FakeShop — Privacy Policy

1. Introduction & Acknowledgment of Sole Responsibility

This Privacy Policy explains how CODELUMA LLC ("Company," "we," "us," or "our") collects, uses, discloses, and safeguards information in connection with your download, installation, access, and use of the FakeShop mobile application (the "App").

By downloading, installing, accessing, or otherwise using the App, you acknowledge that you have read, understood, and voluntarily agree to be bound by this Privacy Policy in its entirety. You further acknowledge and accept that your use of the App is entirely at your own risk and discretion, and that you assume full and sole responsibility for any and all consequences arising from or related to your use of the App. Under no circumstances shall the Company be held liable or responsible for any claim, damage, loss, or legal action arising from your use of, or inability to use, the App, regardless of the legal theory asserted. If you do not agree with any part of this Privacy Policy, you must not download, install, or use the App, and must uninstall it from your device.

2. Eligibility & Children's Privacy

The App is not directed to, and is not intended for use by, children. You must be at least 18 years old, or the age of legal majority in your jurisdiction (whichever is higher), to download, install, or use the App. By using the App, you represent and warrant that you meet this requirement.

We do not knowingly collect personal information from individuals under the age of 13 (as defined under the U.S. Children's Online Privacy Protection Act, "COPPA"), or under 16 where the EU General Data Protection Regulation ("GDPR") applies and a lower age has not been set by the relevant Member State, without verifiable parental consent. If we become aware that we have inadvertently collected personal information from a child in violation of applicable law, we will take reasonable steps to delete such information promptly. Parents or guardians who believe their child has provided us with information may contact us using the details in Section 20 to request deletion.

It is the sole responsibility of any parent or guardian to supervise and restrict a minor's access to the App, including through device-level parental controls, app store age ratings, and operating-system permission settings. The Company disclaims any liability for unauthorized use of the App by minors.

3. Information We May Collect

Device Information: device model, operating system and version, unique device identifiers, advertising identifiers (such as Apple's IDFA or Google's Advertising ID/AAID), language, time zone, and screen resolution.

Usage Information: features accessed, screens viewed, in-app interactions (including simulated "add to cart," "checkout," and similar gameplay actions), session duration and frequency, and crash or performance diagnostics.

Approximate Location (if enabled in the future): general, non-precise location data (e.g., derived from IP address) may be collected for analytics and advertising purposes, subject to your device permissions and applicable consent requirements.

Technical & Log Information: IP address, app version, and similar technical data generated automatically during use of the App.

We do not collect, and the App does not request, any payment card information, bank details, or government-issued identification numbers, since the App does not process real transactions.

No obligation to provide data: You are not required to provide any personal information; however, certain technical data is collected automatically as described. You may limit data collection by adjusting your device settings or by not using the App.

4. How Information Is Collected

Information described above may be collected automatically by the App and by third-party software development kits ("SDKs") integrated for advertising and analytics purposes, as described in Section 6. These SDKs operate under their own privacy policies, which we encourage you to review.

5. How We Use Information

We and our service providers may use the information described above to:

• operate, maintain, and improve the App and its features;
• analyze how users interact with the App's dopamine-awareness mechanics, to improve its educational effectiveness;
• display, measure, and personalize advertisements within the App;
• detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, and protect the technical security of the App;
• comply with applicable legal obligations and lawful requests from public authorities; and
• provide customer support and respond to inquiries.

6. Advertising & Analytics

The App may display advertisements and may use analytics tools provided by third-party advertising and analytics networks (which may include providers such as Google AdMob, Google Analytics / Firebase, Meta Audience Network, and similar industry-standard mobile advertising and measurement platforms).

These third-party providers may collect and process information such as your advertising identifier, IP address, device information, and app usage data in order to:

• deliver advertisements, including personalized or interest-based advertisements;
• measure advertising performance and prevent ad fraud;
• generate aggregated, anonymized usage statistics; and
• operate their own services in accordance with their respective privacy policies.

These third parties act as independent controllers (or processors, depending on the jurisdiction) for the data collected through their SDKs. We do not control, and are not responsible for, their data processing practices beyond our integration choices. We encourage you to review their privacy policies directly.

6.1 Your Advertising Choices

• On iOS: Settings → Privacy & Security → Tracking, to manage App Tracking Transparency permissions.
• On Android: Settings → Privacy → Ads (or Google Settings → Ads), to reset/delete your Advertising ID or opt out of interest-based ads.
• Industry opt-out tools: the Digital Advertising Alliance (optout.aboutads.info) or the Network Advertising Initiative (optout.networkadvertising.org), where applicable.

Disabling these settings may reduce the relevance of ads shown to you but will not stop ads from being displayed and will not disable the App's core simulation features.

6.2 Consent

By downloading and using the App, you acknowledge and, to the extent required by applicable law, consent to the collection and processing of information as described in this Section 6, including the display of third-party advertisements and the use of third-party analytics tools. Where required (for example, for users in the EEA, UK, or Switzerland), such consent may be collected and managed through an in-app consent mechanism.

7. Sharing & Disclosure of Information

We do not sell your personal information for monetary consideration. However, sharing information with advertising partners as described in Section 6 (e.g., for cross-context behavioral advertising) may be considered a "sale" or "sharing" of personal information under certain laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"). Section 10 describes your rights to opt out of such sharing, where applicable.

We may otherwise disclose information:

• to service providers and vendors performing services on our behalf (hosting, analytics, advertising, support);
• to comply with applicable laws, regulations, legal process, or governmental requests;
• to protect the rights, property, or safety of the Company, our users, or others;
• in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets; and
• with your consent or at your direction.

