This Privacy Policy (“Policy”) describes how we collect, use, disclose, and protect your personal information when you access or use our mobile application and any related services (collectively, the “Services”). By using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy.

1. Definitions

For the purposes of this Policy:

• “Personal Data” means any information relating to an identified or identifiable natural person, as defined under the General Data Protection Regulation (“GDPR”).
• “Personal Information” means information that identifies, relates to, describes, or can reasonably be linked with a particular consumer or household, as defined under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).
• “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• “Controller” means the entity that determines the purposes and means of processing Personal Data.
• “Service Provider/Processor” means a third party that processes information on our behalf.

2. Information We Collect

2.1 Personal Information / Personal Data

We may collect the following information when you create an account or interact with the Services:

• Name
• Email address
• Contact information
• Authentication details

2.2 Device and Usage Information

We automatically collect:

• IP address
• Device identifiers
• Mobile operating system and version
• App usage statistics, interactions, features accessed
• Log files and diagnostic data

2.3 Cookies & Tracking Technologies

The mobile app may use:

• Cookies
• SDKs
• Analytics tools
• Push notification identifiers

These technologies help personalize your experience, analyze usage patterns, and improve app performance.

3. Legal Bases for Processing (GDPR)

Where GDPR applies, we process Personal Data based on one or more of the following legal bases:

• Consent – when you voluntarily provide Personal Data or agree to marketing.
• Contract performance – to provide and operate the Services you request.
• Legitimate interests – such as improving the app, preventing fraud, and maintaining security.
• Legal obligation – when we must comply with applicable laws or governmental requests.

4. How We Use Your Information

4.1 Service Delivery

We use your information to:

• Provide, maintain, and improve the Services
• Authenticate users
• Process transactions
• Respond to support requests

4.2 Analytics

We use usage data to:

• Monitor app performance
• Identify trends
• Improve functionality and security

4.3 Marketing

With your consent (where required), we may:

• Send promotional or informational communications
• Deliver targeted advertisements
• Work with trusted partners for marketing purposes

You may withdraw consent at any time.

5. Disclosure of Information

We do not sell, rent, trade, or share your Personal Information with third parties without your prior consent.

We may disclose information in the following limited situations:

• To service providers or processors bound by confidentiality agreements
• To comply with legal obligations or governmental requests
• To protect the safety, security, and rights of users or the public
• During a merger, acquisition, or corporate restructuring (with safeguards)

6. Rights Under GDPR

If you are located in the European Economic Area (EEA), UK, or Switzerland, you have the right to:

• Access your Personal Data
• Rectify inaccurate or incomplete data
• Erase your data (“right to be forgotten”)
• Restrict processing
• Object to processing, including direct marketing
• Data portability
• Withdraw consent at any time

To exercise these rights, contact us using the details provided in the app.

7. Rights Under CCPA/CPRA

If you are a California resident, you have the following rights:

• Right to Know what Personal Information we collect, use, disclose, or sell
• Right to Delete Personal Information, subject to exceptions
• Right to Correct inaccurate Personal Information
• Right to Opt-Out of the sale or sharing of Personal Information
• Right to Limit use of sensitive Personal Information
• Right to Non-Discrimination for exercising your rights

We do not sell Personal Information as defined under CCPA/CPRA.

To exercise these rights, you may submit a verifiable consumer request through the contact information provided in the app.

8. Data Retention

We retain Personal Information only for as long as necessary to:

• Provide the Services
• Comply with legal obligations
• Resolve disputes
• Enforce agreements

When Personal Information is no longer required, we will securely delete, anonymize, or otherwise dispose of it in accordance with applicable laws.

9. Data Security

We implement administrative, technical, and organizational measures designed to protect Personal Information from unauthorized access, disclosure, alteration, or destruction.

However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

10. International Data Transfers

If you access the Services from outside the country in which we operate:

• Your information may be transferred to, stored in, and processed in jurisdictions with different data protection laws.
• Where required, we use GDPR-approved safeguards such as Standard Contractual Clauses (SCCs).

11. Children’s Privacy

The Services are not intended for users under the age of 13 (or 16 where GDPR applies).

We do not knowingly collect Personal Information from children.

If we become aware of such collection, we will delete the information promptly.

12. Changes to This Policy

We may update this Policy to reflect changes in legal requirements or our processing practices.

Updates will be posted in the app with a revised “Last Updated” date.

Continued use of the Services after changes constitutes acceptance of the updated Policy.

13. Contact, Opt-Outs, Updates, Deletions

If you want to:

• Be removed from our database
• Correct or update your information
• Communicate with us for any reason

Contact: contact-ruhlai@ruhl.org