PRIVACY POLICY Effective Date: September 13, 2026 Company: IE KULITSKI, registered in Georgia Application: Spirit Masters ("the App") Contact: meplaydev@gmail.com 1. INTRODUCTION This Privacy Policy explains how IE KULITSKI ("we", "us", or "our") collects, uses, stores, and discloses information when you use the Spirit Masters mobile application. Spirit Masters provides meditation, spiritual practices, self-reflection, AI-assisted guidance, and related features. This Privacy Policy is intended to provide clear information about our data practices and applies to the Spirit Masters application and related services. Where applicable law requires your consent for a particular processing activity, we will request that consent separately. Where processing is permitted on another legal basis, such as providing the service you requested, we may process the relevant information on that basis. 2. INFORMATION WE COLLECT Depending on how you use Spirit Masters, we may collect the following categories of information. 2.1 Account and Authentication Information We may collect or receive: - Email address - Display name - Authentication-related information provided through third-party authentication services, including Firebase Authentication We do not store your account password when authentication is handled by a third-party authentication provider. 2.2 User-Generated Content When you use features that allow you to communicate with Spirit Masters or interact with its practices, we may process information you choose to provide, including: - Messages and prompts submitted to AI features - Reflections and other text you enter - Information contained in spiritual practice interactions - Other content you voluntarily submit through the App 2.3 Audio Data If you use features that require audio recording, the App may request access to your device microphone. Audio recordings are collected only when you grant the applicable permission and use a feature that requires audio. Where cloud storage is enabled or included in the applicable service, recordings may be uploaded and stored so that the corresponding feature can operate. You may withdraw microphone permission through your device settings. Withdrawing permission may prevent features that require audio from functioning. 2.4 Usage, Device, and Technical Information We may process information needed to operate, maintain, secure, and improve the App, including: - App activity and usage information - Device model - Operating system and version - App version - Technical and diagnostic information - Crash and error information - Other technical information generated during use of the App 2.5 Subscription Information We may receive and process information relating to your subscription, such as: - Subscription status - Subscription plan - Entitlement or premium-feature status - Information necessary to verify access to purchased features Payments for subscriptions made through Apple App Store or Google Play are processed by the applicable app store. We do not store your Apple App Store or Google Play payment card details directly. 3. HOW WE USE INFORMATION We may use the information described above to: - Provide and operate Spirit Masters - Provide AI-assisted spiritual guidance and chat features - Generate responses to prompts and other content submitted to AI features - Provide personalized spiritual practices and reflections - Authenticate users and manage accounts - Provide subscription-based and premium features - Store user content when cloud storage is enabled - Maintain, troubleshoot, secure, and improve the App - Detect and investigate technical problems, abuse, fraud, or security incidents - Provide customer support - Communicate with users about the App, service updates, or important changes - Comply with applicable legal obligations 4. AI PROCESSING AND THIRD-PARTY AI PROVIDERS Some Spirit Masters features use third-party artificial intelligence services. When you use an AI feature, the text, prompts, or other information necessary to generate the requested response may be transmitted to and processed by our AI service providers. The AI providers currently used by Spirit Masters are: - OpenAI - Qwen The information sent to an AI provider depends on the feature you use and the content you submit. We do not send information to an AI provider merely because you have installed the App. AI-related processing occurs when you use a feature that requires AI processing. Third-party AI providers process data according to their applicable terms, policies, and technical configuration. We use these services to provide the AI functionality of Spirit Masters. We do not authorize AI providers to use your information for purposes that are not permitted by applicable agreements or law. Where applicable law requires consent before transmitting personal data to a third-party AI provider, we will obtain the required consent. 5. DATA SHARING We do not sell your personal data. We may disclose or provide access to personal data to service providers and technology partners that help us operate Spirit Masters, including providers used for: - Authentication - AI processing - Cloud storage - App infrastructure - Technical diagnostics and service operation - Subscription and entitlement verification Such providers receive only the information reasonably necessary for the relevant service, subject to applicable contractual, technical, and legal requirements. We may also disclose information: - When required by applicable law - In response to valid legal process or a lawful request from a governmental authority - To protect the rights, safety, security, or property of users, the Company, or others - To investigate fraud, abuse, or security incidents - Where disclosure is otherwise permitted or required by law 6. LEGAL BASES FOR PROCESSING IN THE EEA AND UK If the GDPR or UK GDPR applies to our processing of your personal data, the legal basis for processing may include: - Performance of a contract: where processing is necessary to provide Spirit Masters, operate your account, or provide features you request - Consent: where we ask for your consent, including where consent is required for a particular type of data or processing - Legitimate interests: where processing is necessary for legitimate interests such as maintaining, securing, troubleshooting, and improving the service, provided that those interests are not overridden by your rights and interests - Legal obligations: where processing is necessary to comply with applicable law Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. 7. DATA RETENTION We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the service, maintain accounts, comply with legal obligations, resolve disputes, enforce agreements, and protect the security of the App. In general: - Account information may be retained while your account remains active. - User-generated content may be retained for as long as necessary to provide the related features or according to the applicable storage functionality. - AI inputs and related processing data may be retained for the period necessary to provide the requested AI functionality and for limited operational purposes. - Audio recordings are stored only when the relevant feature and storage functionality are used and are subject to applicable deletion requests and storage terms. - Subscription and transaction-related records may be retained where necessary for accounting, legal, fraud-prevention, or dispute-resolution purposes. - Technical and diagnostic information may be retained for as long as reasonably necessary for security, troubleshooting, and service improvement. When you request deletion of your account or data, we will delete or anonymize personal data that we are required and able to delete, subject to information that must be retained by law or is otherwise necessary for legitimate legal or security purposes. Some information may remain in backups for a limited period before it is overwritten or securely deleted. 