Effective Date: July 1, 2025

Last Updated: April 7, 2026

SC POLISEMANTIC IDEAS SRL (“Transform The Day”, the “Company”, “we”, “us”, or “our”) respects the privacy of personal data and is committed to processing it lawfully, fairly, and transparently.

This Privacy Policy explains how we collect, use, store, disclose, and protect personal data when you use the Transform The Day mobile application (the “App”) and the related services (the “Services”).

By using the App, you confirm that you have taken notice of this Privacy Policy. If you do not agree with the practices described in this policy, please stop using the App.

Contents:

1. Who is the data controller
2. What data we collect
3. How we collect da
4. How we use data
5. Legal bases for processing
6. Connecting Instagram, Facebook, and other third-party accounts
7. Use of AI services and third-party providers
8. How we share data
9. Payment data
10. Data storage and security
11. Data retention
12. International data transfers
13. Your rights
14. Children’s privacy
15. Cookies, SDKs, and similar technologies
16. Automated decision-making and profiling
17. Changes to the policy
18. Contact

1. Who is the data controller

The controller of the personal data processed through the App is:

SC POLISEMANTIC IDEAS SRL

Bucharest, District 1, Romania

Contact email: contact@transformtheday.ai

If you have questions regarding the processing of your personal data or if you wish to exercise your legal rights, you may contact us at the address above.

2. What data we collect

În funcție de modul în care utilizați Aplicația, putem colecta și prelucra următoarele categorii de date:

2.1. Identification and account data

- email address;

- account identifiers;

- name or alias, if provided by you or by the authentication service;

- data received from authentication providers such as Google or Apple, for example:

- the name associated with the account;

- email address;

- the unique identifier provided by the relevant service;

– adresă de tip relay oferită de Apple, dacă alegeți această opțiune.

2.2. Data provided directly by you

- responses to questionnaires and onboarding;

- information entered in forms, chat, or other fields within the App;

- the content of requests, instructions, prompts, or messages sent through AI functionalities;

- feedback, reviews, questions, and support requests;

- any other information you choose to provide voluntarily.

2.3. Data about the use of the App

- information about how you interact with the App;

- pages, screens, functionalities, or modules accessed;

- actions performed in the App;

- session data, time of use, and usage preferences;

- service performance data and technical errors.

2.4. Technical and device data

- device type;

- operating system;

- app version;

- technical identifiers of the device or application, to the extent permitted by law and device settings;

- IP address;

- language, time zone, and regional settings;

- log, diagnostic, and crash reporting data.

2.5. Subscription and payment data

- subscription type;

- subscription status;

- transaction and billing history;

- information about the platform through which payment was made.

We do not directly store full payment card details. Payment processing is carried out by third-party providers such as Apple App Store, Google Play Store, and/or other relevant payment processors.

2.6. Data from connected social media accounts

If you choose to connect third-party accounts such as Instagram or Facebook through official authentication and authorization mechanisms provided by third parties (for example, OAuth), we may process data such as:

– username;

- profile or page name;

- profile picture;

- account or page ID;

- information about professional accounts or connected pages;

- content available through official APIs, including posts, captions, Reels, media, and associated metadata;

- performance metrics such as reach, engagement, impressions, and other statistics available through the API;

- comments and interactions related to the content, if such functionalities are enabled and authorized by you;

- other data made available to us by the third-party platform based on the permissions granted by you.

We do not collect your Instagram or Facebook password when authentication is performed through the official flows of the relevant third-party provider.

2.7. Data regarding visual content

If you use visual creation, editing, analysis, or processing functionalities, we may process:

- images uploaded by you;

- images generated through the App;

- visual elements edited through the App;

- metadata associated with files, to the extent necessary for the operation of the service.

2.8. Data we do not intend to collect

We do not intentionally request special categories of personal data (for example, health data, biometric data, political opinions, religious beliefs, etc.), unless you explicitly choose to enter such data into the App. We recommend that you do not transmit such data unless it is strictly necessary.

3. How we collect da

We collect data through the following methods:

3.1. Directly from you

We collect data when you:

- create an account;

- log in using email, Google, or Apple;

- complete questionnaires;

- enter text, prompts, or other information into the App;

- upload images or other materials;

- contact us by email or through support;

- activate or use premium functionalities.

