Privacy Agreement

1. Scope and Controller Contact

This Privacy Agreement explains how Qlea collects, uses, stores, discloses, and protects information when you use the Qlea mobile application, including gameplay, local settings, expansion cards, optional coins, and Apple in-app purchases. It is also intended to serve as Qlea's privacy notice where applicable law requires one.

For privacy questions, access or deletion requests, correction requests, withdrawal of consent, California requests, Canada PIPEDA inquiries, Singapore PDPA inquiries, Australian Privacy Act inquiries, or other regional privacy matters, contact:

Email: Qlea-yb@163.com

For Singapore PDPA purposes, this contact is also the public business contact for Qlea privacy matters and data protection officer communications.

2. Current Privacy Summary

3. Information We Process

The table below reflects the current Qlea app functionality and the categories that may be processed in or through the App.

Qlea does not intentionally collect government identifiers, payment card numbers, precise location, contacts, microphone recordings, camera recordings, biometric identifiers for identification, health data, race or ethnicity, religious beliefs, union membership, or sexual orientation data in the current version.

4. How We Use Information

Qlea uses information for the following purposes:

• Provide and personalize gameplay, including levels, mirror enemies, growth, expansion cards, settings, and local preferences.
• Process and deliver optional coins purchased through Apple in-app purchase.
• Prevent duplicate coin delivery by recording processed transaction identifiers locally.
• Save user-selected card images locally and render them inside Qlea.
• Respond to support, privacy, purchase, legal, and complaint communications.
• Maintain App safety, integrity, security, and performance.
• Comply with applicable laws, platform rules, lawful requests, and dispute obligations.

Where a legal basis is required, Qlea relies on the basis that best fits the context, such as your consent, performance of App features you request, legitimate interests in operating and securing Qlea, compliance with legal obligations, and protection of users and the App.

5. Sharing, Sale, and Advertising

Qlea does not sell personal information and does not share personal information for cross-context behavioral advertising in the current version.

Qlea may disclose information in these limited situations:

• Apple and device platforms: Apple processes in-app purchases, payment confirmation, receipts, refunds, device settings, diagnostics, and App Store systems according to Apple's own rules and privacy practices.
• Support and communications: If you email us, your email provider and our email provider process the message so we can respond.
• Legal and safety reasons: We may disclose information if required by law, valid legal process, platform investigation, security incident response, fraud prevention, consumer protection, or protection of rights, safety, and integrity.
• Business changes: If Qlea is involved in a merger, acquisition, financing, reorganization, or transfer of assets, relevant information may be transferred subject to appropriate safeguards and applicable law.
• With your direction: We may disclose information when you ask us to or consent to it.

6. Local Controls

Because the current version stores much of its data locally, many controls are available on your device:

• Use Qlea settings to change music, sound, haptics, effect intensity, and control sensitivity.
• Use local reset features, where available, to reset progress, selected expansion content, and card images.
• Delete selected card images through App controls where available.
• Delete Qlea from your device to remove App data according to iOS behavior.
• Use Apple device settings to manage in-app purchase permissions, family approval, backups, diagnostics, and App privacy controls.

Some local data may be included in platform backups if your device settings allow it. Qlea does not control Apple backup behavior.

7. Retention

We keep information only as long as reasonably necessary for the purposes described in this Privacy Agreement, unless a longer period is required or allowed by law.

Local gameplay data, settings, coins, transaction delivery records, and selected card images generally remain on your device until changed, removed, reset, deleted, or overwritten. Contact emails are kept as long as reasonably needed to respond, document the request, comply with law, handle disputes, or protect rights.

8. Security

Qlea uses reasonable administrative, technical, and organizational measures appropriate to the nature of the information processed. Current gameplay data is primarily stored locally through Apple platform storage and the App's local files.

No method of storage or transmission is perfectly secure. You should protect your device, Apple account, purchase credentials, backups, and email account. Do not send sensitive information to Qlea unless it is necessary for your request.

9. International Transfers

The current version does not include a Qlea-operated cloud backend for gameplay data. However, Apple, email providers, support tools, device platforms, and future service providers may process information in countries other than where you live.

Where cross-border transfer requirements apply, Qlea will use reasonable safeguards appropriate to the region, such as contractual protections, comparable protection commitments, limited-purpose processing, access controls, and other measures required by applicable law.

10. Children and Parents

Qlea is not directed to children under 13 and does not knowingly collect personal information from children under 13 without appropriate parent or guardian consent. If you believe a child provided personal information to Qlea without appropriate consent, contact us at Qlea-yb@163.com.

