PRIVACY POLICY

Last updated: March 19, 2026

1. INTRODUCTION

LEMON CODES TECNOLOGIA DA INFORMACAO LTDA, registered under CNPJ no. 39.757.236/0001-02, is responsible for processing personal data collected through the WallMaker application.

This Privacy Policy describes how we collect, use, store, and protect your personal information in accordance with Federal Law no. 12.965/2014, Federal Law no. 13.709/2018 (LGPD), and, when applicable, European Regulation no. 2016/679 (GDPR).

2. DATA PROTECTION OFFICER (DPO)

• Name: Hugo Jose da Silva Sousa.
• Email: goj1@hotmail.com.
• For matters related to data protection, the data subject may contact the DPO directly.

3. PERSONAL DATA COLLECTED

• Data provided by the user, such as name, email, login credentials, and other information entered in registration or profile fields.
• Usage data, including accessed features, interactions with creation, downloads, purchases, publications, and marketplace activity.
• Technical data such as device type, operating system, app version, language, IP address, and error logs.
• Images, wallpapers, metadata, and other content uploaded or produced by the user within the platform.
• Subscription and purchase information received from app stores, such as subscription status, plan type, billing dates, and transaction identifiers.

4. DATA WE DO NOT COLLECT DIRECTLY

• WallMaker does not directly collect or store full credit card data, debit card data, or other sensitive financial information.
• Payments are processed exclusively by the Apple App Store and Google Play Store.

5. PURPOSE OF DATA PROCESSING

• Authentication, account creation, and account management.
• Provision of creation, editing, download, publication, and wallpaper commercialization features.
• Personalization of the experience and content recommendations.
• Processing of purchases, subscriptions, credits, and release of benefits.
• Communication about updates, support, security, and operational matters.
• Monitoring, moderation, prevention of fraud, abuse, and unlawful activities.
• Compliance with legal and regulatory obligations and defense of rights.

6. LEGAL BASIS FOR PROCESSING

• Consent, when applicable.
• Performance of a contract and preliminary procedures related to the use of the platform.
• Compliance with legal or regulatory obligations.
• Regular exercise of rights in judicial, administrative, or arbitration proceedings.
• Legitimate interest for security, service improvement, fraud prevention, and platform protection.

7. DATA SHARING

• Essential service providers such as hosting, authentication, analytics, storage, error monitoring, and notifications.
• Apple App Store and Google Play Store for payment processing, subscriptions, and purchase validation.
• Other platform users, to the extent necessary for content display, creator public profile visibility, and marketplace operation.
• Public or judicial authorities when there is a legal obligation, competent order, or need to defend rights.
• WallMaker does not sell, rent, or trade personal data with third parties.

8. DATA STORAGE AND SECURITY

• Data may be stored in Brazil and/or by cloud providers that comply with applicable legal requirements.
• We adopt reasonable technical and organizational measures, including encryption in transit, access control, monitoring, and security routines.
• No system is completely immune to failures, therefore absolute security cannot be guaranteed.

9. RETENTION PERIOD

• Personal data is kept while the account remains active and for the period necessary to fulfill the purposes of this policy.
• In the event of an account deletion request, identifiable data may be deleted or anonymized within a reasonable period, subject to legal retention obligations.
• Anonymized data may be retained for statistical, security, and service improvement purposes.
• Information related to purchases, subscriptions, and transfers may be retained for the period required by tax, accounting, and rights defense legislation.

10. DATA SUBJECT RIGHTS

• Confirmation of the existence of processing and access to data.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data.
• Portability, when applicable.
• Information about data sharing.
• Revocation of consent and deletion requests, when applicable.

11. HOW TO EXERCISE YOUR RIGHTS

• General email: hello@lemoncodes.com.br.
• DPO: goj1@hotmail.com.
• Suggested subject line: DATA SUBJECT RIGHTS - [specify the request].
• Account deletion requests may require confirmation of identity and of the registered email address.

12. CONSENT

By creating an account and using the WallMaker application, you acknowledge this Privacy Policy and, when applicable, consent to the processing of personal data under the terms described herein.

Revocation of consent may make it impossible to use certain features or may result in account termination where processing is essential to provide the service.

13. COOKIES AND SIMILAR TECHNOLOGIES

• The application may use technologies to maintain authentication, store preferences, analyze usage, and improve the experience.
• Management of these preferences may depend on device settings and integrated services used by the application.

14. CHILDREN'S PRIVACY

WallMaker is not intended for the intentional collection of personal data from minors without authorization or supervision from their legal representatives, when required by law.

15. INTERNATIONAL DATA TRANSFER

When necessary, international data transfers may occur through service providers or infrastructure, subject to adequate protection mechanisms and applicable legal requirements.

16. THIRD-PARTY LINKS

The application may contain links to third-party websites, stores, and services. This policy does not apply to those external environments.

17. UPDATES TO THIS POLICY

• This Privacy Policy may be changed at any time to reflect changes in app practices, new legal requirements, or clarity improvements.
• Relevant changes may be communicated through in-app notifications, registered email, or notices on service screens.
• Continued use of the application after changes constitutes acceptance of the current version.

18. GOVERNING LAW AND JURISDICTION

This Policy is governed by Brazilian law, especially the General Data Protection Law. The court of the District of Brasilia, Federal District, is elected to resolve disputes related to this Policy, with express waiver of any other jurisdiction.

19. CONTACT

• General email: hello@lemoncodes.com.br.
• Business hours: 09:00 to 18:00 on business days.