Privacy Policy

INTRODUCTION

Welcome to WasteClear!

OubGame ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains in a clear and transparent manner how we collect, use, store, disclose, and safeguard your information when you use our mobile application "WasteClear" (the "App"), related websites, and services (collectively, the "Services").

This Privacy Policy is designed to comply with applicable data protection laws, including the EU General Data Protection Regulation ("GDPR"), the UK Data Protection Act, the California Consumer Privacy Act ("CCPA"), and the California Privacy Rights Act ("CPRA").

Please read this policy carefully. By downloading, installing, or using our App, you acknowledge that you have read, understood, and agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Services.

DATA CONTROLLER AND CONTACT INFORMATION

The data controller responsible for your personal data is:

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us at the above email address. We will respond to your request within 30 days.

WHAT INFORMATION WE COLLECT

3.1 Information You Voluntarily Provide to Us

When you actively interact with us, we may collect the following information you voluntarily provide:

• Customer Support Communications: When you contact us via email or in-app feedback forms, we collect your email address, device information, and the details of your inquiry.
• Survey and Feedback Responses: When you voluntarily participate in our user research, satisfaction surveys, or product improvement programs, we collect your answers and comments.

Please note that we do not actively request sensitive personal information (such as race, political opinions, religious beliefs, health data, etc.), and we recommend that you avoid disclosing such information in your communications.

3.2 Information We Collect Automatically

When you use the App, we automatically collect the following technical information through your device and our servers to support core cleaning functions and service optimization:

• Device Information: Device model, manufacturer, operating system version and patch level, unique device identifiers, mobile network operator, device language and region settings.
• Usage Data: App usage duration, feature usage frequency, session start and end times, daily active duration, cleaning operation records and function usage logs.
• IP Address and Location Data: Approximate geographic location (city-level) inferred from your IP address. We do not collect precise GPS location.
• Advertising Identifiers: IDFA (iOS) and/or Google Advertising ID (Android) for attribution analysis and personalized/non-personalized advertising display.
• Log Data: Crash logs, error reports, performance data to help us diagnose and fix technical issues and optimize App stability.

3.3 Sensitive Permission Data Collection

To implement the core file cleaning and background operation functions of WasteClear App, we will apply for and collect data corresponding to the following sensitive permissions. All permission calls are only used to provide core App functions and will not be abused for unauthorized purposes:

• Full File Access Permission: This permission is required to scan, identify, and clean junk files, redundant caches, and invalid files in your device storage. It is only triggered when you actively use the App’s cleaning functions, and we only access file data related to cleaning scenarios without collecting or uploading your private file content.
• Foreground Service Permission: This permission is used to maintain stable operation of cleaning tasks, ensure normal progress of background file scanning and cleaning operations, and avoid task interruption caused by system background restrictions. The foreground service will not collect any personal information actively and only runs during the execution of user-initiated cleaning tasks.

3.4 Information from Third-Party Sources

We do not support third-party account login for the App, and we will not actively obtain your personal information from any third-party platforms. All third-party data processing is limited to anonymous device data for advertising attribution and statistical analysis provided by the third-party service providers listed in the appendix.

HOW WE USE YOUR INFORMATION

We use the information we collect for the following business and commercial purposes:

• Providing, maintaining, and optimizing core App functions: Realizing device file scanning, junk cleaning, storage optimization and other core functions, ensuring the normal operation of foreground and background cleaning services, and improving user experience of cleaning functions.
• Customer support: Responding to your questions, complaints, or technical requests, and resolving App functional failures and usage issues.
• Service communications: Sending you important notifications, such as service changes, maintenance announcements, and function update reminders.
• Product analytics and improvement: Aggregating and analyzing anonymous user behavior data to optimize App cleaning efficiency, functional logic and product performance.
• Advertising and monetization services: Realizing advertising attribution, traffic statistics and standardized advertising display through third-party advertising SDKs, providing free App services for users.
• Security: Detecting, preventing, and investigating abnormal usage behaviors, technical failures, or malicious attacks to protect App and user device usage security.
• Legal compliance: Fulfilling legal obligations, responding to lawful requests, and protecting our and our users' legitimate rights.

5. LEGAL BASIS FOR PROCESSING (GDPR/UK GDPR)

For users in the European Economic Area (EEA) and the United Kingdom, we process your personal data based on the following legal grounds:

• Providing core App cleaning functions and service operation – Contractual performance: Processing is necessary for the performance of our service contract with you to provide normal cleaning and device optimization services.
• Customer support and service maintenance – Contractual performance / Legitimate interest: Fulfilling contractual service obligations; maintaining good user service relationships.
• Product optimization and data analytics – Legitimate interest: Optimizing App functions and user experience without causing disproportionate privacy impact on users.
• Advertising attribution and monetization statistics – Legitimate interest: Maintaining free service operation of the App through standardized advertising business, ensuring sustainable product operation.
• Security protection and fault troubleshooting – Legitimate interest / Legal obligation: Protecting user device usage security and App service stability, and complying with legal security obligations.
• Legal compliance – Legal obligation: Processing is necessary for compliance with applicable legal obligations.

6. HOW WE SHARE YOUR INFORMATION

We only share your personal data under lawful, necessary, and limited circumstances, and will never sell your personal private information to third parties for commercial purposes:

6.1 Authorized Third-Party Service Providers

We engage trusted third-party companies as data processors to provide advertising monetization, attribution statistics and technical maintenance services on our behalf. They are only authorized to process your anonymous device and usage data for the purposes described in this policy and are contractually bound to maintain strict data security measures. Our core third-party service providers include:

Advertising & Attribution Service Providers: AppsFlyer (attribution analysis, user behavior statistics), TopOn (aggregated advertising service, traffic optimization), AdMob (aggregated advertising display, monetization service).

