PicABook — Privacy Policy

Effective date: July 1, 2026 · Version 1.0 · SPRRRINT

1. Who we are and what this policy covers

This Privacy Policy explains how Sprrrint Nextgen Global Solutions LLP ("PicABook", "we", "us"), with its registered office at 2608/B Aaradhya High Park, Mira Orchid Ozone, Ghodbander, Thane, Vasai, Maharashtra 401107, India, collects, uses, stores and protects your information when you use the PicABook mobile application and related services (together, the "Service"). PicABook lets you take daily photos (such as selfies or physique photos), organize them into albums, and generate progress videos from them.

By creating an account or using the Service you acknowledge this Privacy Policy. Where the law requires consent (for example for the image-analysis processing described in Section 4), we ask for it separately and explicitly inside the app — this policy alone is not treated as that consent.

2. Information we collect

2.1 Account information — You sign in with Sign in with Apple or Google Sign-In. We receive your name (if you share it), email address (or Apple's private relay address), and a unique account identifier from the sign-in provider. We do not receive or store your Apple or Google password.

2.2 Photos and videos (your content) — This is the core of the Service and the most important thing we collect. Photos you capture or add are uploaded over HTTPS and stored in our cloud storage (Cloudflare R2), associated with your account, so that your albums are backed up and available for video generation. Videos generated from your photos, and an optional profile picture (avatar) if you set one, are stored the same way. Each photo is stored with limited metadata: the date it was taken and its dimensions.

2.3 Notification and device information — If you enable reminders, we store your device's push-notification token and time zone so we can deliver daily logging reminders at your local time. You can disable notifications at any time in iOS Settings, which stops delivery; you can also ask us to remove the token.

2.4 Purchase information — Subscriptions are processed by Apple through the App Store and managed with RevenueCat, our subscription-management provider. We receive subscription status (for example, whether your account has an active PLUS entitlement) and anonymized transaction records. We never see or store your payment-card details.

2.5 Support and feedback — If you submit a feature request or contact support, we receive the text you send and your account identifier so we can respond.

2.6 Usage and log data — Our servers automatically record basic technical logs (IP address, request timestamps, app version, error reports) used for security, debugging and keeping the Service running. We do not use third-party advertising SDKs and we do not track you across other companies' apps or websites.

3. What we deliberately do NOT collect

• We do not collect your precise location.

• We do not scan or import your photo library; only photos you explicitly capture in, or add to, PicABook are uploaded. When you save a finished photo or video back to your library, iOS asks for add-only permission.

Face ID album lock is processed entirely on your device by Apple. When you lock an album with Face ID, authentication happens on-device through iOS. Your Face ID biometric data never leaves your device and is never transmitted to or stored by us.

• We do not sell your personal information, and we do not share it with advertisers or data brokers.

4. Video generation

When you generate a video from an album, your photos are combined into the video on your device. We do not run facial-recognition, landmark, or biometric analysis on your photos, and we do not build any biometric template or face-recognition profile.

5. No AI training on your photos

Your photos and videos are never used to train artificial-intelligence or machine-learning models, ours or anyone else's. Processing described in this policy happens only to deliver the features you request.

6. How we use information

• To provide the Service: storing your albums, syncing across sessions, generating videos, and delivering PLUS features.

• To send you the reminders you asked for.

• To manage your subscription and verify PLUS entitlements.

• To respond to support requests and feature feedback.

• To secure the Service, prevent fraud and abuse, and comply with law.

• To improve the Service using aggregated, de-identified statistics that cannot reasonably identify you.

We will ask for your consent before using your information for any purpose not described in this policy.

7. Legal bases (EEA/UK) and consent (India)

Where the GDPR or UK GDPR applies, we process your data on the following bases: performance of our contract with you (account, photo storage, video generation, subscriptions); your consent (reminders); our legitimate interests (security, debugging, service improvement with de-identified data); and legal obligation (tax and accounting records).

For users in India, we process personal data on the basis of your consent under the Digital Personal Data Protection Act, 2023 (DPDPA), and for the legitimate uses the Act permits. You may withdraw consent at any time as described in Section 10; withdrawal does not affect processing already carried out.

