Privacy Policy

1. Who we are

This app is operated by Filiberto Secchi, ditta individuale, established in Venice, Italy.

• P.IVA (VAT number): 04993020272
• Codice fiscale: SCCFBR85P25Z133O
• Registered address: Venezia, Italia
• Contact: [email protected]

For the purposes of the EU General Data Protection Regulation (GDPR, Regulation 2016/679) and Italian Decreto Legislativo 196/2003 as amended, I am the data controller for any personal data processed in connection with this app.

2. What data we process

Local-only processing

This app does not collect, store, or transmit personal data to me or any third party. All app data — settings, content, preferences — is stored locally on your device and is not synced to any server I control.

This means I have no way to identify you, contact you, or access your data through the app.

In-app purchases and subscriptions

If you make an in-app purchase, the transaction is processed by Apple (App Store) or Google (Google Play). I do not receive your payment details (card number, bank account, billing address). I receive only:

• Confirmation that a valid purchase was made
• An anonymous transaction identifier
• The product purchased and the amount

For how Apple and Google handle your payment data, see Apple's Privacy Policy and Google's Privacy Policy.

• Legal basis: Performance of a contract (GDPR Art. 6(1)(b)) — to provide the purchased digital content or service.
• Retention: Purchase records are retained for the duration legally required for tax and accounting purposes under Italian law (typically 10 years for accounting records).

3. Third-party services

• Apple App Store / Google Play — app distribution and, where applicable, payment processing

4. Your rights

Under the GDPR you have the following rights:

• Right of access (Art. 15) — to obtain confirmation of whether your data is processed and a copy of that data
• Right to rectification (Art. 16) — to correct inaccurate or incomplete data
• Right to erasure (Art. 17) — to request deletion of your data
• Right to restriction (Art. 18) — to limit how your data is processed
• Right to data portability (Art. 20) — to receive your data in a structured, machine-readable format
• Right to object (Art. 21) — to processing based on legitimate interest
• Right to withdraw consent (Art. 7(3)) — at any time, where consent is the legal basis

To exercise any of these rights, email [email protected]. I will respond within 30 days of receiving a valid request.

You also have the right to lodge a complaint with the Italian supervisory authority:

Garante per la protezione dei dati personali
Piazza Venezia, 11 — 00187 Roma, Italia
Web: www.garanteprivacy.it
Email: [email protected]

If you reside outside Italy, you may also lodge a complaint with the supervisory authority in your country of residence.

5. Children's privacy

This app is not directed at children under the age of 13 (or under 16 in EU member states where the digital age of consent is higher under GDPR Art. 8). I do not knowingly collect personal data from children. If you are a parent or guardian and believe a child has provided personal data through the app, please contact me so that it can be deleted.

6. Changes to this policy

If this policy is materially updated, the new version will be posted at this URL with a revised "Last updated" date. For significant changes, I will also notify users through the app where reasonably possible. Continued use of the app after a change indicates acceptance of the updated policy.

7. Contact

For any privacy-related question, email [email protected].