Technical Service Providers: Crash reporting and performance optimization service providers to collect crash logs and technical data for App stability improvement.

Please refer to the Appendix for a detailed list of all third-party service providers, their purposes, and privacy policy links.

6.2 Legal Requirements

We may disclose your information if required by law, or if we believe such disclosure is necessary to protect our rights, the safety of our users, or to comply with judicial proceedings, government investigations or legal mandatory requirements.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or part of our business assets, your information may be transferred as part of the business transaction. We will notify you in advance of any material changes and inform you of your rights and options.

6.4 With Your Explicit Consent

We do not share your personal data with any other third parties, except as described above, without obtaining your separate, explicit consent.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed on servers located in countries outside your country of residence, including but not limited to China, the United States, and other jurisdictions where our third-party service providers operate.

When we transfer personal data from the EEA or the UK to countries not deemed to have an "adequate level of protection," we rely on the following lawful transfer mechanisms:

• Standard Contractual Clauses (SCCs) approved by the European Commission;
• The UK's International Data Transfer Agreement (IDTA);
• Other supplementary measures to ensure your data receives an equivalent level of protection.

If you wish to obtain a copy of these transfer mechanisms, please contact us at oubgame.2020@gmail.com.

DATA RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by legal, accounting, or reporting obligations. Specific retention periods vary by data type and purpose:

• App Usage & Cleaning Operation Data: Retained for 180 days after your last use for product optimization and fault troubleshooting.
• Crash & Technical Logs: Typically retained for 90 days for troubleshooting and performance improvement purposes.
• Customer Support Records: Retained for 3 years after issue resolution for future reference and service improvement.
• Advertising Attribution Data: Retained in accordance with the privacy rules of third-party advertising platforms, and only used for statistical analysis and advertising effect optimization.

When data is no longer needed, we will securely delete or anonymize it so that it can no longer be linked to an identifiable individual.

DATA SECURITY

We implement a range of technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access. These include:

• Encryption in transit: All data transmission is protected by TLS/SSL encryption protocols.
• Access controls: Access to user data is strictly limited to authorized personnel and third-party processors on a "need-to-know" basis.
• Data anonymization: Most usage and statistical data is processed anonymously to avoid identifying individual users.
• Regular security reviews: We conduct periodic security assessments to identify and address potential vulnerabilities.

However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. In the event of a data breach, we will notify affected users and relevant authorities in accordance with applicable law.

YOUR RIGHTS

Depending on your jurisdiction, you may have the following rights regarding your personal data:

10.1 For EEA and UK Residents (GDPR/UK GDPR)

You have the following rights under data protection law:

• Right of Access: Request a copy of the personal data we hold about you and information on how it is processed.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to certain legal exceptions.
• Right to Restrict Processing: Request that we suspend processing of your data in specific scenarios.
• Right to Data Portability: Request that we transmit your data in a structured, commonly used, machine-readable format to you or another controller.
• Right to Object: Object to processing based on legitimate interests on grounds relating to your personal situation.
• Right to Withdraw Consent: Withdraw your consent at any time where processing is based on user authorization.

To exercise any of these rights, please contact us at oubgame.2020@gmail.com. We will respond to your request within one month. You also have the right to lodge a complaint with your local data protection authority.

10.2 For California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights:

• Right to Know: Request information about the categories and specific pieces of personal information we have collected, used, and disclosed in the past 12 months.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information we hold about you.
• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.

We do not "sell" your personal information, nor do we "share" it for cross-context behavioral advertising, so this policy does not include a mechanism to opt out of such activities.

California residents under the age of 18 have the right to request the removal of content they have publicly posted, as provided by the California Business and Professions Code.

CHILDREN'S PRIVACY

Our App is intended for a general adult audience and is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we discover that we have collected such information without verifiable parental consent, we will promptly delete it.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at oubgame.2020@gmail.com.

THIRD-PARTY LINKS & SERVICES

Our App integrates third-party advertising and statistical services provided by AppsFlyer, TopOn and AdMob. This Privacy Policy does not apply to such third-party platforms, and we are not responsible for their independent privacy practices. We encourage you to read the respective privacy policies of these third-party service providers to understand their data processing rules.

Our App does not contain unauthorized third-party website links.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements or our business practices. We will post the revised policy on this page and update the "Last Updated" date at the top.

For material changes that significantly affect your privacy rights, we will provide prominent notice via in-app notifications. Your continued use of the App after the effective date of policy changes constitutes your acceptance of the revised terms.

CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:

Appendix: Third-Party Service Provider List

This appendix details the third-party service providers we use in providing our Services, including their service types, processed data, processing purposes and official privacy policy links:

Provider Name	Service Type	Data Processed	Processing Purpose	Privacy Policy Link
AppsFlyer	Attribution & Analytics	Anonymous device ID, advertising ID, app usage data	User attribution, traffic analysis, advertising effect statistics	https://www.appsflyer.com/legal/privacy-policy/
TopOn	Aggregated Advertising Service	Anonymous device information, advertising ID, ad interaction data	Aggregated advertising display, monetization optimization, ad traffic management	https://www.toponad.com/privacy-policy
AdMob	Aggregated Advertising Service	Anonymous device information, advertising ID, ad click/view data	Intelligent advertising display, user-oriented ad recommendation, app monetization	https://policies.google.com/privacy