Privacy Policy

Effective Date: March 9, 2026 · Last Updated: April 12, 2026

1. Introduction

ACQYR HOLDCO INC. ("we," "us," or "our") operates the CloseUp! mobile application (the "App"). This Privacy Policy explains how we collect, use, and protect your information when you use our App.

We are committed to protecting your privacy. CloseUp! was designed with a privacy-first architecture — your photos are analyzed entirely on your device and are never uploaded to our servers or any third-party service.

2. Information We Collect

2.1 Photo Library Access (On-Device Only)

CloseUp! requests access to your photo library to create the gameplay experience. Here's exactly what happens with your photos:

• Photo scanning and face detection are performed entirely on your device using Apple's Vision framework and CoreML.
• Face embeddings (mathematical representations, not images) are generated on-device to group photos by person. These are stored locally on your device only.
• Photo metadata (dates, locations) is read from your existing photo library to create game categories.
• Your photos are never uploaded, transmitted, or shared with us or any third party.

2.2 Analytics Data

We collect anonymous usage data to understand how the App is used and to improve the experience. This includes:

• App usage events: screens viewed, games played, features used, button taps
• Gameplay statistics: number of games, correct answers, difficulty level chosen, categories played
• Progression data: XP earned, tier level, streaks, badges unlocked
• Device information: device model, OS version, app version, language
• Session data: session duration, app open/close events

This data is collected through our analytics partners (see Section 4).

2.3 Account Information (Optional)

If you choose to sign in with Apple:

• Your Apple-provided user ID
• Your name (if you choose to share it)
• Your email address (if you choose to share it — Apple offers a private relay option)

Sign-in is entirely optional. The App is fully functional without an account.

2.4 Subscription Information

If you purchase a premium subscription, payment processing is handled entirely by Apple through the App Store. We do not collect, store, or have access to your payment details (credit card numbers, billing address, etc.). We receive only a confirmation of your subscription status.

2.5 Information We Do NOT Collect

• Your actual photos or videos
• Face images or biometric data
• Contacts or address book
• Browsing history
• Precise location (we read existing photo metadata only)
• Payment or financial information
• Messages or communications

3. How We Use Your Information

Data	Purpose	Leaves Device?
Photos & face data	Generate gameplay rounds	Never
Photo metadata	Create location/date categories	Never
Usage analytics	Improve app experience	Yes (anonymized)
Account info	Cloud sync (optional)	Only if you sign in
Subscription status	Unlock premium features	Via Apple only

4. Third-Party Services

CloseUp! uses the following third-party services:

4.1 Amplitude (Analytics)

We use Amplitude to understand how users interact with the App. Amplitude collects anonymous usage data, device information, and session data. Amplitude does not have access to your photos.

Amplitude Privacy Policy: amplitude.com/privacy

4.2 RevenueCat (Subscription Management)

We use RevenueCat to manage subscription status. RevenueCat processes subscription data through Apple's payment infrastructure.

RevenueCat Privacy Policy: revenuecat.com/privacy

4.3 Firebase (Google)

We use Firebase for analytics and potential future cloud sync. Firebase may collect device identifiers and usage data.

Firebase Privacy Policy: firebase.google.com/support/privacy

4.4 Apple Frameworks

All photo analysis uses Apple's built-in frameworks (Vision, CoreML) which process data entirely on-device. Apple does not receive your photo data through these frameworks.

5. Data Storage & Security

• On-device data (photos, face embeddings, game data) is stored in your app's sandboxed storage and is protected by iOS security, including your device passcode and biometric authentication.
• Analytics data is transmitted securely (HTTPS/TLS) to our analytics providers.
• Account data (if you sign in) is stored securely and encrypted.
• We do not sell, rent, or trade your personal information to third parties.

6. Your Rights & Choices

6.1 Photo Library Access

You can revoke CloseUp!'s access to your photo library at any time through iOS Settings > Privacy & Security > Photos > CloseUp.

6.2 Analytics Opt-Out

You can limit analytics data collection by enabling "Limit Ad Tracking" or "App Tracking Transparency" in your iOS device settings.

6.3 Data Deletion

You can delete all locally stored app data by:

• Using "Clear & Rescan All Photos" in the App's Settings
• Deleting the App from your device (removes all local data)

If you have an account and wish to delete your data, contact us at hello@playcloseup.com.

6.4 Account Deletion

If you created an account through Sign in with Apple, you can request account deletion by contacting us at hello@playcloseup.com. We will delete your account and associated data within 30 days.

7. Children's Privacy

CloseUp! is not directed at children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected information from a child under 13, we will delete it promptly. If you believe a child under 13 has provided us personal information, please contact us at hello@playcloseup.com.

8. International Users

If you are located in the European Economic Area (EEA), United Kingdom, or other regions with data protection laws:

• Your photo data is processed locally on your device and never transferred internationally.
• Analytics data may be processed in the United States by our third-party analytics providers.
• The legal basis for processing analytics data is our legitimate interest in improving the App.
• You have the right to access, correct, delete, or port your data. Contact us to exercise these rights.

9. California Privacy Rights (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect and how it is used
• Request deletion of your personal information
• Opt out of the sale of personal information (we do not sell personal information)
• Non-discrimination for exercising your privacy rights

10. Notifications

All push notifications are generated and scheduled locally on your device. Notification content (such as "On This Day" memory suggestions) is determined by your local photo library and never transmitted to our servers.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the App or by updating the "Last Updated" date above. Continued use of the App after changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: hello@playcloseup.com
• Website: www.playcloseup.com