PRIVACY POLICY
1. WHO WE ARE
This Privacy Policy is issued by Valery Sihai, an independent mobile application developer established in Warsaw, Poland, European Union ("we", "us", "our", or the "Developer").
We are the data controller for personal data processed through our applications within the meaning of Article 4(7) of Regulation (EU) 2016/679 (the "GDPR").
Contact details
- Valery Sihai, independent app developer
- Rajska 2/18, 02-654 Warszawa, Poland
- Email: deep.value4u@gmail.com
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR. Privacy enquiries are handled directly by the Developer at the contact details above.
Because we are established in the European Union, our supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, "UODO"), ul. Stawki 2, 00-193 Warsaw, Poland — https://uodo.gov.pl.
2. SCOPE OF THIS POLICY
This Privacy Policy applies to all mobile applications, websites and related services published by the Developer through the Apple App Store or other supported platforms (collectively, the "Services"). It applies to every application published under our developer name, including applications released after the date of this Policy, and to every localised version of an application, whatever name that application carries in your country’s App Store.
How to read this Policy
Our applications do different things, and therefore process different information. Not every section of this Policy applies to every application.
Most of this Policy applies to all of our applications. Three sections describe practices that exist only where an application actually offers the relevant feature: Section 3.3 (control of devices on your local network), Section 4 (photo library management) and Section 6.2 (in-app advertising).
Each of those sections opens with a note headed "When this section applies". If the application you are using does not offer the feature described there, that section does not apply to you, the permission in question is never requested, and the processing it describes does not take place.
Where an application processes information in a way that is not described in this Policy, we publish an App-Specific Supplement within that application and at the privacy policy address listed for it in the App Store. In the event of a conflict, the Supplement prevails over this Policy for that application.
Your use of the Services is also governed by our Terms of Use.
This Policy is an information notice, not a contract. Where we rely on your consent, that consent is requested separately and may be withdrawn at any time, as described in Section 12.
3. INFORMATION WE COLLECT
Depending on the application you use, the features you access, your device settings, the permissions you grant and applicable law, we may collect the following categories of information.
3.1 Information collected automatically
When you use the Services, certain information is collected automatically, including:
- Device type and model
- Operating system and version
- App version and build number
- Device language and region
- Time zone
- Screen characteristics
- Anonymous or pseudonymous device identifiers
- IP address
- Approximate geographic information (such as country or region) derived from your IP address
- Technical diagnostic information
- Usage information and interaction timestamps
This information is used for app functionality, security, performance optimisation, analytics, compatibility testing and technical support.
We do not collect precise (GPS-level) location. Where we refer to location, we mean country- or region-level information inferred from your IP address.
3.2 Usage information
We collect information about how users interact with our applications, including screens viewed, features used, navigation within the app, session duration and frequency, performance metrics, error and diagnostic events, subscription-related interactions, and general engagement and usage patterns.
This information helps us understand how our applications are used and improve their functionality, usability, reliability and performance.
3.3 Local network and connected device information
When this section applies. This section applies only where an application offers control of televisions, streaming devices, smart home devices or other compatible hardware on your local network. Applications without such features do not request local network access and do not process any of the information described below.
To provide this functionality, the application requires local network access permission on your device. It then discovers compatible devices on your local network and communicates with them directly. The following information may be processed:
- Device type, manufacturer and model information
- Operating system type of the connected device
- User-assigned device names
- Local network addresses of discovered devices
- Connection characteristics and pairing status
Device discovery and control commands are exchanged directly between your device and the connected hardware on your local network. We do not collect the content displayed on your connected devices, your viewing history, or personal files stored on those devices. Limited technical information about connection success or failure may be included in diagnostic and crash reports so that we can improve compatibility.
You may revoke local network access at any time in Settings › Privacy & Security › Local Network. Revoking access will prevent the remote control features from working.
3.4 Purchase and subscription information
If you purchase a subscription or make an in-app purchase through the Apple App Store, Apple processes the payment transaction. We receive limited information related to your purchase, including subscription status, product identifier, transaction identifier, purchase date, renewal status and expiration information.
We do not collect or store your payment card information.
Apple acts as an independent controller in respect of the payment transaction and your App Store account relationship. Apple's handling of that information is governed by the Apple Privacy Policy, not by this Policy.
3.5 Advertising identifiers and advertising data
When this section applies. This section applies only where an application displays advertising or participates in advertising attribution. See also Section 6.
