Last updated: December 24th, 2024

Introduction

This privacy notice will inform you how we look after, collect, process, and use your personal data when you use our App and tell you about your legal rights.

Please note! We do not knowingly process the personal data of users under the age of 16. If you are such a user or the legal representative of such a user, please contact us.

By accessing or registering the App, the user agrees to the privacy policy and consents to collecting, processing, transferring, and using your personal data.

Before using the App, you must read and accept this privacy policy. If you don’t accept and agree to this privacy notice, you must immediately stop using our App.

Controller

Anton Vasyliev is the controller and responsible for your data (also as "we", "us" or “our”) in this privacy policy).

Contact details

Full name: Anton Vasyliev

Email address: vasylievanton66@gmail.com

Changes to the privacy policy

We reserve the right to and may change this privacy policy from time to time. If we make any material changes, we will notify you through our app or by presenting you with a new version of this privacy policy for you to accept if we, for example, add new processing activities or collect some additional personal data from you.

Your continued use of the app after the effective date of an updated version of the privacy policy will indicate your acceptance of the modified privacy policy. In some cases, you will have to explicitly accept changes to the privacy policy.

Types of data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

When you use the app, you may provide us with any image that is stored on your device. Please don’t provide us with any pictures of yourself or any other information that may be identified as personal data. Nevertheless, we would treat all received photos/images in the same manner as personal data in this privacy policy. We use this information and store it locally on your device.

We automatically or with your actions, collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:

Device data. Includes model, OS version, and language. Unique device identifiers (including IDFA);
Personal data. User name, email.
Location data and Demographic data. Includes location, country, state, city, zip code, time zone;
Device folders and files. Photos on your device, access to the camera.
Usage Data. Includes information about how you use our app, user activity within the app;
Data on subscription fees. This is the information we get from the App Store when you buy our subscription.

We also collect, use, and share aggregated data such as statistics or demographics. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect aggregated data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used under this privacy policy.

We don’t collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We don't collect any information about criminal convictions and offenses.

We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the privacy policy («data minimization principle»).

Lawful bases for processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Consent. You have given clear consent for you to process their personal data for a specific purpose.
Contract. The processing is necessary for a contract you have with us.
Legitimate interests. The processing is necessary for our legitimate interests or the legitimate interests of a third party.

We may process your data if you have given us specific consent to use your personal information for a specific purpose.

If you share with us the personal data of a third party, you confirm that such a third party gave you consent on the collection and processing of his/her data by us. We, in turn, will take the same measures and procedures to ensure the safety of such information as we do in relation to your data.

Purposes for which we will use your data

Below, in table format, we have a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.

Note that we may process your data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on you to process your data where more than one ground has been set out in the table below.

Purpose	Type of data	Lawful basis for processing, including basis of legitimate interest
For marketing and analytical purposes. To provide, improve and develop the application.	Mobile device data. Includes model, OS version, and language. Unique device identifiers (including IDFA or GAID)	Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app)
It is necessary for registration and user identification.	Personal data. User name, email.	Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app)
To use the app's features	Device folders and files. Photos on your device, access to the camera.	Your consent.
For marketing and analytical purposes. To provide, improve, and develop the application. To use functions of the app.	Usage Data. Location data and Demographic data. Includes location, country, state, city, zip code, time zone;	Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).
For marketing and analytical purposes. To provide, improve, and develop the app.	Information about how you use our app and user activity within the application.	Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).
To provide access to the application, identify the user, and track the subscription period.	Data on subscription fees.	Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). It is necessary to comply with a legal obligation.
To participate in reviewing user refund requests to the Apple App Store or our suppliers to prevent fraudulent and deceptive actions by users.	Consumption Information. Account Tenure, App Account Token (UUID), Consumption Status, Customer Consented, Delivery Status, lifetime Dollars Purchased, lifetime Dollars Refunded, Platform, play Time, Refund Preference, Sample Content Provided, and User Status.	Your consent. It is necessary for our legitimate interests (to keep our records updated and to study how customers use our App).

Third Party Services and disclosures of your data

We share your personal data with our service providers, which is strictly limited to cases and purposes stipulated in this privacy policy.

We’ll not use the information gained through your use of our app and other frameworks for advertising or similar services or sell it to advertising platforms, data brokers, or information resellers.

We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes.

