TUREM Privacy Policy

This Privacy Policy explains how TUREM handles information when you:

• use the TUREM application;
• visit the TUREM website;
• import audio files or create Projects;
• use subscriptions or in-app purchases;
• contact TUREM for support or legal enquiries.

TUREM has been designed to process audio, Projects and most technical information locally on the user’s device.

The current version of TUREM does not operate a proprietary user-account system, advertising network, analytics platform, cloud-sync service or developer-controlled backend.

The data controller responsible for any personal data processed directly by TUREM is:

Mario Zanetti Calle Arcediano Andreu 9 46500 Sagunto, Valencia Spain Privacy and legal enquiries: legal@turem.app Technical support: support@turem.app Website: turem.app Mario Zanetti operates TUREM as an individual.

This Privacy Policy applies to:

• the TUREM application for Apple devices;
• the official TUREM website;
• support and legal communications sent directly to TUREM.

Third-party services, including the Apple App Store, Apple Account, StoreKit, iCloud Backup and external websites, are governed by their own privacy policies and terms.

Based on the current released functionality, TUREM does not directly collect or operate systems for:

• user accounts or profiles;
• names, email addresses or telephone numbers through the application;
• passwords or Apple Account credentials;
• precise or approximate location;
• contacts, calendars or reminders;
• microphone recordings;
• camera or photo-library content;
• health or fitness information;
• advertising identifiers;
• cross-app or cross-website tracking;
• behavioural advertising;
• external usage analytics;
• third-party crash reporting;
• biometric information;
• social-network information;
• browsing or search history;
• data-broker activity.

TUREM does not use the imported audio or Projects for advertising, profiling, artificial-intelligence training or unrelated analytical purposes.

TUREM processes information locally when necessary to provide its audio and project-management functions.

This may include:

• audio files selected and imported by the user;
• file names and original file names;
• file type, size and duration;
• audio codec, sample rate and channel information;
• locally generated checksums;
• Project, clip and Sound Bank names;
• loops, regions, cues, effects and audio settings;
• interface layout and application preferences;
• internal identifiers assigned to Projects, clips and media assets;
• language preferences;
• locally generated performance and diagnostic information.

This information is used to:

• import and validate audio;
• organise the local media library;
• detect duplicate files;
• save and reopen Projects;
• reproduce and process sound;
• apply user-selected settings;
• diagnose local technical problems;
• maintain application functionality.

This information is not transmitted to servers operated by TUREM in the current version.

Apple treats information processed only on the device differently from information transmitted and made accessible to the developer. Apple requires developers to update their App Store disclosures whenever their practices change.

Audio files are imported only after the user selects them through the Apple document picker or another system-provided file interface.

TUREM copies selected files into the application’s local sandbox so that they can be used within the application.

Projects and related metadata are stored locally in the application container.

TUREM does not currently:

• upload audio to a TUREM server;
• synchronise Projects through a proprietary cloud service;
• analyse audio remotely;
• listen through the microphone;
• make imported audio publicly available;
• share Projects with other users automatically.

Users should avoid including personal or confidential information in file names or Project names when this is not necessary.

Audio, Projects, settings and associated metadata may remain stored on the device until:

• the user removes them;
• the application removes them as part of an authorised function;
• the application is uninstalled;
• the operating system removes temporary information;
• the device or its storage is erased.

Some TUREM files are stored in areas that may be included in an Apple device backup.

Therefore, although TUREM does not provide its own cloud-sync service, application content may form part of an iCloud Backup or another backup managed through Apple, depending on the user’s device configuration.

TUREM does not control Apple’s backup infrastructure or retention rules.

Removing a reference to an audio file from the TUREM library may remove the item from the application index without immediately deleting the underlying physical file stored inside the application container.

Projects placed in a recently deleted area may remain available until they are permanently removed, the application is uninstalled or the application introduces an automatic deletion period.

Users should not assume that removing a visible reference always results in immediate physical erasure of every associated local file.

TUREM may improve its deletion and retention controls in future versions. This Privacy Policy will be updated when those controls materially change.

TUREM uses Apple StoreKit to obtain information needed to provide subscriptions, trials, purchases and access entitlements.

StoreKit may provide the application with information such as:

• product identifiers;
• transaction identifiers;
• purchase dates;
• subscription expiration dates;
• revocation or refund status;
• introductory-offer or trial status;
• the products that currently grant access.

This information is processed locally to determine whether the user is entitled to FREE, PRO, PRO+, purchased Sound Banks or other eligible content.

In the current implementation, TUREM does not send this transaction information to a proprietary backend and does not receive:

• the user’s payment-card details;
• Apple Account password;
• full Apple Account identity;
• billing address;
• complete payment credentials.

Purchases and subscriptions are processed and administered by Apple. StoreKit allows applications to retrieve products, transactions and current entitlements from the App Store.

Apple’s own processing is governed by Apple’s privacy terms and contractual documentation.

The current version of TUREM does not use:

• third-party analytics SDKs;
• advertising SDKs;
• marketing-attribution SDKs;
• IDFA;
• App Tracking Transparency for cross-company tracking;
• cross-app behavioural tracking;
• personalised advertising;
• data brokers.

TUREM does not track users across applications or websites owned by other companies.

Should TUREM introduce analytics, advertising or tracking in the future, the application, App Store privacy information and this Privacy Policy will be updated before or when the new processing begins, and consent will be obtained where legally required.

Apple requires permission through App Tracking Transparency where data collected in an app is used for tracking across apps or websites owned by other companies.

TUREM may generate limited technical information locally to maintain stability and diagnose problems, including:

• audio-engine status;
• memory and thermal conditions;
• sample rate and audio-buffer information;
• audio-output route;
• technical errors;
• internal object identifiers;
• interrupted or failed operations.

