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Privacy Policy

Waterbit Limited (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we access, process, use, disclose, protect, and retain personal data when you use our mobile applications, websites, customer support channels, and related services (collectively, the “Services”).

 

Our Services may include features for photo organization, AI-powered image generation and editing, and an optional Gmail email cleaning feature that may be available to selected users or future versions of the Application. This Privacy Policy applies to all users of the Services worldwide, subject to additional rights or disclosures required by applicable local law.

 

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

 

1. Interpretation and Definitions

 

1.1 Interpretation

 

Words with an initial capital letter have the meanings defined below. These definitions apply whether the terms appear in singular or plural form.

 

1.2 Definitions

 

For the purposes of this Privacy Policy:

 

Affiliate means an entity that controls, is controlled by, or is under common control with the Company.

 

Application means the software application provided by the Company.

 

Company means Waterbit Limited.

 

Device means any device that can access the Services, such as a mobile phone, tablet, or computer.

 

Personal Data means any information that relates to an identified or identifiable individual.

 

Service Providers means third-party companies or individuals who process personal data on our behalf to support the Services, such as hosting, analytics, customer support, cloud storage, security, infrastructure, or AI processing providers.

 

Services means our Application, websites, and related functionalities.

 

Usage Data means information collected automatically through use of the Services, such as app activity, device information, diagnostics, and logs.

 

You means the individual using the Services, or the legal entity on whose behalf the Services are used.

 

2. Information We Process

 

Depending on the features you use and the permissions you grant, we may access or process the following categories of information as necessary to provide the requested functionality.

 

2.1 Information You Provide

 

We may process information you provide directly to us, including:

 

  • Contact information you provide when communicating with us, such as your email address

  • Preferences and settings associated with your use of the Services

  • Communications you send to us, including customer support requests, feedback, survey responses, or in-app reports

  • Text prompts, instructions, or edits you submit when using AI image features

     

2.2 Photos, Videos and Other Media

 

If you use our photo organization or AI image generation and editing features, we may temporarily process:

 

  • Photos, videos, images, or other media you upload, capture, or select

  • Metadata associated with those files, such as file size, format, and timestamps

  • Generated outputs created through the Services

  • Editing instructions, templates, or feature selections you choose

     

We do not collect or permanently store such content except as necessary to provide the requested functionality, maintain security, prevent abuse, or comply with applicable law.

 

2.3 Face-Related Content

 

If you upload or capture a photo containing a person’s face, we may temporarily process the facial content visible in that user-selected media solely to provide the feature you request, such as AI image generation, AI portrait generation, or editing features.

 

We do not collect or store biometric identifiers such as facial recognition templates, biometric face embeddings used for identification, facial geometry used for identity matching, or Face ID data.

 

2.4 Connected Gmail Account Data

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Gmail data is accessed directly from your Device through Google APIs only to provide the email cleaning actions you request. We do not receive, store, or process Gmail message content, metadata, labels, or OAuth tokens on our servers.

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We do not use Gmail data or other Google user data for advertising, profiling, AI model training, or unrelated purposes. Our use of information received from Google APIs will comply with the Google API Services User Data Policy, including the Limited Use requirements, where applicable.

 

Certain versions of the Application may include, or may be preparing to release, an optional Gmail email cleaning feature. If you choose to use this feature, we may ask you to authorize access to your Google account through Google’s authorization process.

