This Privacy Policy describes how Pupo (“we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with the Pupo mobile application and related services (the “App”). It is designed to align with common expectations for users in the United States (including California), Canada, Singapore, and Australia, among other regions. If local law grants you additional rights, those rights apply alongside this Policy.
Effective date: March 25, 2026.
1. Who we are
The operator of the App is the Pupo development team reachable at the contact email below. Depending on your region, privacy laws may refer to us as the “business,” “organization,” or “APP entity” responsible for personal information covered by this Policy.
2. Information we collect
The App is primarily an on-device interactive canvas for creating and playing with visual scenes. Most creative activity happens locally on your device. We may still collect or process limited information as described below, depending on how you use the App and your device settings.
2.1 Information you provide
- Support and communications: If you email us (for example at pupocyl@163.com), we receive your message content, email address, and any attachments or details you choose to include.
- Voluntary submissions: Any optional surveys, beta feedback, or similar information you send us.
2.2 Information collected automatically
- Device and diagnostic data: Such as device type, operating system version, app version, language/locale, and crash or performance diagnostics, where available through platform tools (for example, Apple crash reports if you opt in at the system level).
- Usage data: Basic interaction or analytics events if we implement analytics in a given App version (we will describe material categories here if that changes).
2.3 Content stored on your device
Scenes, exports (such as videos or GIFs), and similar files you create are typically stored on your device unless you choose to upload or share them through third-party apps or services. We do not access those files on your device without your action (for example, sending us a file as part of support).
2.4 Sensitive information
We do not intend to collect sensitive categories of personal information (such as health data, precise biometrics, or government ID numbers) through the App. Please do not send us such information unless we explicitly request it for a specific lawful purpose.
3. How we use information
We use personal information where permitted by law for purposes such as:
- Providing, maintaining, and improving the App and its features (including canvas interactions, exports, and stability);
- Responding to your requests and providing customer support;
- Detecting, preventing, and addressing fraud, abuse, or security issues;
- Complying with legal obligations and enforcing our User Agreement;
- Conducting analytics in aggregated or de-identified form where appropriate.
Where required, we rely on appropriate legal bases such as performance of a contract with you, legitimate interests (balanced against your rights), your consent, or legal obligation.
4. Sharing & disclosure
We do not sell your personal information for money. We may share information in these situations:
- Service providers: Vendors that help us host, analytics, email delivery, or similar functions, bound by confidentiality and processing instructions.
- Legal and safety: When required by law, legal process, or to protect rights, safety, and security.
- Business transfers: In connection with a merger, acquisition, financing, or sale of assets, subject to appropriate safeguards.
- With your direction: When you choose to share content via system share sheets or third-party apps.
5. International transfers
We may process information in countries other than where you live, including the United States and jurisdictions where our service providers operate. Where required by law (for example, certain transfers from the EEA, UK, Switzerland, Singapore, or Australia), we implement appropriate safeguards such as standard contractual clauses or other approved mechanisms, in addition to applicable statutory exceptions.
6. Retention
We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer period is required or permitted by law (for example, for tax, legal claims, or security logs). Support emails may be retained according to our internal retention schedule. Aggregated or de-identified information may be retained without time limit.
7. Your privacy rights
Depending on where you live, you may have rights to access, correct, delete, or port your personal information; to object to or restrict certain processing; to withdraw consent where processing is consent-based; and to appeal our decisions regarding privacy requests. You may also have rights related to automated decision-making (we do not use the App to make solely automated decisions with legal or similarly significant effects).
7.1 United States — California residents (CPRA / CCPA)
California residents may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including rights to know, delete, and correct personal information; to opt out of “sale” or “sharing” for cross-context behavioral advertising (we state above that we do not sell personal information for money; if we enable advertising or sharing that qualifies under California law in the future, we will provide a clear opt-out and update this Policy); and to limit use of sensitive personal information where applicable. You may designate an authorized agent as permitted by law. We will not discriminate against you for exercising privacy rights.
7.2 Canada
Where Canadian privacy law applies (including substantially similar provincial statutes and the federal Personal Information Protection and Electronic Documents Act where applicable), you may have rights to access your personal information, challenge accuracy and completeness, and withdraw consent subject to legal or contractual restrictions. You may file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner, as applicable.
7.3 Singapore
Where Singapore’s Personal Data Protection Act 2012 applies, you may have rights to access and correct personal data we hold about you, and to withdraw consent where processing is consent-based, subject to exceptions. You may lodge a complaint with the Personal Data Protection Commission (PDPC) where permitted.
7.4 Australia
Where the Privacy Act 1988 (Cth) and Australian Privacy Principles apply, you may request access to and correction of personal information, and you may complain to us or to the Office of the Australian Information Commissioner (OAIC).
7.5 How to exercise rights
Submit requests using the contact email below. We may need to verify your identity before responding. If you are unsatisfied with our response, you may contact your local supervisory authority where available.
8. Children
The App is not directed to children under 13 (or the minimum age required in your jurisdiction to consent to data processing without parental authorization). We do not knowingly collect personal information from children in violation of applicable children’s privacy laws. If you believe we have collected information from a child inappropriately, contact us and we will take appropriate steps to delete it where required by law.
9. Security
We implement reasonable technical and organizational measures designed to protect personal information. No method of transmission or storage is completely secure; we cannot guarantee absolute security.
10. Third-party services
The App may integrate with platform services (such as Apple’s App Store, iOS permissions, and share extensions) and, when you leave the App, third-party sites or apps may collect information under their own policies. We encourage you to read those policies.
11. Changes to this Policy
We may update this Privacy Policy from time to time. We will post the updated Policy with a revised effective date and, where required by law, provide additional notice (for example, in-app or by email). Please review this page periodically.
12. Contact
For privacy questions or to exercise your rights, contact:
Email: pupocyl@163.com