Sunny Studio Limited Privacy Policy

January 15, 2026

1. Acceptance of Terms

We are Sunny Studio Limited ("we", "our" or "us"); Sunny Studio is our official brand. This Privacy Policy governs all our products, software, services and websites (collectively "Services"). By accessing or using our Services, you ("you" or "your") acknowledge having read, understood and agreed to the collection, use, disclosure and handling of your personal and device information as set forth herein. We are committed to protecting your privacy rights and interests. This Policy details our information handling practices in connection with your use of our Services, with the primary purpose of providing and continuously optimizing our Services.

The Services are not intended for individuals unable to enter into legally binding contracts. If you disagree with any provision herein, you must not access, register for or use any of our Services.

2. Information We Collect and Methods

We will NOT collect any of your data before you click to agree to the Privacy Policy. We may automatically collect Personal Information or obtain it from third-party partners only after you click to consent to this Privacy Policy. The categories of Personal Information we collect are as follows:

2.1 Device Information

When you access our website or use our software, we collect relevant device information, including but not limited to IP address, location data, device ID, advertising identifiers (e.g., IDFA for iOS, GAID for Android), browser and device settings, and operating system.

2.2 Activity and Usage Information

When you use our Services, we may automatically collect information about your interactions with the Services, including but not limited to IP address, device/advertising identifiers, MAC address, operating system, browser type, language preference, access/exit pages, crash data, location data, purchase activity, and other usage-related data.

2.3 Information Obtained from Third Parties

Our applications integrate SDKs from third-party analytics providers to optimize product performance. These SDKs may collect relevant information (e.g., GAID for Android, IDFA for iOS, region, location, IP address) in compliance with applicable regulations. This Policy does not apply to third-party analytics tools; you may review their privacy policies via their official websites. Our partners deploying analytics SDKs include:

- Adjust: https://www.adjust.com/terms/privacy-policy/

- AppsFlyer https://support.appsflyer.com/hc/en-us/articles/4417197430289-Google-safety-section-form

- Firebase: https://www.google.com/intl/en/policies/privacy/

- Google: https://policies.google.com/privacy

- AdMob https://developers.google.com/admob/android/privacy/play-data-disclosure

- AppLovin https://www.applovin.com/privacy/

- Chartboost https://docs.chartboost.com/en/monetization/integrate/android/data-safety-details/

- Fyber https://developer.digitalturbine.com/hc/en-us/articles/7594524218257-Google-s-Data-Safety-Form

- IronSource https://developers.is.com/ironsource-mobile/general/googles-data-safety-questionnaire-full/

- Liftoff Monetize https://support.vungle.com/hc/en-us/articles/360047780372-Advanced-Settings

- Meta https://www.facebook.com/privacy/policy

- Mintegral https://www.mintegral.com/en/privacy

- Pangle https://www.pangleglobal.com/integration/app-privacy-details-gp

- Smaato https://www.smaato.com/data-safety-guidance/

- Tapjoy https://dev.tapjoy.com/en/support/Data-Safety

- UnityAds https://docs.unity.com/ads/en-us/manual/GoogleDataSafety

3. How and Why We Use Your Information

We use your information for the following legitimate purposes:

1. Communicate with you, ensure Service operation, optimize Services, develop business, and prevent fraud and spam.

2. Provide non-personally identifiable information (or personally identifiable information only when necessary for billing) to third parties such as advertisers to deliver commercial ads, generating revenue to support Service operation and maintenance.

3. Process your information via technologies (including automated systems) to provide personalized Services/ads and detect improper behaviors (e.g., spam, malware, illegal content).

4. Display personalized ads via third-party advertising networks, based on our legitimate business interests. For users in the European Economic Area, Norway or Switzerland, some third-party networks require your consent to process Personal Information for personalized ads, so we will seek your agreement to collect your mobile advertising identifier and IP address for this purpose.

4. Data Security

We implement industry-standard security measures to prevent information loss, misuse and modification. However, no internet data transmission is 100% secure; we cannot guarantee the security of information you transmit through the Services, and you do so at your own risk.

