Privacy Policy Zoomly Last updated: March 14, 2026 1. Data Controller Zoomly is developed and operated by Dzianis Milasheuski, an individual developer established in Lithuania. Contact email: info@porconova.com 2. Overview Zoomly is designed with privacy as a core principle. The App does not collect, store, transmit, share, or process any personal data. All image analysis is performed entirely on the user's device using an embedded AI model. No images, analysis results, or any other user content are sent to external servers. No user accounts, registration, or sign-in are required. 3. No Data Collection Zoomly does not collect or process: - Personal identification information - Contact information - Location data - Device identifiers - Usage analytics - Crash reports - Cookies or tracking data - Advertising identifiers - Photos or images - Analysis results - Any other personal data The App operates entirely on the user's device. 4. Local Processing All AI image analysis, text extraction, object detection, and other functionality of Zoomly is performed locally on the user's device. The App does not connect to external servers for processing and does not transmit any user content outside the device. The AI model is downloaded once to the device and runs entirely offline thereafter. 5. iCloud Sync If enabled by the user, Zoomly uses Apple's iCloud (CloudKit / iCloud Drive) to sync analysis history across the user's devices. This data is stored in the user's personal iCloud account, managed by Apple, and is not accessible to the developer. iCloud sync can be disabled at any time in the App's settings. The developer does not operate any servers involved in this sync process. 6. No Tracking Zoomly does not use tracking technologies and does not track users across apps, websites, or services. 7. Data Storage The App does not operate external servers or databases. Analysis history, settings, and preferences are stored locally on the user's device (and optionally in the user's personal iCloud account) and are not accessible to the developer. 8. Data Sharing Zoomly does not sell, rent, disclose, or share any user data with third parties. 9. EU and U.S. Privacy Laws Zoomly is designed not to collect or process personal data. As no personal data is processed, most obligations under the EU General Data Protection Regulation (GDPR) and applicable U.S. state privacy laws are not triggered. If the App's functionality changes in the future, this Privacy Policy will be updated accordingly. 10. Children's Privacy Zoomly is not directed to children under the age of 13. The App does not knowingly collect personal data from children or any other users. 11. Changes to This Policy This Privacy Policy may be updated if the App's functionality changes. Any updates will be reflected by revising the "Last updated" date. 12. Governing Law This Privacy Policy is governed by the laws of the Republic of Lithuania, without prejudice to mandatory consumer protection laws applicable in the user's jurisdiction. 13. Contact If you have any questions about this Privacy Policy, please contact: Dzianis Milasheuski Email: info@porconova.com