8. Legal Bases for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area, the United Kingdom, or a jurisdiction with similar requirements, we process personal information on the basis of: (a) your consent, which you may withdraw at any time; (b) our legitimate interests in operating, securing, and improving the App, provided such interests are not overridden by your data protection rights; and (c) compliance with a legal obligation.

9. Your Privacy Rights

Depending on your place of residence, you may have the right to:

• request access to, and a copy of, the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of, or object to, certain processing;
• request data portability in a structured, commonly used format;
• withdraw consent at any time, without affecting prior lawful processing;
• (California residents) know the categories of personal information collected, used, disclosed, or "sold/shared," and opt out of such "sale" or "sharing," including cross-context behavioral advertising; and
• lodge a complaint with a competent data protection supervisory authority in your country of residence.

To exercise these rights, contact us using the details in Section 20. We may take reasonable steps to verify your identity and may decline requests that are manifestly unfounded, excessive, or where an exemption applies under applicable law. We aim to respond within the timeframes required by applicable law (generally within 30 days under GDPR, or 45 days under CCPA, subject to permitted extensions).

10. International Users & Applicable Law

The App may be downloaded and used by individuals worldwide, including in jurisdictions governed by the GDPR, the UK GDPR, Turkey's Law No. 6698 on the Protection of Personal Data ("KVKK"), the CCPA/CPRA, Canada's PIPEDA, Brazil's LGPD, Australia's Privacy Act 1988, and other data protection and consumer protection laws.

We aim, on a best-efforts basis, to operate the App consistently with widely recognized data protection principles across these frameworks. However, it is your sole responsibility to determine whether your download, access, and use of the App — including its simulated content, advertising, and data-processing practices — is lawful in your jurisdiction, and to comply with any local laws applicable to you. If use of the App is prohibited or restricted under the laws of your jurisdiction, you must not download, access, or use the App.

You assume all legal and financial consequences arising from your use of the App in any jurisdiction, including any violation of local laws, and you agree that the Company shall not be held responsible or liable in any manner whatsoever.

11. Data Retention

We retain personal information for as long as reasonably necessary to fulfil the purposes described in this Policy, including to comply with legal obligations, resolve disputes, and enforce our agreements, after which it will be deleted or anonymized.

12. Data Security

We implement reasonable technical and organizational measures designed to protect information from unauthorized access, loss, misuse, or alteration. However, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security. You are solely responsible for the security of your own device, including operating-system updates, app permission settings, and any third-party security tools.

13. International Data Transfers

Information we collect may be transferred to, stored, and processed in countries other than your country of residence, including the United States, which may have data protection laws that differ from those of your country. Where required, we and our service providers rely on appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) for such transfers. You acknowledge and accept such transfers as a condition of using the App.

14. Third-Party Links & Services

The App or this Policy may reference third-party services, including the advertising and analytics providers described in Section 6. We are not responsible for the privacy practices or content of any third party. You access and use third-party services entirely at your own risk, and we encourage you to review their privacy policies before interacting with them.

15. Disclaimer of Warranties

THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR THAT THE APP WILL BE ERROR-FREE OR UNINTERRUPTED. YOU EXPRESSLY AGREE THAT YOUR USE OF THE APP, AND ALL CONTENT AND SERVICES ACCESSED THROUGH THE APP, IS AT YOUR SOLE RISK AND DISCRETION.

16. Limitation of Liability — No Liability Under Any Circumstances

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, CODELUMA LLC AND ITS OFFICERS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF DATA, PROFITS, OR GOODWILL, ARISING OUT OF OR RELATING TO YOUR DOWNLOAD, INSTALLATION, ACCESS, OR USE OF THE APP, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THIS LIMITATION APPLIES TO ALL CLAIMS, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, OR ANY OTHER LEGAL THEORY, AND SURVIVES ANY FUNDAMENTAL BREACH. NOTHING IN THIS POLICY EXCLUDES OR LIMITS LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

YOU ASSUME FULL AND SOLE RESPONSIBILITY FOR YOUR USE OF THE APP, INCLUDING ANY DECISIONS, EMOTIONAL RESPONSES, OR BEHAVIORS (INCLUDING PURCHASING DECISIONS ON OTHER, REAL E-COMMERCE PLATFORMS) THAT MAY BE INFLUENCED, DIRECTLY OR INDIRECTLY, BY YOUR USE OF THE APP. THE APP IS AN AWARENESS AND ENTERTAINMENT TOOL ONLY AND DOES NOT CONSTITUTE FINANCIAL, PSYCHOLOGICAL, OR MEDICAL ADVICE. YOU HEREBY IRREVOCABLY WAIVE ANY AND ALL CLAIMS AGAINST THE COMPANY ARISING FROM OR CONNECTED TO YOUR USE OF THE APP.

17. Indemnification

You agree to indemnify, defend, and hold harmless CODELUMA LLC and its officers, employees, and agents from and against any and all claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or connected with your access to or use of the App, your violation of this Policy, or your violation of any applicable law or third-party right. This indemnification obligation shall survive the termination of this Policy and your use of the App.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The "Last Updated" date above indicates when this Policy was last revised. Your continued use of the App after any update constitutes acceptance of the revised Policy. It is your responsibility to review this Policy periodically for changes.

19. Governing Law

This Privacy Policy is governed by the laws of the State of Delaware, United States of America, without regard to conflict-of-laws principles, except to the extent that mandatory consumer protection or data protection laws of your country of residence apply and cannot be waived. Any dispute arising out of or relating to this Policy or the App shall be subject to the exclusive jurisdiction of the courts located in Delaware, unless otherwise required by mandatory law.

20. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices:

CODELUMA LLC

1111B S Governors Ave STE 39133, Dover, DE 19904, United States

Email: [email protected]