We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section "Types of data we collect" of this privacy policy or collect any personal data that is not required for the mentioned purposes.

For any new purpose of processing, we will ask for your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.

We disclose potentially personally-identifying information (i.e., personal data) among our employees, contractors, and affiliated or other third-party organizations that (i) need to know that information in order to process it on our behalf or to provide services available at the Company and (ii) that have agreed not to disclose it to others.

Cross-border transfer of personal data. Some of those employees, contractors, and affiliated or other third-party organizations may be located within or outside of the USA, EU, or the European Economic Area (EEA); by using our app, you consent to the transfer of such information to them.

We share your data with the parties set out below for the purposes set out in the table above:

External Third Parties: Apple Inc., Google LLC, Meta Platforms Inc., Firebase Inc., Amplitude Inc., Mathpix Inc., Appsflyer Inc.

These parties help us store Personal Data, analyze your data, and show relevant information about the app when you use it. This helps us understand how you use the app, engage with particular features, and what you like or dislike the most, generating statistical reports.

User’s consumption Information and refund. By requesting a refund in the Apple App Store for an in-app purchase or automatically renewing a subscription, you acknowledge and consent to the transfer by us of Consumption Information described in the "Types of data we collect" section to Apple. Our legitimate interest must prevent fraudulent and deceptive actions by users. Apple uses and protects the data you share through the Send Consumption Information API in accordance with Apple’s Privacy Policy.

Opt-out options.

You can withdraw your consent or opt-out, whatever applies in your case, from sharing your Personal Data under this subsection anytime by using one of the following options:

By contacting us at vasylievanton66@gmail.com;
By adjusting your device settings in iOS.
Stop using our app.

Obtaining data from third parties

When a user buys a subscription, we receive transaction data, ID subscriptions, subscription terms, and app statistics from the Apple App Store.

The Apple App Store data processing policy further regulates the collection, processing, and transmission of data on purchase via the Apple App Store data processing policy.

Banking information

When you pay for a subscription to our app, you share your banking information with the Apple App Store. This relationship is further regulated between the user and the privacy policy of the Apple App Store.

We don’t collect or process your bank information when buying a subscription.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data according to our instructions, and they are subject to a confidentiality duty.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also use technical data encryption tools such as SSL protocols to keep your data secure.

Data retention

How long will you use my personal data?

We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

We store your data while you use our application.

In some circumstances, you can ask us to delete your data. To send an email to our address: vasylievanton66@gmail.com.

In some circumstances, we may anonymize your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We do not use user data for sale (or any other commercial activity) to other companies. User data is used solely to ensure the app's functionality.

Your legal rights

Under the legislation of the US and European Union, you have the right to:

receive information, namely, what personal data we process and why (disclosed by this policy);
Right to Erasure. You have the right to delete data under certain circumstances.
Right to Rectification/to be forgotten. You have the right to ask us to correct your inaccurate data, as well as the right to make additions to it.
Right to access. You can request a copy of your data.
Right to restriction of the processing. In certain cases, you have the right to request the termination of data processing by allowing the continued storage of data.
Right to data portability. You can request a copy of your data in a machine-readable form that can be transferred to another person who processes the personal data.
Right to object to marketing. Under certain circumstances, including when data is processed for legitimate interests or marketing purposes, you may object to such processing.
Rights related to automated decision-making, including profiling. In this area, there are several rights related to the fact that processing carried out exclusively on an automated basis can lead to a decision that has legal and other significant consequences for a person. In such circumstances, you have the right to human interference in the decision-making process.
Right to withdraw consent. For example, you can withdraw your consent to receive letters or phone calls.
Right to complain to the relevant data protection authority.

If you wish to exercise any of the rights set out above, please contact us at vasylievanton66@gmail.com.

What we may need from you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

Time limit to respond.

We respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Glossary

In this Policy, the following terms shall have the following meanings:

Lawful basis. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

We don't use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at vasylievanton66@gmail.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

California privacy rights

This section provides additional details about how we process the personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected, including the categories of sources, please see the section “Types of data We collect”. We collect this information for purposes described in the section “Purposes for which we will use your data” of this privacy policy. We may also share your information with certain categories of third parties as indicated in the Section “Data retention”.

Subject to certain limitations, the CCPA provides California consumers with the right to request more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request under their rights under the CCPA by contacting us at vasylievanton66@gmail.com. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.