5. Transfers of Your Information

Your information may be transferred to, processed and stored on servers/databases outside your country/region (including but not limited to the U.S.) when you use our Services or provide information to us. Privacy laws in these regions may be less stringent than in your country of residence. If you disagree with such transfer, processing or storage, do not use our websites or Services.

6. Age Limits

Our Services are not intended for individuals under 16. We will not intentionally collect Personal Information directly from individuals under 16 without parental/guardian consent. If you are under 16, do not provide us with any information. We encourage parents/guardians to supervise their children's online activities.

If you believe we have inadvertently collected information from an individual under 16, contact us immediately at contact@sunnystu.com.

7. Links to Other Websites and Third-Party Ads

Our Services may contain ads or hyperlinks to third-party websites (e.g., business partners, suppliers, advertisers). Third-party ads and linked websites may use Cookies, web beacons or other tracking devices. We have no control over these third-party tracking tools and no access to information they collect.

You acknowledge that we are not responsible for third-party website content or privacy practices. We recommend reviewing their privacy policies before providing them with any information.

8. Data Deletion

1. You have the right to request deletion of your Personal Information collected by us; contact us at contact@sunnystu.com to exercise this right.

2. Account or content deletion requests may take up to 10 working days to complete from the initiation of the process or receipt of the request.

3. Your information will be permanently deleted upon account deletion, unless retention is required by this Policy. Deleted accounts cannot be reactivated.

9. Data Retention

1. Personal Information will only be processed and stored for the period necessary to achieve the collection purpose: Personal Information collected for contract performance will be retained until the contract is fully executed.

2. Personal Information collected for the company's legitimate interests will be retained for the period necessary to fulfill those interests; details are available in relevant sections of this document or by contacting us.

3. If you have consented to Personal Information processing, we may retain such information longer unless you withdraw consent. We may also be obligated to retain Personal Information longer if required by law or competent authorities.

4. Personal Information will be deleted upon expiration of the retention period, after which you will no longer be able to exercise rights of access, erasure, rectification or data portability.

10. California Privacy Rights

California residents are entitled to additional rights under the California Consumer Privacy Act ("CCPA"). See below for details; refer to the "Exercising Your California Privacy Rights" section to exercise these rights.

10.1 Right to Know

You have the right to know and obtain the following information we collected about you in the past 12 months:

- Categories of information collected about you;

- Sources of collected information;

- Business or commercial purposes of collecting your information;

- Categories of third parties with whom we have shared your information;

- Specific pieces of information collected about you.

10.2 Right to Delete

You have the right to request us to delete your collected information (and instruct our service providers to do the same), subject to exceptions including but not limited to when the information is necessary to:

- Complete your transaction;

- Provide you with goods or services;

- Perform the contract between you and us;

- Protect your security and prosecute those responsible for security breaches;

- Repair system bugs;

- Protect your or other users' freedom of speech;

- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code ยง 1546 et seq.);

- Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that complies with other applicable ethical and privacy laws;

- Comply with legal obligations;

- Make other internal and legal uses of the information that are consistent with the context in which you provided it.

10.3 Exercising Your California Privacy Rights

To exercise the above California privacy rights, contact us at contact@sunnystu.com with the subject line "California Privacy Rights Request". We may verify your identity to protect your Personal Information security.

11. Rights for Individuals in the European Economic Area, Switzerland and/or the United Kingdom

This section applies to individuals accessing or using our Services in the European Economic Area, Switzerland and/or the United Kingdom (collectively "Designated Countries") at the time of information collection. We may verify your location via your confirmation or IP address when you use certain Services.

11.1 Data Controller Status

We act as the data controller for Personal Information collected from Service users. A "data controller" determines the purposes and methods of Personal Information processing; third-party service providers acting on our behalf are "data processors" who handle your Personal Information per our instructions.

