Privacy Policy
- Themely is free and supported by ads. There is no account, no sign-up, no login and no in-app purchase.
- The app uses Google AdMob (with mediation partners AppLovin, ironSource, Mintegral, Pangle and Unity Ads), Google Firebase Analytics and Remote Config, and the attribution SDKs Adjust, Meta (Facebook) and TikTok.
- These services receive device identifiers, app usage events and ad interaction data. Your advertising identifier (IDFA) is used only if you allow tracking in Apple's App Tracking Transparency prompt.
- Where required (for example in the EEA, the UK and Switzerland), ad consent is collected through Google's consent form and can be changed later in Settings → Privacy options.
- Your widget designs, favorites, settings and any photo you pick for a Photo widget stay on your device. We do not upload your photos and we run no server for this app.
1. Who we are
Themely ("the app") is an iOS app developed and published on the App Store by Khanh Thong Le ("we", "us", "our"), based in Vietnam. The app lets you design Home Screen and Lock Screen widgets, save wallpapers generated on your device, and apply theme packs that pair the two.
This policy applies to the Themely iOS app (bundle identifier com.exo.themewidget) and its widget extension. We are responsible for the processing described here, except where a third-party provider acts as an independent controller under its own privacy policy (see section 5).
2. Information we collect
We do not ask for your name, email address, phone number or any account details, and the app has no sign-in. The app and the SDKs built into it collect the following information automatically:
| Category | What it includes | Collected by |
|---|---|---|
| Device identifiers | Identifier for Vendor (IDFV), Firebase app instance ID, SDK-generated install or device IDs, and the Advertising Identifier (IDFA) only if you allow tracking. | Firebase Analytics, AdMob and mediation partners, Adjust, Meta, TikTok |
| App usage (product interaction) | Events such as screens reached in the first-run flow, the display language you pick, your answers to two content-preference questions (what you want to start with, which visual style you like), which wallpapers, widgets or themes you preview, save or apply (by item ID), whether you answered the tracking and notification prompts, and app sessions. | Firebase Analytics; app install and session events also go to Adjust, Meta and TikTok |
| Advertising data | Ad requests, impressions, clicks, rewarded-ad completion, and ad failures per placement. | AdMob and mediation partners; Firebase Analytics |
| Device and network information | Device model, iOS version, language and region settings, time zone, app version, IP address, and a coarse (approximate) location that ad networks derive from the IP address. The app itself never asks for your location. | All SDKs listed in section 5 |
| Consent and tracking status | Your App Tracking Transparency answer and, where applicable, your ad consent choices. | Google User Messaging Platform; SDKs that read the tracking status |
We do not collect: photos or the contents of your photo library, contacts, calendar, health or fitness data, precise location, payment information, or crash reports. The app does not include a crash-reporting SDK. None of the information above is linked to your name or to an account, because the app has none.
3. What stays on your device
The following information is processed and stored only on your device. It is never sent to us or to the SDK providers:
- Widget designs you create — widget type, size, colors, text, and countdown or progress settings.
- A photo you pick for a Photo widget. It is copied into the app's protected shared container (
group.com.exo.themewidget) so the widget can display it. It is never uploaded. - Favorites and settings, such as your display language and onboarding progress.
- Battery level and charging state, read while the app is open so a battery widget can show them. This snapshot is stored locally for the widget only.
All wallpapers and theme artwork are drawn on your device. Deleting the app removes everything it stored on the device.
4. How we use information and legal bases
| Purpose | Legal basis (where GDPR / UK GDPR applies) |
|---|---|
| Providing the app and its widgets, including storing your designs on your device | Performance of our agreement with you (the Terms of Service) |
| Showing ads that keep the app free, including measuring and limiting how often they appear and preventing ad fraud | Consent for personalized ads and for storing or reading information on your device where required; legitimate interests for non-personalized ads, frequency capping and fraud prevention |
| Personalized advertising and cross-app ad measurement using the IDFA | Your consent, given through Apple's tracking prompt and, where shown, Google's consent form |
| Attribution — learning which ad campaign led to an install | Consent where required; otherwise legitimate interests in measuring our marketing |
| Analytics — understanding which screens and content people use so we can improve the app | Legitimate interests, or consent where required by local law |
| Remote configuration — turning individual ad placements on or off without an app update | Legitimate interests in operating the app |
| Complying with legal obligations and responding to requests from authorities | Legal obligation |
5. Service providers and SDKs
Themely includes the following third-party SDKs. Each processes data under its own privacy policy, which we encourage you to read.
| Provider | Purpose in Themely | Privacy policy |
|---|---|---|
| Google AdMob and Google User Messaging Platform (Google LLC) | Banner, native, interstitial, app-open and rewarded ads; ad consent form | policies.google.com/privacy · How Google uses data from partner apps |
| AppLovin | Ad mediation partner (bidding through AdMob) | applovin.com/privacy |
| ironSource (Unity) | Ad mediation partner | ironSource privacy policy |
| Mintegral | Ad mediation partner | mintegral.com/en/privacy |
| Pangle (Bytedance) | Ad mediation partner | pangleglobal.com/privacy |
| Unity Ads (Unity Technologies) | Ad mediation partner | Unity app user privacy policy |
| Google Firebase Analytics and Remote Config (Google LLC) | Usage analytics; remote on/off switches for ad placements | firebase.google.com/support/privacy |
| Adjust (Adjust GmbH) | Install attribution and campaign measurement | adjust.com/terms/privacy-policy |
| Meta (Facebook SDK, Meta Platforms) | App event and install measurement for Meta ad campaigns. The app does not offer Facebook login or sharing. | facebook.com/privacy/policy |
| TikTok Business SDK (TikTok) | App event and install measurement for TikTok ad campaigns | TikTok privacy policy |
We do not operate our own backend for Themely, and we do not receive your photos, widget designs or settings.
