Privacy Policy

1. Introduction

Welcome to DAILY. This Privacy Policy ("Policy") describes how DAILY ("DAILY," "we," "us," "our"), a service currently operated by an independent developer based in Lithuania, collects, uses, stores, discloses, transfers, and otherwise processes personal data in connection with your access to and use of the DAILY mobile application and any related features, functionality, and services (collectively, the "Service" or the "App").

We take your privacy seriously. This Policy is intended to be transparent, accessible, and compliant with the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the Lithuanian Law on Legal Protection of Personal Data, and the applicable requirements of the Apple App Store Review Guidelines and the Google Play Developer Program Policies.

Please read this Policy carefully. By downloading, accessing, registering for, or otherwise using the Service, you confirm that you have read, understood, and, where required by law, consented to the practices described in this Policy. If you do not agree with this Policy, you should not use the Service.

This Policy should be read together with our Terms of Service, Community Guidelines, Content Moderation Policy, AI Transparency Policy, Data Deletion Policy, Refund Policy, and Copyright & Intellectual Property Policy, all of which are available at https://dailyemoji.app.

2. Scope of This Policy

This Policy applies to all personal data processed by DAILY in connection with:

• Your creation and management of a DAILY account
• Your use of the App's features, including posting, commenting, reacting, and following
• Your DAILY Premium subscription status and billing
• Your interactions with our customer support
• Our automated content moderation systems
• Our internal analytics, security, and fraud prevention activities

This Policy does not apply to third-party websites, applications, or services that may be linked from within the Service, including Apple's or Google's own platforms (including the Apple App Store and Google Play Billing), which are governed by their own respective privacy policies.

3. Data Controller and Contact Information

The data controller responsible for determining the purposes and means of processing your personal data under this Policy is the independent developer operating DAILY, based in Lithuania. As DAILY is currently operated by an individual developer rather than a registered legal entity, the developer personally acts as the data controller until such time as a company is formally registered, at which point this Policy will be updated accordingly.

Contact Email: support@dailyemoji.app Website: https://dailyemoji.app

If you have any questions, concerns, or requests relating to this Policy or our data practices, please do not hesitate to contact us using the details above. We aim to respond to all legitimate privacy inquiries within the timeframes required under GDPR.

4. Eligibility and Age Requirements

DAILY is intended solely for use by individuals who are at least 16 years of age. We do not knowingly design the Service for, market the Service to, or knowingly collect personal data from individuals under the age of 16.

If we become aware, whether through user reports, internal review, or otherwise, that a user under the age of 16 has created an account or otherwise provided us with personal data, we will take reasonable steps to promptly delete such data and terminate the associated account, in accordance with our Data Deletion Policy.

Parents or guardians who believe that a child under 16 has provided us with personal data without appropriate consent should contact us immediately at support@dailyemoji.app so that we may investigate and take appropriate action.

5. Categories of Personal Data We Collect

We collect the following categories of personal data, depending on how you interact with the Service.

5.1 Account and Identity Data

When you register for DAILY using Apple Sign In or Google Sign In, we receive and store certain identity information that you authorize Apple or Google to share with us, including:

• Your name (or a name you choose to display, including Apple's private relay name option where applicable)
• Your email address (or an anonymized relay email address, depending on your Apple or Google privacy settings)
• A unique authentication identifier issued by Apple or Google that allows us to recognize your account on subsequent logins
• A username that you select or that is generated for your account
• A profile photo that you choose to upload

5.2 Content You Provide

As you use the Service, you will generate and submit content that we store and display in connection with your account, including:

• Photos uploaded as part of your daily post
• Captions accompanying your photos
• Comments you leave on other users' posts
• Reactions you give to other users' posts
• The list of accounts you follow and the list of accounts that follow you

5.3 Activity, Streak, and Transaction Data

We collect data reflecting your engagement with and use of core App features, including:

