Cilue App Privacy Policy & EULA

This Privacy Policy (“Policy”) and End User License Agreement (“EULA”) apply to the Cilue mobile application (the “App”). This combined document governs your use of the App, your collection, use, and disclosure of personal data, and your submission of User-Generated Content (UGC) through the App.

By downloading, installing, registering for, or using the App in any manner, you affirm that you are 18 years of age or older (the “Eligible User”) and you unconditionally accept and agree to be bound by all terms of this Policy and EULA. If you are not 18 years of age or older, you are prohibited from using the App in any form, and we reserve the right to terminate your account and access immediately upon discovery of underage use.

This document complies with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) for users within the European Economic Area (EEA) and the United Kingdom, the Apple App Store Review Guidelines, and applicable data protection and consumer protection laws worldwide. We reserve the right to update this Policy and EULA at any time without prior notice; revised terms will be posted in the App and take effect immediately upon posting. Your continued use of the App after revisions constitutes your acceptance of the updated terms.

1. Definitions

For the purposes of this Policy and EULA, the following terms shall have the meanings set forth below:

• Personal Data: Any information relating to an identified or identifiable natural person (a “Data Subject”) as defined under GDPR, including but not limited to your name, email address, phone number, device information, and usage data.
• User-Generated Content (UGC): Any content, including but not limited to text, images, videos, audio, comments, reviews, and other materials that you submit, post, upload, publish, or share through the App’s public or semi-public features.
• Prohibited Content: Any UGC or use of the App that violates Section 4 of this document, including obscene, offensive, illegal, or discriminatory content and conduct.
• Service: All features, functions, content, and services provided through the Cilue App, including but not limited to UGC hosting and personalized content recommendations.

2. Acceptance of Terms

Your use of the App is conditional upon your full and unwavering acceptance of this Policy and EULA. We do not tolerate objectionable, offensive, or inappropriate content or improper use of the App by any user. If we determine, in our sole and absolute discretion, that you have violated any term of this document, we reserve the right to take any corrective action without prior notice, including but not limited to:

• Removing or disabling access to any UGC you have submitted;
• Suspending or terminating your App account and all associated access to the Service;
• Reporting your conduct to Apple, relevant law enforcement agencies, or third-party rights holders;
• Pursuing civil or criminal legal action against you for damages resulting from your violation.

You acknowledge and agree that our exercise of the above rights is necessary to protect the App, our users, our intellectual property, and compliance with applicable laws. We have no obligation to notify you of minor violations, and our failure to act on a violation does not constitute a waiver of our right to act on the same or similar violations in the future.

3. Privacy Policy (GDPR Compliant)

3.1 Collection of Personal Data

We collect Personal Data and non-personal data from you in the following ways, for the sole purposes of providing and improving the Service, complying with legal obligations, and facilitating UGC features. We do not collect more data than is necessary for these legitimate purposes (GDPR Article 5).

3.1.1 Voluntarily Submitted Data

You may choose to provide us with Personal Data when you:

• Register for an account (e.g., email address, phone number, display name);
• Submit UGC (e.g., display name associated with your content, profile picture);
• Contact our customer support (e.g., email address, account information);
• Participate in App-related surveys or promotions (e.g., name, contact information).

3.1.2 Automatically Collected Data

We automatically collect non-identifiable and identifiable data when you use the App, including via third-party analytics tools (e.g., Apple Analytics) that comply with GDPR:

• Device information (e.g., device model, iOS version, unique device identifier (UDID), IP address, time zone);
• Usage data (e.g., features you access, time spent on the App, UGC you view or interact with);
• Network information (e.g., Wi-Fi/cellular provider, connection type).

3.2 Use of Personal Data

We use your Personal Data only for the following lawful bases as defined under GDPR (Article 6) and applicable laws:

• Performance of a Contract: To provide the Service you requested (e.g., account access, UGC hosting);
• Legitimate Interests: To improve the App’s performance and user experience (e.g., analyzing usage data, optimizing features, responding to customer support inquiries);
• Your Consent: To send you marketing communications (e.g., App updates, new features, promotions) – you may withdraw your consent at any time by unsubscribing or contacting us at info@ciluone.com;
• Legal Obligations: To comply with applicable laws, court orders, or government requests (e.g., responding to law enforcement inquiries).

