Privacy Policy

1. Controller and Scope

In this Policy, “Lyntra,” “we,” “us,” and “our” mean Lyntra Technology Ltd, the provider of Ringtones. Where we determine the purposes and means of processing, we act as the personal information processor or data controller.

This Policy applies to the Ringtones app, its Broadcast Upload Extension, the temporary upload page served by the app on the same Wi-Fi network, and these legal webpages. It does not apply to processing independently performed by Apple, TikTok, Douyin, your email provider, or another third party after you choose to open or share content with that service.

This Policy is provided in English only. Mandatory privacy rights under the law applicable to you remain unaffected.

2. Privacy at a Glance

• No registration: the current version does not require a Ringtones account.
• On-device processing: media, editing instructions, and library data remain primarily in the app container. The Broadcast Upload Extension saves only audio played by another app and does not save the screen image or microphone audio.
• Permissions on demand: Photos, the media library, microphone, and local-network permissions are requested only when you use the corresponding feature.
• Apple payments: Apple processes payment credentials. We receive only the StoreKit information needed to verify a purchase and entitlement status.
• Basic analytics: we integrate Umeng mobile analytics, but not Umeng advertising, push, social-sharing, or performance-monitoring components. We do not upload your audio or video content to Umeng.
• Your controls: you can delete items from the app library, revoke system permissions, cancel a subscription, and contact us to exercise applicable privacy rights.

3. Information We Process and Why

We do not require your real name, telephone number, contacts, precise location, health information, or government identification. The app does not display third-party advertising, create account profiles or credit scores, or make decisions with significant effects based solely on automated processing.

4. How Media Is Processed on Your Device

After import, the app uses Apple system frameworks such as AVFoundation to read media properties, generate previews, trim, combine, change speed or pitch, and convert formats on your device. When you save a project, a copy of the source media, editing instructions, and the export are stored in the local app library so that you can continue editing from the original media later.

The Broadcast Upload Extension receives sample buffers separated by ReplayKit and accepts only the audioApp type—the audio played by another app. The code ignores screen-image and microphone samples. Completed audio is first stored in the App Group on the same device and is imported into Ringtones only when you choose it.

We do not operate a Ringtones cloud server that receives media content, and we do not send that content to Umeng. If you use iCloud Photos and a selected video is not yet on the device, Apple may download it from iCloud. Apple controls that process.

5. System Permissions and Features

You can review, restrict, or revoke permissions at any time in iOS Settings under Privacy & Security or on the Ringtones system-settings page. Revocation does not affect processing already completed under valid authorization, but the related feature may stop working.

6. Umeng Mobile Analytics SDK

The app integrates the Umeng mobile analytics SDK, provided by Umeng Tongxin (Beijing) Technology Co., Ltd., to measure launches, active use, distribution channels, and basic device compatibility. The current app links only the UMCommon and UMDevice components and initializes them when onboarding is first displayed. On later launches, it initializes after the previously completed onboarding state is restored.

According to Umeng’s public disclosures and the SDK’s capabilities, information processed may include device identifiers such as Apple’s IDFV or an SDK-generated identifier; IDFA only if system permission exists and the capability is actually enabled; IP address; network type and carrier; device model; operating-system version; language/region; time zone; app and SDK versions; distribution channel; timestamps; launch and activity events; and device-state information such as storage, CPU, and battery status. Specific fields may change with the SDK version and configuration.

Ringtones currently disables Umeng optional intelligent attribution, Apple Search Ads attribution, and SKAdNetwork attribution. It does not integrate Umeng advertising, push, social-sharing, remote-configuration, or performance-monitoring components. We do not provide Umeng with contacts, photo-library content, audio or video files, microphone recordings, or precise location, and we do not use analytics data for personalized advertising.

You can review the Umeng Privacy Policy. The current version does not offer a separate in-app analytics switch. If you object to this processing, contact us and we will handle the request as required by applicable law. Until the request is completed, you may also stop using and delete the app.

7. Apple Purchases and Auto-Renewal

The Annual Membership and Lifetime Membership are offered through Apple StoreKit. At purchase, Apple processes your Apple Account, payment method, billing, and tax information. Ringtones receives the product ID, Apple-signed transaction-verification result, active status, expiration date, and revocation status to unlock or restore PRO benefits, and caches the current unlocked status on your device.

We do not receive your Apple Account password, complete payment-card number, or card security code. Apple may provide us with aggregated sales, subscription, and refund reports under its policies. You can manage the Annual Membership through Apple Subscriptions and request an eligible refund through Report a Problem.

