Essential Tools Privacy Supplement

Effective Date: May 21, 2026

Supplement Notice: This statement supplements the Smart Bay General Privacy Policy. It details the specific data processing parameters for our zero-account local utility applications, including Flow Smart Search, Flow Browser, and Flow Camera.

Zero-Account Framework Commitment: Our utility apps operate on a strict Zero-Account Framework. We do not require, create, or maintain user registration accounts. All your core operational content, browsing history, and multimedia assets are stored and rendered strictly within your local device sandbox.

1. INFORMATION WE COLLECT AND DISCLOSE

We do not operate backend user servers to harvest your personal content. However, to support ad-supported monetization and application optimization, our Apps integrate trusted third-party software development kits (SDKs), specifically Google AdMob and Firebase Analytics. Through these integration facts, the following categories of information have been collected and disclosed over the past 12 months:

Statutory Category (CCPA)	Collected / Disclosed	Source & Purpose	Retention Period
Identifiers (IP Address, GAID/AAID)	Yes (Google AdMob, Firebase)	Automated SDK telemetry for ad frequency capping, fraud prevention, and app performance monitoring.	Up to 1 year
Characteristics (Aggregated Age/Gender)	Yes (Google Analytics)	Derived automatically via the device's advertising profile.	Up to 1 year
Internet/Network Activity	Yes (Google AdMob, Firebase)	Automatic logging of interactions with the Apps' interface or displayed ads.	Up to 1 year
Geolocation Data (Coarse Location)	Yes (Google AdMob)	Coarse geographic region derived automatically via IP address to display localized ads.	Up to 1 year

2. CATEGORIES OF DATA WE DO NOT COLLECT

We strictly maintain a clean legal perimeter. We have NOT collected, stored, or disclosed:

Biometric Data: Any local biometric verification stays within the Android TEE.
Sensory Data (Audio/Visual): While Flow Camera utilizes your device's camera, all generated multimedia files are directly routed into your local storage sandboxes. We do not transmit your media files to our servers.
Commercial/Financial Data: We do not track shopping histories. Online shopping via Flow Browser is a decentralized channel directly connecting you to third-party merchants.
Inferences: We do not run profiling engines to construct consumer profiles from your local data.

3. SALES AND SHARING OF DATA

Our disclosure of online identifiers to advertising networks like Google AdMob for cross-context behavioral advertising may be legally classified as a "sale" or "sharing" under specific US privacy laws. Except for these automated SDKs, we do not sell or rent your personal information to any third parties.