This information may be held temporarily in memory or recorded through Apple’s system logging facilities.

TUREM does not currently transmit these logs to a third-party crash-reporting provider or proprietary TUREM server.

Apple may independently receive diagnostic and crash information when a user has enabled the relevant sharing options in the device settings. Such processing is controlled by Apple and is subject to Apple’s privacy practices.

The TUREM website may technically process limited information needed to deliver webpages and protect the service, such as:

• IP address;
• date and time of a request;
• requested page;
• browser and device information;
• basic server or security logs.

This information may be processed by the hosting or infrastructure provider used to operate the website.

It may be used for:

• delivering website content;
• maintaining availability;
• identifying technical faults;
• preventing misuse or security incidents;
• complying with legal obligations.

The website does not intentionally use advertising or behavioural-tracking technologies unless a future version explicitly states otherwise.

Where non-essential cookies, analytics or similar technologies are introduced, appropriate information and consent controls will be provided when required.

If you contact TUREM by email, you voluntarily provide information such as:

• your email address;
• your name, when included;
• the content of your message;
• attachments you choose to send;
• technical information included in a support request.

This information is used to:

• respond to enquiries;
• provide support;
• investigate reported problems;
• handle legal or intellectual-property communications;
• maintain necessary correspondence records.

Do not send passwords, payment-card details, Apple Account credentials or unnecessary sensitive information.

Where the GDPR applies, personal data may be processed on one or more of the following legal bases:

• Performance of a contract: when processing is necessary to provide requested support or services.
• Legitimate interests: to operate, secure, maintain and improve TUREM and its website, provided those interests do not override the user’s rights.
• Legal obligation: when information must be retained or disclosed under applicable law.
• Consent: where consent is required, including for any future non-essential cookies or optional processing.
• Steps requested before entering into a contract: when responding to commercial or service enquiries.

The GDPR establishes principles, lawful bases, transparency duties and rights for individuals whose personal data is processed.

TUREM retains personal data only for as long as reasonably necessary for the relevant purpose.

In particular:

• local audio and Projects remain under the user’s control within the application container;
• application preferences may remain until changed or the app is removed;
• purchase status may be processed while needed to determine access;
• support emails may be retained while the enquiry is active and afterwards where necessary for records, disputes or legal obligations;
• website security logs may be retained for a limited operational or security period by the hosting provider.

Different retention periods may apply where required by tax, accounting, consumer-protection or legal obligations.

TUREM does not sell personal data.

Information may be processed or disclosed only where necessary to:

• provide the website or application;
• use Apple services such as App Store, StoreKit or device backups;
• operate website hosting and email infrastructure;
• obtain professional legal, accounting or technical assistance;
• comply with law or a valid authority request;
• protect users, TUREM or third parties from fraud, abuse or security threats.

Any service provider acting on behalf of TUREM should receive only the information necessary for its function and be subject to appropriate contractual or legal obligations.

Apple, hosting, email or other infrastructure providers may process information in countries outside the user’s place of residence.

Where TUREM is responsible for an international transfer of personal data subject to the GDPR, appropriate legal safeguards will be used where required, such as:

• an adequacy decision;
• standard contractual clauses;
• another valid transfer mechanism.

Processing performed independently by Apple is governed by Apple’s own privacy documentation and legal arrangements.

TUREM applies reasonable technical and organisational measures appropriate to the nature of the service.

Current privacy-related safeguards include:

• local processing of audio and Projects;
• application sandboxing;
• use of Apple system frameworks;
• absence of a proprietary user database;
• absence of advertising and third-party tracking SDKs;
• restricted access to files chosen by the user;
• minimisation of information transmitted externally.

No system can guarantee absolute security. Users are responsible for securing their devices, Apple Accounts, backups and imported content.

Where applicable, users may have the right to:

• request access to their personal data;
• request correction of inaccurate information;
• request deletion;
• request restriction of processing;
• object to certain processing;
• request data portability;
• withdraw consent where processing relies on consent;
• lodge a complaint with a competent supervisory authority.

Because most TUREM content is stored only on the user’s device and is not accessible to TUREM, TUREM may not be technically able to retrieve, identify, correct or delete that local content remotely.

Users can normally control local content directly through the application, device storage, backups or by uninstalling the application.

Requests concerning personal data directly held by TUREM may be sent to:

legal@turem.app TUREM may request reasonable information to verify the requester’s identity before responding.

TUREM is not designed to create profiles of children or collect personal information directly from children.

The application does not currently include:

• social networking;
• public user profiles;
• direct messaging;
• targeted advertising;
• child-directed behavioural tracking.

Parents or legal guardians who believe that a child has provided personal information directly to TUREM may contact legal@turem.app.

TUREM and its website may link to or interact with third-party services, particularly Apple services.

TUREM is not responsible for the privacy practices of independent third parties.

Users should review the relevant policies before providing information through an external service.

This Privacy Policy may be updated when TUREM changes its functionality, legal structure or data practices.

A review and update will be required before introducing material features such as:

• proprietary user accounts;
• backend servers;
• cloud synchronisation;
• external analytics;
• third-party crash reporting;
• newsletter subscriptions;
• marketplace functions;
• social features;
• microphone recording;
• remote audio processing;
• advertising or tracking.

The latest version will be identified by its version number, effective date and last-updated date.

Where legally required, users will be given appropriate notice of material changes.

For privacy requests or questions:

Mario Zanetti Calle Arcediano Andreu 9 46500 Sagunto, Valencia Spain Email: legal@turem.app For technical support:

Email: support@turem.app Users may also submit a complaint to the Spanish Data Protection Agency or another competent supervisory authority where applicable.

© 2026 Mario Zanetti. All rights reserved.

TUREM Privacy Policy — Version 1.0