Cadence - Privacy Policy

1. Introduction

Cadence is an iOS speaking-practice application operated by Sirca. This policy explains what information may be collected when you use Cadence, how it is used and shared, and the choices available to you.

2. Information Collected

Cadence uses the TikTok App Events SDK for advertising attribution, campaign measurement, analytics and, where permitted, advertising optimisation. Depending on your device, permissions and use of the app, the SDK may collect or receive:

• • Device identifiers, including advertising or vendor identifiers where available;
• • Purchase and subscription events or status, but not payment-card or bank details;
• • Product interactions, including app installs, launches, sessions and feature interactions;
• • Advertising and attribution data, including campaign and ad-interaction information;
• • Approximate location derived from information such as IP address, country, region, language or locale; Cadence does not provide precise GPS location to TikTok for these purposes; and
• • Crash, performance and other diagnostic information.

TikTok may associate device identifiers, purchase events, product interactions, advertising data and approximate location with a device or identity for advertising measurement or tracking where you have authorised tracking. Diagnostic information is used for analytics and reliability and is not designated by Sirca for tracking.

3. Speaking Exercises and Audio

Cadence may request microphone or speech-recognition access to provide speaking exercises. Sirca does not provide voice recordings, lesson responses or the content of your spoken practice to TikTok for advertising or tracking. Device and Apple services may process permissions or speech-related functions under your iOS settings and Apple's applicable terms and privacy policy.

4. How Information Is Used

Information described above may be used to:

• • Attribute app installs, subscriptions and other events to advertising campaigns;
• • Measure campaign performance and understand app engagement;
• • Optimise advertising delivery and create or measure advertising audiences where permitted;
• • Detect duplicate or invalid events and support security or fraud prevention; and
• • Diagnose crashes, performance issues and technical problems.

Sirca does not authorise TikTok to receive sensitive information, voice content, lesson answers, payment-card details, contacts, or precise GPS location through the SDK.

5. Tracking Permission and Your Choices

Where Apple's App Tracking Transparency framework or applicable law requires consent, Cadence asks for permission before using app data for tracking across apps or websites owned by other companies. You may decline without losing access to Cadence's core speaking features.

You can change your choice at any time in iOS Settings → Privacy & Security → Tracking → Cadence. Disabling tracking limits the use of advertising identifiers and cross-app tracking. It may not prevent the processing of limited, non-tracking information needed for attribution permitted by Apple, diagnostics, security, or basic analytics.

Sirca does not sell personal information for money. Disclosure through the TikTok SDK for targeted advertising or advertising measurement may be considered a "sale," "sharing," or targeted advertising under some laws. Denying or revoking tracking permission is the in-app method for opting out of that activity. You may also contact us using the details below.

6. Third-Party Services

Cadence uses the following third-party services:

• • TikTok App Events SDK: advertising attribution, measurement, analytics and campaign optimisation. TikTok processes information under its own terms, privacy policy and applicable TikTok Business Products Data Terms.
• • Apple App Store and StoreKit: app distribution, subscription management and payment processing. Apple processes billing information; Sirca does not receive your full payment-card details.

Review TikTok's privacy policy, TikTok's Business Products Data Terms, and Apple's privacy policy.

7. Subscriptions and Payments

Purchases and subscriptions are processed by Apple. Sirca may receive subscription status and transaction events needed to provide paid features and measure campaign performance, but does not receive your complete card number or Apple ID password. You can manage or cancel subscriptions in your Apple Account settings.

8. Data Retention and Deletion

Sirca retains information it directly controls only for as long as reasonably necessary for the purposes described in this policy, legal compliance, dispute resolution and enforcement of agreements. Campaign and attribution reports may be retained in aggregated or reporting form for legitimate business records.

TikTok and Apple control their own systems and retention periods. Sirca cannot directly delete information held solely by those providers. You may contact us to exercise an applicable right concerning information Sirca controls, and contact the relevant provider regarding information it controls. Deleting Cadence does not necessarily delete information already transmitted to a third party before deletion.

9. International Transfers

TikTok, Apple and their service providers may process information in countries other than the country where you live. Those providers are responsible for the safeguards applicable to their processing under their terms and privacy notices. Sirca uses providers subject to contractual and legal data-protection obligations but cannot control their independent infrastructure or security practices.

10. UK and European Privacy Rights

Where UK GDPR or EU GDPR applies, tracking and targeted-advertising processing is based on consent where required. Essential app functionality is processed as needed to provide the service, and limited analytics, security and legal-compliance processing may rely on legitimate interests or legal obligations where permitted.

Depending on applicable law, you may have rights of access, correction, deletion, restriction, portability, objection and withdrawal of consent, and the right to complain to your data-protection authority. Withdrawal does not affect processing already lawfully completed. Contact us to submit a request concerning data Sirca controls; we may need to verify your request.

11. United States Privacy Rights

Residents of California and certain other states may have rights to know, access, correct or delete personal information and to opt out of sale, sharing or targeted advertising. Sirca does not discriminate against you for exercising an applicable right. Use Apple's tracking controls as described above or contact us to make a request. These rights are subject to legal exceptions and verification requirements.

12. Children's Privacy

Cadence is not intended for children under 13 to use independently. A parent or guardian should supervise a child's use where appropriate and provide any consent required by law. We do not knowingly use TikTok tracking data from children in violation of applicable law. If you believe a child's information has been processed improperly, contact us so we can investigate and take appropriate action.

13. Security and Third-Party Responsibility

Sirca uses reasonable administrative and technical measures appropriate to the information it controls, but no transmission or storage system is completely secure. Third-party providers control their own systems and are responsible for their processing under their policies, contracts and applicable law. Nothing in this policy excludes rights or responsibilities that cannot lawfully be excluded.

14. Changes to This Policy

We may update this policy to reflect changes to Cadence, third-party services or legal requirements. We will update the date above and provide any additional notice required by law. Continued use after an update is subject to the revised policy, except where further consent is legally required.

15. Contact Us

For privacy questions or requests:

• • Email: info@sirca.io
• • Website: sircatg.com