Where you grant permission through Apple's App Tracking Transparency framework, or where applicable law otherwise permits, we and our advertising partners may process:
- The Identifier for Advertisers (IDFA) or an equivalent advertising identifier
- Ad impressions, ad clicks and ad interaction events
- Install and re-engagement attribution data
- Coarse location (country or region) and device characteristics used for ad delivery
- Interest or audience segments inferred from your activity within our applications
If you decline the App Tracking Transparency request, the IDFA is not available to us and we do not use it.
3.6 Information from third-party sources
Where permitted by law, we may receive limited information from advertising and attribution partners, analytics providers, and platform providers such as Apple and Google. This information is limited to aggregated or pseudonymous campaign, attribution and performance data.
3.7 Information we do not collect
In no application, and regardless of the permissions you grant, do we collect, receive, transmit or store:
- Your name, postal address or telephone number
- Payment card numbers or bank details
- Precise (GPS-level) location data
- Your photos or videos, or their metadata — where an application provides photo management features it accesses your photo library locally on your device, as described in Section 4, but no photo, video or associated metadata ever leaves your device
- Your contacts, calendar entries, microphone or camera content
- The content displayed on, or files stored on, televisions and other devices you may connect to
- Special categories of personal data within the meaning of Article 9 GDPR (including health, biometric, genetic, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life or sexual orientation data)
- Government-issued identification numbers
4. PHOTO LIBRARY ACCESS AND ON-DEVICE PROCESSING
When this section applies. This section applies only where an application offers features for reviewing, organising or deleting photos and videos stored on your device. Applications without such features never request access to your photo library, and none of the processing described below takes place in them.
Where such features are offered, the application requests access to your photo library through the standard iOS Photos permission.
All processing of your photos and videos takes place entirely on your device. This includes:
- Detecting duplicate, similar, blurry or low-quality images
- Identifying screenshots and other clutter
- Grouping photos by date for month-by-month review
- Reading location metadata embedded in photos in order to display a personal map of places
- Image quality enhancement
- Generating anniversary content and home screen widget content
We do not upload, transmit, receive, store or have access to your photos, videos or their metadata. We operate no server on which photos or videos are stored. No third party — including our analytics or advertising partners — receives your photos, videos or any information derived from them.
Location metadata
Photos taken on a mobile device frequently contain GPS coordinates in their EXIF metadata. Where an application displays a map of the places your photos were taken, that metadata is read and used exclusively on your device. We do not collect, receive or store precise location data.
Deletion of photos
When you choose to delete photos or videos, deletion is carried out by iOS through the system photo library. Deleted items are moved to the "Recently Deleted" album and are permanently removed by iOS according to your device settings, normally after 30 days. We are not able to recover deleted items.
Your control
You may revoke or limit photo library access at any time in Settings › Privacy & Security › Photos, including by selecting "Limited Access" so that the application can see only the photos you choose. Revoking access will prevent the relevant features from working but will not affect your subscription.
Advertising and your photos
No information derived from your photos or videos is used to select, target or measure advertising. Advertising, where an application displays it, is based only on the categories of information described in Sections 3.1, 3.2 and 3.5.
5. HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS
We process personal data only where we have a lawful basis to do so. The table below sets out each purpose, the data involved, and the legal basis under Article 6 GDPR. Purposes that relate to a feature-specific practice apply only to applications that offer the relevant feature.
| Purpose | Categories of data | Legal basis (Article 6 GDPR) |
|---|---|---|
| Providing and operating the Services, including the features offered by the application you are using | Device data, usage data, connected device data | Art. 6(1)(b) — performance of a contract |
| Processing subscriptions and in-app purchases, restoring entitlements, preventing refund abuse | Purchase and subscription data | Art. 6(1)(b) — contract; Art. 6(1)(c) for statutory retention |
| Crash reporting, diagnostics, security, and prevention of fraud and abuse | Technical diagnostic data, device data, IP address | Art. 6(1)(f) — legitimate interests in keeping the Services secure and functional |
| Product analytics, measuring feature performance and improving our applications | Usage data, pseudonymous identifiers | Art. 6(1)(f) — legitimate interests; or Art. 6(1)(a) consent where required by local law |
| Advertising measurement and install attribution that does not involve tracking across other companies’ apps and websites | Attribution and campaign data | Art. 6(1)(f) — legitimate interests |
| Serving in-app advertising, cross-app tracking, personalised advertising and audience segmentation | Advertising identifier, ad interaction data, inferred segments | Art. 6(1)(a) — consent, obtained through App Tracking Transparency and, in the EEA, the United Kingdom and Switzerland, through a separate in-app consent prompt |
| Responding to your requests and handling privacy rights requests | Contact data, request records | Art. 6(1)(c) — legal obligation; Art. 6(1)(f) |
| Complying with tax, accounting and other legal obligations, and responding to lawful requests from authorities | Purchase records and other data as applicable | Art. 6(1)(c) — legal obligation |
| Establishing, exercising or defending legal claims | Data as applicable | Art. 6(1)(f) — legitimate interests |
| Developing new features and applications | Aggregated and pseudonymised usage data | Art. 6(1)(f) — legitimate interests |
Where we rely on legitimate interests, we have carried out a balancing assessment and you have the right to object at any time under Article 21 GDPR. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Automated decision-making. We do not use personal data for automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 GDPR.