6. Tracking, advertising and your choices
App Tracking Transparency (IDFA)
When the app first starts, iOS asks whether Themely may track your activity across other companies' apps and websites. If you choose Allow, the SDKs above may use your IDFA for personalized advertising and campaign attribution. If you choose Ask App Not to Track, the IDFA is not available to the app or its SDKs. Meta's automatic event logging and TikTok's tracking stay switched off, and Adjust measures installs without the IDFA.
Even without tracking permission, the SDKs still receive non-advertising identifiers (such as the IDFV or SDK-generated IDs) and the usage and ad events described in section 2. For example, TikTok's SDK keeps sending app events while tracking is disabled, without the IDFA. Ads may still be shown, but they are not personalized using the IDFA.
You can change your answer at any time in iOS Settings → Privacy & Security → Tracking.
Ad consent (EEA, UK, Switzerland and other regions where required)
Before any ad is requested, the app asks Google's User Messaging Platform whether consent is needed in your region. If it is, a consent form is shown. You can review or withdraw your choices at any time in Themely → Settings → Privacy options. That entry appears only where the form applies.
Rewarded ads
Before you save a wallpaper or widget, or apply a theme, the app may show a rewarded ad. The app records only that the ad was shown or completed (see section 2). All content in the app is free, and there are no paid features.
7. Sharing and "sale" of personal information
We share information only with the service providers listed in section 5, for the purposes described above, and with authorities when the law requires it. We do not sell your information for money.
Under some US state laws, such as the California Consumer Privacy Act (CCPA/CPRA), giving device identifiers and app activity to advertising partners for cross-context behavioral advertising can count as "sharing" or "selling" personal information. To opt out, choose Ask App Not to Track (or turn tracking off in iOS Settings) and use Settings → Privacy options where available. You can also email us at the address in section 15.
8. Retention
- On-device data (designs, favorites, settings, photos you picked, battery snapshot) stays until you delete it in the app or delete the app.
- Firebase Analytics event data is kept by Google under the data-retention setting of our analytics property, which for event-level data is at most 14 months.
- Advertising and attribution providers keep data according to their own retention policies, linked in section 5.
9. Security
Data on your device is protected by the iOS app sandbox. Data sent by the SDKs travels over encrypted HTTPS connections to their providers. No method of transmission or storage is 100% secure, but we limit what is collected and do not keep our own copy of it.
10. Device permissions
| Permission | When it is asked | What it is used for |
|---|---|---|
| Tracking (App Tracking Transparency) | On first launch | Lets the ad and attribution SDKs use the IDFA (see section 6). Optional. |
| Photos — add only | When you save a wallpaper | Writes the one wallpaper image you chose into your library. Add-only access cannot read, browse or delete your existing photos. If you decline, you just cannot save wallpapers to Photos. |
| Photo picker (no permission needed) | When you choose a photo for a Photo widget | Apple's system picker gives the app only the single image you select. It stays on your device (see section 3). |
| Notifications | Optional, during first-run setup | If the app asks for this permission, we only record whether you allowed it. The app has no push notification service and does not collect a push token. |
Themely does not request location, camera, microphone, contacts, calendar, Bluetooth or health access. You can change permissions at any time in iOS Settings, which you can open from Themely → Settings → Open iOS Settings.
11. Children's privacy
Themely is a general-audience app and is not directed to children under 13 (or the equivalent minimum age in your country). We do not knowingly collect personal information from children. If you believe a child has used the app and data about them has been collected through the SDKs, contact us and we will help you request its deletion from the relevant providers.
12. Your rights (GDPR, UK GDPR & CCPA)
Depending on where you live, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to data portability, to withdraw consent at any time, and to opt out of the sale or sharing of personal information. You will not be treated differently for using these rights.
Because Themely has no account, we cannot connect data to you by name. The SDK data is keyed to device identifiers. The fastest way to act on your rights is:
- Withdraw tracking permission in iOS Settings → Privacy & Security → Tracking.
- Change your ad consent in Themely → Settings → Privacy options (where available).
- Delete the app to remove all on-device data.
- Email us. We will help you send the request to the providers that hold the data and, where possible, delete analytics data associated with your device.
If you are in the EEA or the UK, you may also complain to your local data protection authority.
13. International transfers
We are based in Vietnam, and our service providers process data in the United States, the European Union, Singapore and other countries. Where data from the EEA, the UK or Switzerland is transferred to countries without an adequacy decision, the providers rely on safeguards such as the European Commission's Standard Contractual Clauses or the EU-US Data Privacy Framework, as described in their own policies.
14. Changes to this policy
We may update this policy, for example when a new app version changes how information is handled. When we do, we will update the "Last updated" date above and, for material changes, give additional notice in the app or on its App Store page. Earlier versions of this policy described a version of Themely without ads or analytics. This version reflects the app as it is now distributed.
15. Contact us
If you have questions about this Privacy Policy or want to exercise your rights, contact:
Publisher: Khanh Thong Le (developer and App Store seller of Themely)
Location: Vietnam
Email: exostudio.feedback@gmail.com
See also our Terms of Service.