Privacy Policy

1. Who we are

This Privacy Policy explains how BARSOVA LTD ("BARSOVA LTD", "we", "us" or "our") collects, uses, shares and protects personal data. BARSOVA LTD is the data controller for the personal data described in this policy.

Company name

BARSOVA LTD

Registered in

England and Wales

Registered office

Office 21055, 182-184 High Street North, East Ham, London, E6 2JA, United Kingdom

Privacy contact

support@barsova.it.com

If you have any questions about this policy or how we handle your data, please contact us using the details above.

2. Scope of this policy

This policy applies to:

• the mobile apps we publish on Google Play under the developer name BARSOVA LTD (our "apps");
• our website at barsova.it.com (our "website"); and
• communications between you and us, such as support emails.

Some apps may give additional privacy information inside the app or on their Google Play listing, for example in the Data safety section. Where that information is more specific, it adds to this policy.

This policy does not cover third-party websites, apps or services that our apps or website link to. They have their own privacy policies.

3. Information we collect

The data we collect depends on which app you use and which features you choose to use. Not every app collects every type of data listed below. The Data safety section of each app's Google Play listing summarises what that app collects and shares.

3.1 Information you give us

• When you contact us: your name, email address, the content of your message and any other details you choose to include, such as your device model or screenshots.
• When you make a privacy or deletion request: the information we need to find your data and process your request.
• Account details (only in apps that offer accounts): for example your email address and display name. If you sign in with a password, it is stored only in securely hashed form by our authentication provider. We never store it in plain text.
• Content you create: notes, settings, files or other content you create in an app. In most cases this stays on your device. Where an app offers cloud sync or backup, the content is stored with our service providers so we can provide that feature.

3.2 Information collected automatically by our apps

• Device and app information: device model and manufacturer, operating system version, app version, language and region settings, and similar technical details.
• Identifiers: for example an app instance ID used for analytics, an installation ID used for crash reporting, a push notification token and, in apps that show ads, your device's advertising ID.
• Usage information: how you interact with the app, such as the screens you view, the features you use, session length and in-app events.
• Diagnostic information: crash reports, error logs and performance data that help us find and fix problems.
• Approximate location: our service providers may estimate your approximate location (such as your country or city) from your IP address, for example to show ads relevant to your region or to understand where our apps are used. Our apps don't collect your precise location unless a feature you choose to use clearly needs it, and in that case the app will ask for your permission first.

3.3 Information from our website

Our website does not use cookies, analytics or advertising trackers. When you visit it, our hosting provider automatically records standard technical information in server logs, such as your IP address, browser type, the pages you request and the date and time of your visit. These logs are used to keep the website secure and working.

If you use our contact form, the details you enter (your name, email address and message) are sent to our business email inbox so that we can reply.

3.4 Information from third parties

• Google Play: when you download an app or buy something in an app, Google processes the transaction. We receive limited information such as an order ID, the product purchased, the purchase date and status and, for subscriptions, whether the subscription is active. We do not receive your full payment card details.
• Ratings and reviews: if you post a public review of one of our apps on Google Play, we can see your review and the name on your Google Play profile, and we may reply publicly.
• Service providers: our advertising, analytics and crash-reporting providers give us reports about how our apps are used and how ads perform. These reports are generally aggregated and do not identify you by name.

3.5 App permissions

Android requires apps to ask for your permission before accessing certain features or data, such as your camera, photos or notifications. Our apps only request the permissions needed for the features they offer. You can grant or withdraw permissions at any time in your device settings, and each app's permissions are shown on its Google Play listing.

3.6 Sensitive information

We do not intentionally collect special category data, such as information about your health, ethnicity, religious or political beliefs, or sexual orientation. Please don't send us this kind of information in support messages.

4. How we use your information and our legal bases

Under UK data protection law (the UK General Data Protection Regulation, or UK GDPR, and the Data Protection Act 2018), we must have a valid legal basis for each way we use personal data. The table below explains what we do and why.

Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms and concluded that our use of your data is proportionate. You can ask us for more details about this assessment.

Where we rely on consent, you can withdraw it at any time (see Your choices and controls). Withdrawing consent doesn't affect anything we did with your data before you withdrew it.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.

