FIRETOWN STUDIOS

Seerenity Privacy Policy

Effective date September 11, 2026 Version 1.0

1 Introduction and Scope

1.1 This Privacy Policy (the "Policy") describes how Firetown Studios Inc ("Company", "we", "us" or "our") collects, uses, discloses, retains and otherwise processes Personal Data in connection with the Seerenity mobile application for iOS and the associated backend services, content and features (collectively, the "Service").

1.2 This Policy applies to all individuals who download, access or use the Service ("Users", "you" or "your"), whether or not they register an account.

1.3 This Policy does not apply to the practices of third parties that we do not own or control, including Apple Inc., Google LLC, and the operators of any platform through which you elect to share content generated by the Service. Such third parties' processing is governed by their respective privacy policies.

1.4 Where Applicable Data Protection Law requires consent for a specific processing activity, we obtain that consent as described in Section 5. Use of the Service is also governed by Apple's Licensed Application End User License Agreement or such other terms of use as we may adopt.

2 Definitions

2.1 "Account" means a registered User account created through Sign in with Apple, Google Sign-In, or an email address and password.

2.2 "Guest Account" means an anonymous, unregistered account created automatically by the Service to enable a User to obtain a reading prior to registration.

2.3 "User Content" means all information a User submits to the Service, including the name provided at onboarding, questions, focus notes, messages sent to the Service's conversational AI feature (the "AI Reader"), and journal entries.

2.4 "Generated Content" means content produced by the Service's AI systems in response to User Content, including readings, AI Reader responses, weekly and monthly reflections, suggested questions and ritual recommendations.

2.5 "Memory Profile" means the structured set of inferences about a User derived by the Service's AI systems from User Content, as described in Section 4.4.

2.6 "Personal Data" means any information relating to an identified or identifiable natural person, and includes "personal information" as defined under applicable United States state privacy laws.

2.7 "Processor" means a third party that processes Personal Data on our behalf and under our instructions.

2.8 "AI Provider" means a third-party provider of large language model inference services engaged by the Company as a Processor to generate Generated Content and the Memory Profile.

2.9 "Applicable Data Protection Law" means all laws and regulations applicable to the processing of Personal Data under this Policy, including, where applicable, Regulation (EU) 2016/679 ("GDPR"), the GDPR as retained in the law of the United Kingdom ("UK GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA"), and other United States state privacy laws.

3 Data Controller

3.1 The data controller responsible for the processing of Personal Data under this Policy is Firetown Studios Inc, 1101 S Brynwood Dr, Browns Mills NJ 08015.

3.2 Inquiries relating to this Policy or to the exercise of rights under Section 11 may be directed to privacy@firetownstudios.com.

4 Categories of Personal Data

4.1 Account Data. Upon registration we collect the following, depending on the authentication method selected:

(a) Sign in with Apple: an identity token issued by Apple and, on first authentication, the name and email address (or Apple-generated relay address) the User elects to share;

(b) Google Sign-In: an identity token issued by Google together with the email address, name and profile image URL associated with the Google account;

(c) Email registration: the email address and a cryptographically hashed representation of the password. Emails are sent for address verification and password reset;

(d) the display name associated with the Account, which the User may modify.

4.2 Guest Account Data. Where a User obtains a reading prior to registration, the Service creates a Guest Account comprising a randomly generated identifier, a creation timestamp and a count of readings requested. A reading obtained during guest use is held on the User's device and is stored by us only if the User registers an Account, in which case it is associated with that Account.

4.3 User Content and Generated Content. We collect and store:

(a) the name by which the User wishes to be addressed;

(b) questions and focus notes submitted for readings and rituals, including any pre-set question selected;

(c) readings, comprising the cards drawn, the spread, the Generated Content interpreting them, and the device-local date on which the reading was drawn;

(d) messages exchanged between the User and the AI Reader within a reading;

(e) journal entries, comprising the reflection prompt and the User's written text;

(f) User preferences, including the selected AI Reader persona and reading style;

(g) weekly and monthly reflections, suggested questions and ritual recommendations generated for the User.

