Privacy Policy

Last updated: October 6, 2026

This Privacy Policy (“Privacy Policy”) explains how SREDA IZRABOTKA EOOD (“Company”, “we”, “us”, or “our”) collects, uses, processes, stores, and otherwise handles information in connection with the Imagionica mobile application (“Imagionica” or the “App”).

We aim to collect and process only the information reasonably necessary to operate, analyze, secure, support, and improve the App.

1. Data Controller and Contact Information

The data controller responsible for the processing described in this Privacy Policy is:

SREDA IZRABOTKA EOOD

g.k. Slaveykov bl. 35, Entrance 5, apt. 15

Burgas 8010, Bulgaria

Privacy and support contact: support@sredadev.com

2. Information We Process

The categories of information processed depend on how you use the App and the features available on your device.

2.1. Photos and User Content

Imagionica allows you to work with photos, images, text, designs, projects, and other materials (“User Content”).

Photos and images selected for editing, including photos and images processed through AI-powered editing features available in Imagionica, are processed locally on your device and are not transmitted to the Company’s servers or to third-party AI services for such processing.

The Company does not access such photos during the ordinary use of the App and does not acquire ownership of your User Content.

If you voluntarily send an image, screenshot, file, or other material to our support team, we may process that material only to the extent reasonably necessary to review and respond to your support request.

2.2. Subscription and Purchase Information

Imagionica provides free and paid functionality and may offer auto-renewable subscriptions, free trials, introductory offers, or other promotional subscription offers.

In order to verify subscription status and provide access to PRO features, information relating to your purchase or subscription may be processed, including:

• whether an active subscription exists;

• subscription type or product;

• free-trial or promotional-offer status;

• renewal or expiration status;

• confirmation that a purchase has been completed.

Payments are processed by Apple App Store or Google Play.

The Company does not receive or store your full payment card details or other full payment credentials.

2.3. Product Analytics and Amplitude

We use Amplitude as a product analytics service to understand how users interact with Imagionica and to improve the App.

Depending on the operating system, SDK version, device configuration, and Amplitude configuration, analytics information may include:

• App launches and session information;

• screens viewed;

• taps and other interactions with the interface;

• features and editing tools used;

• interactions with the paywall and subscriptions;

• other events describing interaction with the App;

• a technical device or installation identifier, such as a Device ID;

• IP address;

• approximate location, such as country, region, or city, which may be inferred from an IP address rather than obtained from precise GPS coordinates;

• device model;

• device manufacturer, where applicable;

• operating system name and version;

• platform;

• App version;

• device language;

• mobile carrier information, where available;

• other technical device properties made available by the applicable analytics SDK.

Imagionica does not request precise GPS location for the purpose of Amplitude product analytics.

Amplitude analytics data is used for purposes such as:

• understanding user flows;

• measuring use of features;

• analyzing paywall and subscription interactions;

• identifying usability or product issues;

• evaluating product performance;

• improving existing functionality;

• developing new functionality.

Amplitude is used for product analytics and is not used by Imagionica to display third-party advertising within the App.

2.4. Diagnostic and Technical Information

We may process technical or diagnostic information necessary to maintain the reliability, security, and performance of the App, including:

• crash information;

• error reports;

• performance information;

• operating system and App version;

• technical logs or diagnostic information necessary to investigate technical issues.

Such information is used to maintain the App, diagnose problems, improve performance, and correct errors.

2.5. Customer Support Information

If you contact us for support, we may process information that you voluntarily provide, including:

• your contact information;

• the content of your request;

• screenshots;

• files;

• technical information reasonably necessary to investigate your request.

Please do not send confidential or sensitive information that is not necessary for resolving your support request.

3. How We Use Information

We may process information for the following purposes:

• to provide and operate Imagionica;

• to provide and verify access to PRO functionality;

• to restore eligible purchases;

• to analyze the use of the App;

• to perform product analytics through Amplitude;

• to understand and improve the user experience;

• to develop and improve features;

• to diagnose and correct errors;

• to maintain App stability and security;

• to provide customer support;

• to prevent fraud, abuse, and misuse;

• to comply with applicable legal obligations.

User Content that is processed locally on the device is not used by the Company to train AI models.

4. Advertising, Tracking, and Sale of Personal Data

Imagionica does not display third-party advertising within the App.

Amplitude is used for product analytics. Product analytics alone does not necessarily constitute tracking under Apple’s App Tracking Transparency framework.

As of the date of this Privacy Policy, the Company does not use information collected through Imagionica to track a user’s activity across apps or websites owned by other companies for targeted advertising or advertising measurement purposes.

We do not sell Personal Data for monetary consideration.

If our practices change in the future and Imagionica begins using data for advertising attribution or tracking that requires additional disclosure or consent, we will update this Privacy Policy and the applicable privacy disclosures in the relevant app stores before such processing begins.

