PRIVACY POLICY - UnicAI

Last Updated: November 05, 2025

1. INTRODUCTION AND SCOPE

This Privacy Policy ("Policy") is issued by LEAP GAME COMPANY LIMITED ("we," "us," or "our"). It governs the data practices for our mobile application, UnicAI (the "App"), and all related services (the "Services").

About UnicAI: UnicAI is an AI-powered creative suite designed to help you transform and enhance your images. Using advanced artificial intelligence, our App allows you to upload your photos and apply a wide range of creative tools and styles. Core features include AI-powered wardrobe changes, digital makeup application, artistic style transformations (e.g., anime, fantasy), professional headshot generation, and advanced editing tools. This Privacy Policy explains how we handle your data to provide this service.

This Policy is a legally binding agreement. By downloading, installing, or using our Services, you acknowledge that you have read, understood, and agree to the data practices described herein. If you do not agree with this Policy, you must not use the Services.

For the purposes of applicable data protection laws, such as the EU General Data Protection Regulation (GDPR), we are the Data Controller of your Personal Data.

2. OUR PRIVACY COMMITMENT

Our approach to privacy is founded on the following core principles:

• Transparency: We are committed to being open and clear about how we handle your data, especially in the context of our AI-powered features.

• Purpose Limitation: We will only collect and process your data for the specified, explicit, and legitimate purposes articulated in this Policy.

• Data Minimization: We adhere to the principle of collecting only the data that is strictly necessary to provide and improve our services.

• Responsible AI: We are committed to the ethical use of artificial intelligence. A core tenet of this commitment is that we do not use your personal content to train our AI models.

• Security by Design: We integrate robust security measures to protect the confidentiality, integrity, and availability of your Personal Data.

3. DATA WE COLLECT AND PROCESS

To provide and improve our Services, we collect several categories of data.

3.1 User-Provided Content (Processed Ephemerally for AI Functionality)

This is the data you provide to enable the core creative features of the App. We have engineered our systems to treat this data with the highest level of privacy.

• What we collect:

￮ Images: Photographs, portraits, or other images that you upload to the App for editing, stylization, or transformation ("User Images").

￮ Text Prompts: Descriptive text you may input to guide the AI's creative process, such as when using the "Magic Brush" feature ("User Prompts").

• How and why we process it:

￮ When you use a feature, your User Images and User Prompts are transmitted to our servers for the sole purpose of real-time processing by our AI models to generate your requested result.

￮ Immediate Deletion from Servers: After the AI processing is complete and the result is delivered to you, the source User Images and User Prompts are immediately and permanently deleted from our servers. They are not stored, cached, or logged on our server infrastructure.

￮ Local Storage of Prompts: For your convenience, your User Prompts may be saved locally on your device, allowing you to easily reuse or modify them. This data is removed if you uninstall the App.

3.2 Technical & Usage Data (Collected Automatically for Service Operation and Advertising)

To ensure our App functions correctly, to resolve technical issues, and to support our advertising-based model, we automatically collect certain technical data.

• What we collect:

￮ Device and Network Information: Your IP address, device manufacturer and model, operating system version, screen dimensions, time zone, network state (e.g., Wi-Fi), and system language.

￮ Application and Advertising Identifiers: Your device's advertising identifier (e.g., Google Advertising ID on Android), the App's version, and unique device identifiers.

￮ Usage and Interaction Data: Information about your interactions with the Services, such as app launches, features used, time spent on pages, and clicks. This also includes information about your interaction with advertisements shown to you.

• Why we collect it: To maintain and improve our Services, analyze usage trends, ensure security, and to facilitate our advertising monetization.

3.3 Communications Data (Voluntarily Provided)

When you voluntarily contact us for customer support or to provide feedback, we collect your email address and the content of your communications. This data is used exclusively to respond to your inquiries.

4. OUR USE OF ARTIFICIAL INTELLIGENCE (AI)

Transparency in our use of AI is a cornerstone of our commitment to you.

• AI Functionality: The core purpose of our App is to use generative AI to apply digital effects, create new artistic styles, and perform other creative transformations based on your input.

• No Training on Your Data: We state unequivocally that your User Images and the resulting AI-generated designs are not used to train or improve our AI models. Your content is your own, and we do not use it for our model development.

• Third-Party AI Providers: To provide specific features, we may utilize specialized AI models from third-party providers.

