Spec LRT-CA-PRV · Data handling
Privacy Notice
Which personal data CleanAgent: Smart Cleanup touches, where each item originates, why it is used, who receives it and when it is discarded. Table 3.1 — the data inventory — is the reference; each other section is a rule that applies to its rows.
- Document
- Privacy Notice
- Effective
- 19 October 2026
- Product
- CleanAgent: Smart Cleanup · iOS
- Controller
- Lirtam LLC · United Arab Emirates
- Registered office
- Sharjah Media City, Sharjah, UAE
- Privacy contact
- growth@lirtam.click
§01Scope and controller
Coverage. Personal data processed through the iOS app CleanAgent: Smart Cleanup (“CleanAgent”, the “App”) and through email support for it — together, the “Service”.
Controller. Lirtam LLC, registered in the United Arab Emirates; registered office Sharjah Media City, Sharjah, UAE. Referred to below as “Lirtam”, “we” or “our”.
Single contact point. Questions, requests and complaints about privacy: growth@lirtam.click.
Definitions. Personal data: information about a living individual who is identified or identifiable. GDPR: Regulation (EU) 2016/679, plus the UK GDPR where that applies. EEA: European Economic Area.
§02Processing boundary: your device
CleanAgent looks for photos, screenshots and videos that repeat or closely resemble one another, and for repeated contact entries, so you can win back space on an iPhone or iPad. These rules fix where that work happens.
Permission gate. Library and address-book reads start only once iOS has granted the corresponding permission. Photos and Contacts are requested separately; full, limited and no access are all valid answers.
Local computation. All matching runs on the device. Image pixels, video content, names, numbers and other contact fields are not sent to Lirtam or to any recipient in §6.
Confirmed deletion only. Removal happens after you review and approve a selection, never before. Removed photos and videos land in Photos › Recently Deleted, which iOS controls.
Revocation. Change either permission whenever you like in the Settings app at Privacy & Security › Photos or Privacy & Security › Contacts. Features needing a withdrawn permission pause until it is granted again.
§03Data inventory
One row per category of personal data. Recipients are expanded in §6; the lawful basis for each purpose is in §5.
| Field | Source | Purpose | Recipient | Retention |
|---|---|---|---|---|
| Support correspondenceyour email address, the message, any attachment | You, by writing to us | Handling the request; diagnosing a reported fault | Lirtam | Until the ticket is closed, plus a reasonable follow-up window |
| Device and technical datahardware model, iOS and App versions, IP address, carrier, language, region, time zone | Read automatically by the App and its SDKs | Operating the App; stability, security, anti-fraud; analytics; ad measurement | Firebase, Apphud, AppsFlyer, Meta, Google Ads | Each provider’s retention schedule |
| Usage eventsscreen views, feature taps, scan start and end, result totals (items found, space reclaimed), paywall impressions and dismissals | Emitted by the App during use | Product analytics; split tests configured in Firebase Remote Config; ad measurement | Firebase, AppsFlyer, Meta, Google Ads | The analytics provider’s retention setting |
| Purchase recordsplan, trial status, renewals, cancellations, transaction IDs, price, currency | Apple, relayed through the App Store and Apphud | Unlocking and restoring Premium; consumption answers for Apple refund reviews; bookkeeping | Apple, Apphud, AppsFlyer; Meta and Google Ads as conversion events | The period that tax and accounting rules prescribe |
| IdentifiersIDFV (identifier for vendor); random SDK-generated IDs; IDFA (advertising identifier) solely after you allow tracking | iOS and the App’s SDKs | Tying events to one installation; attribution; ad measurement | Apphud, AppsFlyer, Firebase, Meta, Google Ads | Per provider; IDFA reads stop the moment tracking is switched off |
| Attribution datathe campaign, network or site behind the install | AppsFlyer and the ad networks | Judging which campaigns bring users | AppsFlyer, Apphud, Meta, Google Ads | The attribution provider’s retention setting |
| Crash diagnosticscrash logs, stack traces, memory and launch timings at the point of failure | Produced by the App when it crashes | Finding and fixing defects | Firebase Crashlytics | Crashlytics retention setting |
| Push tokenan address iOS assigns for notifications | iOS, once notifications are allowed | Delivering notifications | Apple, Firebase Cloud Messaging | Until notifications are turned off or the App is uninstalled |
No row carries a photo, a video, a contact card or any fragment of their content. Usage events hold counts and actions, never media.
§04Out-of-scope data
By design, the Service never collects:
- what your photos, videos and contacts contain;
- precise geolocation;
- card numbers or other payment credentials — Apple handles payment and passes on only the purchase records in Table 3.1.
§05Purposes and lawful bases
For people in the EEA and the UK, each purpose rests on the basis in the right-hand column.
| Purpose | Processing involved | Lawful basis |
|---|---|---|
| P1 · Deliver the App and Premium | Receipt validation, unlocking paid features, purchase restoration | Performance of our contract with you |
| P2 · Stability, security, anti-fraud | Crash reporting, performance monitoring, detecting paywall abuse | Legitimate interest: a dependable, safe product |
| P3 · Analytics and experiments | Usage statistics; split tests configured via Firebase Remote Config | Legitimate interest: product improvement |
| P4 · Ad measurement and audiences | Attributing installs and purchases to campaigns; audience building on Meta and Google platforms | Consent through the App Tracking Transparency (ATT) prompt. If refused: aggregated reports from SKAdNetwork / AdAttributionKit only |
| P5 · Push notifications | Reminders, trial notices, product news | Consent through the iOS notification prompt |
| P6 · Support | Reading and answering emails; checking reported faults | Contract; legitimate interest where there is no contract |
| P7 · Apple refund reviews | Answering Apple’s consumption-information requests about a purchase under refund review | Legitimate interest: refunds decided on accurate facts |
| P8 · Legal compliance | Keeping tax and accounting records; replying to lawful demands; enforcing our terms | Legal obligation; legitimate interest |
Objection applies to rows resting on legitimate interest (see §10). Consent-based rows end when you withdraw consent; processing done before withdrawal stays lawful.
