Summary: Initial Data Practices Charter. Establishes a studio-wide, published test for what may be collected, replacing the common "no personally identifiable information" standard with a two-tier rule: Tier A measurements carry no identifier, no timestamp and no per-event row and are the default; Tier B measurements require a stated purpose, a lawful basis, a Privacy Policy disclosure and an app store declaration before the first row is written. Adds five operating rules, a per-app summary of what is collected today, and an explicit disclosure that the advertising network in NetCloak VPN — and the Google Ads conversion tag on one page of the Kalum marketing site — operate under Google's practices rather than this Charter.
Key Points:
- "No PII" rejected as the collection test — personal data is broader, and the PII standard permits per-device behavioural records
- Tier A defined: totals only, no identifier, no timestamp, no per-event row — the default for product questions
- Tier B defined: anything retaining identity, time or events — requires lawful basis, policy disclosure and store declaration in advance
- Rule 1 — purpose written down before collection; no speculative data gathering
- Rule 3 — we count what we could not serve, not only what succeeded
- Rule 4 — each measurement's known distortion stays attached to the number
- Rule 5 — no shared identifier across NeuEra apps; data is never joined between products
- Per-app position recorded for NetCloak VPN, Play Lounge, Odo and Kalum
- Kalum rate-demand measurement documented as Tier A; call and transaction records remain Tier B and disclosed
- NetCloak's Google AdMob advertising disclosed as outside this Charter; Play Lounge, Odo and Kalum confirmed free of any advertising SDK
- Google Ads conversion tag on kalum.app/call-mexico/ disclosed as outside this Charter — one page of one marketing site, not the apps
- States plainly that Tier A data cannot be produced or deleted on request, because it identifies no one
- Each app's Privacy Policy remains the operative legal disclosure and governs on conflict