￮ Google AI (Gemini, Veo): We use Google's APIs for many of our core image and video generation features. When you use these features, your input data is sent to Google's API for processing. This data is processed according to Google's API Terms of Service and Privacy Policy.

5. PURPOSES AND LEGAL BASES FOR DATA PROCESSING

We only process your Personal Data when we have a valid legal basis for doing so under applicable data protection laws like the GDPR. The table below outlines the purposes for which we process your data, the data categories involved, and the legal justification for each activity.

Click the image to view the sheet.

6. THIRD PARTY SERVICES AND PARTNERS SDKS

We integrate third-party Software Development Kits (SDKs) to provide and maintain the full functionality of our Services, including our core AI features and advertising. These partners may collect data directly from your device and typically act as independent "Data Controllers." We strongly encourage you to review their privacy policies to understand their data practices.

Our primary partners include:

• AI Service Providers

￮ Google (Gemini API, Veo API): Used for core AI generation features. Their policies govern the data processed by this service.

• Advertising & Analytics Partners

￮ Google (AdMob & Firebase): https://policies.google.com/privacy/

￮ Meta (Facebook Audience Network & Analytics): https://www.facebook.com/about/privacy/

￮ AppLovin: https://www.applovin.com/privacy/

￮ Adjust: https://www.adjust.com/terms/privacy-policy/

￮ AppsFlyer: https://www.appsflyer.com/legal/privacy-policy/

￮ Vungle: https://vungle.com/privacy/

￮ InMobi: https://www.inmobi.com/privacy-policy/

￮ Pangle: https://ad.oceanengine.com/union/media/privacy

￮ Mintegral: https://www.mintegral.com/en/privacy/

￮ Unity: https://unity3d.com/legal/privacy-policy/

￮ IronSource: https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

￮ Revenue Cat: https://www.revenuecat.com/privacy/

7. APPLICATION PERMISSIONS AND THEIR PURPOSES

Our App requests only the minimum permissions necessary to provide its features. You are in complete control of these permissions and can manage them at any time through your device's settings menu. This section explains exactly which permissions the App may request and why we need them.

Click the image to view the sheet.

8. INTERNATIONAL DATA TRANSFERS

We operate globally, and your Personal Data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, where our third-party partners operate. We ensure that all such transfers comply with applicable data protection laws by using legally-recognized transfer mechanisms like Standard Contractual Clauses (SCCs).

9. YOUR PRIVACY RIGHTS AND CHOICES

You have rights concerning your Personal Data, subject to limitations provided by law.

9.1 Opt-Out of Personalized Advertising:

You can limit ad tracking by resetting your device's advertising identifier through your device settings (e.g., On Android: Settings > Privacy > Ads). This will limit, but not eliminate, the ads you see.

9.2 Formal Rights Requests:

Depending on your jurisdiction, you may have the right to Access, Rectify, or Erase the Personal Data we hold about you. Because we do not store your User Images, erasure requests will primarily apply to Technical Data and Communications Data associated with you. To exercise any of your rights, please submit a formal request to the email address provided in Section 13.

10. JURISDICTION-SPECIFIC PROVISIONS

10.1 For Residents of the European Economic Area (EEA), UK, and Switzerland (under GDPR):

You have the rights detailed in Section 9, as well as the right to data portability and the right to lodge a complaint with a supervisory authority. The legal bases we rely on are detailed in the table in Section 5.

10.2 For Residents of California (under CCPA/CPRA):

You have the right to know what personal information is collected, to delete it, and to opt-out of the "sharing" of your personal information for cross-context behavioral advertising. Our use of third-party advertising SDKs may be considered "sharing." You can exercise your right to opt-out by managing your device's advertising ID as described in Section 9. We do not "sell" your data for monetary consideration.

11. CHILDREN'S PRIVACY

These Services are not directed to anyone under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personally identifiable information from children. If we become aware that a child has provided us with Personal Data, we will take steps to delete such information immediately.

12. CHANGES TO THIS POLICY

We may update this Policy from time to time. If we make material changes, we will provide notice through the App or by other means to allow you to review the changes before they become effective. Your continued use of the Services after a revision becomes effective constitutes your acceptance of the updated terms.

13. CONTACT INFORMATION

For any questions, concerns, or requests relating to this Privacy Policy, please contact us:

• Company: LEAP GAME COMPANY LIMITED

• Website: https://leapstud.io

• Support Email: support.productai@leapstud.io