We will not use your Personal Data for any purpose other than those stated in this Policy, and we will not process your Personal Data in a manner that is incompatible with these purposes.

3.3 Disclosure of Personal Data

We do not sell, rent, lease, or otherwise disclose your Personal Data to third parties for commercial purposes without your explicit consent. We may disclose your Personal Data only in the following limited circumstances:

• To Apple: For App Store compliance and crash reporting (Apple’s use of your data is governed by Apple’s Privacy Policy);
• To Service Providers: To third-party vendors who perform services on our behalf (e.g., customer support, analytics) – these vendors are bound by contractual obligations to protect your Personal Data and may only use it to perform the services we request;
• For Legal Reasons: To comply with applicable laws, court orders, or government requests; to protect our rights, property, or safety; or to protect the rights, property, or safety of our users or third parties (e.g., reporting illegal UGC to law enforcement);
• With Your Consent: To any third party you explicitly authorize us to disclose your data to.

3.4 Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws. After the retention period, we will permanently delete or anonymize your Personal Data so that it can no longer identify you. For example:

• Account data is retained until you request account deletion (you may request deletion at any time by contacting info@ciluone.com);
• UGC and associated data is retained until you delete it or we remove it in accordance with Section 4, plus a reasonable period to comply with legal obligations.

3.5 GDPR Data Subject Rights

If you are a Data Subject within the EEA or the United Kingdom, you have the following rights under GDPR (Articles 15-21), which we will fulfill free of charge and in accordance with applicable time limits (typically 1 month):

1. Right to Access: Request a copy of the Personal Data we hold about you;
2. Right to Rectification: Request correction of inaccurate or incomplete Personal Data;
3. Right to Erasure (“Right to be Forgotten”): Request deletion of your Personal Data (subject to legal retention obligations);
4. Right to Restriction of Processing: Request that we restrict processing of your Personal Data in certain circumstances;
5. Right to Data Portability: Request a copy of your Personal Data in a structured, machine-readable format;
6. Right to Object: Object to processing of your Personal Data for legitimate interests or marketing purposes;
7. Right to Withdraw Consent: Withdraw any consent you have provided for the processing of your Personal Data (without affecting the lawfulness of processing based on consent before withdrawal).

To exercise any of these rights, please contact our Data Protection Officer (DPO) at info@ciluone.com with the subject line “GDPR Data Subject Request – [Your Full Name]”. We may request proof of identity to verify your request and ensure the security of your Personal Data. You also have the right to lodge a complaint with a supervisory authority in your country of residence if you are dissatisfied with our handling of your Personal Data.

3.6 Data Security

We implement appropriate technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction, in accordance with GDPR (Article 32) and applicable data protection laws. These measures include:

• Encryption of data in transit and at rest;
• Restricted access to Personal Data (only authorized personnel have access);
• Regular security audits and updates to our systems and App;
• Training of our staff on data protection and GDPR compliance.

However, no electronic transmission or storage system is 100% secure. You acknowledge and agree that we cannot guarantee absolute security of your Personal Data, and you assume all risk associated with the transmission of data to and from the App.

3.7 Children’s Privacy

The App is intended for use by Eligible Users (18 years of age or older) only. We do not knowingly collect Personal Data from children under the age of 18. If we discover that we have collected Personal Data from a child under 18, we will immediately delete the data and terminate the child’s account. If you believe that a child under 18 has provided us with Personal Data, please contact us at info@ciluone.com.

4. User-Generated Content (UGC) – Prohibited Content & Conduct

The App may allow you to submit, post, upload, publish, or share UGC through public or semi-public features (the “UGC Features”). You retain all intellectual property rights in your UGC (subject to applicable laws), but by submitting UGC through the App, you grant us a worldwide, non-exclusive, royalty-free, perpetual, irrevocable, and sublicensable license to use, reproduce, modify, adapt, publish, distribute, and display your UGC in connection with the Service, including for promotional and marketing purposes (you may withdraw this license by deleting your UGC or account).

