Purge Cleaner Privacy Policy

Effective Date: March 17, 2025

Thank you for choosing "Purge Cleaner" (hereinafter referred to as "this App") to manage the junk cleaning and related data affairs of your device. We fully value your personal data privacy and security. This Privacy Policy will detail the specific processes by which this App collects, uses, shares, stores, and protects your personal information, as well as the data rights you enjoy in accordance with the law. Your access to or use of this App indicates that you have read, understood, and accepted all the terms and operating procedures of this policy.

We are committed to complying with all applicable privacy laws and regulations, including but not limited to the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), and other regional data protection regulations, to ensure that your personal information is processed legally, compliantly, and securely.

1. Information of the Data Controller

If you have any questions about the processing of personal information, you can contact us through the following methods:

• Email:[email protected]

2. Information We Collect

To achieve the core function of garbage cleaning, ensure service stability, and optimize user experience, we only collect information "necessary for achieving the purpose" and do not collect irrelevant personal information. Specifically, this includes:

(1) Device-related information

1. Required Device Identification: To adapt to different devices and ensure the precise operation of the cleaning function, we will collect your **Device ID** (such as Android ID, used only for device uniqueness identification and not associated with personal identity information);
2. Basic device parameters: including technical information such as device model, operating system version, screen resolution, available storage capacity, Random Access Memory size, etc., which are used to ensure the compatibility and stability of this App under different hardware configurations and avoid functional failures caused by device mismatch.

(2) App Usage Information

1. Function Usage Data: Records your operating behaviors when using this App, such as the usage frequency of functions like "Junk Scan", "Large File Cleanup", "App Management", etc., as well as the size and type of files cleaned in a single operation;
2. Diagnostic and Fault Data: When issues such as app crashes or lag occur, anonymously collected fault logs (excluding personal identity information) are automatically gathered to identify and fix software bugs, thereby enhancing service reliability.

(3) Other Optional Information

We may collect feedback information provided by you only with your active consent, for example:

• The problem descriptions and improvement suggestions you submitted through the "Feedback" feature within the App;
• Information from the user experience survey you voluntarily participated in (such as ratings of satisfaction with features, demand suggestions, etc.).

(4) Specify the information not to be collected

We **will never collect children's information** (i.e., any personal information of juveniles under 13 years old). If it is found that juvenile information has been inadvertently collected, the service will be immediately terminated, and all relevant data will be deleted within 7 working days, and will not be used for any other purpose.

III. How We Use Your Information

We strictly adhere to the principle of "purpose limitation", and the information collected is only used for the following legitimate purposes and will not be used beyond the scope:

(1) Provide core services

1. Implement garbage cleaning function: Based on device information, determine the device storage structure; based on usage information, identify "garbage files" (such as expired files, useless installation packages), complete scanning and cleaning operations, and help you clean up garbage files in the device.
2. Personalized Service Optimization: Based on your usage habits (such as commonly used cleaning functions and cleaning frequency), we will push suitable optimization suggestions (such as reminders for "regularly clean up junk") to enhance operational convenience.

(2) Improve and optimize services

1. Feature Iteration: By analyzing usage data, identify high-frequency user needs (such as the high usage rate of the "Large File Cleanup" feature), and prioritize optimizing or adding relevant features;
2. Performance Improvement: Based on device parameters and fault logs, fix compatibility issues (such as incomplete cleaning problems with specific model devices), and optimize the running speed and stability of the App.

(III) Customer Support

When you provide feedback on issues via email, we will combine the device information and usage scenarios (such as "still prompted for insufficient storage space after cleaning") you provide to quickly identify the root cause of the issue and provide precise solutions.

(IV) Legal Compliance and Rights Protection

Use your information to:

• Respond to legitimate legal processes such as court subpoenas and administrative agency directives;
• Protect the legitimate rights and interests of this App and its users (such as dealing with malicious attacks and fraud, and preventing user data or property from being damaged).

