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Intentionally Creative — Privacy Policy

Last updated: September 1, 2026 · rev 4

[INTENTIONALLY CREATIVE LEGAL ENTITY NAME, JURISDICTION], trading as Intentionally Creative ("Intentionally Creative," "we," "our" or "us"), respects the privacy of the people who use our apps and visit our website, and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy does not address the privacy practices of any third party we do not own or control.

Please read this Privacy Policy together with our Terms of Service, available at https://legal.alc.fyi/legal/terms.html.

By downloading or using our apps, you agree that we will collect and process personal information in accordance with this Privacy Policy. If you are not comfortable with any part of it, please stop using the apps.

Our apps are not intended for children. If you are a minor — under 16 in the European Union and the United Kingdom, under 13 in the United States, or under the minimum age at which you can consent to data processing where you live — you must not download or use our games or provide any personal information to us. Milestone has a stricter rule, because it is a family planning app: the person who installs it and owns the plan must be an adult. See Section 9 and Annex D.

The short version

Everything below is the long form of five sentences.

1. None of our apps asks you to sign up. There is no email address, no password, no username and no profile. What each app has instead is an anonymous device account — a random identifier kept in your phone's keychain, created without asking you for anything — and its only job is to let the app store a copy of your own data for you and hand it back to the same phone. We never learn your name.
2. The thing you make lives on your phone, and some of it is copied to a server we run ourselves. In the two games that copy is your game progress. In Before I Unpack it is your records and photographs, and only if you switch Backup on — it is off until you do. In Milestone it is the plan. The server is our own machine, operated by us; no third-party cloud service holds any of it. Section 2.4 and the annexes say exactly what is copied in each app, and what never is.
3. What does leave is a closed list of counted events — screens opened, levels finished, a purchase completed — with no free text, no names, no amounts and no photographs in them. Every app enforces that list in code before an event reaches any provider.
4. Our two games show ads. Our two utility apps show none, ask no tracking permission, and contain no advertising SDK at all.
5. You can turn analytics off in every app, and "Delete everything" in each app's settings deletes both what is on the phone and what your account owns on our server. It asks the server first and refuses to wipe the phone if the server delete fails, so it can never tell you something is gone while it is still here.

Two promises we hold ourselves to by name, because they are the reason those two apps exist:

Before I Unpack: nothing leaves your phone until you switch Backup on, and Backup starts off. With it off there is no account, no session and no request of any kind. Switch it on and your records and photographs are copied to our own server — encrypted on the way there and encrypted at rest, but not end-to-end encrypted: we hold the keys, which is what the app itself says on the screen where you turn it on. Your key codes and the message you wrote to your landlord are never uploaded in either state. Anonymous usage analytics in that app is also off unless you turn it on.

Milestone: names, amounts, notes and photographs never appear in analytics. Not "we would not send them" — the app filters every event against an allowlist of permitted properties before any provider sees it, and anything not on that list is dropped. That is a promise about analytics, and only about analytics. The plan itself, names and photographs included, is stored on our own server so the owner's phone can get it back. Storing your plan for you and sending a counted event to an analytics provider are two different acts with two different rules, and Annex D keeps them apart.

Contents

1. Scope and Applicability
2. Personal Information That We Collect
3. Why We Collect Your Personal Information
4. How We Disclose Your Personal Information
5. Your Rights and Choices
6. Security
7. Transfers of Your Personal Information
8. Retention of Personal Information
9. Children
10. Changes to This Privacy Policy
11. Contact Us
12. Additional Notice to Individuals in the United States
13. Additional Notice for California Consumers: California Notice at Collection
14. Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland
15. Additional Notice to Individuals in Brazil

• Annex A — Parcel Rush
• Annex B — Pack Perfect
• Annex C — Before I Unpack
• Annex D — Milestone

1. Scope and Applicability

This Privacy Policy applies to personal information we collect when you:

• use our mobile applications that link to this Privacy Policy — Parcel Rush, Pack Perfect, Before I Unpack and Milestone (collectively, the "Apps");
• visit websites we own or operate that link to this Privacy Policy, including get-creative.co (the "Sites"); or
• contact us by email at support@get-creative.co.

The Apps and the Sites are together the "Services."