5. Advertising

Some of our free apps show ads to help cover the cost of developing and maintaining them. Where an app shows ads, they are provided by Google AdMob, an advertising service of Google LLC.

• What AdMob uses: to show and measure ads, AdMob may collect or receive information such as your device's advertising ID, your IP address (used to estimate your approximate location), device and app information, and how you interact with ads.
• Your consent: if you are in the UK, the European Economic Area (EEA) or Switzerland, our apps that show ads use Google's consent tool (the User Messaging Platform) to ask for your consent before personalised ads are shown or information on your device is used for advertising. If you don't consent, you may still see non-personalised or limited ads, which use less data and are not based on your past activity.
• Changing your mind: you can change your choices at any time using the privacy or consent settings in the app, where available.
• Device controls: on most Android devices you can delete or reset your advertising ID in Settings > Privacy > Ads (or Settings > Google > Ads). If you delete it, apps can no longer use it to show you personalised ads.
• Mediation partners: if an app uses other advertising partners through AdMob mediation, they will be named in the app's consent message, and they process data under their own privacy policies.

Google uses information collected through AdMob in line with its own policies. You can read how Google uses information from sites or apps that use its services and manage your Google ad settings in My Ad Center. We do not show personalised ads to users we know to be children.

6. Analytics and crash reporting

Some of our apps use services from Google's Firebase platform to help us understand how our apps are used and to fix problems:

• Google Analytics for Firebase collects usage information and device information, together with an app instance ID, so we can see, in aggregate, which features are used and how our apps perform. We don't use it to identify you personally, and we set analytics data retention to no more than 14 months.
• Firebase Crashlytics collects crash reports and diagnostic information, together with an installation ID, when an app crashes or has an error. Crash data is kept for 90 days.
• Firebase Cloud Messaging (only in apps that send notifications) uses a push notification token to deliver notifications to your device. You can turn notifications off at any time in your device settings.
• Other Firebase services (only where an app needs them), such as Firebase Authentication for accounts and Cloud Firestore for data you choose to sync, process data on our behalf to provide those features.

Google provides these services under its Firebase data processing terms. You can learn more at Privacy and Security in Firebase. Where the law requires your consent for analytics, we will ask for it in the app, and you can change your choice at any time.

7. Google Play and Google Play services

Our apps are distributed through Google Play. When you browse Google Play, download or update an app, or make a purchase, Google processes your data as an independent controller under the Google Privacy Policy.

Our apps may also use Google Play services, a set of Google components on Android devices that supports features such as in-app updates, in-app reviews, in-app purchases (Google Play Billing) and, where offered, signing in with Google. When you use these features, Google may process information such as device identifiers and your Google account details in line with its own policies.

Purchases and subscriptions are processed by Google Play. We never receive or store your full payment card details.

8. Third-party services

The table below lists the third-party services our apps and website may use. Not every app uses every service.

If we start using a new third-party service that processes personal data, we will update this policy.

9. How we share your information

We do not sell your personal data. We only share it in these situations:

• Service providers that process data on our behalf and under our instructions, such as Google (Firebase), our website hosting provider and our email provider. They may only use your data to provide services to us.
• Advertising partners, such as Google AdMob, as described in Advertising. For personalised advertising, Google acts as an independent controller.
• Professional advisers, such as accountants, lawyers and insurers, where necessary and under a duty of confidentiality.
• Legal requirements: where the law requires it, for example in response to a valid request from a court or law enforcement authority, or where necessary to protect our rights, our users or others.
• Business changes: if BARSOVA LTD is involved in a merger, acquisition or sale of assets, personal data may be transferred to the new owner, who must continue to protect it in line with this policy. We will tell you before your data becomes subject to a different privacy policy.
• With your consent, in any other situation where you have asked us to share it.

10. International transfers

Some of our service providers, including Google, process data outside the UK, for example in the United States and the European Economic Area. When personal data is transferred outside the UK, we make sure it is protected by the safeguards UK data protection law requires, such as:

• UK adequacy regulations, for example for the EEA, or for US organisations certified under the UK Extension to the EU-US Data Privacy Framework; or
• the International Data Transfer Agreement, or the International Data Transfer Addendum to the EU Standard Contractual Clauses, issued by the UK Information Commissioner.