8. Who we share information with

We share personal data only with the service providers below, who process it on our instructions under contractual confidentiality and data-protection obligations, and in the limited legal situations described after.

Cloudflare, Inc. (R2 object storage) — stores your photos, generated videos and avatar.

Fly.io, Inc. — hosts our application servers and databases.

RevenueCat, Inc. — subscription entitlement management.

Apple Inc. — Sign in with Apple, App Store payments, and push-notification delivery (APNs).

Google LLC — Google Sign-In, if you choose it.

We may also disclose information if required by law or valid legal process, to enforce our Terms, to protect the rights, property or safety of users or the public, or as part of a merger, acquisition or asset sale (in which case this policy continues to apply to your data and we will notify you of any change of controller). We may share aggregated or de-identified information that cannot reasonably identify you.

9. Retention and deletion

Photos and videos: kept until you delete them or delete your account. When you delete a photo, we also delete derived copies (generated videos that include it) from active storage; residual copies in encrypted backups are purged on a rolling basis within 30 days.

Account data: kept while your account is active. You can delete your account inside the app (Profile → Settings → Delete account); this permanently deletes your photos, videos, albums and profile within 30 days, except records we must keep for legal, tax, security, or fraud-prevention purposes, or to enforce our Terms.

Push tokens: deleted when you sign out, disable reminders, or delete your account.

Server logs: retained for up to 90 days, then deleted or de-identified.

10. Your rights and choices

Subject to applicable law, you have the right to access, correct, download, or delete your personal data; to withdraw consent; to object to or restrict certain processing; and to complain to a supervisory authority (in the EEA/UK, your local data-protection authority; in India, the Data Protection Board of India).

In-app: delete individual photos or albums, delete your account, and manage reminders in Settings.

By email: contact us at info@sprrrint.com for access, correction or portability requests. We will verify your identity before acting and respond within the time required by applicable law.

California residents: we do not sell or share personal information as defined by the CCPA/CPRA, and we do not use or disclose sensitive personal information for purposes requiring a right to limit. You may exercise access and deletion rights as described above, without discrimination.

Grievance Officer (India): Jayprakash Dwivedi, jay@sprrrint.com, 2608/B Aaradhya High Park, Mira Orchid Ozone, Ghodbander, Thane, Vasai, Maharashtra 401107, India. We will acknowledge grievances within 72 hours and resolve them within the period prescribed by the DPDPA and its rules.

11. Security

All transfers use HTTPS/TLS. Photos are stored in access-controlled buckets and are retrievable only through short-lived signed URLs issued to your authenticated session. Access tokens are stored in the iOS Keychain on your device. We restrict internal access to personal data to what is necessary and review those controls regularly. No system is perfectly secure; if a breach affecting your personal data occurs, we will notify you and the relevant authorities as required by law.

12. Children

The Service is not directed to children. You must be at least 13 years old to use PicABook, and at least the age at which you can validly consent to data processing in your country (18 in India under the DPDPA) unless a parent or legal guardian has provided verifiable consent where the law allows. If we learn we have collected personal data from a child in violation of this section, we will delete it. Parents or guardians may contact us at info@sprrrint.com.

13. International data transfers

Our application servers are hosted by Fly.io in the United States (Ashburn, Virginia), and your photos and videos are stored with Cloudflare R2 in the Asia-Pacific region; Cloudflare may replicate data across its global network for durability and performance. Where data is transferred out of your country, we rely on appropriate safeguards such as the providers' standard contractual clauses and equivalent mechanisms required by applicable law.

14. Changes to this policy

We will post any changes here and update the effective date. For material changes we will give you prominent notice in the app (and by email where appropriate) before they take effect. We will not reduce your rights under this policy without your explicit consent.

15. Contact us

Email: info@sprrrint.com

Post: Sprrrint Nextgen Global Solutions LLP, 2608/B Aaradhya High Park, Mira Orchid Ozone, Ghodbander, Thane, Vasai, Maharashtra 401107, India