ChibiMoji Privacy Policy

Effective: April 1, 2025

1. INTRODUCTION

Agneswana LLC (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy Policy”) describes the types of information we may process when you install and/or use “ChibiMoji“ mobile application (the “App”).

When we refer to personal data (personal information, or personally identifiable information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

Our Privacy Policy applies to all users, and others who access the App (“Users”).

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

This Privacy Policy complies with the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

2. ABOUT REQUESTING FOR KEYBOARD FULL ACCESS

The App contains a custom keyboard software program that runs on an Apple iOS operating system. More specifically, the App’s containing custom keyboard software program (hereinafter “our Keyboard”) may be run by switching Apple’s default system Keyboard into our Keyboard.

Apple guides third-party custom keyboard providers like us to follow some restrictions on implementing custom keyboards. One of the most important things is whether to ask users for keyboard full access (“open access for a custom keyboard”).

According to Apple’s guideline on open access for a custom keyboard, without requesting open access for a custom keyboard, any other third party keyboard can:

  • NOT access to the file system apart from the keyboard’s own sandbox container;

  • NOT access to microphone and speaker;

  • NOT able to participate directly or indirectly in iCloud;

  • NOT access Location Services and Contacts;

  • NOT send keystrokes or other input events for server-side processing.

There are a few reasons why we cannot avoid requesting full keyboard access from users.

Firstly, our Keyboard offers free and pro features differently based on the user's subscription status. The only way to determine whether a user is subscribed is through the communication of verification data between our Keyboard and the subscription server.

Secondly, our App stores user-created emojis (we call them as chibimojis for multi-line emojis and kaomojis for single-line emojis) on the device’s local file system and the user’s iCloud server. To fetch user-created emojis in our Keyboard, our Keyboard should access the device’s local file system and/or the user’s iCloud server.

To address these requirements, we must request full keyboard access from users.

Note that any privacy-related data connected to personal information is NOT collected or tracked on our Keyboard.

We all know that keyboards handle sensitive data such as passwords as well as everyday messages related to privacy.

Thus, with privacy being of the utmost importance, data we may collect, store, and use is very limited to resolve errors or improve features as in section 3 below.

3. CATEGORIES OF PERSONAL DATA WE COLLECT

3-1. Contact Information

We collect information that you directly provide to us via feedback email and Apple App Store Review.

For example, we need to collect a few important details about you, such as your name, email address, and your device information (see below 3-2. Device Information).

When you contact customer support or communicate with us via feedback email, we will collect whatever information you volunteer or that we need to resolve your question.

When you post a review on the App’s page in Apple App Store, we will collect your user name and your review content.

We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.

3-2. Device Information

We may collect information about your device, including the hardware model, operating system and version, and preferred language. However, we do not collect unique device identifiers (including MAC address and IMEI).

We may also ask you to provide us with some additional information such as a screen shot image that runs the App in order to debug errors.

3-3. Subscription-related Information

Except for additional features, the App is free to use.

Additional features (“Pro access”) are available only to subscription users.

We need to collect your purchase history from Apple App Store to determine if you are a non-subscribed or subscribed user.

We use a third-party subscription management service provider, RevenueCat, Inc. (based in California, USA), to manage your subscriptions and purchases on App Store.

3-4. Usage Information

We use a third-party app analytics service provider, Mixpanel, Inc. (based in California, USA) to manage usage data on our App and our Keyboard.

The usage data we collect on our App and our Keyboard is limited to how users interact with our own assets, NOT user-created content or user-typed keystrokes.

We need to collect the usage data to improve the features of our App and our Keyboard related to our own assets.

Note that the usage data we collect through our third-party app analytics service provider is NOT related to personally identifiable information.

4. PURPOSES FOR COLLECTING PERSONAL DATA

We may collect your personal data in order to:

  • Develop, improve, and refine the functionality;

  • Communicate with you. We may respond to your comments and questions; provide customer service; and send you technical notices, and other informational messages;

  • Manage your subscription payments.

The purposes mentioned above are subject to a legal basis, including the provisions of the GDPR Art. 6(1)(a) (User consent), Art. 6(1)(b) (performance of a contract) and Art. 6(1)(f) (legitimate interests).

5. DISCLOSURE TO THIRD PARTIES

We will share your information with third parties only in the ways that are described in this Privacy Policy.

Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information like purchase history and usage data related to our assets with third-party organizations that provide automatic data processing technologies for the App.

We may engage RevenueCat, Inc. as a third-party subscription management service provider in order to process subscription payments and engage Mixpanel, Inc. as an app analytics service provider in order to manage usage data related to our own assets. The third parties manage anonymous IDs and purchase history and do not use these information for purposes beyond those stated in this policy.