8. Feedback and Customer Support

An email leaves your device only after you complete the feedback form and confirm sending in the system mail composer. The draft contains the feedback category and message and automatically includes the app version and build number, iOS name and version, device category, hardware model, and system language to help us reproduce an issue. You may review, edit, or delete the email content before sending.

Do not send your Apple Account password, complete payment-card information, identity documents, private recordings unrelated to the issue, or other unnecessary sensitive information. We may ask for minimum non-sensitive fields from an Apple receipt, screenshots, or reproduction steps, but we will not ask for passwords or verification codes by email.

9. Local-Network Uploads, External Apps, and Sharing

Direct transfer on the same Wi-Fi network

When you open Computer Upload, Ringtones temporarily listens for a TCP connection on the local network and advertises the _ringstudio._tcp service through Bonjour. A computer browser sends a file directly to your phone using the local IP address and random port shown on the page. Cellular-network interfaces are disabled. When you close the page or finish the flow, the listener and active connections stop, and temporary files not taken into the editor are deleted.

Another device with access to that local-network address may attempt to connect. Use this feature only on a Wi-Fi network you trust, do not share the address with unrelated people, and close the page when the upload is complete.

External apps and system sharing

When you choose to open TikTok, Douyin, or another app, iOS transfers control to that third party, which may process data under its own policy. After you send media through the system share sheet, Mail, Files, AirDrop, or another destination, that destination independently processes its copy. We cannot withdraw content that you have already sent or saved elsewhere.

10. Data Processing on These Legal Pages

These are static pages. They do not set cookies, use Local Storage, load third-party fonts or analytics scripts, or collect form data. Their JavaScript runs only in your browser to display reading progress and the current year.

A future hosting provider, content-delivery network, DNS provider, or browser may still generate server logs containing an IP address, request time, User-Agent, and requested path for security and delivery. The final provider’s practices will govern that processing. If these pages are deployed online, we will add the actual provider and log-retention details where required.

11. Processors, Sharing, Transfers, and Disclosure

We do not collect personal information for sale. Information is processed by or disclosed to third parties only where reasonably necessary to provide a feature, comply with law, or protect legitimate rights, as described below.

We do not publicly disclose personal information unless you authorize it or the law permits or requires it. If there is a merger, acquisition, reorganization, or asset transfer, personal information may transfer with the relevant business. We will require the recipient to continue to follow this Policy or obtain any new consent required by law.

We may disclose the minimum necessary information to a competent authority or professional adviser to comply with legal process, protect users or public safety, investigate fraud, or preserve legal rights. We will review the legal validity of such requests.

12. Storage Locations and International Transfers

Media files and most editing data remain on your device, so their location follows the device. Apple may process purchase and system-service data using its global infrastructure and policies.

Umeng’s public policy states that its SDK service data is stored in mainland China. When a user outside mainland China uses Ringtones with Umeng analytics enabled, the analytics data listed in Section 6 may be transferred to and stored in mainland China. We will use notices, consent, contracts, or other cross-border safeguards required by applicable law. If no lawful transfer basis can be established, that processing should not be enabled for the affected user.

You may contact us to ask about arrangements relevant to your region or to object to non-essential cross-border analytics processing.

13. Retention

• Library media and editing records: retained on your device until you delete them in the app, uninstall the app, the system removes them, or the device is erased. Copies shared elsewhere are retained independently by their destination.
• Photo import-session identifiers: held only in memory for an import session lasting up to approximately five minutes and not written to our servers.
• Temporary media: generally deleted after cancellation, failure, completed import, or leaving the relevant screen; the system may also remove it under its storage policies.
• Free-use count: stored in a “this device only” Keychain item. iOS may retain it after uninstalling the app until the device is erased, the system clears it, or the app updates the item.
• Membership cache: retained on the device until the entitlement changes, app data is removed, or the transaction is reverified. Apple retains transaction records under its legal and business requirements.
• Support email: generally deleted or anonymized within 12 months after the last support contact. It may be kept longer to the extent necessary for a dispute, security investigation, or legal requirement.
• Umeng analytics: retained for the shortest period necessary for analytics, security, and legal obligations, subject to Umeng’s policy and console configuration. Aggregated results that can no longer identify or be linked to a person may be retained longer.

When a processing purpose is complete, consent is withdrawn and no other lawful basis remains, or applicable law requires deletion, information under our control will be deleted or anonymized.