11.2 Legal Bases for Processing

We have detailed the legal bases for Personal Information processing throughout this Policy; a summary of processing purposes and corresponding legal bases is as follows:

- You have given consent for one or more specific purposes;

- Providing information is necessary for the performance of the contract between you and us and/or any pre-contractual obligations;

- Processing is necessary to comply with legal obligations to which we are subject;

- Processing is related to tasks carried out in the public interest or in the exercise of official authority entrusted to us;

- Processing is necessary for the legitimate interests pursued by us or a third party.

For further clarification on the specific legal basis applicable to processing (especially whether Personal Information provision is a statutory/contractual requirement or a prerequisite for entering into a contract), contact us.

11.3 Your Individual Rights

You enjoy the following rights when using our Services. Contact us at contact@sunnystu.com to exercise these rights under applicable laws; we may verify your identity to protect your Personal Information security.

- Right to Withdraw Consent: You may withdraw consent for Personal Information processing at any time; withdrawal does not affect the legality of processing conducted prior to withdrawal.

- Right of Access: We will provide a copy of your Personal Information in our files promptly and free of charge upon request, unless a reasonable fee is permitted by law. Access may be restricted if it harms others' rights and freedoms.

- Right to Rectification: You may request correction or update of your Personal Information; we may provide in-Service functions for direct updates.

- Right to Erasure ("Right to be Forgotten"): We will erase your Personal Information if it is no longer necessary for the collection purpose, collected based on withdrawn consent, or you object to processing without overriding legitimate grounds.

- Right to Restriction of Processing: You may restrict our processing of your Personal Information under certain conditions. During restriction, we will only process such information with your consent, for legal claims, to protect others' rights, or for public interest. We will notify you when restriction is lifted.

- Right to Object: You may object to processing based on consent, contract or legitimate interests at any time under applicable laws. We may continue processing if necessary for legal claims or other permitted exceptions.

- Right to Data Portability: If we process your Personal Information based on contract or consent via automated means, you may request it in a structured, commonly used and machine-readable format, and require direct transfer to another controller if technically feasible (without harming others' rights).

- Notification to Third Parties: We will notify third parties processing your relevant Personal Information when fulfilling correction, erasure or restriction requests, unless impossible or overly burdensome. We will identify these third parties upon your request.

- Right Against Automated Individual Decision-Making: You have the right to not be subject to decisions based solely on automated processing (including profiling) with legal or similarly significant effects, unless exceptions apply under applicable laws.

- Limitations on Rights Requests: We may limit requests if denial is required/authorized by law, access harms others' privacy, to protect our rights/property, or the request is frivolous/excessively burdensome.

11.4 International Data Transfers

We transfer your Personal Information in compliance with applicable data protection laws and implement appropriate safeguards. For transfers outside the Designated Countries, we have signed necessary contractual clauses with receiving third parties, relying on legal mechanisms such as Standard Contractual Clauses or cooperating with U.S.-based third parties certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

11.5 Right to Lodge Complaints

If you believe we have violated your privacy rights under applicable laws or this Policy, contact us at contact@sunnystu.com to resolve the issue. You also have the right to file a complaint with the competent supervisory authority in your country of residence, place of work or alleged infringement.

12. Disclosure of Your Information

1. We will disclose your Personal Information in accordance with law if you violate laws, regulations or relevant service agreements (e.g., sending harassing messages).

2. Your payment information may be shared with third parties as needed for billing and fraud prevention.

3. Your information (including Personal Information) may be transferred to the acquiring entity in the event of a business transfer (e.g., merger, acquisition, sale of all or part of assets).

4. We may disclose your Personal Information to public authorities (e.g., courts, government agencies) in response to legal requirements or valid requests.

13. Changes to This Privacy Policy

We reserve the right to modify this Policy at any time. We recommend regular reviews for updates. For major changes, we may notify you via email or in-app messages. Your continued use of the Services after modifications are posted constitutes acceptance of the updated terms.

14. Contact Information

For questions, comments or requests regarding this Policy or the processing of your Personal Information, contact us at contact@sunnystu.com.