Lunfil Privacy Policy

1. Introduction & Scope

This Privacy Policy applies to the Lunfil mobile application (hereinafter referred to as the “App”), a local PDF tool and file manager designed for iOS devices and distributed on the Apple App Store for users in Europe, the United States and other global regions.

App is a fully local, offline processing tool. All core functions including PDF viewing, editing, conversion, file sorting, file management and local file processing are completed entirely on the user’s device. No user files, documents or personal data will be uploaded to any cloud server. The App requires no account registration, no login, and can be used immediately after installation.

This policy complies with the Apple App Store Review Guidelines, General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable global privacy laws. It fully discloses our data processing rules to ensure complete transparency for all users.

2. Data Processing & Information Collection

We strictly follow the data minimization principle. All file processing behaviors occur locally on users’ iOS devices. We do not collect, upload, store or synchronize any user files, PDF documents, local file content or user personal privacy data to any server.

2.1 User File Data (100% Local Processing)

All files processed, viewed or managed through App remain exclusively stored on the user’s local device. The App does not access, read, collect, cache or upload user files to any external server, third-party platform or cloud service. Users retain full ownership and control of all local file data at all times.

2.2 Passive Anonymous Device Data

To ensure normal App operation, fix technical bugs, optimize device compatibility and improve user experience, we automatically collect non-identifiable, non-private anonymous device information when you use the App, including:

- Device model and device identifier (IDFV)

- iOS system version and system language

- General approximate region (country/region level only, no precise location)

Such data is fully anonymous, cannot be used to identify any individual user, and will never be associated with user files or personal identities.

2.3 Data We Absolutely Do NOT Collect

We clearly declare that App will never collect the following information: user name, email, phone number, identity information, precise geographic location, contact list, photos, sensitive personal data, payment information, and any content of user local files and PDFs.

3. Purpose of Data Usage

The limited anonymous device data we collect is only used for the following legitimate operation purposes and will not be used for any other commercial or unauthorized scenarios:

- Ensure stable local operation of PDF processing and file management functions

- Adapt different device models and system versions to resolve compatibility issues

- Fix App crashes and technical bugs to optimize running stability

- Conduct anonymous aggregated statistics to iterate and optimize product functions

No data is used for user tracking, portrait building, precise push or illegal data mining.

4. Third-Party Services & Data Sharing Statement

App contains no third-party AI services, no third-party advertising SDKs, no third-party data statistics plug-ins, and no external data transmission channels.

Different from other intelligent tool applications, all algorithm logic, PDF parsing and file management functions of this App are independently implemented through local device code. There is no external data transmission, no third-party data interaction, and no cross-platform data sharing during the whole use process.

We will not sell, rent, transfer or disclose any anonymous device data or user local file data to any third-party individuals or institutions, unless required by mandatory legal provisions.

5. Data Storage, Clearing & Security Protection

5.1 Local File Data Storage

All user files and PDF data are stored only in the user’s local device sandbox. We have no server-side storage authority and cannot obtain or view any user file content. Users can delete local files and App cache data at any time through device settings.

5.2 Anonymous Device Data Management

Anonymous device operation data is stored in encrypted local cache. The data will be automatically and completely cleared when the user uninstalls the App or terminates the App process. No long-term server retention will be formed.

5.3 Security Protection Measures

The App adopts iOS official sandbox isolation mechanism and local encryption technology to protect user file data security. All processing behaviors are limited to the local device sandbox, effectively preventing data leakage, tampering and unauthorized access. We strictly abide by Apple’s local data security specifications to fully protect user data privacy.

6. User Legal Rights (GDPR / CCPA Compliance)

In accordance with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and other global privacy laws, you enjoy the following complete data rights:

- Right to Transparency: You have the right to know the scope and usage of anonymous device data processed by the App

- Right to Data Deletion: You can clear local App cache or uninstall the App at any time to erase all anonymous local data

- Right to Opt-Out: You can disable device data collection through iOS system privacy settings

- Right to Complaint: You have the right to submit complaints to local data protection authorities if you believe our data processing violates relevant laws

7. Apple ATT & Compliance Declaration

This App fully complies with Apple’s App Tracking Transparency (ATT) framework and 2025 latest App Store privacy review rules. The App does not implement cross-App or cross-device user tracking behaviors. Since no third-party advertising and AI data transmission services are integrated, there is no risk of unauthorized data sharing and user tracking.

This App is not oriented to minors. We do not collect any personal information of children under 13 years old, complying with global children’s privacy protection regulations.

8. Policy Updates

We reserve the right to update this Privacy Policy in a timely manner in response to product function iteration, system adaptation updates and legal rule adjustments. The updated policy will be published within the App with a revised effective date. Your continued use of the App after updates constitutes your acceptance of the latest policy terms.

9. Contact Us

If you have any questions, suggestions or rights protection requests regarding this Privacy Policy and our data processing behaviors, please contact us via official email:

Email:[email protected]