The per-app annexes are part of this policy, not a summary of it. Our four apps do genuinely different things with data, and the annex for the app you are using is the specific, binding statement for that app. Where an annex is narrower than the common sections, the annex governs.

2. Personal Information That We Collect

The sections below list the categories of personal information that may be collected across the Services. Not every category applies to every app — which categories apply to which app is set out in the annexes, and an app that does not contain a provider collects nothing through it.

2.1 Information you voluntarily provide us

Almost nothing, because no app asks you to register. None of them has a sign-up form, and none of them has a field for who you are.

• Correspondence. If you email support@get-creative.co, we receive your email address and whatever you write to us, and we keep it long enough to answer you and to keep a record of the request.
• App settings and preferences. Your language, sound and gameplay preferences are stored on your device; in the two games they also travel with the cloud save, so a new phone plays the way the old one did. Your analytics choice is stored on the device only and is never uploaded.
• The content you put into Before I Unpack and Milestone, in the circumstances Section 2.4 sets out. You give it to the app, and the app copies some of it to our server.

We do not ask for, and the Apps have no field for, your name, postal address, phone number, date of birth, or a photograph of you. Names, phone numbers, addresses and photographs that you type or take inside an app — the people in a Milestone court, the address of the flat in Before I Unpack — are Section 2.4's subject rather than this one: we never ask for them, we never use them to identify you, and they are never sent to an analytics provider or an advertiser.

2.2 Information collected automatically

• Your anonymous account identifier. When an app creates its anonymous device account (Section 2.4), our server issues a random user id and the app keeps it in your phone's keychain. Every row and every file the app stores for you is owned by that id, and the database refuses to hand one account's rows to any other. It carries no name, no email address, no password and no profile, and there is nothing in it from which we could work out who you are.
• Pseudonymous provider identifiers. Each analytics or attribution provider in an app generates its own random, device-local identifier (a PostHog "distinct id," an AppsFlyer ID, a RevenueCat anonymous app user ID). None of them is connected to a name, an email address, or to your account identifier.
• Device identifiers. The vendor identifier (IDFV) and, in our two games only and only if you allow tracking when asked, the advertising identifier (IDFA). Our two utility apps disable advertising identifiers at the SDK level before the SDK starts and never read the IDFA.
• Device and system information. Operating system and version, device model, time zone, language and country/region setting, app version.
• Coarse, country-level location. Advertising and attribution providers in our games derive an approximate country or region from your IP address. No app requests or receives precise or GPS location, ever, and no app asks for a location permission. In Before I Unpack and Milestone we disable the analytics provider's own IP-based location lookup.
• Product interaction events. A closed, named list of events per app — screens viewed, a level finished, a record exported, a paywall seen, a purchase started or completed. The full list for each app is in that app's annex.
• Advertising events (games only). Ad requests, impressions, clicks and the revenue an impression produced.
• Purchase records. Product identifier, transaction identifier, whether the entitlement is active. Apple, not us, processes the payment; we never see your card number, bank details or billing address.

2.3 Information we receive from third parties

• Apple and RevenueCat tell us that a transaction occurred, which product it was for, and whether the resulting entitlement is active or refunded.
• AppsFlyer tells us, at the level of a marketing campaign and never at the level of a person, that installs came from a particular campaign — using Apple's SKAdNetwork, which returns aggregated postbacks that contain no user identifier by design.

We do not buy personal information from data brokers, and we do not upload customer lists to advertising platforms to build custom or lookalike audiences.

2.4 Your account, our server, and what is stored on it

This is the most important section in this policy, and it is the one that changed in this revision. Read it before the annexes.

The account. Each app can create an anonymous device account for you. It is created silently, without a screen and without asking you for anything, because there is nothing to ask for: no email address, no password, no username, no profile, no phone number, no photograph of you. It is a random identifier that lives in your phone's keychain. When it is created differs by app, and the difference is deliberate:

The server. It is our own server infrastructure, operated by us: our own machine, running the open-source Supabase software we host ourselves, in a data centre in Ashburn, Virginia, United States. It is not a third-party "backend as a service", nothing is stored at supabase.com, and no other company holds your rows. Each app has its own database schema and its own private file bucket, and every table and bucket refuses to return anything to any account except the one that owns it.

