Privacy Policy

Last updated: March 16, 2026

Oleksandr Shemyakin ("Developer", "we", "us", or "our"), a sole proprietor registered in Poland (NIP: 5252923043, REGON: 523081083), operates mobile applications (collectively, the "Apps"). This Privacy Policy explains how we collect, use, and protect your information when you use our Apps. We act as the data controller within the meaning of the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Information We Collect

Our Apps may collect the following types of information: • Personal Information: name, email address, and other contact details you provide when creating an account, subscribing to a service, submitting a contact or feedback form, or opting in to communications. • Device Information: device type, operating system version, unique device identifiers. • Usage Data: how you interact with the App, features you use, session duration. • Crash Reports: diagnostic data to help us fix bugs and improve stability. • Purchase Data: information about in-app purchases and subscriptions, processed through Apple App Store, Google Play, and RevenueCat. We do not have access to your full payment card details. We only collect personal information that is necessary for the purposes described in this policy or that you voluntarily provide.

2. Legal Basis for Processing

Under the GDPR, we process your data based on the following legal grounds: • Contractual necessity (Art. 6(1)(b) GDPR): processing necessary to provide the Apps, manage your account, and fulfill in-app purchases or subscriptions. • Legitimate interests (Art. 6(1)(f) GDPR): analytics, crash reporting, and monitoring to improve the Apps, ensure security, and diagnose issues. • Consent (Art. 6(1)(a) GDPR): where you have opted in, such as for email communications, newsletters, marketing messages, or personalized advertising. You may withdraw consent at any time by using the unsubscribe link in our emails or by contacting us. • Legal obligation (Art. 6(1)(c) GDPR): where required to comply with applicable laws.

3. How We Use Your Information

We use the collected information to: • Provide, maintain, and improve our Apps. • Create and manage your account (where applicable). • Process and manage in-app purchases and subscriptions. • Send transactional communications (e.g., purchase confirmations, service updates). • Send promotional emails, newsletters, and product announcements (only with your consent). • Respond to your inquiries and provide customer support. • Personalize your experience within the Apps. • Diagnose technical issues and fix bugs. • Analyze usage trends to enhance user experience. • Comply with legal obligations.

4. Data Storage, Security, and Retention

We take reasonable technical and organizational measures to protect your information from unauthorized access, alteration, disclosure, or destruction. Data is stored securely and retained only for as long as necessary to fulfill the purposes outlined in this policy. Specifically: • Account and contact data (name, email): retained for the duration of your account or until you request deletion. If you unsubscribe from communications, we retain a record of your opt-out to honor your preference. • Analytics and usage data: retained for up to 26 months. • Crash reports: retained for up to 180 days. • Purchase and subscription records: retained for the duration of your subscription and as required by tax and accounting laws (up to 5 years). • Support correspondence: retained for up to 3 years after the last interaction.

5. Third-Party Services

Our Apps may use third-party services that collect and process information on our behalf. These include: • Google Analytics / Firebase Analytics — analytics and usage tracking. • Firebase Crashlytics — crash reporting and diagnostics. • RevenueCat — in-app purchase and subscription management. • Google Cloud Platform — cloud infrastructure and backend services. • Grafana Cloud — monitoring and observability. • Google AdMob — advertising and ad personalization. These third-party services operate under their own privacy policies. We encourage you to review them.

6. International Data Transfers

Some of the third-party services we use (such as Google Cloud Platform, Firebase, RevenueCat, and Grafana Cloud) may transfer and process your data outside the European Economic Area (EEA), including in the United States. Where such transfers occur, they are safeguarded by: • European Commission adequacy decisions; • Standard Contractual Clauses (SCCs) approved by the European Commission; or • The EU-U.S. Data Privacy Framework, where applicable. You may request further details about the safeguards in place by contacting us.

7. Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights regarding your personal data: • Right of access — obtain confirmation of whether your data is being processed and request a copy (Art. 15). • Right to rectification — request correction of inaccurate data (Art. 16). • Right to erasure — request deletion of your data ("right to be forgotten") (Art. 17). • Right to restriction — request limitation of processing (Art. 18). • Right to data portability — receive your data in a structured, machine-readable format (Art. 20). • Right to object — object to processing based on legitimate interests or direct marketing (Art. 21). • Right to withdraw consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing. How to delete your data: • From within the App: go to your Profile page and select Delete Account. This will permanently remove your account and all associated personal data. • By contacting support: send a request to [email protected] and we will process the deletion within 30 days. To exercise any other rights listed above, please contact us at [email protected]. We will respond within 30 days.

8. Right to Lodge a Complaint

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority. In Poland, the competent authority is: Prezes Urzędu Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland Website: https://uodo.gov.pl

9. Children's Privacy

Our Apps are not directed at children under the age of 16. We do not knowingly collect personal information from children under 16 (or under 13 in jurisdictions where that is the applicable age threshold). If you believe we have inadvertently collected such information, please contact us so we can promptly delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. For material changes, we will make reasonable efforts to notify you (e.g., via an in-app notice). We encourage you to review this policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at: Oleksandr Shemyakin ul. Czyżówka 14 lok. 0.3 30-526 Kraków, Poland Email: [email protected]