 

Depending on the permissions granted, the Application may access certain Google account and Gmail data, such as:

 

  • Your Google account email address

  • Account identifier and basic profile information provided by Google

  • Email metadata

  • Message headers

  • Message content

  • Categories, labels, or other mailbox-related information

     

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2.5 Information Processed Automatically

 

When you use the Services, we may automatically process certain information, including:

 

  • IP address

  • Device type and model

  • Operating system and version

  • App version

  • Device identifiers

  • Language and region settings

  • Usage activity, including feature interactions, session duration, and in-app events

  • Diagnostic data, crash logs, and performance information

  • Advertising identifiers, where permitted by law and your device settings

  • Approximate location derived from IP address or device settings, where applicable

     

2.6 Information from Third Parties

 

We may receive or process information from third parties, such as:

 

  • Analytics providers

  • Attribution and measurement partners

  • Platform operators such as Apple App Store or Google Play

  • Authentication or connected account providers, including Google

  • Customer support tools or fraud prevention vendors

 

3. How We Process Information

 

We process personal data in the following ways:

 

  • Directly from you, when you upload or capture content, use app features, connect a Gmail account, contact support, grant permissions, submit prompts or instructions, or otherwise use the Services

  • Automatically, through your use of the Services and your Device

  • From third parties, when you use integrated services, connect a third-party account, or when our vendors provide operational, analytics, attribution, or security-related information

 

4. Permissions and Connected Accounts

 

Certain features of the Services require access to device permissions or external accounts.

 

4.1 Photo Library and Camera Access

 

If you use photo organization or image editing features, we may request access to your photo library, camera, or media files. We use this access only to provide the requested functionality, such as organizing your photos, allowing you to upload or capture images and videos, or generating edited content.

 

You may deny or revoke these permissions through your device settings, but doing so may limit certain features.

 

4.2 Gmail Account Access

 

If you choose to use the optional Gmail email cleaning feature, we may ask you to authorize access to your Google account through Google’s authorization process. We do not request or store your Gmail password directly in our app.

 

You may revoke the Application’s access to your Google account at any time through your Google account settings. Revoking access may disable or limit Gmail-related features.

 

5. How We Use Personal Data

 

We may use personal data for the following purposes:

 

  • To provide, operate, maintain, and improve the Services

  • To remember your preferences and settings

  • To provide photo organization features, such as grouping, sorting, detecting duplicates, or helping you manage selected photos and videos

  • To provide AI-powered image generation and editing features based on your uploaded images, prompts, and instructions

  • To temporarily process face-related content solely to provide user-requested features

  • To provide the optional Gmail email cleaning feature, if you choose to use it, based on your selected actions and permissions

  • To respond to support requests and communicate with you about updates, notices, or service-related issues

  • To analyze usage trends, troubleshoot bugs, monitor performance, and improve product quality

  • To protect the security and integrity of the Services and prevent fraud, abuse, unauthorized access, or misuse

  • To comply with legal obligations, enforce our terms, and protect our legal rights

     

We do not use face-related content for facial recognition, identity verification, authentication, advertising, profiling, tracking, or any unrelated secondary purpose.

 

We do not use Google user data obtained through Google APIs for advertising purposes, including personalized advertising, remarketing, or interest-based advertising.

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6. Feature-Specific Disclosures

 

6.1 Photo Organization

 

If you use our photo organization features, we may analyze photos and videos you select or allow us to access in order to help you organize your media library. This may include detecting duplicate or similar items, screenshots, large files, blurred images, or other categories selected by you.

 

We do not delete photos or videos from your device unless you explicitly confirm the deletion or removal action.

 

6.2 AI Image Generation and Editing

 

If you use our AI image generation or editing features, we may temporarily process:

 

  • Images or other media you upload, capture, or select

  • Text prompts or editing instructions you submit

  • Generated images or outputs created through the Services

     

We use this information solely to provide the requested functionality, maintain service quality, improve performance, prevent abuse, and support troubleshooting and safety measures.

 

Some features may temporarily process face-related content visible in user-selected photos solely to provide the feature requested by the user, such as AI image generation, AI portrait generation, or editing features.

 

We do not collect or store biometric identifiers such as facial recognition templates, biometric face embeddings used for identification, facial geometry used for identity matching, or Face ID data.

 

6.3 Face Data Policy

 

If you upload or capture a photo containing a person’s face, we may temporarily process the facial content visible in that user-selected media solely to provide the feature you request.