6. ADVERTISING, TRACKING AND YOUR CHOICES
6.1 App Tracking Transparency
Some of our applications request permission to track your activity across other companies’ apps and websites using Apple’s App Tracking Transparency ("ATT") framework. If you grant permission, advertising identifiers and similar identifiers may be used for advertising attribution, campaign measurement, analytics, fraud prevention and improving advertising effectiveness.
If you decline permission, we do not access the IDFA and we do not track you across other companies’ apps and websites. You may change your decision at any time in Settings › Privacy & Security › Tracking.
6.2 In-app advertising
When this section applies. This section applies only where an application displays advertising. Applications that do not display advertising do not integrate advertising software development kits, and no advertising identifier is processed within them.
Where an application displays advertising, that advertising is supplied by third-party advertising networks, including Google AdMob and Meta Audience Network. Advertising may be:
- Personalised (interest-based) — shown on the basis of your advertising identifier and inferred interests. We serve personalised advertising only where you have granted ATT permission and, in the EEA, the United Kingdom and Switzerland, given consent through our in-app consent prompt.
- Non-personalised (contextual) — shown on the basis of the content of the application and coarse information such as country. Declining tracking does not remove advertising; it makes the advertising you see less relevant.
6.3 Consent in the EEA, the United Kingdom and Switzerland
If you are located in the EEA, the United Kingdom or Switzerland, we present a separate consent prompt through a certified consent management platform before any personalised advertising is served or any advertising identifier is used. You may change or withdraw your choices at any time through the "Privacy choices" option within the application.
6.4 How to control advertising and tracking
- iOS tracking permission: Settings › Privacy & Security › Tracking
- Apple personalised advertising: Settings › Privacy & Security › Apple Advertising
- In-app privacy choices: available in the settings of any application that displays advertising
- Google advertising controls: https://adssettings.google.com
- Meta advertising controls: https://www.facebook.com/adpreferences
- You may also email us at deep.value4u@gmail.com and we will action your request
6.5 Analytics
We use analytics technologies to understand how users interact with our applications, evaluate feature performance, improve usability, identify technical issues and develop new functionality. Analytics data is pseudonymous and we do not attempt to re-identify you from it or combine it with directly identifying information.
The specific analytics and advertising technologies we use may change over time. Where a change materially alters the categories of data collected or the recipients of that data, we will update this Policy before the change takes effect.
7. SHARING OF INFORMATION AND THIRD-PARTY RECIPIENTS
We do not share your personal information except as described below. Where a recipient acts as our processor, we have a data processing agreement in place under Article 28 GDPR.
| Recipient | Role | Purpose | Privacy information |
|---|---|---|---|
| Apple Inc. / Apple Distribution International Ltd. | Independent controller | App Store distribution, payment and subscription processing, App Store Connect Analytics, Apple Search Ads Attribution | apple.com/legal/privacy |
| Google LLC / Google Ireland Ltd. (Google Analytics for Firebase, Firebase Crashlytics) | Processor | Product analytics, crash reporting and diagnostics | firebase.google.com/support/privacy |
| Google LLC / Google Ireland Ltd. (Google AdMob, Google Ads) | Independent controller | Serving and measuring in-app advertising — applications that display advertising only | business.safety.google/privacy |
| Meta Platforms, Inc. / Meta Platforms Ireland Ltd. (Meta Audience Network, Meta Ads) | Independent controller | Serving and measuring in-app advertising and advertising campaigns — applications that display advertising only | facebook.com/privacy/policy |
| Apphud Inc. | Processor | Subscription management, receipt validation and subscription analytics | apphud.com/privacy |
| PostHog, Inc. | Processor | Product analytics and feature usage measurement | posthog.com/privacy |
| Professional advisers, auditors and public authorities | Independent controller | Where required to comply with a legal obligation or to establish or defend legal claims | Not applicable |
Not every application uses every recipient listed above. Advertising partners are present only in applications that display advertising; an application without advertising does not contain their software and sends them nothing.