What is stored on it, per app:

• Parcel Rush and Pack Perfect — your game progress, and nothing else. Boards cleared and their results, coins and stars, streaks, daily runs, album and postcard entries, unlocks and cosmetics, how you have arranged your yard or room, and which purchase is active. No photographs and no content of yours, because these games take none from you.
• Before I Unpack — nothing at all, unless you switch Backup on. With Backup on: your places and their addresses, your records, rooms, meter readings, key-set counts, inventory, the notes you wrote, and the original photographs and voice notes. Never uploaded in any state: your key codes, and the message you wrote to your landlord.
• Milestone — the owner's plan. The event, the people in it with their names and phone numbers, the court and the padrinos, the sequence, the decisions, rehearsals, day-of items, the thank-you list, and the photographs you add. Money — amounts, budget items, totals and vendor quotes — is stored in separate tables the honoree's side cannot reach; that is why it is a separate table rather than a column, because a fence around a column is not something a database can enforce.

What never reaches the server in any app: your analytics choice; Before I Unpack's key codes and landlord message; and, in Milestone, the settings that belong to that phone rather than to the event.

None of this is analytics. Analytics is Section 2.2's closed list of counted events, and no photograph, name, amount or note is ever in one. This policy never uses one of those two things to describe the other.

Consistent with that, in every app:

• Session replay is off. It would record the screen, and the screen contains your content.
• Autocapture and vendor lifecycle events are off. They would send text read off the interface, which is outside the app's declared event list.
• Event properties are limited to a declared allowlist. No event carries free text, a name, an amount, a note, a file path or a photograph.

3. Why We Collect Your Personal Information

• Operate and administer the Apps. Run the app, keep your progress, deliver what you purchased and restore it on a new device.
• Hold your copy for you, so the app can give it back. Keep on our server what Section 2.4 describes, and return it to your phone after a reinstall. In Before I Unpack this happens only because you switched Backup on; in Milestone and the games it is how the app keeps what you made.
• Provide customer support. Answer the email you send us.
• Send you service-related communications. If we have your email address because you wrote to us, we may reply and may tell you about a material change to these documents. We do not run a marketing mailing list from app data, because we do not collect email addresses in the apps.
• Understand and improve the Apps. Count how many people finished a level, exported a document or reached a screen, so we know what to fix and what to build. This is aggregate, pseudonymous and property-limited.
• Measure our advertising. Learn, at campaign level, which marketing produced installs, so we do not spend money on advertising that does not work.
• Show advertising (games only). Fill the ad placements in Parcel Rush and Pack Perfect, and — only if you allowed tracking — make those ads more relevant.
• Keep the Apps and our business secure. Detect fraud, abuse and technical failure.
• Comply with law. Meet our tax, accounting and legal obligations and respond to lawful requests.
• Corporate transactions. Handle a merger, acquisition or sale of the business (Section 4).
• With your consent, for any other purpose we describe to you at the time.

We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you.

4. How We Disclose Your Personal Information

• Nobody, for the content in Section 2.4 — with one ordinary exception, stated here so it is not a surprise. What an app stores on our server stays on our server. It is not sent to an analytics provider, an advertising network, another company's cloud or anyone else, and we do not read it to build products, train models or sell anything. The exception is infrastructure: our machine sits in a rented data centre, and the nightly backups described in Section 8 are held by two object-storage providers. Those companies hold encrypted copies under contract, act only on our instructions, and are not permitted to use them for anything of their own.
• Service providers. The analytics, attribution, advertising-mediation and purchase providers named in Section 2 and in the annexes, plus ordinary business vendors (email, accounting, legal). They may use the information only to provide the service to us. The full list, with the data each one receives and a link to its own privacy policy, is at https://legal.alc.fyi/legal/partners.html.
• Advertising partners — in our two games only. AppLovin MAX mediates our ad placements and passes an ad request to the advertising networks bidding on it. Those networks receive device and ad-event information and, if you allowed tracking, your advertising identifier. Under the broad definitions in some United States state privacy laws, this may be a "sale" or "sharing" of personal information. See Sections 12 and 13 for how to opt out. Our two utility apps contain no advertising SDK, so nothing of this kind happens in them.
• Merger, acquisition, or other business transaction. If we are acquired or sell substantially all of our assets, information may transfer to the acquirer. We will require the acquirer to remain subject to this Privacy Policy, or to obtain your consent.
• Professional advisors. Lawyers, accountants, auditors and insurers, where necessary for them to advise us.
• Legal obligations and safety. Where reasonably necessary to comply with valid legal process or a request from a public authority; to comply with law; to enforce our Terms; to protect our legal interests; or to protect the rights, property or safety of you, our users or others. Where we are legally permitted to do so, we will give you notice before disclosing your information in response to a demand.
• With your consent, to anyone else you direct.

