Privacy Policy
Last updated: [Date]
[App Name] (hereinafter referred to as the "Application") is developed and operated by [Company / Individual Name] ("we", "our", "us"). We are committed to protecting your privacy and handling your personal data responsibly, transparently, and in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws.
This Privacy Policy explains what data we collect, how we use it, your rights, and how you can exercise them.
Data Controller
The Data Controller responsible for your personal data is:
[Company / Individual Name]
[Registered address]
Email: [Privacy contact email]
Data We Collect
When you use our Application, we may collect the following categories of personal data:
- Account Information: Your email address, provided during registration or subscription.
- Technical Data: Device identifiers, operating system, app version, crash logs, and usage statistics.
- Subscription and Payment Data: Transaction details related to purchases or subscriptions. Payments are processed securely by third-party providers (Google Play, Apple App Store); we do not store full payment card details.
- Advertising and Analytics Data: Information collected automatically through Google AdMob for displaying ads and improving user experience.
Purposes of Processing
We process personal data for the following purposes:
- To create, maintain, and manage your user account.
- To provide and manage subscriptions and in-app purchases.
- To display advertising through Google AdMob. Personalized ads are shown only with your explicit consent.
- To communicate with you regarding your account or our services.
- To comply with legal obligations (e.g., tax and accounting).
- To monitor, analyze, and improve the performance and security of the Application.
Legal Bases for Processing
We process personal data based on the following legal grounds:
- Performance of a contract (Art. 6(1)(b) GDPR): providing access to the Application and subscription services.
- Legal obligations (Art. 6(1)(c) GDPR): compliance with accounting, tax, and other statutory requirements.
- Legitimate interests (Art. 6(1)(f) GDPR): ensuring Application security, preventing fraud, and improving user experience.
- Consent (Art. 6(1)(a) GDPR): for example, when you agree to personalized advertising.
Data Sharing and International Transfers
We share data only when necessary and only with trusted third parties:
- Payment providers (Google Play, Apple App Store) to process subscriptions.
- Advertising providers (Google AdMob) to display ads.
- Hosting and cloud service providers for data storage and security.
- Analytics providers for monitoring and performance improvements.
If data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or equivalent legal mechanisms, as required by GDPR.
Data Retention
- Account data is retained as long as your account is active.
- If you delete your account, your data will be erased or anonymized within 30 days, except for information we are legally required to retain.
- Payment records and legal documents are stored in accordance with statutory retention periods.
User Rights
Under GDPR, you have the following rights:
- Right of access β request a copy of your personal data.
- Right to rectification β request correction of inaccurate or incomplete data.
- Right to erasure β request deletion of your data ("right to be forgotten").
- Right to restriction of processing β request limits on how we use your data.
- Right to data portability β request transfer of your data to another provider.
- Right to object β object to data processing (including for advertising).
- Right to withdraw consent β withdraw consent at any time, without affecting prior lawful processing.
You also have the right to lodge a complaint with your local data protection authority if you believe your data is being processed unlawfully.
To exercise these rights, please contact us at: [Privacy contact email].
Account Deletion
You can delete your account at any time via:
- The Application (account settings).
Once deleted, your data will be permanently erased or anonymized, except where retention is legally required.
Advertising and Cookies
The Application uses Google AdMob to serve ads.
- Personalized ads: shown only if you give your explicit consent. You can withdraw consent at any time in the Application settings.
- Non-personalized ads: may still be displayed, but they are not based on your personal data.
You can manage your ad settings through Google: https://www.google.com/settings/ads
Children's Privacy
Our Application is not directed to children under the age of 16. We do not knowingly collect personal data from children.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately so we can delete it.
Data Security
We use appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If we make significant changes, we will notify you through the Application or via email before the changes take effect.
Contact
If you have any questions regarding this Privacy Policy or how we handle your data, please contact us:
[Company / Individual Name]
Email: [Privacy contact email]