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Privacy Policy

Last updated: 21.07.2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Application refers to PayRoulette, the software program provided by the Company.
• Advertising Identifier (IDFA) means the Identifier for Advertisers, a resettable device identifier provided by the operating system for advertising purposes.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to InnoQA LLC.
• Country refers to: Qatar
• Device means any device that can access the Service, such as a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company, such as the third-party companies used to facilitate the Service, to provide the Service on behalf of the Company, or to display advertising.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• You means the individual accessing or using the Service.

Collecting and Using Your Personal Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), Your Device type, Your mobile operating system, unique device identifiers, and other diagnostic data.

Information Collected for Advertising

The Service displays advertising provided by Google AdMob. To do so, advertising-related information may be collected, including Your Device ID and Advertising Identifier (IDFA), along with advertising and usage data.

This data may be used to serve personalized advertising only where You have provided the required consent (see "Consent Management" below) and, on iOS, only after You have granted tracking permission through App Tracking Transparency (see below). Where permission is not granted, only non-personalized advertising is served.

Google's handling of this data is governed by Google's own privacy policy: https://policies.google.com/privacy. You can learn how Google uses information from apps that use its services at https://policies.google.com/technologies/partner-sites.

Purchases

The Application offers an optional in-app purchase ("Premium"). Purchases are processed by Apple through the App Store; We do not receive or store Your payment details. We receive purchase status information (whether Premium is active) in order to unlock and restore the corresponding features. This purchase information is used solely for app functionality and is not used to track You. Apple's handling of purchase data is governed by Apple's privacy policy: https://www.apple.com/legal/privacy/.

Tracking Technologies

The Service uses mobile device identifiers (such as the Advertising Identifier) rather than browser cookies. These identifiers are used to deliver and measure advertising as described above, subject to Your consent and tracking permission. You can reset or limit Your Advertising Identifier at any time in Your device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To display advertising within the Application, in accordance with Your consent and tracking preferences.
• For the performance of a contract: to provide and restore any in-app purchase (Premium) You have made.
• To manage Your requests: to attend to and manage requests You make to Us.
• For legal compliance: to comply with applicable legal obligations, resolve disputes, and enforce our agreements.

App Tracking Transparency (iOS)

On iOS, before any data is used to track You across apps and websites owned by other companies, the Application requests Your permission through Apple's App Tracking Transparency framework. If You do not grant permission, the Application does not track You and serves only non-personalized advertising.

You can change Your choice at any time in Settings → Privacy & Security → Tracking on Your device.

Consent Management (EEA, UK & Switzerland)

If You are located in the European Economic Area, the United Kingdom, or Switzerland, the Application presents a consent form (provided by Google's User Messaging Platform) on first launch, in accordance with the EU General Data Protection Regulation (GDPR) and related regulations. You may consent to, or decline, the use of Your data for personalized advertising.

You can review or change Your consent choices at any time within the Application under Settings → Privacy Settings.

Legal bases (GDPR Art. 6): where We rely on Your consent (personalized advertising), the legal basis is Art. 6(1)(a). Where We process data to provide the Service and fulfil in-app purchases, the legal basis is the performance of a contract (Art. 6(1)(b)) and our legitimate interests in operating and securing the Service (Art. 6(1)(f)).

Sharing Your Personal Data

We may share information with the following Service Providers, who act as independent controllers or processors of the data they receive:

• Google (AdMob) — for serving and measuring advertising. See Google's Privacy Policy.
• Apple — for processing in-app purchases. See Apple's Privacy Policy.

We may also disclose Your Personal Data in connection with a business transfer, or where required to comply with the law.

Retention of Your Personal Data

We do not maintain our own servers or databases of Your Personal Data. Any advertising or purchase data described above is retained by the respective Service Provider (Google, Apple) in accordance with their own privacy policies and retention periods. We retain information only for as long as necessary for the purposes set out in this Privacy Policy and to comply with our legal obligations.

Transfer of Your Personal Data

Your information may be processed at locations outside of Your state, province, country, or other governmental jurisdiction where data protection laws may differ. In particular, our Service Providers (Google and Apple) may process data outside the European Economic Area. Such transfers are carried out under the safeguards provided by those providers. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Law enforcement and other legal requirements

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities. The Company may also disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing, protect the personal safety of users, or protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your Rights Under the GDPR

If You are located in the EEA, the UK, or Switzerland, You have the following rights regarding Your Personal Data:

• Access — request a copy of the Personal Data We hold about You.
• Rectification — request correction of inaccurate data.
• Erasure — request deletion of Your data.
• Restriction — request that We restrict processing of Your data.
• Objection — object to the processing of Your data.
• Data portability — request transfer of Your data.
• Withdraw consent — withdraw any consent You previously gave, at any time (e.g. via Settings → Privacy Settings in the Application), without affecting the lawfulness of prior processing.
• Lodge a complaint — with a data protection supervisory authority ([SUPERVISORY_AUTHORITY]).

To exercise any of these rights, please contact Us using the details below.

Children's Privacy

Our Service does not address anyone under the age of 16, and We do not knowingly collect personally identifiable information from children. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from a child without verification of parental consent, We take steps to remove that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, or wish to exercise Your data protection rights, You can contact Us:

• InnoQA LLC
• Office No. 8, Floor No. 1, QFC Tower 1, Doha, Qatar
• Email: info@innoqa.com