Where local law sets a higher digital consent age, users under that age should use Qlea only with parent or guardian involvement. Parents and guardians should use device restrictions, Apple family controls, purchase approval, and privacy settings as appropriate.

11. Your Privacy Choices and Rights

Depending on where you live, you may have rights to:

• Access or know what personal information is held about you.
• Correct inaccurate personal information.
• Delete personal information, subject to legal exceptions.
• Receive information about sources, purposes, categories, disclosures, and retention.
• Withdraw consent where processing is based on consent, subject to reasonable notice and legal limits.
• Object to, restrict, or opt out of certain processing where applicable.
• Opt out of sale, sharing, or targeted advertising where applicable. Qlea does not currently sell or share personal information for cross-context behavioral advertising.
• Limit use and disclosure of sensitive personal information where applicable. Qlea does not intentionally collect sensitive personal information in the current version.
• Not be discriminated against for exercising privacy rights.
• Complain to Qlea and, where applicable, to a privacy authority.

To exercise rights, email Qlea-yb@163.com with the subject "Privacy Request." Include your region, request type, and enough information for verification. Do not include unnecessary sensitive information.

Because the current version is local-first, Qlea may not be able to access or delete data that exists only on your device. In those cases, we may explain how to use App or device controls to reset or delete local data.

12. California Notice

This section is for California residents and is designed to address the California Consumer Privacy Act as amended, where it applies.

California residents may request to know/access, delete, correct, opt out of sale or sharing, limit sensitive personal information, and avoid discrimination for exercising privacy rights. Qlea does not currently sell or share personal information for cross-context behavioral advertising and does not intentionally collect sensitive personal information.

You may use an authorized agent where California law allows it. We may ask for proof of authorization and may need to verify your identity directly. If a right does not apply because Qlea is not subject to a particular threshold or because the data is only local on your device, we will explain that in our response.

Global Privacy Control signals: because Qlea does not currently sell or share personal information for cross-context behavioral advertising, there is no sale or sharing to opt out of. If future features create such activity, Qlea should update this Privacy Agreement and honor applicable opt-out preference signals where required.

13. Canada, Singapore, Australia, and Other Regions

Canada. Where Canada's PIPEDA or substantially similar provincial laws apply, Qlea will use personal information for appropriate purposes, identify purposes, seek consent where required, limit collection, use, disclosure, and retention, use safeguards appropriate to sensitivity, maintain openness, provide access and correction rights, and receive compliance challenges through the contact email above.

Singapore. Where Singapore's PDPA applies, Qlea will provide notice of purposes, seek consent where required, allow withdrawal of consent with reasonable notice, limit purposes to appropriate purposes, use reasonable security arrangements, keep data only as needed for legal or business purposes, provide access and correction where required, manage cross-border transfers with comparable protection where required, and assess notifiable data breaches according to PDPA requirements.

Australia. Where the Australian Privacy Act and Australian Privacy Principles apply, Qlea will maintain transparent privacy practices, limit collection to information reasonably necessary for Qlea functions, use and disclose information for stated purposes or as otherwise permitted, take reasonable steps to secure information, allow access and correction where required, and provide a complaint process through the contact email above.

Other regions. Users in other jurisdictions may have similar or additional rights. Qlea will respond to valid privacy requests according to applicable law.

14. Tracking, Ads, and Do Not Track

The current reviewed codebase does not include third-party advertising, third-party analytics SDKs, or cross-app tracking SDKs. Qlea does not currently respond differently to browser Do Not Track signals because Qlea is a mobile app and does not currently perform browser-based tracking. Device-level privacy controls and Apple privacy settings may still affect platform data collection.

15. Changes to This Privacy Agreement

We may update this Privacy Agreement to reflect App changes, legal requirements, platform requirements, new features, or improved explanations. Material changes should be presented through reasonable notice, such as an updated effective date, in-app notice, or renewed consent where required.

The effective date at the top shows when this version became effective.

16. Contact and Complaints

For privacy questions, requests, complaints, or regional rights inquiries, contact:

Email: Qlea-yb@163.com

Please write clearly and include your region and request type. We will respond within the timeframe required by applicable law. If you are not satisfied with our response, you may have the right to contact a privacy regulator, such as the California Privacy Protection Agency or California Attorney General, the Office of the Privacy Commissioner of Canada, Singapore's Personal Data Protection Commission, or the Office of the Australian Information Commissioner, depending on your location.