4. Rules for Data Sharing and Transfer

We strictly adhere to the principles of "minimum necessity" and "obligation of confidentiality", **and will never sell or rent your personal information to third parties for marketing purposes**. Your information may only be shared or transferred in the following circumstances:

(1) Sharing with third-party service providers

Only for the purposes described in this Policy, we will share information with third-party partners who provide us with technical support, and will sign a <Non Disclosure Agreement> with them, requiring them to comply with the following obligations:

• Process data only in accordance with our instructions and not for its own purposes;
• Take security measures no less than those of this App to protect data;
• Data shall not be retransferred to other third parties (except with your consent or as required by law).

Common sharing scenarios include:

1. Server hosting service providers: Share anonymized copies of device information and usage data to ensure the stable operation of App servers (such as traffic load balance);
2. Data Analysis Service Provider: Share usage data without personal identity (such as function usage rate statistics) to generate user experience analysis reports and assist us in optimizing functions.

(2) Sharing Required by Law

We may disclose your information to the relevant authorities when the following legal circumstances exist:

• Comply with applicable laws, regulations, or administrative orders;
• Respond to legitimate investigations or official requests from government agencies (such as public security organs and market regulatory departments);
• Protect the legitimate rights and interests of this App, users, or the public (such as dealing with suspected fraud and behaviors endangering network security).

(3) Data transfer in business transfers

If we undergo changes such as business combinations, acquisitions, asset sales, etc., your personal information may be transferred to a new entity as part of the transaction assets, but we will require the new entity to continue to comply with all terms of this Privacy Policy; if there are significant changes to the policy terms, we will notify you through methods such as App pop-ups to obtain your consent.

5. Your Legal Rights

In accordance with applicable privacy laws and regulations (including but not limited to CCPA, VCDPA, GDPR), you are legally entitled to the following data rights, and we will facilitate the exercise of your rights:

(1) Basic rights (applicable to all users)

1. Right to be informed: You have the right to know whether we collect, use, or share your personal information, as well as the categories of information collected, the purposes of use, and the recipients of sharing (detailed explanations can be obtained by referring to this Policy or contacting customer service);
2. Right of access: You have the right to request us to provide you with a copy of your personal information stored in the system (such as feedback records you submitted, device information);
3. Right to Correction: If you find that your personal information (such as contact information filled in during feedback) is inaccurate, you may request us to correct it;
4. Right to deletion: Under the following circumstances, you have the right to request us to delete your personal information:

⚪︎ The purpose of information collection has been fulfilled (e.g., if you no longer use this App);

⚪︎ You withdraw your previous consent;

⚪︎ Our processing actions violate laws and regulations;

We will process the request and provide feedback on the results within 15 working days after receiving the request (except for those that need to be retained as required by law);

1. Right to Object to Permissions: You can revoke the authorization for permissions such as "Storage" and "Device Information Access" through device system settings (e.g., "App Management - Purge Cleaner - Permissions"). After revocation, it may affect the use of some functions (e.g., being unable to scan stored files);
2. Right to lodge a complaint : If you believe that our information processing practices have infringed upon your legitimate rights and interests, you have the right to lodge a complaint with the local data protection regulatory authority (such as the Federal Trade Commission (FTC) in the United States, the European Union data protection authority).

(2) Additional Rights for California Users (under CCPA)

In addition to the above basic rights, California residents (as defined by CCPA) also enjoy the following rights:

1. Right to Request Disclosure: You have the right to request that we provide you once a year, free of charge, with "the categories, sources, purposes of use of your personal information collected within the past 12 months, as well as the categories of information shared with third parties and the names of third parties".
2. Right to Opt Out: If we were to engage in "personal information sales" in the future (which we do not currently do), you have the right to opt out; even if information sharing is involved, you may also request to stop sharing by contacting customer service;
3. Supplementary Provisions on the Right to Delete : When you request the deletion of personal information, we will, after verifying your identity, delete all information that can be linked to you, unless the law requires us to retain it (such as for the purpose of responding to legal proceedings).

