1. Introduction

Welcome to Blux ("we", "us", "our"), a mobile application designed exclusively for users aged 18 years and older. This Privacy Policy ("Policy") outlines how we collect, use, disclose, and protect personal information of users of the Blux application (the "App"), available on the Apple App Store. This Policy also includes our User-Generated Content (UGC) Guidelines and In-App Purchase Terms, which govern all content posted, shared, or transmitted by users on the App and all paid transactions within the App. By accessing or using the App, you confirm that you are 18 years of age or older and agree to be bound by this Policy, our UGC Guidelines, and our In-App Purchase Terms.

We are committed to complying with the General Data Protection Regulation (GDPR) for users located in the European Economic Area (EEA), United Kingdom, and Switzerland, as well as all applicable data protection laws globally and Apple's App Store Review Guidelines for in-app purchases.

2. Data Collection & GDPR Compliance

2.1 Personal Information We Collect

We collect personal information that you voluntarily provide to us, including but not limited to:

• Contact information (name, email address, phone number)
• Account credentials (username, password, security questions)
• Profile information (profile photo, bio, preferences)
• User-generated content (messages, posts, comments, media)
• Usage data (app interactions, feature usage, session duration)
• Device information (device model, OS version, unique device identifiers)
• Payment and transaction data (payment method identifiers, purchase history, transaction amounts, receipt information - collected only for in-app purchases)

2.2 GDPR Rights for EEA Users

2.3 Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, regular security audits, and employee training on data protection practices. For payment data, we use Apple's secure in-app purchase system and do not store full credit card details, CVV numbers, or other sensitive payment information on our servers. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

3. In-App Purchase (IAP) Terms & Data Practices

3.1 Types of In-App Purchases

Blux offers the following categories of in-app purchases:

• Consumable Items: Digital goods that are used up after use (e.g., virtual currency, single-use premium features, access to limited-time content) - these purchases are non-refundable after use.
• Non-Consumable Items: Permanent digital goods that unlock premium features or content (e.g., ad-free experience, premium functionality, permanent content access) - these purchases are tied to your Apple ID and can be restored on compatible devices.
• Auto-Renewable Subscriptions: Recurring payments for ongoing access to premium content or features (e.g., monthly/annual premium membership). Subscriptions automatically renew unless canceled at least 24 hours before the end of the current billing period.
• Non-Renewing Subscriptions: Fixed-term access to premium content (e.g., 7-day premium pass) that expires at the end of the term without automatic renewal.

3.2 Payment Processing & Data Collection

All in-app purchase transactions are processed exclusively through Apple's official payment system. We do not collect, store, or process your full payment card details, bank account information, or other sensitive payment credentials. The only payment-related data we receive and store includes:

• Apple ID transaction identifiers (non-personally identifiable)
• Purchase date and time
• Type of product purchased
• Transaction amount (in the currency of purchase)
• Receipt information for verification purposes
• Subscription status (active, expired, canceled)

This data is used solely for the following purposes:

• Verifying and processing your purchase
• Providing access to purchased content/features
• Maintaining purchase history for account restoration
• Resolving billing disputes and processing refunds (where applicable)
• Complying with legal and tax obligations
• Analytics to improve our products and services (anonymized only)

3.3 Subscription Management & Cancellation

You can manage and cancel your auto-renewable subscriptions at any time through your Apple ID settings:

1. Open the Settings app on your iOS device
2. Tap your name at the top of the screen
3. Tap "Subscriptions"
4. Select Blux from the list of active subscriptions
5. Tap "Cancel Subscription" (or "Cancel Free Trial")

Cancellation takes effect at the end of the current billing period. We do not offer prorated refunds for unused portions of subscription periods, except as required by applicable law.

3.4 Refund Policy

All in-app purchases are subject to Apple's App Store refund policy. Refund requests must be submitted directly to Apple through the App Store or iTunes Support within 90 days of purchase. We do not process refunds directly, but we will assist with verification if requested by Apple or the user. Refunds may be granted at Apple's discretion in the following circumstances:

• Accidental purchases (e.g., unintended taps, purchases by minors without parental consent)
• Technical issues preventing access to purchased content/features
• Duplicate purchases
• Failure to deliver purchased content as described
• Legal requirements mandating a refund

To request a refund, contact Apple Support at https://reportaproblem.apple.com or through the App Store app. For assistance with refund verification, contact us at chatwithus@bluxpark.com with "Refund Verification Request" in the subject line, including your purchase date, product name, and Apple ID transaction ID.