4.4 Memory Profile. The Service derives and stores a Memory Profile from User Content for the purpose of personalizing subsequent Generated Content. The Memory Profile may comprise: (a) stable facts concerning the User's circumstances, including place of residence, occupation, household and relationship status; (b) observed patterns in the User's manner of expression; (c) recurring themes across readings; (d) references to third parties mentioned by the User, together with an inferred sentiment and frequency of mention; (e) dated events referenced by the User; and (f) summaries derived from journal entries. The Memory Profile may be viewed by the User, and its elements edited or deleted, through the Memory screen of the Service.

4.5 Special Categories of Personal Data. The Service does not request special categories of Personal Data. However, the nature of the Service is such that User Content may, at the User's election, reveal information concerning health, sex life or sexual orientation, religious or philosophical beliefs, immigration status, or other sensitive matters, and may include Personal Data relating to third parties. Such information is processed solely as part of the User Content and Memory Profile for the purposes set out in Section 5 and on the legal basis described therein. Personal Data relating to third parties is processed only because, and to the extent that, the User has chosen to include it in User Content.

4.6 Transaction Data. All purchases are transacted through the Apple App Store. We do not receive payment card or bank account information. Through our subscription management Processor we receive and store the product identifier, the App Store transaction identifier, purchase and expiry timestamps, the price charged, the currency, the App Store storefront country, and the resulting entitlements (reading credits and owned rituals).

4.7 Gift Data. Where a User purchases or sends a gift, we store the redemption code, the identifier of the sending Account, the redemption timestamp, the identifier of the redeeming Account, and, for ritual gifts, any personal message composed by the sender for display to the recipient.

4.8 Device and Technical Data. We collect:

(a) where notification permission is granted, a push notification token, the platform identifier, and the timestamp of the User's most recent use of the Service;

(b) authentication event records, including IP address, user-agent string and timestamps, maintained by our authentication Processor for security purposes;

(d) server-side diagnostic logs of AI requests, comprising principally token counts, latency, cost, error codes, the Account identifier and, for quality monitoring, brief fragments of Generated Content.

4.9 Attribution Identifiers. As described in Section 8, our attribution Processor collects the device's identifier for vendors (IDFV), an attribution-provider-generated device identifier, the Account identifier, and, solely where the User has granted permission under Apple's App Tracking Transparency framework, the identifier for advertisers (IDFA).

4.10 Data Held on the Device. The following data is held on the User's device and is not stored by us server-side: the authentication session (held in the iOS Keychain and presented to our servers to authenticate requests); AI Reader persona preference; cached suggested questions; a record of the hours at which the Service is typically opened, used to schedule the daily card notification; an indicator that the complimentary reading has been used; and any gift code entered prior to registration.

4.11 Data Not Collected. The Service does not request access to, and does not collect, the device's precise geolocation, contacts, photo library, camera, microphone or health data.

5 Purposes and Legal Bases of Processing

5.1 We process Personal Data for the purposes, and in reliance on the legal bases, set out in the following table. Legal bases are stated with reference to the GDPR and UK GDPR and apply to Users in jurisdictions where such a basis is required.

Purpose

Categories of Personal Data

Legal basis

Creation and administration of Accounts and Guest Accounts; authentication

Account Data; Guest Account Data; Device and Technical Data

Performance of a contract (Art. 6(1)(b))

Generation, storage and display of readings, AI Reader responses, journal entries, reflections and recommendations

User Content; Generated Content; Memory Profile

Performance of a contract (Art. 6(1)(b))

Processing of special categories of Personal Data voluntarily included in User Content

User Content; Memory Profile

Explicit consent (Art. 9(2)(a)), given at onboarding and withdrawable at any time by deleting the relevant content or the Account