4.1 Absolute Prohibition of Certain UGC

You may not submit, post, upload, publish, or share any UGC that contains, depicts, or promotes any of the following (the “Prohibited Content”). This list is non-exhaustive, and we reserve the right to determine, in our sole discretion, what constitutes Prohibited Content:

1. Obscene/Adult/Indecent Content: Pornography, sexually explicit material, nudity, sexual acts, or any content that is sexually suggestive, vulgar, or obscene; any content that depicts or promotes sexual violence or exploitation.
2. Offensive/Disgusting Content: Any content that is grossly offensive, disgusting, or likely to cause emotional distress, discomfort, or revulsion to reasonable users (e.g., depictions of graphic violence, gore, self-harm, animal cruelty, or other disturbing material).
3. Illegal Activities: Any content that depicts, promotes, or facilitates illegal activities, including but not limited to:
   • Gambling (including online gambling, sports betting, poker, or any form of wagering for real money or virtual currency);
   • Drug-related activity (including the sale, distribution, use, or promotion of illegal drugs, controlled substances, or drug paraphernalia);
   • Theft, fraud, hacking, or other cybercrimes;
   • Any other activity that violates local, state, national, or international law.
4. Political Content: Any content that involves political advocacy, political campaigning, support for political parties or candidates, political commentary that is inflammatory or divisive, or any content that seeks to influence political outcomes or public opinion on political matters.
5. Discrimination/Hate Speech: Any content that is discriminatory, hateful, or harassing based on race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, age, disability, or any other protected characteristic; any content that promotes or incites violence, hatred, or discrimination against any individual or group.
6. Infringing Content: Any content that violates the intellectual property rights of third parties (e.g., copyright, trademark, patent, or trade secret infringement); any content that uses third-party material without proper authorization.
7. Harassment/Threats: Any content that is harassing, threatening, intimidating, or abusive to any individual or group; any content that contains death threats, physical threats, or blackmail.
8. False/Misleading Content: Any content that is false, misleading, deceptive, or constitutes fake news; any content that spreads misinformation or disinformation about important topics (e.g., health, safety, current events).
9. Spam/Unsolicited Content: Any unsolicited commercial content, spam, phishing, or content that is intended to promote products or services without our authorization.
10. Violation of Others’ Privacy: Any content that discloses the Personal Data of third parties without their explicit consent (e.g., addresses, phone numbers, email addresses, social media accounts, or other private information).

4.2 UGC Monitoring & Removal

We reserve the right, but not the obligation, to monitor all UGC submitted through the App for compliance with this Section 4. We may remove, disable, or delete any UGC that we determine, in our sole discretion, to be Prohibited Content at any time without prior notice to you. We also reserve the right to limit or disable your access to the UGC Features if you submit Prohibited Content.

You acknowledge and agree that you are solely responsible for all UGC you submit, and you will indemnify and hold us harmless from any and all claims, damages, losses, liabilities, and expenses (including legal fees) arising from or related to your UGC, including any claim that your UGC violates this EULA, applicable laws, or the rights of third parties.

4.3 Reporting UGC

We encourage all users to report any Prohibited Content they encounter in the App by contacting us at info@ciluone.com with the subject line “UGC Report – Prohibited Content” and providing the following information:

• A description of the Prohibited Content;
• The location of the Content in the App (e.g., feature, post ID, user display name);
• Screenshots or other evidence of the Content (if available);
• Your contact information (if you wish to receive a response).

We will review all valid UGC reports in a timely manner and take appropriate action (e.g., removing the Content, terminating the offending user’s account) as necessary.

5. End User License Agreement (EULA) – Additional Terms

5.1 License Grant

We grant you a limited, non-exclusive, non-transferable, revocable license to download, install, and use the App on a single iOS device owned or controlled by you, in accordance with this EULA and Apple’s App Store Terms of Service. This license does not include the right to:

• Modify, adapt, translate, reverse engineer, decompile, disassemble, or create derivative works of the App;
• Rent, lease, lend, sell, trade, or distribute the App or any part of it;
• Use the App for any commercial purpose without our explicit written authorization;
• Use the App in a way that violates this EULA, applicable laws, or the rights of third parties;
• Circumvent any security or anti-piracy measures in the App.

5.2 Intellectual Property

All intellectual property rights in the App (including but not limited to copyrights, trademarks, patents, trade secrets, and design rights) are protected by international intellectual property laws. You may not use our trademarks, logos, or other brand assets without our explicit written authorization.

