Privacy Policy for “Spark – Random Photo Ideas”

Effective Date: January 16, 2026

1. Introduction

Hangzhou Shiguangshi Technology Co., Ltd. (“the Company” or “we”) values your privacy. This Privacy Policy explains how “Spark – Random Photo Ideas” (“the App”) processes your personal information during usage.

The App adheres to the following principles:

Principle of minimal and necessary data collection
Transparency and informed consent
Local-first data processing
Compliance with international privacy regulations

Please read this Privacy Policy carefully before using the App.

2. Information We Collect

The core functionality of the App (random photo browsing, image processing, inspiration generation, etc.) can be used entirely offline. The App does NOT actively collect, upload, or store any of your personal information, including but not limited to:

Photo library content, original images, or processed images
Device identifiers (IDFA, IDFV, IMEI, IMSI, MAC address, OAID, etc.)
(except data collected automatically by third-party advertising SDKs disclosed in Section 4)
User analytics or behavioral data
Crash logs or performance metrics
Account information (no registration required)
Any information that directly or indirectly identifies a user

3. Necessary Online Activities

The App normally operates offline, but network access may occur in the following situations:

1. Loading Online Documents

The App connects to the internet to load the online Privacy Policy and Terms of Use. No personal data is uploaded.

2. Advertisement Display

The App loads the appropriate advertising platform depending on user region:

Mainland China: Tencent Youlianghui (GDT) SDK
Outside Mainland China: Google AdMob SDK

Outside of the above scenarios, the App does not perform any network data transmission.

4. Third-Party Advertising SDK Disclosures (Compliance Requirement)

The App does not actively collect user data. However, for ad display, anti-fraud, and attribution purposes, third-party advertising SDKs may automatically process certain necessary information. The Company does not access, store, or analyze any of this data.

4.1 Mainland China — Tencent Youlianghui (GDT) SDK

Provider: Shenzhen Tencent Computer Systems Co., Ltd.
SDK Name: Youlianghui (GDT) SDK

1. Purpose of Use

Advertisement display
Ad monitoring and performance optimization
Ad attribution
Anti-fraud verification

2. Types of Personal Information That May Be Collected (iOS Actual Behavior)

Information Type	Description
Device information	Model, OS version, language, screen parameters
Network information	Wi-Fi / cellular network (for loading ads)
Approximate location	Based on IP address for regional ad targeting
Device identifiers	IDFA (if the user grants permission)
App information	Bundle ID, version
Ad event data	Impressions, clicks (for anti-fraud and analytics)

3. Required Permissions

Access to ad identifier (IDFA)
Network access
IP-based approximate location

4. Official Privacy Policy

Youlianghui SDK Privacy Policy

4.2 Outside Mainland China — Google AdMob SDK

1. Possible Information Collected

Information Type	Description
Advertising ID	IDFA (iOS) or GAID (Android)
Device information	Model, OS version, language
Approximate location	Based on IP for ad regional targeting
Network status	Wi-Fi or cellular network
Ad events	Impressions, clicks for fraud prevention and billing

2. Official AdMob Privacy Documentation

AdMob Privacy and Data Information

5. What We Do NOT Do (Commitments)

We strictly commit that we DO NOT:

Upload your photos
Store your image data
Collect device unique identifiers
Track user behavior or build user profiles
Perform device fingerprinting
Send custom user data to advertising platforms
Sell any personal information

All ad-related data processing is performed solely by third-party ad platforms under their own privacy policies.

6. On-Device Image Processing & Data Security

All image processing is performed locally on the device
The App never uploads your photo library content
The App does not collect EXIF or location metadata
The App keeps no history of edited photos
Uninstalling the App removes all cached files automatically

7. Children's Privacy

The App is not intended for children under the age of 14. Minors must use the App under guardian supervision. If we become aware of accidental collection of minor data, we will delete it immediately.

8. International Privacy Compliance (GDPR / CCPA / PIPL)

1. GDPR (EU)

Users have the right to:

Access
Rectification
Erasure
Restriction of processing
Objection
Data portability

Since the App stores no identifiable data, uninstalling the App removes all local data.

2. CCPA (California)

No personal data is sold
Only non-personalized (contextual) ads are used
No user identity data is stored

3. PIPL (China)

Minimal and necessary data processing
Clear user notification
Third-party processor disclosures (Youlianghui SDK)
No sensitive personal information is processed

9. Your Rights

Revoke photo access permissions at any time
Uninstall the App to delete all local data
Access and review the latest version of this Privacy Policy at any time

10. Updates to This Privacy Policy

We may update this Policy due to service adjustments or regulatory changes. Updates will be displayed in the online document. Your continued use of the App signifies acceptance of the updated Policy.

11. Contact Us

If you have questions or complaints about this Privacy Policy, please contact us:

Email: sgskj.dev@gmail.com

Conclusion

We follow the principles:

Collect nothing unless necessary; Process everything locally; Avoid user identification whenever possible.

Thank you for using “Spark – Random Photo Ideas.”