Effective Date: November 16, 2025
Controller: ZEMO Digital, LLC (Texas, USA) (“ZEMO,” “we,” “us,” or “our”)
App: Lookdrop (iOS – Apple App Store)

Child‑Directed App. Lookdrop is suitable for children ages 4+. We designed our data practices to avoid collecting children’s personal information beyond what is strictly necessary to provide the app.

Plain‑Language Summary

• No ZEMO account. Lookdrop does not create or require a ZEMO account. The app may rely on your device’s Apple ID/iCloud only to access Apple services (e.g., CloudKit). We do not receive your Apple ID.

• On‑device image processing. Camera access and LUT application happen locally on your device. We do not upload your photos or videos to ZEMO.

• CloudKit for content delivery. We use Apple CloudKit solely to deliver effect/LUT catalog items to your device; we do not store your personal data in our CloudKit containers.

• No advertising; no sale/sharing. We do not sell personal information or share it for cross‑context behavioral advertising.

• Diagnostics & (optional) analytics. We may receive crash/performance data from Apple. If analytics are enabled, they are for internal operations/service improvement only—not for ads or cross‑app tracking.

• In‑app purchases. Processed by Apple; we do not receive your payment card numbers.

• Your privacy choices. Email legal@zemodigital.com or use Settings → Feedback → Submit Request in the app to exercise privacy rights.

Scope

This Policy applies to the Lookdrop iOS app and our support channels. It does not apply to third‑party websites or services you access via the app (e.g., destinations in the iOS Share Sheet).

Information We Process

1) On‑Device Processing

• Camera/Microphone/Photos: Accessed only to preview/capture and apply LUTs. Processing occurs on‑device; ZEMO does not receive your media.

• User Content: Photos/videos you create or edit remain on your device or where you choose to export/share.

2) CloudKit (Content Delivery Only)

• We use Apple CloudKit to fetch public effect/LUT assets and metadata to your device. We do not create private CloudKit user records about you. Apple may process device/iCloud information to authenticate and deliver the service; ZEMO does not receive your Apple ID credentials.

3) In‑App Purchases (IAP)

• Purchases (e.g., LUT packs/subscriptions) are processed by Apple. We receive purchase confirmations/receipts necessary to unlock features but not full payment details.

4) Diagnostics and Reliability

• Crash/performance data (e.g., OS/app version, device type, error codes) may be provided by Apple or our processors to maintain and improve the app.

5) Support Communications

• If you contact us (email or in‑app feedback), we will receive the information you provide (email address, description, attachments).

6) Analytics (If Enabled)

• If enabled, analytics are used only for internal operations (e.g., counting installs, feature usage, stability). We do not use analytics to build advertising profiles, track across other apps, or target children with ads.

We do not knowingly collect precise geolocation, contact lists, or health/biometric data.

How We Use Information

• Operate Lookdrop (e.g., deliver effect catalog via CloudKit, unlock IAP).

• Maintain safety, performance, and reliability (diagnostics/updates).

• Provide support and respond to requests.

• Improve features and design (limited analytics, if enabled).

Disclosures of Information

We do not sell personal information. We may disclose limited information to:

• Service Providers/Processors (e.g., Apple services like CloudKit; crash reporting/analytics if enabled) under contracts restricting use to our instructions.

• Legal/Compliance when required to comply with law or protect rights and safety.

Data Retention

• User Content: Stays on your device; we do not retain it.

• Diagnostics/Analytics: Kept only as long as needed for the stated purposes (typically ≤ 24 months).

• Support Records: Typically ≤ 36 months.
  We may retain information longer where required by law or to establish/defend legal claims.

Security

We use reasonable administrative, technical, and physical safeguards appropriate to the limited personal data we handle. No system is 100% secure.

Children’s Privacy (U.S., EU, UK)

• COPPA (U.S.). Lookdrop is child‑directed and does not require children to provide personal information to use core features. Any analytics are for internal operations only. If we later wish to collect personal information from children under 13 (e.g., contact info), we will first obtain verifiable parental consent and provide additional notices.

• EU/UK (GDPR/UK GDPR). Where we process children’s personal data, we obtain parental consent when required by law (age threshold varies—typically 13 in the UK; 13–16 in the EU). We do not use children’s data for behavioral advertising.

International Users; Legal Bases (EU/UK)

• Controller: ZEMO Digital, LLC (address below).

• Purposes & Legal Bases:

  • App operation (CloudKit content delivery; IAP unlocking) — Contract necessity.

  • Diagnostics/analytics for service improvement — Legitimate interests (and consent where required).

  • Support communications — Legitimate interests or Contract necessity.

• EU/UK Rights: Access, correction, deletion, portability, restriction, objection, and withdrawal of consent. Submit via legal@zemodigital.com or Settings → Feedback → Submit Request.

• Representative: If required by law, we will appoint an EU/UK Article 27 representative and update this Policy with contact details.

• International Transfers: Where providers transfer data outside your region, we rely on appropriate safeguards (e.g., Standard Contractual Clauses) as applicable.

State Privacy Rights (U.S.)

Residents of certain U.S. states (including Texas and California) may have rights to access, correct, delete, and opt out of certain processing. We do not sell personal information or share it for cross‑context behavioral advertising. Submit requests via legal@zemodigital.com or Settings → Feedback → Submit Request. Appeals of denied requests may be submitted by replying to our decision email; we will explain the appeal outcome in writing.

Your Choices

• Device settings for camera/photos/microphone.

• OS settings for analytics/diagnostics.

• In‑app feedback form to submit privacy requests.

• You may uninstall the app at any time.

Changes to This Policy

We may update this Policy; see the Effective Date above. Material changes will be announced in‑app or by other reasonable means.

Contact Us

ZEMO Digital, LLC
Email: legal@zemodigital.com

Informational References

Texas Data Privacy and Security Act; CCPA/CPRA; COPPA Rule; GDPR/UK GDPR; Apple App Store Review Guidelines; Apple Standard EULA; Apple CloudKit documentation.