Fulfillment of purchases, subscriptions, entitlements and gifts; restoration of purchases

Transaction Data; Gift Data; Account Data

Performance of a contract (Art. 6(1)(b))

Delivery of push notifications

Device and Technical Data

Consent (Art. 6(1)(a)), given via the iOS notification permission

Cross-application attribution using the IDFA

Attribution Identifiers

Consent (Art. 6(1)(a)), given via the App Tracking Transparency permission

Attribution and marketing measurement not involving the IDFA; fraud prevention; enforcement of fair-use limits; security; monitoring of reliability and cost

Attribution Identifiers (excluding IDFA); Device and Technical Data; Transaction Data

Legitimate interests (Art. 6(1)(f)) in operating, securing and promoting the Service

Product research and development, including analysis of the questions, themes and features Users engage with in order to evaluate existing features and to design new readings, rituals and content

User Content (questions and focus notes); Generated Content; Memory Profile themes; Device and Technical Data; Transaction Data

Legitimate interests (Art. 6(1)(f)) in improving and developing the Service (see Section 5.4)

Retention of transaction records

Transaction Data

Legitimate interests (Art. 6(1)(f)) in complying with legal obligations to which we are subject and in establishing, exercising or defending legal claims; compliance with a legal obligation (Art. 6(1)(c)) where that obligation arises under EU or UK law

Compliance with legal process and enforcement of our terms

All categories as necessary

5.2 We do not process User Content, Generated Content or the Memory Profile for the purpose of third-party advertising, and we do not use such data to train artificial intelligence models. Recommendations of readings, rituals and other features of the Service are personalized using such data as described in Section 6.

5.3 Where we rely on legitimate interests, we have assessed that such interests are not overridden by the interests or fundamental rights and freedoms of Users. Users may object to such processing in accordance with Section 11.

5.4 Product Research. Analysis of User Content for product research and development is directed at identifying recurring subject matter, themes and patterns of use across Users, and not at evaluating or making decisions concerning any individual User. Results of such analysis are disclosed outside the Company only in aggregated form.

5.5 Provision of Personal Data. Provision of Account Data is necessary to create and maintain an Account; without it, we are unable to provide the registered features of the Service. All other User Content is provided at the User's discretion.

6 Automated Processing and Artificial Intelligence

6.1 Generated Content and the Memory Profile are produced by large language models operated by one or more AI Providers. Requests to AI Providers are made from server infrastructure operated on our behalf; the Service does not transmit Personal Data to an AI Provider directly from the User's device.

6.2 For each request, our servers transmit to the AI Provider the data used to produce the response, which may include: the name by which the User wishes to be addressed; the current question, cards and spread; the conversation history within the relevant reading; the User's selected AI Reader persona and reading style; the Memory Profile; a summary of recent readings including the questions asked; Generated Content previously produced for the User where relevant to the request; and, for the generation of journal insights and reflections, the text of the relevant journal entries. We do not transmit the User's email address, authentication credentials, payment information or Attribution Identifiers to any AI Provider.

6.3 Each AI Provider processes such data as our Processor under commercial terms that restrict its use of inputs and outputs to providing the service to us and that do not permit it to use inputs or outputs to train its models. The AI Provider's retention of inputs and outputs is governed by those terms and is limited in duration.

6.4 Generated Content is produced automatically without human review. The Memory Profile constitutes profiling within the meaning of Article 4(4) GDPR; it is used to personalize Generated Content for the User to whom it relates and, in aggregated form only, for the product research described in Section 5.4. We do not make decisions based solely on automated processing that produce legal effects concerning the User or similarly significantly affect the User.

7 Disclosure of Personal Data

7.1 Processors. We engage the following Processors, each under terms that require it to process Personal Data on our behalf and to maintain appropriate security measures:

Processor

Function

Personal Data processed

Supabase, Inc.