In case you want to learn more about the third-party’s services and their privacy options (including opt-out) please consult the correspondent websites and privacy policies (https://www.revenuecat.com/privacy/, https://mixpanel.com/legal/privacy-policy/). We are not responsible for any usage of your personal data by the third parties in violation of our instructions.

6. SALE OF PERSONAL DATA

We do not sell any of your personal data to third parties.

7. RETENTION PERIOD

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information.

We retain your contact information such as your email for one year after your inquiry is resolved.

We retain your App Store review information as long as the review is published in App Store.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

8. YOUR RIGHTS AS A DATA SUBJECT

8.1 California residents

8.1.1 Right to Know

If you are a California resident, you have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • the categories of personal information that is processed;

  • the categories of sources from which personal information is obtained;

  • the purpose for processing of user personal data;

  • the categories of third parties with whom we may share your personal information;

  • the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

8.1.2 Right to Delete

You have the right to request that we delete the personal information that we have collected from you.

8.1.3 Right to Opt-Out of Sale of Personal Information

You have the right to opt-out of the sale of your personal information.

8.1.4 Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, such as your name.

8.1.5 Exercising Your Rights

Data Access and Portability

You can request copies of your personal information.

Change or Correct Data

You have the right to ask to correct, change, update or rectify your data.

Data Retention and Deletion

The personal data is generally retained for as described in section 7. However, specific retention times can vary based on context of the processing performed.

You have the right to ask to delete all or some of the personal data that is held about you.

Restriction of Processing

Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

Exercising the right to know about data sharing

You have the right to know whether your data is shared with third parties. Detailed information on this issue is contained in section 5 of this Privacy Policy, however, if you have further questions in this regard, you can contact us at any time.

8.2 EU citizens

The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) the following rights, with some limitations. Users may contact us, at the address provided in the “11. HOW TO CONTACT US” section below, to exercise any of those rights and we will respond with the requested action or information, or will let you know why that right does not apply to you.

8.2.1 Right Not to Provide Consent or to Withdraw Consent

We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdrawal.

8.2.2 Right of Access

You have the right to obtain confirmation as to whether or not we collect or process personal information concerning you and, if this is the case, you have the right to request a copy of such personal information in digital format.

8.2.3 Right of Rectification

You have the right to require that we correct any inaccurate personal information concerning you, and that we complete incomplete personal information.

8.2.4 Right of Erasure

In certain circumstances, you have the right to request that we erase personal information concerning you. For example, if it is no longer necessary for the purposes for which it was originally collected.

8.2.5 Right to Restrict Processing

In certain circumstances, you have the right to request that we restrict the processing of the personal information that we have collected about you. For example, where you believe that the personal information that hold about you is not accurate or lawfully held.

8.2.6 Right to Data Portability

In certain circumstances, you have the right to receive the personal information concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the information to another entity where technically feasible.

8.2.7 Right to Object to the Processing

In certain circumstances, you have the right to request that we stop processing your personal information.

8.2.8 Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects

In certain circumstances, you have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly affects you.

8.2.9 Right to Complain to a Supervisory Authority

You have the right to lodge complaint with a supervisory authority if you believe that our processing of personal information relating to you infringes the GDPR.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you can always file a complaint with the supervisory authority in your Member State or the national authority in your country.

8.3 Exercising your rights

Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

And please note that we access and store your data only mentioned in section 3 in this Privacy Policy.

You can exercise your privacy rights by submitting a request by contacting us at support@agneswana.com.

We will not discriminate against you for exercising your privacy rights.

We try to respond to a consumer request within forty (40) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please mind that we are only required to respond up to two requests per customer in a year.

9. CHILDREN’S PRIVACY

The App is not intended for children under the age of eighteen (18). Therefore, we do not knowingly collect or solicit any personal information from children under eighteen (18). If you have not reached the age of majority or legal age in your jurisdiction (i.e. if you are between the ages of thirteen (13) and seventeen (17)), your use of the App is possible only with the relevant consent and under the supervision of the holder of parental responsibility for you.

No one under the age of thirteen (13) may provide any personal information to the App. If we discover that we have collected personal information from a child under the age of eighteen (18) without verification of the holder of parental responsibility for a child, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under eighteen (18) and data processing is carried out without the relevant consent of the holder of parental responsibility for a child, please contact us.

10. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is updated regularly.

Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

11. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us at support@agneswana.com.

12. LAST REVISION DATE

This Policy Policy was last revised on, and effective as of, April 1, 2025.