Contact us if you would like more information about the safeguards we use.

11. How long we keep your information

We keep personal data only for as long as we need it for the purposes in this policy. After that, we delete or anonymise it.

Data stored only on your device, such as settings or content in apps without accounts, stays on your device until you delete it, clear the app's storage or uninstall the app.

12. Children's privacy

Our apps and website are intended for a general audience and are not directed at children under 13. We do not knowingly collect personal data from children under 13. In the UK, children under 13 need consent from a parent or guardian for online services that rely on consent.

If you are a parent or guardian and believe your child has given us personal data, please contact us at support@barsova.it.com and we will delete it.

If we publish an app designed for children, or for both children and older audiences, its Google Play listing will say so. That app will follow the Google Play Families Policy. For example, it will:

• only use advertising and analytics tools that are approved for use in apps for children;
• not show personalised ads to children; and
• not collect the advertising ID or other device identifiers from children.

We also take into account the UK Information Commissioner's Age Appropriate Design Code (the Children's Code) when designing our apps.

13. Your rights

Under UK data protection law you have the following rights. Some of them apply only in certain circumstances.

• Access: ask for a copy of the personal data we hold about you.
• Rectification: ask us to correct data that is inaccurate or incomplete.
• Erasure: ask us to delete your personal data (see our Account & Data Deletion page).
• Restriction: ask us to limit how we use your data, for example while we check its accuracy.
• Data portability: ask for data you gave us in a structured, commonly used, machine-readable format, or ask us to send it to another organisation.
• Objection: object to our use of your data where we rely on legitimate interests. You can always object to direct marketing. We don't send marketing messages unless you have agreed to receive them.
• Withdrawing consent: where we rely on your consent, you can withdraw it at any time.
• Automated decisions: not to be subject to decisions based solely on automated processing that have legal or similarly significant effects on you. We do not make decisions like this.

How to exercise your rights

Email support@barsova.it.com with the subject line "Data request". Tell us which right you want to use and which app your request is about, and include the email address or account ID linked to your data, if any. We may ask for information to confirm your identity. We will never ask for your password.

We will respond without undue delay and in any case within one month of receiving your request. If your request is complex, or you make several requests, we may extend this by up to two further months. If so, we'll tell you within the first month. There is normally no charge.

14. Complaints

If you're unhappy with how we've handled your personal data, please contact us first at support@barsova.it.com and we'll do our best to put things right. We will acknowledge your complaint within 30 days and let you know the outcome.

You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk/make-a-complaint or on 0303 123 1113. If you live in the EEA, you can also contact your local data protection authority.

15. How we protect your information

We use appropriate technical and organisational measures to protect personal data, including:

• encrypting data in transit (HTTPS/TLS) between our apps, our website and the services we use;
• limiting access to personal data to people who need it, protected by strong passwords and two-factor authentication;
• using reputable service providers with strong security standards; and
• collecting and keeping only the data we need.

No method of transmitting or storing data is completely secure, so we cannot guarantee absolute security. If a personal data breach happens that is likely to put your rights at risk, we will tell you and the ICO where the law requires it.

16. Your choices and controls

• App permissions: review or change them in your device settings, usually under Settings > Apps > [app name] > Permissions.
• Advertising ID: delete or reset it in Settings > Privacy > Ads (or Settings > Google > Ads, depending on your device).
• Consent choices: change them in the app's privacy or consent settings, where available.
• Notifications: turn them off in your device settings or in the app.
• Stopping all data collection by an app: uninstall the app. This stops any further collection. To delete data we already hold, see our Account & Data Deletion page.

17. Links to other websites

Our apps and website may link to third-party websites and services, such as Google Play. We are not responsible for their privacy practices, so please read their privacy policies.

18. Changes to this policy

We may update this policy from time to time, for example when we release new features or when the law changes. When we do, we will update the "Last updated" date at the top of this page. If we make significant changes, we will let you know in the app, on our website or by email where appropriate.

19. Contact us

If you have any questions about this policy or about how we handle your personal data, please contact us:

Data controller

BARSOVA LTD

Email

support@barsova.it.com

Post

BARSOVA LTD, Office 21055, 182-184 High Street North, East Ham, London, E6 2JA, United Kingdom

Registered in

England and Wales