8. YOUR PRIVACY RIGHTS Depending on your location and applicable law, you may have rights regarding your personal data, including: - The right to know what personal data we process about you - The right to access your personal data - The right to correct inaccurate or incomplete information - The right to request deletion of your personal data - The right to restrict certain processing - The right to object to certain processing - The right to data portability, where applicable - The right to withdraw consent where processing is based on consent - The right to lodge a complaint with a competent data protection authority These rights are subject to applicable legal exceptions and limitations. You can exercise certain deletion rights directly through the data/account deletion functionality available in the Settings section of the App. You may also contact us at: meplaydev@gmail.com We may need to verify your identity before completing a request in order to protect your account and personal information. For requests made under the GDPR or UK GDPR, we generally respond without undue delay and, where applicable, within the period required by law. 9. CALIFORNIA AND OTHER U.S. STATE PRIVACY RIGHTS If you are a resident of a U.S. state that provides specific privacy rights, you may have additional rights under applicable state privacy laws. Depending on the applicable law, these rights may include the right to: - Know or access categories and specific pieces of personal information - Correct inaccurate personal information - Delete personal information, subject to legal exceptions - Obtain information about how personal information is collected and used - Opt out of certain types of processing where applicable - Receive equal treatment when exercising applicable privacy rights We do not sell personal data. If a U.S. state privacy law provides you with rights that are not specifically described in this Privacy Policy, we will handle applicable requests in accordance with that law. 10. INTERNATIONAL DATA PROCESSING Spirit Masters is operated by IE KULITSKI, registered in Georgia. Your information may be processed or stored in Georgia, Belarus, the United States, the European Economic Area, or other countries where we or our service providers operate. Some of our service providers, including AI service providers, may process information outside your country of residence. Where applicable law requires specific safeguards for international transfers of personal data, we will use legally recognized transfer mechanisms and appropriate safeguards. 11. DATA SECURITY We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include access controls, secure communications, authentication mechanisms, and other security measures appropriate to the nature of the information and the risks involved. However, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security. 12. CHILDREN'S PRIVACY Spirit Masters is not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will take reasonable steps to delete that information. If applicable law establishes a higher minimum age for certain processing, the requirements of that law will apply. 13. MICROPHONE AND DEVICE PERMISSIONS Spirit Masters may request access to device features such as the microphone when a specific feature requires that access. Permissions are controlled through your device operating system. You may generally change or revoke permissions through your device settings. If you revoke a permission, some related features may no longer function. 14. ACCOUNT AND DATA DELETION Spirit Masters provides an in-app functionality for deleting your account and/or associated personal data through the Settings section of the App. When you initiate deletion through the App, we will process the request and delete or anonymize personal data that we are required and able to delete, subject to applicable legal, security, fraud-prevention, accounting, dispute-resolution, and other lawful retention requirements. Some information may remain in backups for a limited period before it is overwritten or securely deleted. If you are unable to use the in-app deletion functionality, you may request deletion by contacting: meplaydev@gmail.com Please include the email address associated with your account and clearly state that you want your account and/or associated personal data deleted. Deleting your account does not automatically cancel a subscription purchased through Apple App Store or Google Play. To cancel a subscription, use the subscription-management functionality provided by the applicable app store. 15. SUBSCRIPTIONS AND PAYMENTS Subscriptions purchased through Apple App Store or Google Play are subject to the payment and subscription systems of the applicable platform. We do not directly process or store your Apple or Google payment card information. Subscription status and entitlement information may be provided to us by the applicable platform so that Spirit Masters can determine whether you are entitled to premium features. Cancellation and refund procedures are governed by the applicable app store's rules and procedures. 16. SERVICE TERMINATION If Spirit Masters is permanently discontinued, we may provide users with notice where required by applicable law or contractual obligations. After termination, personal data will be deleted or anonymized in accordance with this Privacy Policy and applicable law, except where retention is legally required or otherwise permitted. 17. LEGAL REQUESTS AND COMPLIANCE We may disclose personal data when we reasonably believe disclosure is required or permitted by applicable law. This may include lawful requests from courts, law enforcement agencies, regulators, or other governmental authorities. Where legally permitted, we will seek to limit disclosures to the information reasonably necessary for the applicable purpose. 18. CHANGES TO THIS PRIVACY POLICY We may update this Privacy Policy from time to time. If we make material changes, we may provide additional notice where required by applicable law, including through the App or other appropriate means. The updated Privacy Policy will include a revised Effective Date. Your continued use of the App after an updated Privacy Policy becomes effective does not replace any consent that applicable law requires us to obtain separately. 19. DATA CONTROLLER AND CONTACT INFORMATION Data Controller: IE KULITSKI Georgia Privacy contact: meplaydev@gmail.com 20. IMPORTANT INFORMATION ABOUT THIRD-PARTY SERVICES Spirit Masters relies on third-party services to provide certain functionality. Third-party services may process information on our behalf or independently according to their own terms and privacy policies. The principal third-party services relevant to personal data processing currently include: - Firebase Authentication - OpenAI - Qwen - Apple App Store - Google Play The exact data processed by each service depends on the Spirit Masters feature being used and the technical configuration of the service. We may update our service providers from time to time. When this affects the information described in this Privacy Policy, we will update the Policy as required by applicable law. 21. NO SALE OF PERSONAL DATA We do not sell your personal data. We do not provide personal data to third parties in exchange for monetary consideration. Any disclosure or processing described in this Privacy Policy is performed for the purposes of operating, providing, securing, supporting, or improving Spirit Masters, complying with law, or otherwise as permitted by applicable law. 22. CONTACT US If you have questions about this Privacy Policy, want to exercise a privacy right, or want to request deletion of your data, contact: IE KULITSKI Email: meplaydev@gmail.com End of Privacy Policy.