Venn Diagram by Japality

Privacy Policy

Last updated: July 2026

1. Introduction

Japality Limited ("we", "us", or "our") operates the Venn Diagram mobile application ("App"). We are committed to protecting your privacy and handling your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the App. By using the App, you agree to the practices described in this policy.

2. Data Controller

The data controller responsible for your personal data is:

Japality Limited
A company incorporated in Hong Kong Special Administrative Region
Email: japalitylimited@gmail.com

3. Personal Information Collection Statement (PICS)

In accordance with DPP1 of the PDPO, we provide this Personal Information Collection Statement to inform you about the collection of your personal data:

  • What we collect: We do not require you to create an account or provide personal identification information. Your diagram data (sets, labels, items, colors) is stored locally on your device and is not transmitted to our servers.
  • Third-party collection: If you are not an Ad-Free subscriber, Google AdMob may collect device identifiers (such as IDFA on iOS), IP address, and usage data for advertising purposes. On iOS 14.5+, we request your explicit consent via App Tracking Transparency before personalized advertising.
  • Subscription data: If you purchase an Ad-Free subscription, Apple processes your payment. We receive only subscription status (active/expired) from Apple — we do not receive or store your payment card details, billing address, or Apple ID.
  • Purpose of collection: Personal data is collected only for: (a) displaying advertisements to non-subscribers, (b) verifying subscription status, (c) responding to your support requests.
  • Voluntary provision: You are not obliged to provide tracking consent. Declining ATT does not affect core App functionality.
  • Transfer of data: Personal data may be transferred to Google (AdMob) and Apple (StoreKit) for the purposes described above. These third parties are subject to their own privacy policies and applicable data protection laws.

4. What Data Stays on Your Device

Data you create in the App — Venn diagram sets, labels, colors, and export settings — is stored locally on your device. We do not operate a cloud account system and do not receive your diagram content unless you choose to share or export it through your device's share features.

5. Information Third Parties May Collect

If you use certain App features, the following third parties may collect data:

  • Google AdMob — Non-subscribers may see banner, interstitial, and app-open ads. AdMob may collect device identifiers and usage data to deliver and measure ads. See Google's Privacy Policy.
  • Apple App Store — If you purchase an Ad-Free subscription, Apple processes payment and may collect purchase-related information according to Apple's Privacy Policy.
  • Apple SKAdNetwork — May receive attribution signals related to app installs and advertising on iOS.

6. App Tracking Transparency (iOS)

On iOS 14.5 and later, we ask for your explicit permission before tracking your activity across other companies' apps and websites for advertising purposes. You can change this choice anytime in Settings → Privacy & Security → Tracking.

7. Subscriptions

If you purchase an Ad-Free subscription (monthly or yearly), payment is handled entirely by Apple. We do not receive or store your payment card details. Apple provides us with subscription status so we can enable ad-free features. You can manage or cancel subscriptions in your Apple ID account settings.

8. Retention of Personal Data (DPP2)

We retain subscription status data only for as long as your subscription is active, plus a reasonable period thereafter to facilitate restoration. Your diagram data remains on your device until you delete it or uninstall the App. We do not retain any personal data longer than is necessary for the fulfillment of the purposes for which it was collected.

9. Use of Personal Data (DPP3)

We use information only to:

  • Provide core App functionality
  • Display advertisements to non-subscribers
  • Verify subscription status for Ad-Free users
  • Respond to support requests you send us

We do not use your personal data for purposes other than those stated at the time of collection without obtaining your prescribed consent.

10. Security of Personal Data (DPP4)

We take all practicable steps to protect the personal data we hold against unauthorized or accidental access, processing, erasure, loss, or use, including:

  • Personal data is stored locally on your device, not on our servers.
  • Subscription status is cached locally using Apple's secure storage mechanisms.
  • We do not collect or transmit sensitive personal data such as payment details or identity documents.
  • All communications with third-party services (Apple, Google) use industry-standard encryption (TLS/HTTPS).

11. Transparency (DPP5)

This Privacy Policy is publicly available at https://app.japality.com/venn/i/privacy_policy/ and is accessible within the App at all times. We maintain transparency about:

  • The kinds of personal data we hold
  • The purposes for which personal data is collected and used
  • Our policies and practices in relation to personal data

12. Your Rights — Access and Correction (DPP6)

Under the PDPO, you have the right to:

  • Request access to your personal data held by us
  • Request correction of your personal data if it is inaccurate
  • Request deletion of your personal data where applicable

To exercise these rights, please contact us at japalitylimited@gmail.com. We will respond to your request within 40 days as required by the PDPO. We may charge a reasonable fee for complying with a data access request. Please note that since most of your data is stored locally on your device, you can delete it directly by clearing app data or uninstalling the App.

13. Direct Marketing

We do not use your personal data for direct marketing purposes. We do not send promotional emails, push notifications for marketing, or share your data with third parties for their marketing. If we ever intend to use your data for direct marketing, we will obtain your explicit consent (opt-in) in advance as required under Part VIA of the PDPO.

14. Data Breach Notification

In the event of a data breach involving personal data that poses a real risk of significant harm, we will notify the Privacy Commissioner for Personal Data, Hong Kong, and affected individuals as required by the PDPO.

15. Children's Privacy

The App is not directed at children under 13. We do not knowingly collect personal information from children.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will update the "Last updated" date when changes are made. Material changes will be communicated to you through the App.

17. Complaints

If you have concerns about how we handle your personal data, you may contact us at japalitylimited@gmail.com. You also have the right to lodge a complaint with the Privacy Commissioner for Personal Data, Hong Kong:

Office of the Privacy Commissioner for Personal Data
Room 1303, 13/F, Dah Sing Financial Centre
248 Queen's Road East, Wanchai, Hong Kong
Phone: +852 2827 2827
Website: www.pcpd.org.hk

18. Contact Us

For any privacy-related questions or to exercise your data subject rights, contact:

Japality Limited
Email: japalitylimited@gmail.com

© 2026 Japality Limited. All rights reserved.