14. Security

We use measures proportionate to the risk, including prioritizing on-device processing, limiting SDK components, verifying Apple-signed StoreKit transactions, storing the free-use count in a “this device only” system Keychain item, disabling local-network uploads over cellular interfaces, validating uploaded media, and limiting employee or provider access to support information according to role.

Direct local-network HTTP transfer does not provide internet-grade end-to-end encryption and should be used only on trusted Wi-Fi. No system can guarantee absolute security. If a security incident is likely to affect your rights, we will take remedial steps and provide notice as required by applicable law.

15. Your Privacy Rights

Depending on the law where you live, you may have rights to information, access, a copy, correction, deletion, restriction, withdrawal of consent, objection, data portability, account closure (there is currently no Ringtones account), and complaint to a supervisory authority.

Controls available directly to you

• Delete ringtones, alert tones, and their local records from the in-app library.
• Revoke Photos, microphone, media-library, or local-network permission in iOS Settings.
• Cancel the Annual Membership or review transactions through your Apple Account.
• Delete the app to remove its primary local-container data.
• Edit or cancel feedback before sending the email.

Submitting a request to us

Email Ringtones@support.growing.inc with the subject “Privacy Rights Request” and include your country or region, the type of request, and the minimum information needed to locate relevant records. To prevent impersonation, we may verify your control of a relevant email address, transaction, or device record, but we will not ask for your Apple password or complete payment-card number.

Because local media and Keychain records are not uploaded to our servers, we generally cannot remotely view, export, or delete them. Please use the controls on your device. If Umeng data cannot reasonably be linked to an identified person, we may need an SDK-available device identifier and will explain any limitation when identification is not possible.

We will respond within the period required by applicable law. A request may be reasonably limited to protect another person’s rights, comply with legal retention, preserve security, prevent fraud, or address inability to verify identity; we will explain the basis. Exercising a statutory right will not result in discriminatory treatment.

16. Regional Disclosures

Mainland China

We process personal information in accordance with the Personal Information Protection Law and other applicable requirements, following principles of lawfulness, legitimacy, necessity, good faith, specified purpose, minimum scope, openness, and transparency. Before recording or processing media that may contain another person’s voice or private content, ensure that you have authority to do so. Where separate or written consent is legally required—for example, for certain sensitive-information processing, disclosure to another processor, or a cross-border transfer—we will obtain it separately. You may withdraw consent and request an explanation of our processing rules.

European Economic Area, United Kingdom, and Switzerland

We rely on the following legal bases as applicable: performance of a contract or steps you request for editing, purchases, and support; consent where required for system permissions, non-essential analytics, or international transfers; legitimate interests in security, troubleshooting, and proportionate product improvement, balanced against your rights; and compliance with legal obligations. You may object to processing based on legitimate interests, withdraw consent, or complain to your local data-protection authority.

California, United States

During the preceding 12 months, we may have processed identifiers/device information, internet or electronic-network activity, commercial information such as purchase status, audio/video content that remains primarily local, and customer-record information included in feedback, as those categories are defined by California law. Sources include your device, your voluntary submissions, Apple, and Umeng. Purposes and recipients are described in Sections 3, 6, 7, 8, and 11.

We do not “sell” personal information for monetary consideration or authorize “sharing” of Ringtones data for cross-context behavioral advertising, and we do not knowingly sell or share the information of users under 16. If applicable law characterizes a third-party analytics activity differently, you may submit a “Do Not Sell or Share” request by email. Where applicable, we will also recognize and honor a valid Global Privacy Control signal.

17. Children’s Information

Ringtones is intended for a general audience and is not specifically directed to children under 14. We do not knowingly ask a child to submit a name, contact information, or account profile. Minors should use the app under the guidance of a parent or guardian, particularly when recording audio, processing media involving others, opening a third-party app, or making a purchase.

If you are a parent or guardian and believe that a child sent personal information to us without appropriate consent, contact us. After verification, we will delete it or take other protective action as required by applicable law. Media stored locally on the device must be deleted by the parent or guardian using that device.

18. Changes to This Policy

We may update this Policy when features, SDKs, processing purposes, or laws change. We will provide notice of material changes through an in-app notice, this webpage, or another reasonable method. If renewed consent is required, we will obtain it before continuing the affected processing.

The date at the top identifies the latest version. An updated Policy will not retroactively create a lawful basis for processing that lacked one when it occurred.

19. Contact Us

Personal information processor / data controller: Lyntra Technology Ltd.

Privacy email: Ringtones@support.growing.inc.

To protect your privacy, do not include identity documents, your Apple Account password, complete payment-card details, or unnecessary private audio or video in your first email. We will first identify the minimum verification information needed for the request.