Privacy Policy

NEWTOP Co.Ltd Privacy Policy

Privacy Policy

Effective Date: June 24, 2026

NEWTOP Co. Ltd (“we”, “us”, or “our”) respects your privacy. This Privacy Policy explains how our mobile application (the “DocScan Converter— Scan to Convert PDF”) handles information when you use our PDF scanning, document management, and related features.

By using the App, you acknowledge that you have read and understood this Privacy Policy.


1. Scope of This Policy

This Privacy Policy applies to the App and explains how information may be collected, used, stored, processed, and shared in connection with the App.

The App is designed as a PDF scanner and file management tool. Its core functions may include scanning documents, importing images or files, creating PDF files, organizing documents, editing file names, exporting files, and sharing files through the operating system or other apps chosen by the user.


2. Information We Process

The types of information processed by the App may depend on the features you use, the permissions you grant, your device settings, and the third-party services integrated into the App.

2.1 Documents, Images, and PDF Files

When you use the App to scan, import, create, edit, manage, or export PDF files, the App may process the following information on your device:

* Photos or images captured through the camera

* Imported images or documents selected by you

* PDF files created or edited within the App

* File names, folder names, and document organization information

* Local app settings related to document management

Unless otherwise stated, your scanned documents, imported files, and generated PDF files are stored locally on your device. We do not intentionally upload the contents of your scanned documents or PDF files to our own servers.

If you choose to share, export, upload, back up, or open a file using another app or service, that action is controlled by you and may be subject to the privacy policy of the third-party app or service you choose.

2.2 Camera and File Access

The App may request access to certain device permissions in order to provide its core functionality, including:

* Camera: to scan documents and create PDF files from captured images.

* Photos, media, files, or storage access: to import images or files, save generated PDFs, export files, or manage documents, depending on your device and operating system version.

We use these permissions only to provide the features requested by you. You can manage or revoke these permissions at any time through your device settings. Some features may not work properly if required permissions are disabled.

2.3 Advertising and App Interaction Data

The App may display advertisements to support free access to the App. To provide advertisements, measure ad performance, prevent fraud, and improve advertising services, we may use third-party advertising services, including but not limited to Google AdMob or Google Mobile Ads SDK.

These third-party advertising services may automatically collect or process certain information, such as:

* IP address

* Advertising ID or other device identifiers

* Device information, such as device model, operating system, language, and app version

* App interaction data, such as ad impressions, ad clicks, session activity, and usage events

* Crash logs, diagnostics, and performance data

* Approximate location inferred from IP address

This data may be used for purposes such as:

* Showing ads within the App

* Measuring ad performance

* Limiting ad frequency

* Detecting and preventing fraud, abuse, and security issues

* Improving advertising and related services

* Complying with legal and platform requirements

We do not control the independent data practices of third-party advertising providers. Their handling of data is governed by their own privacy policies and applicable terms.

2.4 Diagnostics and Crash Data

The App, the operating system, app stores, or third-party SDKs may process limited technical information to help maintain app stability, diagnose crashes, improve performance, and ensure security.

This may include:

* Crash logs

* Performance data

* Device type and operating system version

* App version

* Technical diagnostics

Such information is used to maintain, troubleshoot, and improve the App.


3. Information We Do Not Intentionally Collect

We do not require users to create an account to use the basic features of the App.

We do not intentionally collect the following information directly from users:

* Name

* Email address

* Phone number

* Contact list

* Precise GPS location

* Government ID numbers

* Payment card information

* Address book data

We do not intentionally review, sell, or use the contents of your scanned documents or PDF files for advertising purposes.


4. How We Use Information

Information processed in connection with the App may be used for the following purposes:

* To provide PDF scanning and document management features

* To allow users to create, edit, save, organize, export, and share PDF files

* To provide app functionality requested by the user

* To maintain app stability and performance

* To diagnose crashes and technical issues

* To display advertisements

* To measure advertising performance

* To prevent fraud, abuse, and security risks

* To comply with legal, regulatory, platform, or enforcement requirements


5. Third-Party Services

The App may use third-party services or SDKs to support advertising, analytics, diagnostics, crash reporting, or platform functionality.

These services may include, depending on the actual version of the App:

* Google AdMob / Google Mobile Ads SDK

* Google Play services

* Google Play Console diagnostics

* Other advertising, analytics, or crash reporting services that may be integrated into the App

Third-party services may collect, process, or receive certain data as described in their own privacy policies.

Users should review the privacy policies of relevant third-party providers for more information about how they handle data.


6. Data Sharing

We do not sell your scanned documents, PDF files, or locally stored document content.