Database hosting, authentication and server-side functions (infrastructure provided by Amazon Web Services in the United States)

All categories stored server-side; authentication event records

AI Provider(s)

Large language model inference (Section 6)

As set out in Section 6.2

RevenueCat, Inc.

In-app purchase and subscription management

Account identifier; Transaction Data received from Apple; IDFV; IDFA (where permitted); attribution-provider identifier

AppsFlyer Ltd.

Install attribution and marketing measurement

Attribution Identifiers; Account identifier; install and purchase events

Expo (650 Industries, Inc.)

Push notification relay to the Apple Push Notification service

Push notification token; notification text

7.2 Independent Controllers. Apple Inc. (in respect of Sign in with Apple, App Store purchases and push notification delivery) and Google LLC (in respect of Google Sign-In) process Personal Data as independent controllers in accordance with their own privacy policies.

7.3 Legal Requirements. We may disclose Personal Data where we believe in good faith that disclosure is required by applicable law, regulation, legal process or governmental request, or is necessary to protect the rights, property or safety of the Company, Users or the public, or to detect, prevent or address fraud, security or technical issues.

7.4 Corporate Transactions. In the event of a merger, acquisition, reorganization, financing, sale of assets or insolvency proceeding, Personal Data may be transferred to the successor or acquiring entity. Such Personal Data will remain subject to the version of this Policy then in effect, as it may subsequently be amended in accordance with Section 17.

7.5 No Sale. We do not sell Personal Data (as that term is defined under Applicable Data Protection Law), and we do not disclose Personal Data to data brokers.

7.6 Changes to Processors. We may engage, replace or discontinue Processors, including AI Providers, from time to time. Where such a change is material, we will update this Section in accordance with Section 17.

7.7 Aggregated Data. We may disclose, without restriction, aggregated or de-identified data that cannot reasonably be used to identify a User. We do not attempt to re-identify such data.

8 Advertising Identifiers and Attribution

8.1 The Service does not display third-party advertising. We engage AppsFlyer Ltd. to attribute installations and subscriptions to the Company's own marketing activities.

8.2 Before any IDFA is collected, the Service requests permission under Apple's App Tracking Transparency framework. Where the User grants permission, the IDFA is disclosed to AppsFlyer for the purpose of matching the installation to a marketing campaign encountered outside the Service. Where permission is refused, the IDFA is not collected, and cross-application attribution is limited to Apple's SKAdNetwork framework, which does not identify individual Users. The User may change this permission at any time in iOS Settings.

8.3 Irrespective of the App Tracking Transparency election, AppsFlyer receives the IDFV, an AppsFlyer-generated device identifier, the Account identifier, and purchase events forwarded by RevenueCat, for the purposes of measuring subscriptions attributable to marketing activity and detecting fraud within the Service. No User Content, Generated Content or Memory Profile data is disclosed to AppsFlyer.

8.4 Disclosure of the IDFA occurs only with the User's affirmative consent and only for the measurement of the Company's own marketing and related fraud prevention. The Company does not consider such disclosure to constitute a "sale" or "sharing" of personal information for cross-context behavioral advertising within the meaning of the CCPA or comparable state laws. Refusal or withdrawal of the App Tracking Transparency permission operates as an opt-out from such disclosure.

9 User-Initiated Disclosure

9.1 The Service permits the User to export a reading as an image via the device's native sharing interface. The image is rendered locally on the device and comprises the question submitted, the cards drawn and the Generated Content interpreting them. AI Reader messages are not included.

9.2 Content, gift codes or gift links that the User elects to share with third parties or through third-party platforms are disclosed at the User's sole discretion. Such disclosures are outside the scope of this Policy and the Company assumes no responsibility for the subsequent use of such content by recipients or platforms.