3.2. Automatically, through use of the App

We may automatically collect certain technical and usage data through logs, SDKs, analytics tools, security tools, and similar technologies.

3.3. From third-party services connected by you

We receive data from third-party providers when you:

- log in with Google or Apple;

- connect an Instagram, Facebook, or other compatible third-party account;

- use functionalities that depend on APIs or third-party services.

3.4. From payment providers and distribution platforms

We may receive information from Apple App Store, Google Play, or other payment processors regarding purchases, renewals, cancellations, refunds, and subscription status.

4. How we use data

We use your personal data for the following purposes:

4.1. Providing and administering the Services

- creating and administering your account;

- authentication and securing access;

- providing the App’s functionalities;

- personalizing the user experience;

- providing recommendations, strategies, and suggestions generated by the system;

- managing subscriptions and access to premium features.

4.2. Analysis and personalization

- analyzing responses to questionnaires;

- analyzing how the App is used;

- analyzing connected social media accounts and content performance;

- generating personalized recommendations;

- adapting results and the experience to the user’s needs.

4.3. AI functionalities

- processing input entered by you;

- generating responses, strategies, suggestions, post ideas, or other outputs;

- analyzing content provided by you or available through connected accounts, if necessary for the requested functionality;

- generating or editing images and other materials.

4.4. Support and communication

- responding to your requests;

- sending notifications regarding your account, subscription, or service operation;

- resolving technical incidents;

- providing customer support.

4.5. Product improvement and security

- understanding how users use the Services;

- detecting errors, fraud, unauthorized access, and abusive use;

- improving the performance, stability, and security of the App;

- developing new functionalities.

4.6. Marketing

- sending promotional communications, newsletters, or offers where we have your consent or another applicable legal basis;

- analyzing the effectiveness of communications and marketing campaigns;

- sending communications about similar services where permitted by law.

4.7. Compliance with legal obligations

- complying with legal, tax, accounting, and regulatory requirements;

- handling requests from authorities;

- defending our rights and legitimate interests.

5. Legal bases for processing

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction that requires identification of a legal basis for processing, we process your data on the basis of one or more of the following legal grounds:

5.1. Performance of a contract

We process data where this is necessary for:

- creating and administering your account;

- providing the App’s functionalities;

- providing the requested recommendations and analyses;

- connecting and using social accounts at your request;

- managing subscriptions and access to paid services;

- service-related support.

5.2. Legitimate interests

We process data where we have a legitimate interest, provided that your rights and freedoms do not override it, for example for:

- security and protection of infrastructure;

- prevention of fraud and abuse;

- internal analysis and service improvement;

- defense of our rights in the event of a dispute;

- measuring App performance.

5.3. Consent

We rely on consent where required, for example for:

- certain marketing communications;

- certain tracking or advertising technologies where the law requires consent;

- certain optional permissions of the device or third-party accounts, as applicable.

You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

5.4. Legal obligation

We process data where this is necessary to comply with legal obligations applicable to us.

6. Connecting Instagram, Facebook, and other third-party accounts

6.1. Optional account connection

After authenticating in the App, you may choose to optionally connect third-party accounts, including Instagram and Facebook, in order to activate certain functionalities.

6.2. What we process from connected accounts

Depending on the permissions granted by you, the type of account, and the data available through the platform’s official APIs, we may process:

- profile information and identifiers;

- information about pages or professional accounts;

- content and associated metadata;

- performance metrics and statistics;

- comments and interactions, if the relevant functionality is enabled and authorized;

- other data available through the API and permitted by the relevant platform.

6.3. Purpose of using data from connected accounts

We use this data exclusively for:

- account and content analysis;

- providing personalized recommendations;

- generating insights and strategic suggestions;

- functionalities expressly requested by the user;

- improving the experience within the App.

We will not publish content, respond to comments, modify settings, or perform other actions on your behalf on third-party platforms unless:

- such functionality is explicitly offered in the App; and

- you have expressly authorized such action.

6.4. Revoking access

You may revoke the App’s access to your third-party accounts at any time:

- from your account settings on the relevant third-party platform;

- from the settings available in the App, if such option is implemented.

After disconnection, we will stop collecting new data from the relevant account and will delete or anonymize the associated data within a reasonable time, generally no later than 30 days, except where retention is necessary for:

- legal obligations;

- security;- security;

- fraud prevention;

- dispute resolution;

- temporarily retained backup copies.