We may share or allow third-party services to process certain information in the following situations:

* With advertising providers to display ads, measure ad performance, prevent fraud, and improve ad services

* With analytics or diagnostics providers to maintain app stability and improve performance

* With service providers that help operate or improve the App

* When required by law, legal process, regulation, or enforceable government request

* To protect the rights, safety, and security of users, the App, our business, or others

* When you choose to export, share, back up, or open files using another app or service

When you use system sharing, cloud storage, email, messaging apps, file managers, or other third-party services to share or store files, those services may process your files according to their own privacy policies.


7. Data Storage and Retention

Scanned documents, imported files, generated PDFs, and related file management information are generally stored locally on your device unless you choose to export, share, back up, or upload them using another app or service.

You may delete files created or stored in the App through the App’s file management features or your device storage settings, depending on your device and operating system.

Advertising, analytics, diagnostics, and crash-related data may be retained by third-party service providers according to their own retention policies.

We do not maintain a user account database for the basic use of the App.


8. Data Security

We take reasonable measures to protect information handled by the App. However, no method of electronic storage, transmission, or processing is completely secure.

Because your scanned documents and PDF files are generally stored on your device, you are responsible for protecting your device, using device security features, and controlling access to your files.

When data is processed by third-party services, those services are responsible for their own security practices.


9. User Choices and Controls

You may control your information in the following ways:

* Grant or revoke camera, photo, media, file, or storage permissions through your device settings.

* Delete scanned documents, imported files, or generated PDFs from the App or your device.

* Choose whether to export, share, upload, or back up files using third-party apps or services.

* Reset or manage your advertising ID through your device settings, where available.

* Manage ad personalization settings through your device or relevant advertising provider settings.

Please note that disabling certain permissions may limit the functionality of the App.


10. Children’s Privacy

The App is not intended for children under the age of 13, or the minimum age required by applicable law in the user’s jurisdiction.

We do not knowingly collect personal information from children. If you believe that a child has provided personal information through the App, please contact us and we will take appropriate steps to address the issue.

If the App is later made available to children or families, we will update this Privacy Policy and related compliance settings as required by applicable laws and platform policies.


11. International Data Transfers

We are based in Hong Kong / China / other applicable jurisdiction, and third-party service providers used by the App may process data in countries or regions outside your country of residence.

For example, advertising, analytics, and diagnostics providers may process data on servers located in different countries. These providers are responsible for applying appropriate safeguards according to their own policies and applicable laws.


12. Legal Bases for Processing

Where required by applicable law, we process information based on one or more of the following legal bases:

* To provide the App features requested by the user

* To pursue legitimate interests, such as maintaining app security, improving performance, preventing fraud, and supporting the App through advertising

* To comply with legal obligations

* With user consent, where consent is required by applicable law or platform policy


13. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information, such as the right to access, correct, delete, object to, restrict processing, or request portability of personal information.

Because the App’s core document scanning and PDF management features are generally local to your device and do not require an account, we may not be able to identify individual users or access locally stored files.

For data processed by third-party advertising, analytics, diagnostics, or platform providers, please refer to the privacy controls and policies provided by those third parties.

If you contact us regarding a privacy request, we may need limited information to verify and respond to your request.


14. Advertising

The App may show ads provided by third-party advertising partners. These partners may use data such as advertising identifiers, device information, app interactions, ad interactions, diagnostics, and approximate location inferred from IP address to provide, measure, and improve ads.

Depending on your location and device settings, you may be able to limit ad tracking, reset your advertising ID, opt out of personalized ads, or manage consent through your device settings or advertising consent forms displayed in the App.

We do not use the contents of your scanned documents or PDF files to personalize advertisements.


15. Permissions Used by the App

Depending on your device, operating system version, and the features you use, the App may request the following permissions:

* Camera access: used for scanning documents.

* Photo, media, files, or storage access: used for importing, saving, exporting, or managing documents and PDF files.

* Internet access: used for loading advertisements, diagnostics, updates, or other online services.

The App does not request access to contacts or precise GPS location for its core PDF scanning and file management functionality.


16. Google Play Data Safety

We aim to provide accurate disclosures in the Google Play Data Safety section based on the App’s actual data practices, permissions, and third-party SDKs.

The data disclosed in Google Play may include data processed by third-party advertising, analytics, diagnostics, or platform services integrated into the App.

If the App’s features, SDKs, permissions, or data practices change, we may update our Data Safety disclosures and this Privacy Policy accordingly.


17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the “Effective Date” at the top of this page.

Your continued use of the App after the updated Privacy Policy becomes effective means that you acknowledge the updated policy.


18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

NEWTOP Co. Ltd

Email: lunasea2026@outlook.com