We do not disclose personal information to co-sponsors, promotion partners or social platforms for their own marketing. We run no promotions, sweepstakes or contests, and no App has a social login.

5. Your Rights and Choices

5.1 Your privacy rights

Depending on where you live, you may have the right to:

• Know / access — obtain a copy, or a list of categories, of personal information we hold about you.
• Correct / rectify — have inaccurate personal information corrected.
• Delete / erase — have personal information we hold about you deleted.
• Portability — receive personal information in a structured, commonly used, machine-readable format.
• Restrict or object — limit or object to certain processing.
• Opt out of "sale," "sharing" or processing for targeted advertising.
• Non-discrimination — not be treated worse for exercising a right.
• Appeal a refusal, where your state or country provides that right.

5.2 The honest limit on access and deletion requests

We want to be exact about this rather than promise a process we cannot run.

We still hold no record we can look you up in. Your account has no email address, no password and no profile, so nothing on our side maps a row to a person. If you write to us from an email address, we cannot tell which account — if any — is yours, and we will not guess: matching a stranger's email address to somebody's photographs would be the worse of the two failures available to us.

Your phone can do what we cannot, and that is the design rather than an excuse. The account identifier lives in your phone's keychain, so the app is authenticated as you and as nobody else:

1. Use the delete in the app — Section 5.4. It removes what is on the phone and the rows and files your account owns on our server, because the app is signed in as that account at the moment it asks.
2. Take a copy without involving us. Before I Unpack exports the whole record as a PDF and Milestone's Exportar todo hands you the whole plan as a file, both on the device.
3. Give us the pseudonymous identifier if you want analytics events already sent to be removed. Every app can show you its analytics identifier on request via support@get-creative.co, and with it we will ask our analytics provider to delete the associated event stream. Without it there is nothing for either of us to point at.

If you want us to act on one of the rights in Section 5.1 and the routes above do not cover it, email us anyway and we will tell you honestly what we can and cannot do from our side.

To make any request, email support@get-creative.co with the subject line "Privacy Rights Request." We will respond within the period the applicable law allows. Where the law requires us to verify your identity before acting, we will ask for what we need and no more; where there is nothing to verify against, we will tell you so instead of asking for a copy of your ID.

Your rights are not absolute. We may decline a request where the law requires or permits us to, where granting it would harm another person's privacy, or where it has no legal basis.

5.3 The switches in the apps

5.4 Deletion

Every app has a destructive delete in its own settings, and it does what it says: it erases the app's saved content, its settings and the analytics bookkeeping stored on the device, and it deletes what your account owns on our server — the rows, and the files in that app's bucket — by calling a server-side delete_account routine that runs as your own account.

The order is server first, then phone. If the server delete fails, nothing on the phone is touched and the app tells you so, because an app that reported a deletion it had not performed is exactly the failure this path exists to prevent. Milestone goes one step further and reads the plan back afterwards, refusing to call it deleted while a row is still there.

One thing survives, and it holds nothing about you. The anonymous identity row itself — the empty account record, with no email address, no name and no profile in it — remains in the authentication system. Everything it owned is gone; the row is left because removing it is a separate operation and it contains no personal information to remove.

It cannot be undone and we cannot recover anything for you afterwards. If something matters to you, export it first.

It does not cancel or refund an App Store purchase. That purchase belongs to your Apple ID, and "Restore purchases" will bring it back on any device signed in to that Apple ID. Refunds are handled by Apple, not by us.

Full per-app instructions: https://legal.alc.fyi/legal/deletion.html.

