TRUEVOW PRIVACY POLICY — Advertising & Tracking Disclosure Sections

ADSLUX LLC

Prepared: March 2026 • Effective Date: March 2026

1. Third-Party Advertising Partners

ADSLUX LLC (“we,” “our,” or “us”) partners with the following third-party advertising platforms to promote the TrueVow application and measure the effectiveness of our advertising campaigns:

1.1 Meta Platforms, Inc. (Facebook & Instagram)

We use the Meta Ads platform, including the Meta Pixel (for web), Meta SDK for iOS, and the Meta Conversions API to deliver, measure, and optimize advertisements for TrueVow across Facebook, Instagram, Messenger, and the Meta Audience Network.

1.2 TikTok (ByteDance Ltd.)

We use the TikTok Ads platform, including the TikTok Pixel (for web), TikTok SDK for iOS, and the TikTok Events API to deliver, measure, and optimize advertisements for TrueVow on the TikTok platform.

2. Data Collected Through Advertising SDKs

When you interact with a TrueVow advertisement or install and use the TrueVow app, the following categories of data may be collected by or shared with our advertising partners:

2.1 Device and Technical Information

• Device type, model, and operating system version
• Unique device identifiers, including Identifier for Advertisers (IDFA) when you have granted permission via Apple’s App Tracking Transparency (ATT) prompt
• IP address (which may be used to derive approximate location at the city or regional level)
• Language and timezone settings
• Network connection type (e.g., Wi-Fi, cellular)

2.2 App Event Data

• App install and first-open events
• Registration/account creation events
• Purchase events (e.g., challenge enrollment at $99, retry purchase at $49), including transaction value and currency
• Challenge start and completion events
• Subscription events (e.g., trial start, conversion, cancellation)
• In-app engagement milestones (e.g., Day 7 conversion, Day 30 completion)

Challenge Reward Status

We store whether you have earned a free next challenge (our reward for completing a 30-day challenge with 80% or greater consistency). This flag is used solely to apply your earned free pass at the payment gate of your next challenge. It is not shared with third parties.

Children's Privacy

TrueVow is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13.

2.3 Advertising Interaction Data

• Ad impressions, clicks, and view-through data
• Attribution data linking ad interactions to app installs or conversions
• Ad creative identifiers and campaign metadata

2.4 Data NOT Collected or Shared with Advertising Partners

We do not share the following with Meta, TikTok, or any other advertising partner:

• Your habit names, descriptions, or completion details
• Your identity statements, Deep Why responses, or onboarding answers
• Health or fitness data
• Contact lists or address book data
• Precise GPS location
• The content of any communications with accountability partners
• Photos, videos, or other media you create within the app

3. Purposes of Data Collection and Sharing

Purpose	Description
Ad Delivery	Serving TrueVow advertisements to relevant audiences on Meta and TikTok platforms.
Campaign Measurement	Measuring the performance of advertising campaigns, including impressions, clicks, installs, and conversions.
Conversion Optimization	Optimizing ad delivery to reach users who are most likely to install TrueVow and complete meaningful actions (e.g., challenge enrollment, challenge completion).
Audience Creation	Building lookalike and custom audiences based on aggregated user characteristics to reach similar potential users.
Attribution	Determining which advertisements led to app installs and in-app actions to allocate advertising spend effectively.
Fraud Prevention	Detecting and preventing fraudulent ad clicks, installs, and other invalid traffic.

We do not use data collected through advertising SDKs to make decisions about the features, content, or services available to you within TrueVow, nor do we use this data to determine pricing or credit eligibility.

4. Apple App Tracking Transparency (ATT)

In compliance with Apple’s App Tracking Transparency framework, TrueVow will request your permission before allowing Meta, TikTok, or any other third party to track your activity across other companies’ apps and websites.

4.1 What Happens When You Allow Tracking

If you grant tracking permission, our advertising partners may:

• Access your device’s Identifier for Advertisers (IDFA)
• Attribute your app install and in-app events to specific advertisements
• Use your data to measure ad effectiveness and build audience segments
• Deliver more relevant advertisements to you on their platforms

4.2 What Happens When You Deny Tracking

If you deny tracking permission:

• Your IDFA will not be shared with any advertising partner
• Meta and TikTok will receive limited, aggregated event data through privacy-preserving mechanisms such as Apple’s SKAdNetwork
• You may still see TrueVow advertisements, but they will not be personalized based on your activity
• All TrueVow app features and functionality remain fully available regardless of your tracking choice

4.3 Changing Your Preference

You may change your tracking preference at any time by navigating to Settings > Privacy & Security > Tracking on your iOS device and toggling tracking permission for TrueVow.