(3) Additional Rights of Virginia Users (under VCDPA)

Residents of Virginia (as defined by VCDPA), in addition to their basic rights, also enjoy:

1. Right to Data Portability: You have the right to request that we provide you with a copy of your personal information in a "machine-readable" format (such as a CSV file), facilitating your transfer to other data controllers;
2. Right to Object to Processing : If we process your information based on "legitimate interests", you have the right to object to such processing, and we will review and provide feedback within 15 working days (if the objection is reasonable, we will cease processing).

(4) Additional rights for EU users (under GDPR)

Residents within the EU (the "data subjects" as defined by the GDPR) enjoy the following exclusive rights in accordance with the General Data Protection Regulation (GDPR) in addition to the above basic rights:

1. Right to obtain details of data processing: You have the right to request us to clearly inform you whether we are processing your personal information; if such processing exists, we must provide detailed explanations of the purpose of processing, the legal basis on which it is based (such as "obtaining your consent", "fulfilling contractual obligations", "based on legitimate interests", etc.), the specific categories of personal information, the recipients of the information (especially recipients outside the EU), and the retention period of the information (when there is no fixed period, the criteria for determining the period must be stated);
2. Right to Restrict Processing: In the following circumstances, you have the right to request us to suspend the processing of personal information (only retaining the right to store it):

• You have raised an objection to the accuracy of your personal information, and we are currently verifying it;
• The processing activity is illegal, but you do not wish to delete the information and only request that processing be restricted;
• We no longer need to process the information, but you need to retain it for legal proceedings;
• You have exercised your right to object to processing, and while we are reviewing the reasonableness of your objection;

During the processing period, in addition to storage, if other operations need to be performed on the information, explicit consent from you must be obtained in advance, or such operations must be carried out to fulfill legal obligations, protect the legitimate rights and interests of others, or safeguard public interests;

1. Right to Object to Automated Decision-Making and Profiling: If we make decisions regarding your personal information through an automated system (without human intervention) (such as determining your service usage rights based on Data Analysis), and such decisions may have legal or significant impacts on you, you have the right to object to such decisions, and at the same time, you have the right to request us to re-review the decision results through human intervention, explain the decision basis, and obtain an opportunity for recheck; if profiling (assessing your personal characteristics through information analysis) based on "legitimate interests" or "contract performance" is involved, you also have the right to object;
2. Right to Revoke Consent Immediately: If you have previously authorized us to process your personal information based on "consent", you have the right to revoke such consent at any time, and the revocation shall be retroactive to the time of authorization (after revocation, we shall no longer process information based on the original consent, and the information that has already been processed shall be properly disposed of in accordance with regulatory requirements, except as otherwise provided by law); the method of revoking consent shall be as convenient as the method of granting consent, and you may directly submit a revocation application via email or in-app settings (if available);
3. Right to object to cross-border data transfer: If we need to transfer your personal information to a recipient outside the EU (such as an affiliated company in a non-EU region) and the region has not been recognized by the European Commission as having an "adequate level of data protection", you have the right to object to such transfer; we are required to explain to you the supplementary measures taken to ensure data security (such as signing EU standard contractual clauses, adopting binding corporate rules, etc.). If you still have objections to the supplementary measures, you may further lodge a complaint with a data protection authority within the EU;
4. Right to free exercise of rights and language guarantee: When you exercise the above GDPR-related rights, we will provide free services in principle (only when the request is clearly unfounded, repeatedly submitted, or exceeds a reasonable scope, we may charge a reasonable fee or refuse to process it, and provide a written explanation of the reasons and the fee calculation standard); meanwhile, you may choose to submit your request in English or the official language of your EU member state, and we will respond with the processing results in the same language within 15 working days (when the situation is complex and requires an extension, the extension shall not exceed 30 working days at most, and you shall be informed in advance of the reasons for the extension).