Your photos and videos are never shared with any recipient listed above, in any application.
We may also disclose information to comply with legal obligations, to respond to lawful requests from public authorities, to protect our rights and property, to investigate security incidents or misuse of the Services, and in connection with a merger, acquisition, financing or other business transaction. If our business is transferred, we will notify you and the acquirer will remain bound by this Policy until it is lawfully replaced.
We do not sell personal information in exchange for money. Please see Section 12.2 for how United States state privacy laws treat interest-based advertising, and how to opt out.
8. INTERNATIONAL DATA TRANSFERS
Your information may be transferred to and processed in countries outside your country of residence, including the United States. Where we transfer personal data outside the European Economic Area, we rely on one of the following safeguards:
- The European Commission’s adequacy decision of 10 July 2023 in respect of the EU–US Data Privacy Framework, where the recipient is certified under that framework;
- The European Commission’s Standard Contractual Clauses (Implementing Decision (EU) 2021/914), together with supplementary technical and organisational measures where required following a transfer impact assessment;
- An adequacy decision in respect of the recipient country.
You may request a copy of the relevant safeguards by contacting us at deep.value4u@gmail.com.
9. DATA RETENTION
We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When information is no longer required, we delete it, anonymise it, or securely isolate it until deletion is reasonably possible.
| Category of data | Retention period |
|---|---|
| Photos, videos and their metadata | Not retained. This data never leaves your device and is never received by us. |
| Crash and diagnostic logs | Up to 90 days |
| Product analytics data (pseudonymous) | Up to 14 months, after which data is aggregated or anonymised |
| Advertising and attribution identifiers | Up to 12 months from your last interaction, or shorter where required by the relevant advertising partner |
| Subscription and purchase records | Five years from the end of the calendar year in which the related tax obligation arose, in accordance with Polish tax and accounting legislation |
| Support and privacy request correspondence | Three years from closure of the request |
| Records of consent and consent withdrawal | For the duration of the processing and for the applicable limitation period thereafter |
These periods are indicative. We may retain data for longer where necessary to comply with a legal obligation, resolve a dispute, or establish, exercise or defend legal claims.
10. DATA SECURITY
We implement commercially reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration and disclosure. These include encryption of data in transit, access controls, keeping processing on your device wherever it is technically possible, and selecting service providers that maintain recognised security standards.
However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
Personal data breaches. In the event of a personal data breach, we will notify the President of the Personal Data Protection Office (UODO) without undue delay and, where feasible, within 72 hours of becoming aware of it, in accordance with Article 33 GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 GDPR.
11. CHILDREN
Our applications are intended for a general audience and are not directed to children.
An age rating of 4+ in the Apple App Store indicates only that an application contains no objectionable content. It does not mean that the application is designed for, targeted at, or primarily intended for children. Our applications are not published in the Apple Kids Category.
United States. Our Services are not directed to children under 13 within the meaning of the Children’s Online Privacy Protection Act ("COPPA"), and we do not knowingly collect personal information from children under 13. We do not knowingly sell or share the personal information of consumers under 16 years of age.
European Economic Area and United Kingdom. Where we rely on consent — including consent to tracking for advertising purposes — we do not knowingly seek that consent from a child below the age specified by national law. In Poland that age is 16 years (Article 8 GDPR). Consent given by a child below that age is not valid unless given or authorised by the holder of parental responsibility.
If any of our applications is or becomes directed to children, we will, for that application:
- not request App Tracking Transparency permission;
- not serve personalised or interest-based advertising, and will tag all advertising requests for child-directed treatment with the relevant advertising networks;
- not use third-party advertising or third-party analytics in any application published in the Apple Kids Category; and
- publish an App-Specific Supplement describing the applicable practices.
If we become aware that we have collected personal information from a child in a manner that violates applicable law, we will take reasonable steps to delete that information promptly. If you believe that a child has provided us with personal information, please contact us at deep.value4u@gmail.com.
