiers, and user identifiers if set by the App's developer.
• Information about applications. App name, API key, version, and properties of our App may be reported for automated processing and analysis.
• Cookies and similar technologies. Pixels, web beacons, scripts, and similar technologies may be used to understand usage, optimize the App, improve marketing efforts, and provide content and features of interest.
• Log file information. Time and date when you start and stop using the App and how you interact with it.
• Ad-related information. The date and time an ad is served, whether it was clicked or shown as a conversion event, what the ad is about, its type, placement, and whether you respond to it.
• In-app events. Activity information such as taps, scrolls, screens visited, cards scanned, onboarding steps, progression events, payments, in-app purchases, and other custom events.
• Subscription details. Subscription start date, duration, payment receipts, registration data, login history, currently connected devices, and information about promo codes used for accessing the Pro version of the App.

Information provided automatically to advertising, attribution, or analytics tools does not generally come under our control. Some services may engage in profiling and may obtain information related to your personality and/or your device through technologies outside our scope of responsibility. Any information request regarding the disclosure of your personal information should be directed to those third parties.

Payment information. Our e-commerce provider (Apple / Google) is responsible for billing, processing, and charging for in-app purchases, handles your personal information, and keeps it secure. We cannot access or use your credit or debit card information.

Camera and card photos. Cardtrove's core service requires access to your device camera and/or photo library so you can capture or upload a picture of a trading card for identification and valuation. Card images you capture are processed to recognize the card and estimate its market value, and may be transmitted to our servers and to the AI and pricing providers described below for that purpose. We do not collect or store biometric data such as facial features, geometry, or physiological, biological, or behavioural characteristics, and we do not use face recognition or other technical means for unique identification or authentication of a user. Please avoid capturing images that contain other people or unrelated personal information.

Generated Content. We may process the content produced through the App, including the card identifications, condition and valuation estimates, price history, and the collections and notes you build in the App. Subject to our Terms of Use, you may use that content for your own purposes at your own risk and responsibility. Valuation figures shown in the App are estimates for informational purposes only and are not an offer, appraisal, or guarantee of price.

III. Service Providers We Rely On

To operate the App we use a limited number of trusted third-party service providers, each acting under its own privacy policy:

• Apphud — subscription management and in-app purchase infrastructure.
• Adjust — install attribution and marketing measurement.
• Google Firebase — analytics and crash diagnostics.
• Meta (Facebook) SDK — advertising measurement and attribution.
• AI and pricing providers — computer-vision and large-language-model services used to recognize a card, plus card-market data sources used to estimate its value.
• Cloud hosting providers — secure storage and processing of requests.

These providers process only the data needed to perform their function and are not permitted to use it for unrelated purposes.

IV. The Purposes of Processing Your Personal Data

Our mission is to constantly improve our App and provide new experiences. We use information for the following purposes:

• to make our service available and provide requested functionality, including card recognition, valuation, and collection tracking;
• to improve, test, and monitor the effectiveness of our App, understand user behavior and trends, and detect outages and technical issues;
• to provide interest-based advertising or other targeted content;
• to communicate with you, including newsletters, marketing notifications, feedback requests, and policy updates;
• to prevent fraud and spam, investigate security breaches, protect our trademarks, and enforce our Terms of Use.

If new purposes for processing your personal data arise, we will update this Privacy Policy accordingly.

V. Sharing of Your Information

We share information with third parties only in the ways described in this Privacy Policy. We adhere to the U.S. Digital Advertising Alliance's Self-Regulatory Principles for the Mobile Environment.

We choose third parties that can apply technical and organizational measures to protect user personal data. However, we cannot guarantee the security of information transmitted to any such third party and are not responsible for accidental loss or unauthorized access through the fault of third parties.

We will not rent or sell your personal data to third parties, but we may share information such as log files, device identifiers, cookie data, and card images with the service providers listed above that provide automatic data processing technologies for the App. We do not control or influence those third parties' tracking technologies or how they may be used.

We may disclose personal information if needed for objective reasons, public interest, or unforeseen circumstances:

• as required by law;
• when we believe in good faith that disclosure is necessary to protect our rights, your safety, the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, in which case you will be notified of changes in ownership or the use of your personal information.

VI. International Data Transfers

We work in a cross-border environment and provide our App to users around the world. We and third-party organizations that provide automatic data processing technologies or advertising partners may transfer automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer personal information to countries that do not have the same data protection laws as your jurisdiction.

We try to ensure that recipients of personal data provide proper protection in accordance with current legislation. For storage purposes, we use hosting organizations and, where possible, encrypt personal data before sending it for storage. We cooperate only with hosting organizations that have passed our security and reliability checks.

VII. How Long We Use Your Personal Data

We generally retain personal information for as long as necessary to perform the functional service of the App and comply with legal obligations. If you no longer want us to use information that we physically access and store, you can request that we erase your personal information and close your account.

Some data may still be stored for a certain time period if necessary to comply with legal obligations, maintain safety and backup settings, or prevent fraud and other malicious acts.

VIII. Exercising Your Rights

Applicable data protection laws may give you certain rights regarding your personal information. You may have the right to:

• request access to copies of your personal information;
• ask to correct, change, update, or rectify your data;
• ask to delete all or some of the personal data held about you;
• request restriction of processing in certain circumstances.

To exercise these rights, contact us at support@blowy.tech. Please bear in mind that we can ensure these rights only with respect to the information that we physically access and store.

When personal information is processed automatically, you may object to such processing in some circumstances. Where it is processed for direct marketing purposes, you may ask us to cease such processing.

IX. How to Opt Out

If you do not want third-party service providers to use personalized ads based on your interests, please follow the instructions below:

• On iOS, disable tracking in `Settings > Privacy & Security > Tracking`, and adjust `Settings > Privacy & Security > Apple Advertising`. Additional information is available at support.apple.com/en-us/HT202074.
• On Android, choose "Opt out of Ad Personalization" in `Settings > Google > Ads`.

You can also visit youradchoices.com for the same purpose.

Please mind that even if you opt out of certain interest-based advertising, you may still receive contextual ads based on other non-personal information.

X. Children's Privacy

The App is not directed to children under the age of 13 (or the minimum age required in your jurisdiction), and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, please contact us at support@blowy.tech and we will take reasonable steps to delete it.

XI. Security

The security of your personal information is highly important to us. We follow generally accepted industry standards and take reasonable and appropriate measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

We implement technical and organizational measures designed to support data-protection principles such as data minimization and to integrate necessary safeguards into processing. We seek to have personal data encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. We do our best to protect your personal data, nevertheless we cannot guarantee absolute security. If personal information is compromised as a breach of security, we will notify you in compliance with applicable law.

XII. Changes to the Privacy Policy

This Privacy Policy is updated regularly. Whenever we change it, we will post those changes to this page and, where appropriate, may provide additional forms of notice.

XIII. How to Contact Us

If you have any questions about this Privacy Policy, please contact us at support@blowy.tech.