5. Data Retention and Handling by Advertising Partners

5.1 Meta

Data shared with Meta is processed in accordance with Meta’s Data Policy (https://www.facebook.com/privacy/policy/). Meta may retain event data and use it as described in their terms. You can manage your Meta ad preferences at https://www.facebook.com/adpreferences and download your data at https://www.facebook.com/dyi.

5.2 TikTok

Data shared with TikTok is processed in accordance with TikTok’s Privacy Policy (https://www.tiktok.com/legal/privacy-policy). TikTok may retain event data and use it as described in their terms. You can manage your TikTok ad preferences within the TikTok app under Settings > Privacy > Personalization and data.

5.3 Our Retention Practices

ADSLUX LLC retains advertising performance data (aggregated campaign metrics, conversion counts, and cost data) for as long as necessary to operate and improve TrueVow’s advertising strategy. This data is aggregated and does not directly identify individual users. If you delete your TrueVow account, we will remove any identifiable data from our advertising systems within 30 days, though data already transmitted to Meta or TikTok is subject to their respective retention policies.

6. Legal Basis for Processing (EEA/UK Users)

For users in the European Economic Area (EEA) or United Kingdom, we process advertising-related data under the following legal bases:

• Consent: Your consent, obtained through Apple’s ATT prompt and/or a separate consent mechanism within the app, for tracking and personalized advertising
• Legitimate Interest: Our legitimate interest in measuring the effectiveness of our advertising campaigns and preventing fraud, balanced against your privacy rights
• Contract Performance: Performance of our contract with you, where advertising data is necessary to deliver purchased services (e.g., verifying challenge enrollment for conversion tracking)

You have the right to withdraw consent at any time by changing your tracking preferences on your device or contacting us at the address below. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

7. Your Rights Regarding Advertising Data

Depending on your jurisdiction, you may have the following rights with respect to data collected through our advertising integrations:

• Access: Request access to the personal data we have shared with advertising partners
• Deletion: Request deletion of your personal data from our advertising systems
• Opt-Out of Sale/Sharing: Opt out of the sale or sharing of your personal data for advertising purposes (applicable under CCPA/CPRA for California residents)
• Correction: Request correction of inaccurate personal data
• Objection: Object to processing of your data for direct marketing purposes
• Restriction: Restrict or limit our use of your personal data

To exercise any of these rights, please contact us at:

ADSLUX LLC
Email: lucian@adslux.com
Mailing Address: 254 Chapman Rd, Ste 208 #15588, Newark, Delaware, 19702, US

We will respond to verified requests within the timeframes required by applicable law (typically 30–45 days).

8. California Residents (CCPA/CPRA Supplement)

If you are a California resident, the sharing of your data with Meta and TikTok for targeted advertising may constitute a “sale” or “sharing” of personal information under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).

Categories of personal information shared for advertising purposes:

• Identifiers (device identifiers, IDFA, IP address)
• Internet or other electronic network activity information (app events, ad interactions)
• Commercial information (purchase events and transaction values)
• Inferences drawn from the above categories

You may opt out of this sharing by:

• Denying tracking permission when prompted by Apple’s ATT framework
• Contacting us at the email address above with the subject line “Do Not Sell or Share My Personal Information”
• Using any “Do Not Sell or Share” link we provide on our website or within the app

We do not knowingly sell or share personal information of consumers under 16 years of age.

9. Children’s Privacy

TrueVow is not directed at children under the age of 13 (or the applicable minimum age in your jurisdiction). We do not knowingly collect personal information from children. Our advertising integrations with Meta and TikTok are configured to exclude audiences under 18 from ad targeting. If we learn that we have collected personal information from a child under the applicable minimum age, we will take steps to delete that information promptly.

10. Changes to These Advertising Disclosures

We may update these advertising and tracking disclosures from time to time to reflect changes in our practices, our advertising partners’ policies, or applicable laws. We will notify you of material changes by posting the updated privacy policy within the TrueVow app and updating the “Effective Date” at the top of the policy. Where required by law, we will obtain your consent before making material changes to how your data is used for advertising purposes.