1. Data controller
The operator of Bale (“we,” “us,” or “our”) is responsible for this Privacy Policy. Contact: balecyl@163.com.
2. Scope
This policy applies to personal information processed in connection with Bale on iPhone. It is intended to align with common expectations under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), Canada’s Personal Information Protection and Electronic Documents Act and substantially similar provincial laws (“PIPEDA” and provincial privacy laws), Singapore’s Personal Data Protection Act 2012 (“PDPA”), and the Australian Privacy Act 1988 and Australian Privacy Principles (“APPs”), where they apply to you.
3. Categories of information we may process
Depending on how you use Bale, we may process the following categories of information:
- Identifiers and contact: email address or other identifiers only if you choose to send them to us (for example in feedback you email to us).
- Device and technical data: device model, OS version, app version, language/locale, crash or diagnostic data if you share it with us or if Apple provides aggregated technical reports to developers in accordance with Apple’s programs.
- Usage and preferences: in-app settings you choose (for example visual or audio preferences) stored on your device.
- Photos, camera, and microphone: if you grant permission, Apple may allow the app to access the camera, microphone, or photo library for features such as capturing stills or selecting a backdrop image. Such content is primarily stored and used on your device as described in the app.
- Purchase-related data: transaction identifiers and product information processed by Apple for in-app purchases; we do not receive your full payment card number from Apple.
- Advertising / tracking choices: if you interact with App Tracking Transparency, Apple communicates an authorization status; we use it as permitted by Apple and applicable law.
We do not use Bale to knowingly collect sensitive categories of information (such as health data) beyond what you voluntarily provide through ordinary app use and device permissions.
4. Purposes of processing
We use information to:
- Provide, maintain, and improve Bale and its features;
- Process optional virtual currency and in-app purchases through Apple;
- Respond to support requests sent to our contact email;
- Protect security and integrity, detect abuse, and comply with legal obligations;
- Comply with regulatory requests where required by law.
5. Legal bases (global framing)
Where a jurisdiction requires a “legal basis,” we rely on performance of our relationship with you, your consent where required (for example for certain permissions or marketing, if ever offered), compliance with law, and, where applicable, legitimate interests such as securing the app and understanding aggregate stability—balanced against your rights.
6. On-device storage
Much of what you create in Bale (for example portfolio images or settings) may remain on your device. Uninstalling the app may delete locally stored data according to iOS behavior unless you have separately backed it up.
7. Sharing and recipients
We may share information with:
- Apple, as necessary for App Store distribution, in-app purchases, and platform services;
- Service providers who assist us under strict instructions (for example email or infrastructure), where we use any;
- Authorities when required by law or to protect rights and safety.
We do not sell personal information as “sale” is defined under the CCPA/CPRA, and we do not sell personal information for monetary or other valuable consideration. We do not share personal information for cross-context behavioral advertising as “sharing” is defined under CPRA.
8. International transfers
If you are outside the country where we operate systems, your information may be processed in the United States or other countries where we or our processors work. Where required (for example Singapore PDPA or comparable rules), we take appropriate steps—including contractual or organizational measures—to protect personal data subject to cross-border transfer, consistent with applicable law.
9. Retention
We retain information only as long as needed for the purposes above, including legal, accounting, and reporting requirements. Email correspondence may be retained for a reasonable period. On-device data retention is largely controlled by your device and your actions.
10. Security
We implement reasonable administrative, technical, and organizational measures designed to protect personal information. No method of transmission or storage is completely secure.
11. Children
Bale is not directed to children under 13 (or the higher age required by your jurisdiction for valid consent to data processing). We do not knowingly collect personal information from children below that age. If you believe a child has provided personal information to us, contact balecyl@163.com and we will take appropriate steps.
12. Your privacy rights
California residents (CCPA/CPRA)
You may have the right to know, access, correct, delete, and port certain personal information, and to limit use of sensitive personal information where applicable. You may not be discriminated against for exercising CPRA rights. To submit a request, email balecyl@163.com with “California Privacy Request” in the subject line. We will verify your request as required by law. You may designate an authorized agent where permitted; we may require proof of authorization.
Canada
Subject to PIPEDA or applicable provincial law, you may have rights to access, correct, or challenge our handling of your personal information. Contact us at balecyl@163.com. You may also complain to the Office of the Privacy Commissioner of Canada or your provincial commissioner, as applicable.
Singapore
Under the PDPA, you may have rights to access and correct your personal data in our possession or control, subject to exceptions. Contact balecyl@163.com. If you have unresolved concerns, you may contact the Personal Data Protection Commission (PDPC) Singapore.
Australia
Under the APPs, you may access and seek correction of personal information we hold about you. Contact balecyl@163.com. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC).
Other regions
If local law grants you additional rights, we will honor those requests where required. Email balecyl@163.com describing your jurisdiction and request.
13. Automated decision-making
We do not use automated decision-making that produces legal or similarly significant effects solely based on profiling in Bale.
14. Changes to this policy
We may update this Privacy Policy from time to time. The effective date at the top will change, and we may provide additional notice in the app where appropriate. Continued use after the effective date constitutes acceptance of the updated policy where permitted by law.
15. Contact
Privacy questions and requests: balecyl@163.com