6. Security

We use commercially reasonable administrative, technical and physical safeguards to protect personal information against unauthorized access, alteration, disclosure or destruction. Concretely:

• Everything is encrypted in transit between an app and our server.
• Every table and every file bucket is fenced to one account. The database refuses to return a row, or a file, to any account but the one that owns it, and that is enforced by the database itself rather than by the app asking politely. We test it on the live server with two accounts that try to read each other's rows.
• No key with administrative power is ever inside an app. The only key an app ships with is a public one that grants nothing on its own.
• Files are encrypted at rest on our server, and the private buckets are not readable without an authenticated request from the owning account.

What we do not claim: this is not end-to-end encryption. We hold the keys. That means we could in principle be compelled to hand over what is stored, and it means a breach of our server would be a breach of the content on it. Before I Unpack says exactly this, in its own words, on the screen where you switch Backup on, and this policy will not say anything softer than the app does. If that is not acceptable to you, leave Backup off — that app works completely without it.

No system is perfectly secure, and we cannot guarantee absolute security. We are not responsible for the security of information transmitted over networks we do not control. If you believe an interaction with us is no longer secure, tell us at support@get-creative.co.

7. Transfers of Your Personal Information

The limited data described in Section 2 is processed by providers that operate internationally, and it may be processed in the United States, the European Union and other countries where our providers maintain facilities. Those countries may have data protection laws that differ from those where you live.

Our own server is in the United States. The content Section 2.4 describes — your game progress, a Before I Unpack backup, a Milestone plan — is stored on our machine in a data centre in Ashburn, Virginia. Wherever you are, that is where it is, and it is not moved anywhere else. [OPEN ITEM — COUNSEL REQUIRED.] The transfer mechanism that applies to that storage for users in the EEA, the UK, Switzerland and Brazil depends on where our legal entity is established, which is unresolved. See OPEN-ITEMS.md.

Specifically, at the date of this policy: our product analytics for Parcel Rush, Pack Perfect and Before I Unpack is hosted in the European Union (PostHog EU Cloud), and for Milestone in the United States (PostHog US Cloud). Our attribution, advertising-mediation and purchase providers operate across multiple regions.

If you are in the EEA, the UK or Switzerland, see Section 14 for the transfer mechanisms we rely on. If you do not want your information transferred outside your country, stop using the Services and turn off analytics in the app.

8. Retention of Personal Information

We retain personal information only as long as needed for the purposes in this policy, or as required to meet legal obligations, resolve disputes and enforce our agreements.

In practice:

• Content you create in an app is retained on your device for exactly as long as you keep it, and is destroyed the moment you use "Delete everything."
• The copy on our server (Section 2.4) is kept for as long as your account holds it. There is no expiry timer and no periodic purge — it is there until you delete it, either with the in-app delete or, in Before I Unpack, with Delete the backup, which removes the server copy and leaves the phone untouched.
• Backups of our database. We back the database up every night, keep copies with two independent storage providers so that one failure cannot take both, and restore them into a scratch database on a schedule to prove they actually work. The copies are encrypted in transit and at rest and are used for disaster recovery and nothing else. A backup taken before you deleted something still contains it until that backup ages out, which is true of every system that has backups at all. [PLACEHOLDER — the backup retention window must be confirmed and stated here before publication. See OPEN-ITEMS.md.]
• Pseudonymous analytics events are retained by our analytics provider for the provider's standard retention period for our plan and then deleted or aggregated.
• Attribution postbacks are aggregated by design and are retained by our attribution provider under our contract with it.
• Purchase records are retained as long as we must keep them for tax, accounting and refund-dispute purposes.
• Support email is retained for as long as needed to resolve your request and to keep a record of it.

9. Children

Our Services are not directed to children and we do not knowingly collect personal information from a child below the minimum age in their jurisdiction.

Our games (Parcel Rush, Pack Perfect). You must not use them if you are under 16 in the European Union or the United Kingdom, under 13 in the United States, or under the minimum age of consent for data processing where you live. The games show advertising and, where allowed, use an advertising identifier; we do not operate them as child-directed services and they are not designed or rated for children.