Where Apple’s App Tracking Transparency (“ATT”) framework applies, the required system permission will be requested before tracking subject to ATT occurs.

5. Legal Bases for Processing

Where applicable law requires a legal basis for processing Personal Data, we may rely on the following:

• Performance of a contract — where processing is necessary to provide Imagionica, verify a subscription, restore eligible purchases, or provide requested support;

• Legitimate interests — where processing is reasonably necessary for product analytics, security, diagnostics, fraud prevention, maintenance, and improvement of the App, provided those interests are not overridden by your rights and freedoms;

• Consent — where applicable law requires your consent;

• Compliance with legal obligations — where processing is necessary to comply with applicable laws or lawful requests.

6. Third-Party Service Providers

We use or may use third-party technology providers to operate Imagionica, including:

• Apple App Store;

• Google Play;

• Amplitude for product analytics;

• services used to manage subscriptions or verify purchases;

• crash-reporting and diagnostic services;

• hosting and other technical infrastructure providers.

These providers may process information only to the extent necessary to provide the relevant service, subject to their applicable contractual and legal obligations.

Apple and Google independently process information relating to your store account, payments, and purchases under their own terms and privacy policies.

Where required by applicable law, we take reasonable steps designed to ensure that service providers processing Personal Data on our behalf use the information only for agreed purposes and implement appropriate safeguards for that information.

7. International Data Transfers

Some service providers may process information in countries other than the country in which you reside.

Where applicable law requires safeguards for international transfers of Personal Data, we rely on appropriate contractual, organizational, or other legally recognized transfer mechanisms.

8. Data Retention and Deletion

We retain information only for as long as reasonably necessary for the purposes for which it was collected, taking into account applicable legal requirements, security needs, and the retention settings of relevant service providers.

Retention periods may differ depending on the category of information.

Photos and images used for ordinary editing and locally processed AI-powered features remain on the user’s device and are not stored by the Company on its servers for such processing.

Product analytics and diagnostic information may be retained for the period reasonably necessary to analyze, maintain, secure, and improve the App, subject to the configuration and retention policies of the relevant service provider.

Information provided in connection with customer support may be retained for as long as reasonably necessary to resolve the request, handle related issues, establish or defend legal claims, and comply with legal obligations.

You may request deletion of Personal Data relating to you by contacting: support@sredadev.com

We will process valid deletion requests in accordance with applicable law. Certain information may be retained where necessary to comply with legal, accounting, security, fraud-prevention, dispute-resolution, or other legitimate obligations.

9. Security

We use reasonable technical and organizational measures designed to protect information against unauthorized access, misuse, alteration, loss, or disclosure.

Where information is processed by third-party service providers, appropriate safeguards are applied in accordance with applicable legal and contractual requirements.

However, no electronic transmission or storage method can be guaranteed to be completely secure.

10. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• request information about how your Personal Data is processed;

• request access to your Personal Data;

• request correction of inaccurate Personal Data;

• request deletion of Personal Data;

• request restriction of certain processing;

• object to certain processing;

• withdraw consent where processing is based on consent;

• request data portability where applicable;

• lodge a complaint with a competent data protection authority.

To exercise applicable privacy rights, including requesting deletion, contact: support@sredadev.com

We may request reasonable information necessary to verify the identity or authority of the person making the request.

11. European Economic Area

If you are located in the European Economic Area, you may lodge a complaint with the competent data protection supervisory authority in your country.

The supervisory authority for the Company in Bulgaria is the Commission for Personal Data Protection (CPDP).

Nothing in this Privacy Policy limits any mandatory rights available under applicable data protection law.

12. Children’s Privacy

Imagionica is not specifically directed to children.

Where applicable law requires the consent of a parent or legal guardian for a minor to use the App or for Personal Data to be processed, the App should only be used with such consent.

We do not knowingly process children’s Personal Data in violation of applicable law.

If you are a parent or legal guardian and believe that a minor’s Personal Data has been processed in violation of applicable law, please contact: support@sredadev.com

13. Device Permissions

Imagionica may request access to photos, media, or other device functionality where necessary for a feature selected by the user.

Permissions are requested only where required for the relevant functionality.

You can manage permissions through your device settings.

If you deny or revoke a permission, the corresponding App functionality may be unavailable or limited.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to Imagionica functionality;

• changes to technology providers or SDKs;

• changes to our data-processing practices;

• changes to applicable laws or app-store requirements.

The current version will be made publicly available on the Imagionica website.

The “Last updated” date at the top of this Privacy Policy identifies the date of the latest revision.

Where required by applicable law, we will provide additional notice or obtain consent before material changes take effect.

15. Contact Us

SREDA IZRABOTKA EOOD

g.k. Slaveykov bl. 35, Entrance 5, apt. 15

Burgas 8010, Bulgaria

Privacy and support contact: support@sredadev.com