 

We do not use face-related content for facial recognition, identity verification, authentication, advertising, profiling, tracking, or any unrelated secondary purpose.

 

If cloud processing is required to provide the requested feature, user-selected media containing facial content may be securely transmitted to our servers and trusted Service Providers acting solely on our behalf.

 

We do not sell face-related content or share face-related content with advertisers, data brokers, or unrelated third parties.

 

6.4 Gmail Account Connection and Email Cleaning

 

The optional Gmail email cleaning feature is used only if you choose to connect your Gmail account and grant the requested permissions.

 

We use this access only to provide the actions you request, such as reviewing, organizing, archiving, labeling, deleting, moving, or unsubscribing from selected emails, where supported.

 

6.5 Google User Data Deletion and Revocation

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We do not store Gmail message content, metadata, labels, or OAuth tokens on our servers for the optional Gmail email cleaning feature. Because Gmail data is accessed directly from your Device through Google APIs, there is generally no server-side Gmail data for us to delete.

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You may revoke the Application’s access to your Google account at any time through your Google Account permissions page. You may also remove local app data by using the Application settings, your device settings, or by uninstalling the Application.

 

If you contact us at feedback@waterbitlimited.com, we can assist with privacy questions and delete any personal information that we actually maintain, if any, subject to legal, security, fraud-prevention, or dispute-resolution requirements.

 

7. How We Share Personal Data

 

We may share personal data in the following circumstances:

 

7.1 Service Providers

 

We may share information with Service Providers that help us operate the Services, such as vendors providing:

 

  • Cloud hosting and storage

  • Analytics and diagnostics

  • Customer support

  • Security, fraud prevention, and infrastructure monitoring

  • AI processing or model inference services

  • Backend operational support

     

These providers are permitted to process personal data only on our behalf and only for the purposes described in this Privacy Policy or as otherwise permitted by law.

 

For the optional Gmail email cleaning feature, we do not transfer Gmail message content, metadata, labels, or OAuth tokens to third-party Service Providers.

 

7.2 Platform Operators and Integration Providers

 

We may interact with platform operators or connected service providers, such as Apple, Google, or Google API services, where necessary to provide the Services.

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7.3 Legal and Regulatory Requirements

 

We may disclose personal data if required to do so by law, regulation, court order, legal process, or governmental request, or if we believe disclosure is necessary to:

 

  • Comply with applicable law

  • Protect our rights or property

  • Prevent fraud, abuse, or security issues

  • Protect the safety of users or others

     

7.4 Business Transfers

 

If we are involved in a merger, acquisition, reorganization, financing, sale of assets, or similar transaction, personal data may be transferred as part of that transaction, subject to applicable legal requirements.

 

If such a transaction involves personal data, we will handle the transfer in accordance with applicable law and this Privacy Policy.

 

7.5 With Your Direction or Consent

 

We may share information where you direct us to do so or otherwise provide your consent.

 

We do not sell your personal data.

 

We do not sell Google user data.

 

8. Data Retention

 

We retain personal data only for as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and protect our legitimate business interests.

 

Retention periods may vary depending on the type of data, the feature used, and applicable legal requirements.

 

For example:

 

  • Support communications and related contact information may be retained for customer service, recordkeeping, or legal compliance purposes

  • Usage, diagnostics, and security logs may be retained for product improvement, troubleshooting, and fraud prevention

  • Uploaded images, prompts, or generated outputs may be retained only for as long as needed to provide the feature, support user access where applicable, improve service performance, or comply with legal and operational needs

  • Face-related content is retained only for as long as necessary to complete processing, deliver the requested result, maintain security, prevent abuse, and comply with legal obligations. It is then deleted within a limited retention period unless a longer period is required by law or temporarily necessary for security or abuse prevention

When personal data is no longer needed, we will delete it, anonymize it, or securely store it in a form that no longer identifies you, unless retention is required by law.