Our utility apps (Before I Unpack, Milestone). These are adult tools. Milestone in particular:

The person who installs Milestone and owns the plan must be an adult — a parent, godparent or other adult organizer. The celebration's honoree is typically a teenager, and Milestone is built for her to take part on the account owner's device, under the account owner's supervision. Her side of the app is a view of the same plan, and her lane contains no money and no purchases: the budget does not exist in it, no amount, quota or vendor quote is ever shown to her, and she is never shown a paywall or a purchase prompt. This is enforced in the app, not by a policy sentence. There is no separate account for her and no login of her own. Her name, and the photographs in the plan, are stored on our server as part of the account owner's plan (Section 2.4) — that is the owner's own copy of her own celebration, held so that a lost phone does not lose it, and Borrar mi cuenta deletes all of it. Nothing about the honoree is ever sent to an analytics provider or an advertiser.

If you are a parent or guardian and believe a child has provided personal information to us, contact us at support@get-creative.co with the subject line "Request for Child Data Deletion – Parental Verification", and include:

• the app concerned;
• the app's analytics identifier from the child's device, if you can get it (Settings will show it on request to support);
• your contact details; and
• a clear request to delete all data relating to the child.

We will take reasonable steps to confirm you are the parent or guardian before acting, and we may reply to your email address for confirmation. We will not ask you for more identification than the request needs.

In almost every case the complete remedy is immediate and in your hands, and it reaches our server as well as the phone: open the app, use "Delete everything" (Borrar mi cuenta in Milestone), and then delete the app. That one action deletes the rows and files the account owns on our side, not only the ones on the device. We will confirm it in writing and will delete any pseudonymous event stream you can identify to us.

10. Changes to This Privacy Policy

We may change this Privacy Policy from time to time. The "Last updated" date at the top will change, and the change takes effect on that date. If a change materially affects your privacy rights — for example, if an app begins collecting a category it did not collect before — we will give additional notice in the app itself before the change takes effect. Continuing to use the Services after a change means you accept it.

11. Contact Us

Questions about this Privacy Policy or our privacy practices:

• Email: support@get-creative.co
• Post: [INTENTIONALLY CREATIVE LEGAL ENTITY NAME, REGISTERED ADDRESS]

12. Additional Notice to Individuals in the United States

12.1 Your rights

Depending on your state, you may have the rights listed in Section 5.1, including the right to know/access, correct, delete, port, opt out of sale or sharing for targeted advertising, opt out of profiling with legal or similarly significant effects, appeal a refusal, obtain a list of third parties to whom we have disclosed personal information, and not be discriminated against for exercising any of them. Where a right is not provided to you by law, we may still honor it at our discretion.

We do not engage in profiling that produces legal or similarly significant effects.

12.2 Submitting a request

Email support@get-creative.co, tell us which right you want to exercise and which app it concerns. See Section 5.2 for what we can and cannot look up. State law may limit how often you may make certain requests in a 12-month period.

12.3 Sale and sharing, and how to opt out

• We do not sell or share, for targeted advertising or for anything else, the content stored on our own server (Section 2.4). It is disclosed to nobody, in any app, including the two games.
• In Before I Unpack and Milestone we do not sell or share personal information for targeted advertising. There is no advertising SDK in either app.
• In Parcel Rush and Pack Perfect, personal information (device and advertising identifiers, device and app information, ad events) is disclosed to advertising partners to serve and measure ads. Under some states' broad definitions this may be a "sale" or "sharing."

You can opt out at any time, and all three of these work:

1. In the game: Settings → Ad & data choices, and turn off Share usage analytics.
2. On your device: iOS Settings → Privacy & Security → Tracking, and turn off tracking for the app. With tracking off, the advertising identifier is unavailable and the ads you see are non-personalized.
3. Email us at support@get-creative.co with "Do Not Sell or Share My Personal Information" in the subject line.

Opt-out preference signals. Our apps are not browsers and do not receive a browser signal. On our website, if and when we run any advertising technology there, we will honor the Global Privacy Control signal and say so here.

12.4 Authorized agents

You may use an authorized agent where your state allows it. The agent must give us your written, signed permission, and we may ask you to confirm the authorization directly.

13. Additional Notice for California Consumers: California Notice at Collection

If you are a California resident, this section applies in addition to the rest of this Privacy Policy. The California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA") requires the disclosures below.