• Your current and historical daily posting streak information
• Your DAILY Premium subscription status (for example, whether you currently hold an active subscription)
• The billing platform (Apple App Store or Google Play Billing) associated with your subscription, and your subscription expiration or renewal date
• General app usage information, such as which features you access, how frequently you use the App, and how you navigate through the App

5.4 Technical, Device, and Security Data

To operate, secure, and improve the Service, we automatically collect certain technical information, including:

• Device information, such as device model, operating system, and app version
• IP address
• Crash logs, generated when the App encounters a technical error, to help us diagnose and fix issues
• Security logs, generated to help us detect, investigate, and prevent unauthorized access, fraud, or abuse

5.5 Communications Data

If you contact our support team, we will collect and retain the content of your communications, including your email address and any information you choose to provide, in order to respond to your inquiry.

5.6 What We Do Not Collect

We do not request or knowingly collect the following:

• Passwords (authentication is handled entirely by Apple and Google)
• Payment card numbers or full financial account details (these are processed exclusively by Apple App Store or Google Play Billing)
• Special categories of sensitive personal data under GDPR Article 9 (such as health data, biometric data, genetic data, political opinions, religious beliefs, or trade union membership), except to the limited extent such information may be voluntarily and incidentally included by a user within their own uploaded photos, captions, or comments, which remains that user's independent choice and responsibility

6. How We Collect Personal Data

We collect personal data through the following channels:

6.1 Directly From You

When you register an account, complete or edit your profile, upload a photo, write a caption, post a comment, react to content, follow another user, subscribe to DAILY Premium, or contact our support team.

6.2 Automatically Through Your Use of the Service

As you use the App, certain technical and usage data is automatically collected via standard mobile application logging and diagnostic mechanisms, including device information, IP address, crash logs, and security logs.

6.3 From Third Parties

We receive limited identity information from Apple Sign In and Google Sign In, consisting only of the data elements you authorize those platforms to share with us at the time of registration. We also receive confirmation of your DAILY Premium subscription status and transaction events from Apple App Store or Google Play Billing, without receiving your full payment card details.

7. Legal Bases for Processing (GDPR)

We rely on the following legal bases, as applicable, to process your personal data:

7.1 Performance of a Contract (Art. 6(1)(b) GDPR)

Processing necessary to create and administer your account, provide core App functionality (posting, commenting, reacting, following, streak tracking), and fulfill and verify your DAILY Premium subscription.

7.2 Legitimate Interests (Art. 6(1)(f) GDPR)

Processing necessary for our legitimate interests in operating a safe and functional platform, including: maintaining platform security; detecting and preventing fraud, spam, and abuse; operating AI-assisted content moderation systems; diagnosing technical issues through crash logs; and improving the Service. We have considered these interests against your rights and freedoms and believe they are appropriately balanced; you retain the right to object as described in Section 13 below.

7.3 Consent (Art. 6(1)(a) GDPR)

Where required by applicable law, we will rely on your consent for specific processing activities, such as optional features that may be introduced in the future. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7.4 Legal Obligation (Art. 6(1)(c) GDPR)

Processing necessary to comply with our legal obligations, such as retaining certain purchase records for tax and accounting purposes, or responding to lawful requests from public authorities.

8. How We Use Your Personal Data

We use the personal data described above for the following purposes:

• To create, verify, and maintain your DAILY account
• To authenticate you when you log in via Apple or Google Sign In
• To enable and display core social features, including posting, commenting, reacting, and following
• To calculate, track, and display your daily posting streak
• To verify, record, and manage your DAILY Premium subscription status through Apple App Store or Google Play Billing
• To operate our AI-assisted content moderation systems, including analyzing content and reports for potential Community Guideline violations
• To route flagged content and reports to human administrators for final review and decision
• To respond to and act upon user reports concerning posts, comments, or profiles
• To detect, investigate, and prevent fraud, security incidents, and abuse of the Service
• To diagnose, troubleshoot, and resolve technical issues through the analysis of crash and security logs
• To communicate with you regarding your account, transactions, or support requests
• To send push notifications relating to DAILY features, including daily emoji reveals, reactions, friend activity, reminders, and important account or security notices, subject to your notification preferences.
• To enforce our Terms of Service and Community Guidelines
• To comply with applicable legal, regulatory, and tax obligations
• To maintain records necessary to demonstrate our compliance with applicable law

We do not use your personal data for any purpose incompatible with those described in this Policy without first notifying you and, where required, obtaining your consent.