12. YOUR PRIVACY RIGHTS
12.1 Rights in the European Economic Area and the United Kingdom
Under the GDPR and the UK GDPR you have the right to:
- Access your personal data and obtain a copy of it (Article 15)
- Have inaccurate or incomplete data rectified (Article 16)
- Have your data erased in the circumstances set out in Article 17 ("right to be forgotten")
- Restrict processing in the circumstances set out in Article 18
- Receive your data in a structured, commonly used and machine-readable format and have it transmitted to another controller (Article 20)
- Object to processing based on legitimate interests, and to object at any time and without justification to processing for direct marketing purposes (Article 21)
- Withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal (Article 7(3))
- Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Article 22)
You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Article 77). Our supervisory authority is:
Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, Poland — https://uodo.gov.pl
A list of EEA supervisory authorities is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. In the United Kingdom, the supervisory authority is the Information Commissioner’s Office (https://ico.org.uk).
12.2 Rights in the United States
Depending on your state of residence, you may have rights under the California Consumer Privacy Act as amended by the CPRA, or under comparable laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland and other states.
Categories of personal information we collect. In the twelve months preceding the date of this Policy we have collected the following categories: identifiers (including device identifiers, advertising identifiers and IP address); commercial information (subscription and purchase records); internet or other electronic network activity information (usage and interaction data); coarse geolocation data (country or region); and inferences drawn to create advertising or audience segments. The sources, purposes and recipients of each category are described in Sections 3, 5 and 7.
Your rights. Subject to your state’s law, you may have the right to know what personal information we collect, use and disclose; to access a copy of it; to correct inaccurate information; to request deletion; to opt out of the sale or sharing of personal information and of targeted advertising; to opt out of profiling in furtherance of decisions producing legal or similarly significant effects; to limit the use of sensitive personal information; and to appeal a denial of a request.
Sale and sharing. We do not sell personal information in exchange for money. However, in applications that display advertising, our use of third-party advertising partners for interest-based advertising may constitute a "sale" or a "share" for cross-context behavioural advertising under the CCPA and comparable state laws. You may opt out at any time by:
- declining or revoking the App Tracking Transparency permission in Settings › Privacy & Security › Tracking;
- using the "Privacy choices" setting within any application that displays advertising; or
- emailing deep.value4u@gmail.com with the subject line "Do Not Sell or Share My Personal Information".
Global Privacy Control. Where you access a website operated by us, we recognise and honour opt-out preference signals, including the Global Privacy Control (GPC).
Sensitive personal information. We do not collect or use sensitive personal information for purposes that would give rise to a right to limit its use under the CCPA. Your photos and videos are never collected by us.
Non-discrimination. We will not discriminate against you for exercising any of these rights. We do not offer financial incentives in exchange for personal information.
Authorised agents. You may designate an authorised agent to submit a request on your behalf. We may require proof of the agent’s authority and verification of your identity.
12.3 How to exercise your rights
To exercise any right, contact us at deep.value4u@gmail.com with a description of your request. We may need to ask for information to verify your identity or to locate the data associated with your device; if we cannot identify you from the pseudonymous data we hold, we will tell you so (Article 11(2) GDPR).
We respond to requests under the GDPR within one month, which may be extended by two further months where the request is complex, and to requests under United States state privacy laws within 45 days, which may be extended by a further 45 days. Exercising your rights is free of charge, except where a request is manifestly unfounded or excessive.
13. COOKIES AND OUR WEBSITE
Our applications do not use cookies. We do not currently operate a website other than the page on which this Privacy Policy is published, and that page uses only cookies that are strictly necessary for it to function.
If we introduce a website that uses analytics or advertising cookies, we will request your consent through a cookie banner in accordance with the ePrivacy Directive and Article 6(1)(a) GDPR, and will publish a separate cookie notice before those cookies are set.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our Services, legal requirements or privacy practices. The updated version will be indicated by the "Last updated" date at the top of this document.
Where we make material changes — including any change to the categories of personal data we collect, the purposes for which we use them, or the recipients with whom we share them — we will provide notice within the affected application or through the App Store release notes at least 14 days before the change takes effect. Where a change requires your consent, we will ask for it separately and the change will not apply to you until you give it.
15. CONTACT
If you have any questions, concerns or requests regarding this Privacy Policy or our privacy practices, please contact:
Valery Sihai
Rajska 2/18, 02-654 Warszawa, Poland
Email: deep.value4u@gmail.com
If you are not satisfied with our response, you may lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, or with the supervisory authority in your country of residence.