6.5. Third-party platforms

The App may use official integrations and APIs provided by third parties, including Meta Platforms, Inc. and its services, such as Facebook and Instagram. The use of such integrations is also subject to the terms, conditions, and policies of the respective platforms.

Except where expressly and officially indicated otherwise, no such integration shall be interpreted as constituting sponsorship, endorsement, or administration of the App by the respective third-party platforms.

The use of connected accounts is also subject to the terms, policies, and practices of the respective platforms. For more information, we recommend that you consult the privacy policies of Meta, Google, Apple, and other relevant providers.

7. Use of AI services and third-party providers

7.1. AI-based functionalities

The App uses artificial intelligence technologies and models to generate responses, recommendations, strategies, content ideas, visual materials, and other outputs.

7.2. Third-party AI providers

For certain functionalities, we may use third-party AI technology providers, including OpenAI and Google, as well as other similar providers, depending on the active functionalities.

7.3. What data may be processed through these providers

To the extent necessary to provide the functionalities requested by you, we may transmit to such providers:

- text entered by you;

- questionnaire responses;

- prompts and instructions;

- content selected for analysis;

- uploaded or generated images;

- certain data derived from connected social media accounts, if necessary for the requested analysis, recommendation, or function.

7.4. Purpose of this processing

The data is processed by these providers exclusively for:

- generating outputs and responses;

- analyzing content;

- providing AI functions available in the App;

- supporting the technical operation of the product.

7.5. No sale of data

We do not sell your data to AI providers. We use such providers only to the extent necessary for the operation and delivery of the Services.

7.6. Warning regarding information entered by the user

We recommend that you do not enter into AI functionalities:

- unnecessary sensitive data;

- confidential information that you are not entitled to disclose;

- personal data relating to third parties without a legal basis.

8. How we share data

We do not sell your personal data. We may share your data only in the following situations:

8.1. Service providers

We may share data with providers that help us operate the App, for example for:

- hosting and cloud infrastructure;

- authentication;

- analytics and monitoring;

- technical support;

- email and communication services;

- storage and security;

- AI processing;

- social network integration;

- image and media file processing.

These providers will process data on our behalf or, in some cases, as independent controllers, depending on the nature of the service.

8.2. Payment providers and distribution platforms

We may receive and share necessary data with Apple App Store, Google Play, and/or other relevant processors in connection with subscriptions, payments, cancellations, or refunds.

8.3. Third-party services connected by you

When you choose to connect Instagram, Facebook, or other third-party services, certain data exchanges take place between the App and those platforms based on the authorization granted by you.

8.4. Legal requirements and protection of rights

We may disclose data where necessary for:

- compliance with legal obligations;

- responding to legitimate requests from authorities;

– investigarea fraudei sau a abuzului;

- protecting the rights, property, or safety of the Company, users, or third parties;

- enforcing our contractual terms.

8.5. Corporate transactions

In the event of a reorganization, merger, acquisition, sale of assets, or similar transaction, data may be transferred to the successor entity, subject to applicable legal safeguards.

9. Payment data

Payments and subscriptions may be managed through:

- Apple App Store;

– Google Play Store;

- other payment providers indicated in the App.

We do not directly store your full payment card number. Information regarding the card and payment methods is processed by the relevant payment providers in accordance with their own privacy policies and contractual terms.

We may process information such as:

- subscription type;

- payment status;

- purchase date;

- renewal date;

- cancellation or refund status;

- transaction identifiers.

10. Data storage and security

We implement reasonable and appropriate technical and organizational measures to protect personal data against:

- unauthorized access;

- misuse;

- accidental loss;

- destruction;

- unauthorized alteration or disclosure.

These measures may include, where appropriate:

- access control;

- encryption in transit and/or at rest;

- role separation and internal access restrictions;

- logging and monitoring;

- backups;

- periodic security assessments.

However, no IT system and no method of transmission or storage can guarantee absolute security.

11. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including for:

- providing the Services;

- maintaining the account;

- performing the contract;

- compliance with legal obligations;

- dispute resolution;

- preventing fraud and defending our rights.