8.1 Analytics and Service Improvement

We may analyze aggregated and, where possible, anonymized information about how users interact with DAILY to improve the App, develop new features, enhance safety, optimize performance, and better understand how the Service is used.

We do not sell, rent, or share your personal data with advertisers, data brokers, or other third parties for their own marketing purposes.

9. Sharing and Disclosure of Personal Data

9.1 Third-Party Service Providers

We engage the following third-party service providers to help us operate the Service. Each provider processes personal data only to the extent necessary to perform its designated function, and in accordance with appropriate data processing agreements where required under GDPR.

9.2 Other Users

Certain information you choose to make available through your public profile and posts — such as your username, profile photo, posts, captions, comments, reactions, and follower/following relationships — is visible to other users of the Service as part of the Service's core social functionality.

9.3 Legal and Safety Disclosures

We may disclose personal data where we believe in good faith that such disclosure is necessary to: (a) comply with a legal obligation, court order, or valid governmental request; (b) protect and defend our rights or property; (c) prevent or investigate possible wrongdoing in connection with the Service; (d) protect the personal safety of users or the public; or (e) protect against legal liability.

9.4 Business Transfers

If DAILY undergoes a business transition, such as a merger, acquisition, incorporation, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate confidentiality protections and consistent with this Policy.

9.5 No Sale of Personal Data

We do not sell your personal data to third parties for monetary or other valuable consideration, and we do not share your personal data with third parties for their own independent marketing purposes.

9.6 No Advertising Data Sales

We never sell, rent, or license your personal data to advertisers, advertising networks, or data brokers.

We do not provide third parties with your personal data for their own advertising or marketing purposes.

10. AI-Assisted Processing of Personal Data

As part of our content moderation systems, we use AI-assisted tools to automatically analyze uploaded photos, captions, comments, and user reports in order to detect possible violations of our Community Guidelines. Where the AI system determines that content or a report may warrant further attention, it is flagged and forwarded to a human administrator for review.

Importantly, our AI systems do not make final decisions that produce legal or similarly significant effects concerning you. AI tools do not permanently delete accounts, permanently ban users, or otherwise finalize moderation outcomes. All consequential decisions — including content removal, warnings, account restrictions, suspensions, and permanent bans — are made exclusively by human administrators. For further detail regarding our use of AI, including your rights in connection with automated processing, please see our AI Transparency Policy. We may also use aggregated and anonymized moderation outcomes to evaluate and improve the accuracy, consistency, and reliability of our AI-assisted moderation systems over time.

11. International Data Transfers

Some of our third-party service providers, including Supabase, may process personal data on servers located outside the European Economic Area ("EEA"). Where personal data is transferred outside the EEA, we take steps to ensure that such transfers are conducted in compliance with GDPR, including through the use of the European Commission's Standard Contractual Clauses, adequacy decisions, or other legally recognized transfer mechanisms, as applicable.

You may contact us at support@dailyemoji.app for further information regarding the safeguards applicable to a specific international transfer of your personal data.

12. Data Retention

We retain personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, as described in this Policy, unless a longer retention period is required or permitted by law. Our general retention practices are as follows:

• Account and profile data: Retained for as long as your account remains active, and deleted or anonymized following account deletion in accordance with our Data Deletion Policy.
• Content data (photos, captions, comments, reactions): Retained for as long as your account remains active, unless removed earlier by you or by us pursuant to our Content Moderation Policy.
• Purchase and transaction history: Retained for the period required under applicable tax, accounting, and financial recordkeeping law, which may extend beyond account deletion.
• Refund requests: Records of refund requests submitted through the App or by email, including the reason provided and the outcome, are retained for the same period as related purchase and transaction history, to demonstrate compliance with our Refund Policy and applicable consumer protection law.
• Crash logs and security logs: Retained for a limited period necessary for diagnostic, security, and fraud-prevention purposes, after which they are deleted or anonymized.
• Support communications: Retained for a reasonable period necessary to resolve your inquiry and to maintain records of our customer support interactions.