10 Data Retention

10.1 Personal Data is retained for no longer than is necessary for the purposes for which it was collected, as follows:

Category

Retention period or criteria

Account Data; User Content; Generated Content; preferences

For the life of the Account, or until the User deletes the individual item

Memory Profile

Stable facts and expression patterns: for the life of the Account or until deleted by the User. Time-limited elements (recurring themes, third-party references and dated events): automatically reduced in weight and then removed after a period of weeks to months without reinforcement, dated events being closed shortly after the referenced date. Removal is effected upon the next update of the Memory Profile.

Guest Accounts not converted to an Account

Deleted automatically approximately 30 days after creation

Push notification token; last-use timestamp

For the life of the Account

Fair-use request counters

A short rolling period, after which counts are reset

Transaction Data

Entitlement and subscription records: deleted upon Account deletion. A transaction ledger comprising the transaction identifier, product identifier, price, currency and storefront country, dissociated from any Account identifier upon Account deletion, is retained for the period required for accounting, tax and dispute-resolution purposes, generally not exceeding seven (7) years.

Gift Data

Gifts sent by the User: deleted upon Account deletion. Gifts redeemed by the User: the redeeming Account identifier is removed upon Account deletion; the remaining record is retained in the sender's history.

Authentication event records

Retained by the authentication Processor for a limited period determined by that Processor

Data held by AI Providers

Subject to the AI Provider's retention terms described in Section 6.3

Data held by RevenueCat and AppsFlyer

Upon Account deletion we instruct RevenueCat to delete the associated subscriber record. Data otherwise held by RevenueCat and AppsFlyer is retained in accordance with their respective terms.

10.2 Upon Account deletion, the data identified above as deleted is removed from production systems without undue delay. Residual copies may persist in encrypted backups for a limited period, generally not exceeding 30 days, until those backups are overwritten in the ordinary course. Data held on the device pursuant to Section 4.10 is generally removed upon uninstallation of the Service; the authentication session held in the iOS Keychain may persist on the device until it expires.

11 Rights of Data Subjects

11.1 Controls within the Service. The Service provides the following controls: (a) view, edit, mark as resolved or delete elements of the Memory Profile through the Memory screen; (b) delete individual readings and journal entries; (c) modify the display name; (d) delete the Account through the Profile screen, whereupon associated data is deleted as described in Section 10; (e) disable push notifications through iOS Settings; and (f) modify the App Tracking Transparency permission through iOS Settings. Deletion of an element of the Memory Profile does not prevent the Service from deriving the same inference from subsequent User Content. Account deletion does not cancel any subscription contracted through the Apple App Store, which must be managed through the User's Apple ID settings.

11.2 Statutory Rights. Subject to Applicable Data Protection Law, Users have the right to: (a) obtain confirmation as to whether Personal Data concerning them is being processed and to access such data; (b) receive a copy of Personal Data they have provided in a structured, commonly used and machine-readable format; (c) obtain rectification of inaccurate Personal Data; (d) obtain erasure of Personal Data; (e) obtain restriction of processing; (f) object to processing conducted on the basis of legitimate interests; (g) withdraw consent at any time, without affecting the lawfulness of processing conducted prior to withdrawal; and (h) lodge a complaint with a supervisory authority, being, for Users in the European Economic Area, the supervisory authority of the Member State of their habitual residence, place of work or place of the alleged infringement (a list is available at edpb.europa.eu), and, for Users in the United Kingdom, the Information Commissioner's Office. (https://edpb.europa.eu/about-edpb/about-edpb/members_en)

11.3 Exercise of Rights. Requests may be submitted to privacy@firetownstudios.com. We may require the request to originate from the email address associated with the Account, or require such other information as is reasonably necessary to verify the identity of the requester. We will respond within the period prescribed by Applicable Data Protection Law, including any extension permitted thereunder, and where no period is prescribed, within a reasonable time. A User may designate an authorized agent to submit a request on the User's behalf, in which case we may require evidence of the agent's authority.

12 Supplemental Notice for United States Residents

12.1 This Section supplements the remainder of this Policy for residents of California and of other United States states that have enacted comprehensive consumer privacy legislation, to the extent such legislation applies to the Company.