Depending on the category of data, retention periods may, by way of guidance, be as follows:

11.1. Account data

It is retained for the duration of the account’s existence and for a reasonable period thereafter, as necessary for legal obligations, security, and management of potential disputes.

11.2. Communication and support data

It may be retained for up to 5 years if this is necessary for support, internal records, defense of our rights, or legal obligations.

11.3. Usage and diagnostic data

It may be retained for limited periods depending on operational necessity, internal analysis, and security.

11.4. Payment and billing data

It is retained in accordance with applicable legal, tax, and accounting obligations and in accordance with the rules of relevant providers.

11.5. Data from connected social accounts

It is retained as long as the account remains connected and for as long as necessary to provide the requested functionalities. After disconnection, we will delete or anonymize it within a reasonable time, generally no later than 30 days, except where legal obligations or legitimate reasons justify temporary retention.

11.6. Images and content processed through AI

They are retained for as long as necessary to provide functionalities, maintain account-related history, security, improve the service, and administer deletion requests. If you request deletion of your account or data, we will process the request in accordance with applicable law and our internal policies, taking into account any temporary backup copies.

12. International data transfers

Depending on the infrastructure used and the third-party providers involved, your data may be transferred to and processed outside your country of residence, including outside the European Economic Area, for example in the United States.

Where we transfer data outside the EEA or other jurisdictions requiring special safeguards, we take measures to ensure an adequate level of protection, such as:

- Standard Contractual Clauses approved by the European Commission;

- adequacy decisions, where available;

- other lawful transfer mechanisms recognized by applicable law.

13. Your rights

Depending on applicable law, you may have the following rights:

- the right to access your data;

- the right to rectification;

- the right to erasure;

- the right to restriction of processing;

- the right to data portability;

- the right to object to certain processing;

- the right to withdraw your consent where processing is based on consent;

- the right to lodge a complaint with the competent supervisory authority.

If you are located in Romania, the competent authority is:

National Supervisory Authority for Personal Data Processing (ANSPDCP)

To exercise your rights, you may write to us at:

contact@transformtheday.ai

We may request reasonable information to verify your identity before responding to a request.

14. Children’s privacy

The App is not intended for use by children who do not have the legal capacity to accept the applicable terms without the involvement of a parent or legal guardian, in accordance with applicable law.

If you are under 18 years old, you must use the App only with the consent of your parent or legal guardian.

We do not knowingly collect personal data from children below the minimum age permitted by law without the required consent of a parent or legal guardian. If we learn that we have collected such data without the necessary legal basis, we will take reasonable steps to delete it.

Parents or legal guardians may contact us at contact@transformtheday.ai for requests relating to a minor’s data.

15. Cookies, SDKs, and similar technologies

The App and related services may use technologies such as:

– SDK-uri;

- device identifiers;

- local storage;

- logs;

- analytics and monitoring technologies;

- cookies or similar technologies, to the extent they are used through websites, webviews, or related services.

These technologies may be used for:

- technical operation of the service;

- remembering preferences;

- security;- security;

- performance analysis;

- diagnostics and product improvement;

- marketing and campaign measurement, where permitted and/or with the necessary consent.

You may control certain settings through your device, operating system, browser settings, or app settings, as applicable.

16. Automated decision-making and profiling

We may use automated processes, including AI models and algorithmic logic, for:

- personalizing the experience;

- generating recommendations;

- analyzing responses and content;

- evaluating the performance of connected content;

- detecting unusual or abusive activities.

These processes are used to provide the App’s functionalities and, generally, do not produce legal effects or similarly significant effects based solely on an automated decision without human involvement, within the meaning of applicable law.

17. Changes to the policy

We may update this Privacy Policy from time to time to reflect:

- changes to our services;

- technological changes;

- new integrations or providers;

- legal or regulatory requirements.

If the changes are important, we will inform you through reasonable means, for example:

- in-app notification;

- updating the published text;

- email, where appropriate.

Your continued use of the App after the updated version takes effect constitutes confirmation that you have taken notice of the changes.

18. Contact

For any questions, requests, or complaints regarding data protection, you may contact us at:

SC POLISEMANTIC IDEAS SRL

Bucharest, District 1, Romania

Email: contact@transformtheday.ai

If you write to us to exercise a legal right, please include:

- your name;

- the email address associated with your account;

- a description of your request;

- any useful information to help identify the request.