5.3 User Responsibilities

You are solely responsible for:

• All activities conducted through your App account;
• Maintaining the confidentiality of your Apple ID and any account credentials used to access the App;
• Notifying us immediately of any unauthorized use of your account or any other security breach (contact info@ciluone.com);
• Complying with all applicable laws, regulations, and this EULA in your use of the App;
• Ensuring that your use of the App does not infringe the rights of third parties.

We are not liable for any losses or damages arising from your failure to fulfill these responsibilities.

5.4 Disclaimer of Warranties

THE APP AND SERVICE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. WE HEREBY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:

• Implied warranties of MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT;
• Warranties that the App will be UNINTERRUPTED, ERROR-FREE, OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS;
• Warranties that the UGC posted in the App is ACCURATE, RELIABLE, OR APPROPRIATE;
• Warranties related to THIRD-PARTY SERVICES INTEGRATED INTO THE APP.

Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you. In such cases, the implied warranties are limited to the maximum extent permitted by law.

5.5 Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WE SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM OR RELATED TO YOUR USE OF THE APP OR SERVICE, INCLUDING BUT NOT LIMITED TO:

• LOSS OF DATA, PROFITS, OR REVENUE;
• DAMAGE TO YOUR DEVICE OR SOFTWARE;
• HARM ARISING FROM UGC (INCLUDING PROHIBITED CONTENT);
• INAPPROPRIATE OR UNAUTHORIZED USE OF THE APP BY THIRD PARTIES;
• SUSPENSION OR TERMINATION OF YOUR ACCOUNT.

Our total aggregate liability to you for any claim arising from or related to this EULA or the App shall not exceed the total amount you have paid to us in the 12 months prior to the claim. Some jurisdictions do not allow the limitation of liability for consequential or incidental damages, so the above limitation may not apply to you.

5.6 Indemnification

You agree to indemnify, defend, and hold us, our affiliates, directors, officers, employees, and agents harmless from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorney’s fees) arising from or related to:

• Your use or misuse of the App or Service;
• Your violation of this Policy or EULA;
• Your submission of Prohibited Content or any other UGC;
• Your violation of applicable laws or the rights of third parties;
• Any unauthorized use of your account by a third party (to the extent caused by your failure to maintain account security).

5.7 Termination

This EULA is effective until terminated by you or us. You may terminate this EULA at any time by deleting the App from your device and requesting account deletion (contact info@ciluone.com). We may terminate this EULA at any time without prior notice if you violate any term of this document (e.g., submitting Prohibited Content, underage use).

Upon termination of this EULA:

• Your license to use the App is immediately revoked;
• You must delete the App from all your devices;
• We may delete your account and all associated data (in accordance with our data retention policy);
• Sections 3 (Privacy Policy), 4 (UGC), 5.2 (Intellectual Property), 5.4 (Disclaimer of Warranties), 5.5 (Limitation of Liability), 5.6 (Indemnification), and 5.8 (Governing Law) shall survive termination.

5.8 Governing Law

This Policy and EULA shall be governed by and construed in accordance with the laws of the State of California, United States (without regard to its conflict of law principles) for users in the United States, and the laws of Ireland for users in the EEA and United Kingdom (to comply with GDPR). For all other users, this Policy and EULA shall be governed by the laws of the jurisdiction in which you reside.

Any dispute arising from or related to this Policy or EULA shall be resolved in the courts of the applicable governing jurisdiction, and you consent to the exclusive jurisdiction of such courts.

6. General Provisions

6.1 Entire Agreement

This Policy and EULA constitutes the entire agreement between you and us with respect to your use of the App and Service, and supersedes all prior or contemporaneous oral or written agreements, understandings, and representations.

6.2 Severability

If any provision of this Policy or EULA is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect. The invalid, illegal, or unenforceable provision shall be replaced with a valid, legal, and enforceable provision that most nearly reflects the original intent of the parties.

6.3 Waiver

Our failure to enforce any provision of this Policy or EULA shall not constitute a waiver of such provision or our right to enforce it in the future.

6.4 Contact Us

We are dedicated to protecting your privacy and providing a safe, compliant, and enjoyable experience for all Eligible Users of the Cilue App. Your adherence to this Policy and EULA is essential to maintaining the integrity of the App and the safety of our user community. Thank you for your cooperation and support!