(5) Manner of exercising rights

(5) Manner of exercising rights

You may exercise the above rights in the following ways:

1. Send an email to the Data Protection Officer's mailbox ([email protected]), indicating "Rights Exercise Request" + specific requirements (e.g., "Access to personal information", "Delete data");

6. Data retention rules

We retain your personal information in accordance with the principle of "necessary shortest retention period", and the specific retention periods are as follows:

1. Device information and usage information: Retained only until the "period required to achieve the purpose", i.e.,

• If you continue to use this App, it will be retained for 12 months after your last use (automatically anonymized after the expiration of the term and cannot be associated with an individual);
• If you stop using this App (no operation for 18 consecutive months), all relevant data (except for data that must be retained as required by law) will be deleted within 30 working days;

1. Feedback and questionnaire information: Retained until "6 months after the problem is resolved/requirement response is completed", and then automatically deleted;
2. Information retained as required by law: If data needs to be retained to comply with legal proceedings or regulatory requirements, it will be retained until the expiration of the legal time limit and then deleted.

VII. Legal Basis for Data Processing

In accordance with applicable privacy laws and regulations, the legal bases for our processing of your personal information include the following scenarios:

1. Your Consent: For "optional information" (such as feedback information) and "non-essential permission authorization" (such as push optimization suggestions), your explicit consent is the legal basis for processing; you may withdraw your consent at any time without affecting the legal processing that occurred prior to the withdrawal;
2. Performance of contractual obligations: To provide you with garbage disposal services (i.e., the service contract between you and us), processing device information and usage information is a necessary step, which meets the legal requirements of "performance of contract".
3. Legitimate Interests: Without compromising your privacy rights, processing information to ensure service security is in line with the principle of "legitimate interests".
4. Legal Obligations: Processing information to comply with laws and regulations (such as responding to tax and regulatory requirements) is a necessary act of "fulfilling legal obligations".

8. Information Security Protection Measures

We implement a triple security measure of "technology + management + physical" to ensure that your personal information is not accessed, used, or disclosed without authorization:

1. Technical Security:

• Data transmission encryption: Uses protocol encryption to transmit personal information, preventing it from being stolen during the transmission process;
• Storage Encryption: Sensitive information (such as device ID) is stored using encryption algorithms, and only authorized personnel can access it;
• Vulnerability Protection: Regularly conduct security vulnerability scans (at least once per quarter) and promptly address potential risks;

2. Manage Security:

• Access Control: Only employees "for the purpose of achieving work objectives" are granted data access rights (e.g., customer service staff can only view user feedback and cannot view device IDs);
• Employee Training: Regularly conduct data security training, requiring employees to comply with confidentiality obligations and strictly prohibiting the disclosure of user information;

IX. Third-Party Service Instructions

This App may integrate a small number of third-party service modules to implement specific auxiliary functions. Third parties will process data in accordance with their independent privacy policies. We carefully select these third-party services and make commercially reasonable efforts to require them to comply with data protection obligations. However, we have no direct control over the operations and actions of third parties and do not assume responsibility for the consequences of their actions. We recommend that you review in advance:

1. Data Analysis Service: For example, integrating Google Analytics (only collects anonymized usage data for statistical function usage rates), and its privacy policy can be viewed viahttps://policies.google.com/privacy.
2. Advertising Services: If AdMob is integrated, its Privacy Policy can be viewed at [ https://policies.google.com/privacy ].

10. Updates to the Privacy Policy

We may update this Privacy Policy under the following circumstances:

1. Changes in laws, regulations, or regulatory requirements;
2. Significant adjustments have been made to the functions and data processing methods of this App;
3. User requirements or privacy protection standards have been enhanced.

After this policy is updated, your continued use of this App indicates your acceptance of the updated terms.

XI. Contact Information

If you have any questions, comments, or complaints about this Privacy Policy, you may contact us through the following methods:

Email: [email protected]

We will respond within 15 working days after receiving your inquiry, and complex issues (such as data deletion, complaint handling) will be processed and the results will be fed back within 15 working days.