Privacy Policy

1. Who we are

This app, Charmz ("the App", "we", "us", "our"), is operated by Noviq Labs Limited, 74-78 Stanley Street, Won Hing Building, Flat 5, 4/F, Central, Hong Kong, company registration number 80611241.

If you have any questions about this policy or your data, you can contact us at [email protected].

2. Scope of this policy

This policy explains what personal data we process when you use the Charmz mobile app and this website, why we process it, on what legal basis, who we share it with, and what rights you have. It applies to users in the European Union, the United Kingdom, Switzerland and elsewhere.

3. Data we process

Charmz is built to collect as little personal data as possible.

3.1 No account needed

You can play Charmz without creating an account. We do not ask for your name, email address or a profile in order to play the game.

3.2 Purchase and subscription data

If you buy Charmz Premium, the purchase is processed by the app store (Google Play or the Apple App Store). We receive confirmation of your subscription status and a purchase identifier, but we never receive your full payment details such as card or bank data. Those are handled solely by the store.

3.3 Basic technical data

To run the App and keep it stable, basic technical data may be processed, such as device type, operating system and version, app version and language settings. We do not use analytics or tracking tools to profile you.

3.4 Device identifier

When you first launch the App, a random anonymous identifier is generated on your device and stored in secure local storage. This identifier is used solely to recognise your device across sessions so that your subscription status can be verified and restored correctly. It is transmitted to our subscription provider, RevenueCat, Inc., for this purpose. The identifier is not linked to your name, email address, or any other information that could identify you as a person, and it is not used for advertising or tracking purposes.

3.5 Push notifications

If you allow notifications, we process a device push token so that we can send you notifications (for example about new openers or features). You can turn notifications off at any time in your device settings.

4. Purposes and legal bases (GDPR Art. 6)

• Providing the App and its features – legal basis: performance of a contract (Art. 6(1)(b) GDPR).
• Processing purchases and managing subscriptions – legal basis: performance of a contract (Art. 6(1)(b) GDPR).
• Keeping the App secure, stable and free of errors – legal basis: our legitimate interest (Art. 6(1)(f) GDPR).
• Sending push notifications you have opted into – legal basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time by turning off notifications in your device settings.

5. Third-party services we use

We rely on the following providers, each of which has its own privacy policy:

• Google Play / Google LLC – app distribution and payment processing on Android.
• Apple App Store / Apple Inc. – app distribution and payment processing on iOS.
• RevenueCat, Inc. – management of subscriptions and Premium access, including processing of the anonymous device identifier described in section 3.4.
• Despia – the technology used to package and deliver the Charmz app on mobile devices.

6. Purchases and subscriptions

Charmz Premium is offered as an auto-renewing subscription (for example a monthly or 6-month plan). Billing, renewals and cancellations are managed by the app store you purchased through. You can manage or cancel your subscription at any time in your Google Play or Apple account settings. We receive only your subscription status, never your payment method.

7. International data transfers

Charmz is operated by a company based in Hong Kong. Some of the providers listed above (such as Google, Apple, RevenueCat and Despia) are based in the United States or other countries outside the European Economic Area (EEA). Where personal data is transferred outside the EEA, we rely on appropriate safeguards, such as the EU Standard Contractual Clauses or the certified transfer mechanisms offered by these providers.

8. How long we keep data

We keep personal data only as long as necessary for the purposes described above. Purchase and subscription records are kept for as long as required by applicable tax and accounting law. Basic technical data and push tokens are kept only as long as needed to operate and secure the App.

9. Your rights

If the GDPR applies to you, you have the right to access your data, have it corrected or deleted, restrict or object to its processing, request data portability, and withdraw any consent you have given. You also have the right to lodge a complaint with your local data protection supervisory authority.

To exercise any of these rights, contact us at [email protected].

10. Children

Charmz is intended for a general, adult audience and is not directed at children. We do not knowingly collect personal data from children under the age of 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Security

We take reasonable technical and organisational measures to protect your data against loss, misuse and unauthorised access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

12. Changes to this policy

We may update this policy from time to time. The current version is always available at this address, with the date of the last update shown at the top.

13. Contact

Noviq Labs Limited
74-78 Stanley Street, Won Hing Building, Flat 5, 4/F
Central, Hong Kong
Email: [email protected]