Where we no longer have a legitimate business need to process your personal data, we will delete or anonymize it, or, if this is not possible, securely store it and isolate it from further processing until deletion is possible.

For security, fraud prevention, and abuse detection purposes, certain security logs, moderation records, and technical audit logs may be retained for a limited period even after related content or accounts have been deleted, where permitted or required by applicable law.

13. Your Data Protection Rights Under GDPR

If you are located in the European Economic Area, or otherwise benefit from rights under GDPR, you have the following rights with respect to your personal data, subject to certain exceptions and limitations set out in applicable law:

• Right of Access – You may request confirmation as to whether we process personal data concerning you, and, if so, request a copy of that data along with supplementary information about our processing activities.
• Right to Rectification – You may request that we correct inaccurate personal data or complete incomplete personal data concerning you.
• Right to Erasure ("Right to be Forgotten") – You may request that we delete your personal data in certain circumstances, such as where it is no longer necessary for the purposes for which it was collected.
• Right to Restriction of Processing – You may request that we restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested.
• Right to Data Portability – Where processing is based on consent or contract and carried out by automated means, you may request to receive your personal data in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where technically feasible.
• Right to Object – You may object to processing of your personal data based on our legitimate interests, including profiling, on grounds relating to your particular situation.
• Right to Withdraw Consent – Where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing conducted prior to withdrawal.
• Right Not to Be Subject to Solely Automated Decision-Making – As described in Section 10 above and in our AI Transparency Policy, you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects concerning you, without meaningful human involvement.
• Right to Lodge a Complaint – You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement. In Lithuania, the relevant supervisory authority is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).

To exercise any of these rights, please contact us at support@dailyemoji.app. We may need to verify your identity before processing certain requests. We will respond to your request within one month of receipt, as required under GDPR, subject to possible extension in complex cases, in which event we will inform you of the reasons for the delay.

14. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage, taking into account the nature, scope, and purposes of processing and the risks involved. These measures include, among others, reliance on reputable infrastructure providers (such as Supabase, Apple, and Google) that maintain their own industry-standard security controls, and the fact that we do not store user passwords, as authentication is handled entirely by Apple Sign In and Google Sign In.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security of your personal data. You are responsible for maintaining the security of the Apple or Google account used to access DAILY.

If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, affected users, in accordance with GDPR Articles 33 and 34.

15. Account Deletion and Its Effect on Your Data

You may delete your DAILY account at any time through the App's account settings. Upon deletion, we will delete or irreversibly anonymize your personal data in accordance with our Data Deletion Policy, except to the extent that continued retention of certain data (such as transaction records) is required by applicable law, as described in Section 12 above.

16. Children's Privacy

As set out in Section 4, DAILY is intended for use by individuals aged 16 and older, and we do not knowingly collect personal data from children under this age. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at support@dailyemoji.app so we can investigate and, where appropriate, delete such data.

17. Third-Party Links and Services

The Service may allow you to sign in through Apple or Google, and to subscribe to DAILY Premium through Apple App Store or Google Play Billing. These third parties operate independently of DAILY and maintain their own privacy policies governing their handling of your personal data. We encourage you to review the privacy policies of Apple and Google to understand how they process your personal data.

18. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in our data practices, the Service, or applicable law. If we make material changes, we will notify you through the App, by email, or by other appropriate means, and will update the "Last Updated" date at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the Service after any changes take effect constitutes your acceptance of the revised Policy.

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your data protection rights, please contact us at:

Email: support@dailyemoji.app Website: https://dailyemoji.app

We are committed to working with you to resolve any concerns you may have about our handling of your personal data.