12.2 Categories Collected. In the preceding twelve (12) months we have collected the following categories of personal information: identifiers (email address, name, Account identifier, device identifiers); commercial information (Transaction Data); internet or other electronic network activity information limited to activity within the Service; inferences drawn from User Content (Memory Profile); sensitive personal information to the extent voluntarily included in User Content; and other personal information described in Section 4. The sources of such information are the User, the User's device, and the Processors and independent controllers identified in Section 7.

12.3 Business Purposes. Each category identified in Section 12.2 is used for the business purposes identified in Section 5, including performing services on our behalf, helping to ensure security and integrity, debugging, short-term transient use, undertaking internal research for technological development and demonstration, and verifying, maintaining, improving, upgrading or enhancing the Service, and has been disclosed to the Processors identified in Section 7.1 for those purposes.

12.4 Sale and Sharing. We have not sold personal information, and have not shared personal information for cross-context behavioral advertising, in the preceding twelve (12) months, and we have no actual knowledge of selling or sharing the personal information of consumers under sixteen (16) years of age.

12.5 Sensitive Personal Information. Where sensitive personal information is voluntarily included in User Content, we use and disclose it only to provide the Service requested by the User and as otherwise permitted by Cal. Code Regs. tit. 11, § 7027(m).

12.6 Rights. Residents of the applicable states have the right to know, access, correct and delete personal information, the right to data portability, and the right not to be discriminated against for exercising those rights, exercisable in accordance with Section 11.3.

13 Security

13.1 We implement technical and organizational measures appropriate to the risk presented by the processing, including encryption of Personal Data in transit and at rest and access controls designed to restrict each Account to its own data.

13.2 No method of transmission or storage is entirely secure, and we do not warrant the absolute security of Personal Data. In the event of a personal data breach affecting Users, we will notify affected Users and competent authorities as required by Applicable Data Protection Law.

14 International Data Transfers

14.1 The Company is established in the United States, and Personal Data is stored and processed there and in other jurisdictions in which our Processors operate, which may not afford a level of data protection equivalent to that of the User's jurisdiction.

14.2 Where Applicable Data Protection Law requires a transfer mechanism for an onward transfer of Personal Data to a Processor, we rely on an adequacy decision, the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework where the Processor is certified thereunder, or standard contractual clauses approved by the competent authority. Information about the mechanism relied upon for a particular transfer is available on request through the contact details in Section 18.

15 Age Restrictions

15.1 The Service is intended solely for individuals who are eighteen (18) years of age or older, and the App Store age rating for the Service reflects this.

15.2 We do not knowingly collect Personal Data from any individual under the age of eighteen (18). If we become aware that Personal Data has been collected from such an individual, we will delete it without undue delay. Any person who believes that such collection has occurred should contact us using the details in Section 18.

16 No Professional Advice

16.1 The Service is provided for purposes of personal reflection and entertainment only. Generated Content is produced by automated systems and does not constitute, and shall not be construed as, medical, psychological, legal, financial, immigration or other professional advice, and should not be relied upon as a substitute for consultation with a qualified professional.

16.2 Users experiencing a crisis or emergency should contact local emergency services or a crisis support line in their jurisdiction.

17 Amendments

17.1 We may amend this Policy from time to time. The current version will be published within the Service and at the URL indicated in the App Store listing, with the effective date and version number stated above.

17.2 Where Applicable Data Protection Law requires us to inform Users of a change to this Policy before it takes effect, we will do so through the Service or by other reasonable means. Continued use of the Service following the effective date of an amendment constitutes acknowledgment of the amended Policy.

18 Contact Information

18.1 All inquiries, requests and complaints relating to this Policy or to the processing of Personal Data should be addressed to:

Firetown Studios Inc
1101 S Brynwood Dr Browns Mills NJ 08015
privacy@firetownstudios.com