Shine Context Privacy Policy

Application: Shine Context

Developer: MagicHabits Labs Limited

Effective Date: June 19, 2026

MagicHabits Labs Limited ("MagicHabits", "Shine", "we", "us", or "our") operates the Shine Context mobile application and related services (the "Service").

This Privacy Policy explains how we collect, use, disclose, store, and protect information when individuals, organizations, schools, businesses, and other entities use Shine Context.

1. Overview

Shine is an environment-adaptation platform that enables organizations to define temporary device expectations within specific environments, activities, or sessions ("Shine Zones").

Shine is designed to minimize the collection of personal information. Participants generally do not need to create an account or provide their name, email address, phone number, or other direct identifiers in order to participate in a Shine Zone.

Shine does not access the content of personal messages, emails, photos, videos, files, browsing history, social media content, or activity within personal applications.

2. Information We Collect

To provide and operate the Service, Shine may collect and process the following information:

Operational Participation Data

  • Pseudonymous participant identifiers
  • Device identifiers or pseudonymous device references
  • Zone identifiers
  • Organization or environment identifiers
  • Session start times
  • Expected session end times
  • Actual session end times
  • Participation status
  • Consent status
  • Compliance and integrity status
  • Session events and activity logs
  • Verification results
  • Device platform information (such as iOS or Android)
  • Application version information

Zone Configuration Data

  • Zone settings and configuration information
  • Session rules
  • Time restrictions
  • Exit policies
  • Allowed or restricted application settings
  • Operational configuration data required to administer Shine Zones

Notification Data

  • Push notification tokens used to deliver operational notifications and service-related communications

Usage Analytics

Shine uses Firebase Analytics to collect limited usage and technical information that helps us understand application performance, reliability, and service usage patterns.

Shine does not use analytics information for advertising, profiling, or marketing purposes.

Diagnostic Information

Shine uses Firebase Crashlytics and related service functionality to collect technical diagnostic information that helps us identify, investigate, and resolve application errors and service issues.

This information may include device information, application version information, crash reports, error logs, and related technical diagnostics.

Administrator Information

Where an organization uses administrative features, Shine may collect administrator account information, including:

  • Name
  • Email address
  • Authentication credentials
  • Administrative activity records

3. Information We Do Not Collect

Shine is designed to minimize the collection of personal information and does not collect or access the following participant information as part of its normal operation:

  • Precise GPS location data
  • Background location tracking data
  • Personal messages
  • Emails
  • Photos
  • Videos
  • Files or documents
  • Contact lists
  • Browsing history
  • Social media content
  • Content stored within personal applications
  • Phone call content
  • Advertising profiles
  • Marketing profiles

Shine verifies participation and compliance states. Shine does not inspect the content of personal applications.

4. Location and Network Information

Shine does not collect precise GPS location information and does not perform background location tracking.

On certain iOS devices, Shine may request location-related permissions because Apple requires these permissions to access Wi-Fi network information. Shine uses network and Wi-Fi information solely to support operational functions such as verifying participation within approved environments, validating network conditions, and supporting zone verification requirements.

Shine does not use these permissions for GPS tracking or location monitoring.

5. How We Use Information

We use information collected through Shine to:

  • Operate Shine Zones
  • Verify participation and compliance status
  • Deliver the Service
  • Maintain operational records
  • Support customer administration and reporting
  • Deliver operational notifications
  • Troubleshoot technical issues
  • Improve application reliability and performance
  • Protect the security and integrity of the Service
  • Investigate misuse, fraud, or security incidents
  • Comply with legal obligations
  • Establish, exercise, or defend legal claims

We do not sell participant information.

We do not use participant information for third-party advertising.

6. Sharing of Information

We may share information with:

Service Providers

We use trusted service providers to operate the Service, including:

  • Google Firebase services, including Firestore, Firebase Cloud Messaging (FCM), Firebase Analytics, Firebase Crashlytics, and Remote Config
  • Google Cloud Platform
  • Apple platform services
  • Google platform services

These providers process information solely to support operation of the Service.

Organizations Operating Shine Zones

Organizations operating Shine Zones may receive information relating to participation in those Zones, including:

  • Pseudonymous participant identifiers
  • Session timestamps
  • Participation status
  • Compliance status
  • Verification results
  • Session event records

Organizations do not receive participant messages, emails, photos, files, browsing history, social media content, or other personal content through Shine.

Organizations may independently associate a participant identifier with an individual through their own records. Such activities occur outside of Shine and are governed by the organization's own policies and practices.

Legal Requirements

We may disclose information when required to:

  • Comply with applicable law
  • Respond to lawful requests from public authorities
  • Protect the rights, safety, or security of users, customers, or the public
  • Enforce our agreements
  • Investigate fraud, misuse, or security incidents

7. Data Retention

Shine retains operational participation, compliance, verification, and audit records for a minimum of twelve (12) months.

Records may be retained for longer periods where necessary to:

  • Support customer requirements
  • Comply with legal obligations
  • Support safety investigations
  • Resolve disputes
  • Investigate incidents
  • Maintain security
  • Establish, exercise, or defend legal claims

Where appropriate and legally permissible, records may be deleted or anonymized.

8. Children's Privacy

Shine may be used in educational, youth, family, workplace, and organizational environments, including environments involving children.

Shine is designed to minimize personal information collection and generally does not require participants to provide names, email addresses, or phone numbers to participate in a Shine Zone.

Organizations deploying Shine in educational or youth environments remain responsible for obtaining any permissions, notices, or consents required under applicable law.

Use of the Service may also be subject to agreements, policies, notices, and Terms of Service established by the organization operating the relevant Shine Zone.

9. International Data Transfers

Shine and its service providers may process and store information in countries other than the country where a participant resides.

Information may be transferred to and processed in jurisdictions where Shine, Google Firebase, Google Cloud Platform, or other service providers operate.

We take reasonable measures designed to protect information during such transfers.

10. Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, misuse, or destruction.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10A. Security Incidents

If we become aware of a security incident involving information under our control, we will take reasonable steps to investigate, contain, mitigate, and respond to the incident.

Where required by applicable law, contractual obligations, or regulatory requirements, we may notify affected customers, users, regulators, or other relevant authorities.

11. Your Rights and Choices

Depending on applicable law, users and organizations may have rights regarding information held by Shine, including rights to:

  • Request access to information
  • Request correction of information
  • Request deletion of information
  • Request restriction of processing
  • Object to certain processing activities

Because Shine generally does not require participants to provide names, email addresses, or phone numbers, Shine may not be able to directly identify an individual participant from a privacy request alone.

In some cases, requests may need to be submitted through the organization operating the relevant Shine Zone, particularly where the organization is the only party capable of associating a participant identifier with an individual.

Some requests may be limited where information must be retained for legal, security, operational, audit, compliance, safety, or dispute-resolution purposes.

Requests may be submitted using the contact information below.

Where Shine is operated by an organization, certain requests may need to be directed through that organization.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When material changes are made, we will update the Effective Date above and may provide additional notice where appropriate.

Continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

13. Contact Us

MagicHabits Labs Limited

Email: hello@shineverify.com

Contact Form: https://www.shineverify.com/contact

If you have questions regarding this Privacy Policy or Shine's privacy practices, please contact us using the information above.