13.1 Categories collected, used and disclosed

In the preceding 12 months, depending on which app you used, we may have collected these categories of personal information (Cal. Civ. Code §1798.140(v)(1)):

Categories we do not collect: (C) protected classification characteristics; (E) biometric information; (I) professional or employment information; education information; and sensitive personal information as defined by the CCPA. We do not use or disclose sensitive personal information for purposes requiring a right to limit. In particular, the contents of your communications are never uploaded: the message Before I Unpack helps you write to your landlord, and your key codes, stay on the phone and are excluded from the backup by the code that builds it.

Sale and sharing: see Section 12.3. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Retention: see Section 8.

13.2 Shine the Light

California Civil Code §1798.83 permits California residents with an established business relationship with us to request information about disclosures of certain personal information to third parties for those third parties' own direct marketing purposes in the preceding calendar year. We make no such disclosures. If you would like that confirmed in writing, email support@get-creative.co, say you are a California resident making a "Shine the Light" inquiry, and we will respond. This request may be made once per calendar year.

14. Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

14.1 Our relationship to you

We are the data controller for personal information collected through the Services. Our providers act as processors on our instructions, except for the advertising networks in our games, which act as independent controllers for their own advertising purposes and to which you consent through the consent form shown in the game.

The content stored on our own server (Section 2.4) has no third-party processor holding it at all — we run the machine ourselves. The only other companies involved are the data-centre operator and the two backup-storage providers named in Section 4, which act as processors on our instructions and on nothing else.

• Controller: [INTENTIONALLY CREATIVE LEGAL ENTITY NAME, JURISDICTION], [REGISTERED ADDRESS] — support@get-creative.co
• EU / UK representative under Article 27: [TO BE APPOINTED — see OPEN-ITEMS]
• Data protection officer: [ASSESSMENT PENDING — see OPEN-ITEMS]

14.2 Legal bases for processing

You may withdraw consent at any time, in the app's Settings or in your device's tracking settings. Withdrawal does not affect processing carried out before you withdrew.

14.3 Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability, and the right not to be subject to a decision based solely on automated processing with legal or similarly significant effects — we make no such decisions. Please read Section 5.2 first: because we hold no identifier that maps to you, the fastest complete route for erasure is the in-app delete.

You have the right to lodge a complaint with your supervisory authority. In the UK it is the Information Commissioner's Office (ico.org.uk); in Switzerland the Federal Data Protection and Information Commissioner (edoeb.admin.ch); in the EEA, your national data protection authority.

14.4 Marketing

We do not run an email marketing programme from app data, because the apps collect no email addresses. If we ever contact you electronically for marketing, it will be with your prior consent or as otherwise permitted by law, and every message will carry a one-click unsubscribe.

14.5 International transfers

Where we transfer personal information out of the EEA, the UK or Switzerland, we rely on the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum where applicable), on an adequacy decision covering the recipient country, or on the EU-U.S. Data Privacy Framework where the recipient is certified. Our product analytics for the three apps named in Section 7 is hosted in the EU precisely to reduce the number of such transfers. Our own server, which holds the content in Section 2.4, is in the United States, and the mechanism that applies to it is the open item flagged in Section 7. You may request a copy of the relevant safeguards at support@get-creative.co.

15. Additional Notice to Individuals in Brazil

If you are in Brazil, the Lei Geral de Proteção de Dados (Law 13.709/2018, "LGPD") applies to our processing of your personal data, and we are the controlador.

Milestone is offered in Brazilian Portuguese with a Brazilian celebration pack, so this section is not boilerplate for us.

• Legal bases (Art. 7 LGPD): performance of a contract with you; compliance with a legal obligation; our legitimate interests; and your consent for product analytics and attribution, which is the switch in Settings.
• Your rights (Art. 18 LGPD): confirmation of processing; access; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data; portability; information about with whom we have shared your data; information about the consequences of refusing consent; and withdrawal of consent. Section 5.2 applies equally here: the in-app delete is immediate and complete, and it is the remedy we can always deliver.
• How to exercise them: support@get-creative.co.
• International transfer: your personal data may be processed outside Brazil. Milestone's plan — including names and photographs — is stored on our own server in the United States (Section 2.4), and Milestone's product analytics is hosted in the United States as well. We rely on contractual clauses that provide the level of protection the LGPD requires; the open item flagged in Section 7 applies here too.
• Encarregado (DPO) / national contact: [TO BE APPOINTED — see OPEN-ITEMS].
• You may also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

Annex A — Parcel Rush

A puzzle game. Shows ads. Asks for tracking permission once.