 

9. International Data Transfers

 

Your personal data may be processed in countries other than the country in which you reside, including Hong Kong and other jurisdictions where we or our Service Providers operate.

 

Where required by applicable law, we implement appropriate safeguards for international transfers of personal data, including Standard Contractual Clauses or other legally recognized transfer mechanisms.

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By using the Services, you understand that your information may be transferred to and processed in jurisdictions that may have different data protection laws than those in your country of residence.

 

10. Data Security

 

We implement reasonable technical, administrative, and organizational safeguards designed to protect personal data, including, where appropriate:

 

  • Encryption in transit and, where applicable, at rest

  • Secure servers and restricted access controls

  • Monitoring, logging, and security review processes

  • Routine internal privacy and security practices

  • Staff training and access limitation measures

 

However, no method of transmission over the internet or method of electronic storage is completely secure. As a result, we cannot guarantee absolute security.

 

11. Your Rights

 

Depending on your location and applicable law, you may have certain rights regarding your personal data.

 

11.1 EEA and UK Users

 

If you are located in the European Economic Area or the United Kingdom, you may have the right to:

 

  • Access your personal data

  • Correct inaccurate personal data

  • Request deletion of your personal data

  • Restrict or object to certain processing

  • Request portability of your personal data

  • Withdraw consent where processing is based on consent

  • Lodge a complaint with a competent supervisory authority

     

11.2 California Users

 

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

 

  • Know what categories of personal information we collect

  • Request access to specific personal information we have collected about you

  • Request deletion of your personal information

  • Request correction of inaccurate personal information

  • Limit the use of sensitive personal information, where applicable

  • Not be discriminated against for exercising your privacy rights

     

To exercise any applicable rights, please contact us at: feedback@waterbitlimited.com

 

We may need to verify your identity before processing your request.

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12. Legal Bases for Processing (EEA/UK)

 

If you are located in the EEA or UK, we process personal data only where we have a valid legal basis, including:

 

  • Performance of a contract, where processing is necessary to provide the Services you request

  • Consent, where you have given us permission to process your personal data for a specific purpose

  • Legitimate interests, where processing is necessary for our legitimate interests and those interests are not overridden by your rights and freedoms

  • Legal obligation, where processing is required to comply with applicable law

     

13. Children’s Privacy

 

Our Services are not intended for children under the age of 13, or under the minimum age required by local law, such as 16 in certain EEA jurisdictions.

 

We do not knowingly process personal data from children below the applicable age threshold. If we become aware that such information has been provided without appropriate authorization, we will take steps to delete it.

 

If you believe that a child has provided us with personal data, please contact us at feedback@waterbitlimited.com.

 

14. Analytics and Advertising

 

We may use third-party analytics and attribution tools, such as Firebase, Google Analytics, Appsflyer, or similar providers, to help us understand how users interact with the Services, improve product performance, measure engagement, and detect technical issues.

 

These providers may process information in accordance with their own privacy policies and contractual obligations with us.

 

If the Services display advertising or use advertising-related measurement tools, such processing will be carried out only where permitted by applicable law and, where required, with your consent. You may be able to control personalized advertising through your device or browser settings.

 

We do not use Google user data obtained through Google APIs for advertising purposes.

 

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15. Third-Party Services and Links

 

The Services may contain links to third-party websites, products, or services, or may integrate with third-party platforms. We are not responsible for the privacy practices, content, or policies of those third parties.

 

We encourage you to review the privacy policies of any third-party services you access through or in connection with our Services.

 

16. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations.

 

If we make material changes, we will provide notice through the Services or by other appropriate means. Your continued use of the Services after the updated Privacy Policy becomes effective means that you acknowledge the updated terms, to the extent permitted by law.

 

17. Contact Us

 

If you have questions about this Privacy Policy, privacy requests, data requests, or questions about Google account access, please contact us at:

 

Waterbit Limited

 

Email: feedback@waterbitlimited.com

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