— Last updated 18 May 2026

Privacy Policy

Suanpan

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 your personal data to me. All app data — settings, content, preferences — is stored locally on your device and is not synced to any server I control. The only data that leaves your device is the anonymous crash and diagnostic data described in the next section.

Crash reporting via Google Firebase Crashlytics

I use Google Firebase Crashlytics to collect crash and diagnostic data for the purpose of identifying and fixing bugs. The data collected includes:

  • Device model and operating system version
  • Anonymous installation identifier generated by Crashlytics
  • Stack traces and crash logs at the moment of a crash
  • Approximate time of the crash

This data is not used to identify you personally and is not combined with other data to do so.

  • Legal basis: Legitimate interest (GDPR Art. 6(1)(f)) — improving app stability and security.
  • Processor: Google LLC, acting as a data processor under a Data Processing Addendum.
  • International transfer: Data is processed by Google LLC in the United States. Transfers are covered by Google's adherence to the EU-US Data Privacy Framework and the European Commission's Standard Contractual Clauses.
  • Retention: Crash data is retained by Google for up to 90 days; diagnostic data for up to 30 days. After this period it is automatically deleted.

3. Third-party services

  • Google Firebase Crashlytics — crash and diagnostic reporting (see above)
  • Apple App Store / Google Play — app distribution

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].