Privacy Notice

1. Definitions

For the purposes of this Notice:

• “User” refers to any individual who installs, accesses, or otherwise uses the Application.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on Personal Data, whether automated or not.
• “Third-Party Service Provider” refers to any external entity engaged to deliver technical, analytical, infrastructural, or transactional services in support of the Application.

2. Scope of Application

This Notice applies to all Processing operations conducted through the Application. By installing or using the Application, the User confirms their understanding of, and agreement to, the Processing activities described herein.

3. Categories of Data Processed

3.1 System-Generated Technical Data

Upon installation and during use of the Application, certain information may be collected automatically for operational, diagnostic, and security purposes. Such information may include:

• Network identifiers (e.g., IP address);
• Records of interaction with Application components (e.g., access timestamps, pages or screens accessed);
• Aggregate duration of use;
• Device operating system specifications.

3.2 Data Provided by Users

Certain features may require the User to submit information that may constitute Personal Data. Such data is provided voluntarily and is processed exclusively for purposes described in Section 4.

3.3 Data Not Collected

The Application does not collect precise geolocation data (including GPS-derived coordinates).

4. Purposes of Processing

Personal Data and technical information may be processed for the following purposes, each deemed necessary for the operation and lawful use of the Application:

• Ensuring functional performance, stability, and security of the Application;
• Identifying, analyzing, and remediating operational faults;
• Conducting statistical assessments based on aggregated usage data;
• Communicating mandatory notifications, administrative messages, or compliance-related information;
• Where legally permissible, issuing non-essential informational or promotional communications.

5. Engagement of Third-Party Service Providers

The Service Provider may engage Third-Party Service Providers to perform analytics, performance monitoring, error reporting, subscription management, advertising technology management, or similar technical functions.

Third-Party Service Providers may Process data strictly to the extent necessary for fulfilling their contractual obligations to the Service Provider. They are prohibited from using such data for independent purposes and are required to adhere to confidentiality and data-protection requirements.

The identities of Third-Party Service Providers are not listed herein, as the composition of such providers may change. Information regarding such providers may be furnished upon lawful request where appropriate.

6. Conditions for Disclosure

Data may be disclosed only under the following conditions:

• Legal obligation: where disclosure is required by law, regulatory authority, court order, or comparable binding directive.
• Protection of legitimate interests: where necessary to defend rights, prevent misuse of the Application, investigate fraud, or address safety concerns.
• Authorized processors: where disclosure is necessary for Third-Party Service Providers performing tasks on behalf of the Service Provider.

7. Termination of Processing

Processing associated with the User’s use of the Application ceases upon the uninstallation of the Application. Users may uninstall the Application using standard device or marketplace removal procedures.

8. Retention and Erasure of Data

Data submitted by the User is retained for the duration necessary to fulfill the purposes identified in Section 4 and for an additional period permitted under applicable law.

Requests for erasure of User-submitted data may be directed to:
[email protected].

Erasure requests will be evaluated and executed where legally and operationally feasible.

9. Children’s Data

The Application is not intended for use by individuals under 13 years of age. The Service Provider does not knowingly Process Personal Data relating to minors within this age group. Should such data be identified, it will be removed without undue delay. Guardians may request review or deletion by contacting the Service Provider.

10. Security Measures

Appropriate technical and organizational measures are implemented to mitigate risks associated with unauthorized access, alteration, disclosure, or destruction of data. Notwithstanding these measures, no system of storage or transmission can be guaranteed to be entirely secure.

11. Processing Related to Refund Assessment

For in-app purchase refund assessments conducted by the relevant platform operator, the Service Provider may be required to transmit specific transactional parameters. Such parameters may include:

• Time elapsed since installation of the Application;
• Total Application usage time;
• Internal anonymized identifiers associated with the User’s device or account;
• Extent to which the purchased functionality was accessed or consumed;
• Presence of a trial period attached to the purchase;
• Cumulative expenditure within the Application;
• Total amount previously refunded to the User.

Such disclosure is conducted exclusively for the purpose of refund verification.

12. Amendments

The Service Provider may amend this Notice periodically. The most recent version shall prevail and will be made available within the Application or through the Service Provider’s designated online resources. Continued use of the Application constitutes acceptance of the amended Notice.

Effective date: 2025-05-19

13. Contact Information

Inquiries, requests, or communications related to this Notice may be submitted to:
[email protected]