Bundle identifier: co.getcreative.parcelrush

Annex B — Pack Perfect

A packing puzzle game. Shows one kind of ad — a rewarded video you ask for.

Bundle identifier: co.getcreative.packperfect

Annex C — Before I Unpack

A move-in condition record. No ads. No tracking prompt. Backup off unless you turn it on, and analytics off unless you turn it on.

Bundle identifier: co.getcreative.beforeiunpack

Nothing leaves your phone until you switch Backup on, and Backup starts off. With it off there is no account, no session and no request of any kind — not one. Switch it on and your records and the original photographs and voice notes are copied to our own server, as a second copy: they stay on the phone as well. Your key codes and the message you wrote to your landlord are never uploaded, in either state. The PDF you export is created on your device and goes where you send it.

What Backup is not: it is not end-to-end encrypted. Files are encrypted on our server and on the way there, but we hold the keys — so in principle we could be made to hand them over. If that matters to you, leave it off; every part of this app works without it.

One honest consequence, stated because it is ours to carry, not yours: because analytics starts off, every number this app produces describes the people who opted in, and they are not a random sample of its users. The same is true of Backup: most people who use this app will never have a copy on our server, and that is the outcome the default was chosen for.

Annex D — Milestone

A celebration planner (quinceañera, festa de 15 anos, debut, sweet sixteen). No ads. No tracking prompt.

Bundle identifier: co.getcreative.milestone

Names, amounts, notes and photographs never appear in analytics. Not as a promise of restraint — the app filters every event against an allowlist of permitted properties before any provider sees it, and anything not on that list is dropped and logged as an error. Every event in the app's taxonomy is tested against that refusal.

Never appears in analytics, in any event, ever: the honoree's name and everyone else's; any amount, budget, quota or vendor quote; every note anyone typed; every photograph and every file path to one; phone numbers; the venue, the address, the church and the date; which app a card was shared to; and any row identifier — screen names are normalized so that an id can never ride along in one.

That is a statement about analytics. The plan itself is stored on our own server so the owner's phone can get it back, and the row below says exactly what that includes. The two lists are different on purpose, and this annex will never let one stand in for the other.

Change log

• September 1, 2026 · rev 4 — Hosting move only, no change to any data practice. The hosted copies of these documents now live at https://legal.alc.fyi/legal/, which is live today with a valid certificate, and every URL printed in this suite points there. The move is a hosting decision and nothing more: the studio is still Intentionally Creative, get-creative.co is still the Sites this policy covers, contact is still support@get-creative.co, and no data, processor, retention period or right changed.
• September 1, 2026 · rev 3 — Publisher rename only, no change to any data practice. The studio behind the four apps is Intentionally Creative (get-creative.co); every reference to the former name and to its domain is gone, contact is now support@get-creative.co, and the hosted copies of these documents were given a home under the studio's own domain (superseded at rev 4). The entity placeholder is renamed to match and stays a placeholder — the contracting entity is still counsel's and the founder's call. The four annexes print the reissued bundle identifiers, co.getcreative.*, which is what all four apps now carry; none of them has shipped under the old prefix, so nothing of the old name survives in a binary. Nothing else moved: the same data, the same server in Ashburn, the same processors, the same allowlists, the same rights.
• September 1, 2026 · rev 2 — The backend now exists. Replaced the claims that there is no account, no server, no sync and no backup with what is actually running: an anonymous device account per app, our own self-hosted server in Ashburn, Virginia, game-progress cloud save in both games, opt-in and off-by-default Backup in Before I Unpack (explicitly not end-to-end encrypted), and plan sync in Milestone with money in access-fenced tables. Section 2.4 rewritten, Sections 5.2/5.4/6/7/8 and the CCPA and GDPR disclosures updated, all four annexes updated. Unchanged and re-affirmed: the analytics allowlists, no advertising SDK in either utility app, no precise location anywhere, and Milestone's promise that names, amounts, notes and photographs never appear in analytics.
• September 1, 2026 · rev 1 — First draft of the suite.