§06Recipients and processors
| Provider | Function | Data received | Policy |
|---|---|---|---|
| Apple | App Store billing, subscription management, push delivery, refund decisions | Purchase records; push token; purchase usage during a refund review | Apple privacy |
| Apphud | Subscription SDK: receipt checks, revenue analytics | Purchase records; IDs; device data; attribution data | Apphud privacy |
| AppsFlyer | Attributing installs to campaigns | IDs (IDFA requires ATT consent); device data; IP; in-app and purchase events | AppsFlyer privacy |
| Google Firebase | Crashlytics, Analytics, Cloud Messaging, Remote Config | Usage events; diagnostics; IDs; push token; device data | Firebase privacy |
| Meta | Meta SDK; measuring our ads on Facebook and Instagram | In-app events; device data; IDs (IDFA requires ATT consent) | Meta privacy |
| Google Ads | Measuring conversions from Google ad campaigns | In-app events; IDs (IDFA requires ATT consent) | Google privacy |
Processor status. These providers act on Lirtam’s instructions under data processing terms and may not repurpose the data. For ad measurement, Meta and Google may additionally process it as independent controllers, governed by their own policies.
Other disclosures:
- Authorities and courts — when legally compelled, or to protect the safety, rights or property of users, Lirtam or third parties;
- Corporate transactions — if Lirtam merges, is acquired or sells assets; the successor must honour this notice;
- Your agreement — any disclosure you request or approve.
No sale. Lirtam sells personal data to nobody.
§07Tracking controls
Each switch below changes what the App or an ad platform may do.
| Control | Location | Effect |
|---|---|---|
| ATT prompt | iOS, the first time the App asks | Choosing “Ask App Not to Track” blocks IDFA access; attribution falls back to aggregated data |
| Tracking switch | Settings › Privacy & Security › Tracking | Reverse your earlier choice at any moment |
| Apple Advertising | Settings › Privacy & Security › Apple Advertising | Turns Apple’s own ad personalisation on or off |
| Meta ad preferences | facebook.com/adpreferences | Limits Meta ads driven by app activity |
| My Ad Center | myadcenter.google.com | Adjusts Google’s ad personalisation |
| Industry opt-outs | AppChoices · NAI opt-out | Opt-out tools run by participating ad companies |
Browser Do Not Track: not applicable. CleanAgent is a native app and ignores browser DNT signals; the iOS controls above are what count.
§08Cross-border transfers
Several providers in §6 operate in other countries, the United States among them, so processing may occur outside your country of residence.
Transfers out of the EEA or UK rest on one of two mechanisms: an adequacy decision for the destination — including, for certified US recipients, the EU–U.S. Data Privacy Framework (dataprivacyframework.gov) — or Standard Contractual Clauses adopted by the European Commission, with the UK addendum where relevant.
Ask at the §14 address for details of the mechanism behind any specific transfer.
§09Retention and security
Retention rule. Storage is limited to what each purpose needs; per-category limits sit in the Retention column of Table 3.1. Past that limit, data is deleted or anonymised.
Security controls. Traffic between the App and its providers uses TLS encryption. Access follows least privilege: only staff and systems with a defined need get it.
Residual risk. No system achieves absolute security; controls are reviewed and incidents acted on.
§10Data-subject requests
Depending on the law that governs your situation, you can request:
- Access — confirmation of processing and a copy of your data;
- Rectification — fixing entries that are inaccurate or incomplete;
- Erasure — deletion;
- Restriction or objection — pausing processing, or halting processing grounded in legitimate interest;
- Portability — an export, machine-readable, of data you supplied;
- Consent withdrawal — for anything that relies on consent.
Procedure. Email growth@lirtam.click. Identity verification may be required. Response time: one month, extendable by two more months for complex or high-volume requests, with notice to you.
Locating records. A transaction ID or purchase date in your request helps us find data linked to your installation.
Complaints. You can complain to the supervisory authority in the country of your residence or workplace, or where the alleged breach happened.
§11US state privacy laws
Residents of California and other US states with comprehensive privacy statutes also have the following rights.
Know, delete, correct: obtain the categories and specific items of personal information held about you, or have them deleted or corrected.
Sale and sharing. Lirtam does not sell personal information. To opt out of “sharing” — disclosure for cross-context behavioural ads — select “Ask App Not to Track” in iOS, or email us using the subject Do Not Share.
Categories collected over the past 12 months: identifiers; commercial information (purchase records); network activity information (usage events, diagnostics); approximate location derived from IP; the contents of any support email you send. Sources, purposes and recipients match Table 3.1.
Non-discrimination. Using these rights never changes the price or quality you receive.
Agents. An authorised agent may submit requests with your signed permission; we may verify you directly.
Shine the Light (California). Once per calendar year you may ask whether we passed personal information to third parties for their direct marketing. Lirtam makes no such disclosures.
§12Age threshold
Threshold: 16. CleanAgent is not intended for younger users and Lirtam does not knowingly collect their data. A parent or guardian who thinks a child under 16 has given us data can contact us to have it erased.
§13Revision control
Every revision updates the effective date shown above. For significant revisions, an in-app notice appears before they apply. The version at this URL is the one in force.
§14Contact
- Controller
- Lirtam LLC
- Country
- United Arab Emirates
- Address
- Sharjah Media City, Sharjah, UAE
- growth@lirtam.click
See also the Terms and Conditions and the Subscription Billing Terms.