3.5 Purchase Restoration

Non-consumable purchases and active subscriptions can be restored on compatible devices using the same Apple ID used for the original purchase. To restore purchases:

1. Open the Blux app
2. Navigate to "Settings" or "Profile"
3. Tap "Restore Purchases"
4. Authenticate with your Apple ID when prompted

If you experience issues restoring purchases, contact our support team at chatwithus@bluxpark.com with your purchase receipt and Apple ID (partial ID only, e.g., "j***@example.com") for assistance.

3.6 GDPR & In-App Purchase Data

For EEA users, your GDPR rights extend to purchase data with the following exceptions:

• We may retain transaction records for legal, tax, or accounting purposes for the period required by law (typically 7 years)
• Subscription data may be retained to process cancellation requests and prevent unauthorized access to premium features
• Receipt information may be retained to verify purchases and resolve disputes

To request access to or deletion of your purchase data (where legally permissible), contact us at chatwithus@bluxpark.com with "Purchase Data Request" in the subject line.

3.7 Price & Availability

Prices for in-app purchases are displayed in your local currency (based on your Apple ID region) and include applicable taxes as required by law. Prices are subject to change without notice, but changes will not affect active subscriptions until renewal. We reserve the right to modify or discontinue any in-app purchase products at any time, but will honor all existing purchases and active subscriptions for their full term.

4. User-Generated Content (UGC) Guidelines

Blux allows users to create, post, share, and transmit content (including text, images, videos, audio, links, and other materials) ("UGC"). All users must comply with these UGC Guidelines, which are enforced to maintain a safe, respectful, and appropriate environment for our 18+ user base. We have a zero-tolerance policy for UGC that violates these guidelines, including UGC related to in-app purchases (e.g., fraudulent claims about premium features, promotion of unauthorized purchase methods).

4.1 Prohibited UGC Content

4.2 Zero-Tolerance Policy for Inappropriate UGC

We have a zero-tolerance policy for UGC that is pornographic, offensive, discriminatory, or otherwise inappropriate. Specifically, any content related to nudity, sexual acts, violence, hate speech, gambling, drug-related imagery or references, or political propaganda aimed at inciting division or harm is strictly prohibited. Additionally, any content that is generally regarded as offensive, such as extremely vulgar language, content that demeans or humiliates others, or content that goes against common moral and ethical standards, is not allowed.

We explicitly state that we do not tolerate any content that is offensive, abusive, or harassing towards other users. This includes but is not limited to name-calling, personal attacks, derogatory language, and any form of verbal abuse (辱骂) that targets individual users or groups. All users must treat each other with respect and dignity at all times.

We also maintain zero tolerance for UGC related to fraudulent in-app purchase activities, including but not limited to sharing account credentials to access premium features, promoting refund fraud, or distributing unauthorized methods to obtain paid content for free.

4.3 UGC Monitoring & Enforcement

We employ a combination of automated tools and human moderators to monitor UGC on the App for compliance with these guidelines. However, we do not pre-screen all UGC, and the presence of any UGC on the App does not constitute our endorsement or approval of such content. We reserve the right to review, remove, or disable access to any UGC at our sole discretion, without prior notice, for any reason, including but not limited to violation of these guidelines.

Users who violate our UGC Guidelines may face disciplinary action, including but not limited to:

• Removal of the offending UGC
• Warning notifications
• Temporary suspension of account features (posting, commenting, messaging, access to purchased content)
• Permanent suspension or termination of the user's account (including revocation of access to paid content)
• Reporting of illegal content to relevant law enforcement authorities
• Reporting of fraudulent purchase activity to Apple

5. Reporting Violations & Enforcement Measures

5.4 Enforcement Standards

Our moderation team applies consistent enforcement standards when reviewing reported content:

• All reports are evaluated based on the same guidelines, regardless of the user's popularity, follower count, or status (including premium subscribers)
• Context is considered (e.g., educational content about drugs vs. promotion of drug use)
• Cultural differences are taken into account, but our zero-tolerance policy for illegal content applies globally
• Repeat offenders face progressively stricter penalties (warning → temporary suspension → permanent ban, including loss of paid content access)
• Users found to be engaging in fraudulent purchase activity may have their accounts terminated and reported to Apple

7. Changes to This Policy

We reserve the right to update or modify this Policy at any time. When we make material changes to this Policy, including changes to in-app purchase terms, we will notify you by posting the updated Policy on the App, sending a notification to your registered email address, or through other reasonable means. Your continued use of the App after such changes constitutes your acceptance of the updated Policy.

For changes to subscription pricing or terms, we will provide at least 30 days' notice before the changes take effect for existing subscribers.

We encourage you to review this Policy periodically to stay informed about our privacy practices, UGC guidelines, and in-app purchase terms.