Privacy Policy

Welcome to MyKinDomApp ("the App"). Your privacy matters to us. This Privacy Policy explains how InDevLab Ro S.R.L. ("we," "us," or "our") collects, uses, stores, shares, and protects your personal data when you use the App.

This Privacy Policy has been prepared in compliance with:

• Regulation (EU) 2016/679 — the General Data Protection Regulation ("GDPR")
• Romanian Law No. 190/2018 — on measures for the implementation of GDPR
• Romanian Law No. 506/2004 — on the processing of personal data and the protection of privacy in the electronic communications sector (transposing the ePrivacy Directive 2002/58/EC)
• Google Play Store and Apple App Store privacy requirements

By installing, accessing, or using MyKinDomApp, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the App.

The data controller responsible for the processing of your personal data is:

For any questions, concerns, or requests related to data protection, please contact us at [email protected].

We collect and process the following categories of personal data through the App and the third-party services integrated into it:

3.1 Data Collected Automatically

3.2 Data Collected Through In-App Purchases

When you make an in-app purchase, your transaction is processed by the platform store (Google Play or Apple App Store). We do not collect or store your payment information (e.g., credit card numbers). However, we may receive:

• Transaction confirmation and purchase receipt
• Product/subscription identifier
• Purchase date and time
• Transaction status (e.g., completed, refunded)

All payment processing is handled directly by Google Play or the Apple App Store under their respective privacy policies.

3.3 Data We Do NOT Collect

We do not directly collect or process:

• Your name, email address, or phone number (unless you contact us voluntarily)
• Precise geolocation data
• Contacts, photos, or files from your device
• Health, biometric, genetic, or other special categories of data
• National identification numbers (CNP or equivalent)

In accordance with Article 6 of the GDPR, we process your personal data based on the following legal bases:

We use the following third-party services that act as data processors on our behalf or as independent controllers of certain data:

5.1 Google AdMob

• Provider: Google LLC (USA)
• Purpose: To display advertisements within the App
• Data Collected: Device identifiers (advertising ID), IP address, user interactions with ads, diagnostic information, device and account identifiers
• Legal Basis: Consent for personalised advertising; legitimate interest for non-personalised advertising
• Privacy Policy: https://policies.google.com/privacy
• How Google Uses Data: https://policies.google.com/technologies/partner-sites

Google AdMob may use cookies and similar technologies to serve ads. You may opt out of personalised advertising through your device settings:

• Android: Settings → Google → Ads → Opt out of Ads Personalisation
• iOS: Settings → Privacy & Security → Tracking → disable per-app tracking; Settings → Privacy & Security → Apple Advertising → disable Personalised Ads

5.2 Firebase Analytics (Google Analytics for Firebase)

• Provider: Google LLC (USA)
• Purpose: To collect anonymous and aggregated statistics about app usage, such as the number of active users, session data, feature popularity, and app stability
• Data Collected: App Instance ID, device identifiers, device information (model, OS), app version, country, session data, screen views, in-app events, crash/performance data
• Legal Basis: Legitimate interest (Art. 6(1)(f) GDPR) — to understand and improve the App's performance and functionality
• Privacy Policy: https://firebase.google.com/support/privacy
• Google Analytics Terms: https://www.google.com/analytics/terms/

Opt-out: You may opt out of Firebase Analytics data collection by adjusting your device settings or by disabling analytics collection through the App's settings (if available). Google provides general information about how it uses data at https://policies.google.com/technologies/partner-sites.

5.3 Google Play / Apple App Store (In-App Purchases)

• Providers: Google LLC / Apple Inc.
• Purpose: Processing in-app purchases and managing subscriptions
• Data Collected: Payment and transaction data (handled exclusively by Google/Apple)
• Privacy Policies: Google Play: https://policies.google.com/privacy, Apple: https://www.apple.com/legal/privacy/

The App and its third-party partners (Firebase Analytics, Google AdMob) may use cookies, mobile device identifiers, and similar tracking technologies to collect and store information.

These technologies are used for:

• Essential functionality — ensuring the App operates correctly
• Analytics — understanding how users interact with the App
• Advertising — delivering and measuring the effectiveness of advertisements

You can control the use of these technologies through your device settings and through the consent mechanism presented in the App. Refusing non-essential cookies/trackers will not affect the core functionality of the App, but may result in non-personalised advertising.

The third-party services used by the App (Google LLC) are based in the United States. This means your personal data may be transferred to and processed in countries outside the European Economic Area (EEA).

These transfers are protected by appropriate safeguards in accordance with Chapter V of the GDPR, including:

• EU-U.S. Data Privacy Framework — Google LLC has certified its compliance with the EU-U.S. Data Privacy Framework
• Standard Contractual Clauses (SCCs) — as approved by the European Commission, ensuring an adequate level of data protection

You may obtain further information about the safeguards in place by contacting us at [email protected].

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

After the applicable retention period expires, personal data is securely deleted or anonymised.

As a data subject in the European Union, you have the following rights under the GDPR:

How to Exercise Your Rights

To exercise any of the above rights, please contact us at:

Email: [email protected]

We will respond to your request within one (1) month from receipt. In complex cases or where we receive a high volume of requests, this period may be extended by an additional two (2) months, in which case we will notify you of the extension and the reasons for it.

Important Note on Third-Party Data

Since we, as the app developer, do not directly store or process personal data that allows us to identify you individually, we may not be able to fulfil certain data access, rectification, or erasure requests for data collected exclusively by third-party services (Google AdMob, Firebase Analytics). In such cases, you may need to exercise your rights directly with the relevant third-party provider through their privacy settings and tools:

• Google Privacy Controls: https://myaccount.google.com/privacy
• Google Ad Settings: https://adssettings.google.com
• Apple Privacy Settings: Settings → Privacy & Security on your iOS device

If you believe that your personal data has been processed in violation of the GDPR or Romanian data protection law, you have the right to lodge a complaint with:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)

You may also lodge a complaint with the supervisory authority in your country of habitual residence, your place of work, or the place of the alleged infringement.

MyKinDomApp is not directed at children under the age of 16 (the age of digital consent under the GDPR as applicable in Romania pursuant to Art. 8(1) GDPR and Romanian Law No. 190/2018).

We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided personal data through the App, please contact us at [email protected], and we will take steps to delete such data promptly.

If we become aware that we have inadvertently collected data from a child under 16 without verified parental consent, we will delete such data as quickly as possible.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, in accordance with Article 32 of the GDPR. These measures include, but are not limited to:

• All data transmitted between the App and third-party services is encrypted using Transport Layer Security (TLS)
• We limit access to personal data to those who need it for legitimate business purposes
• Our third-party processors (Google LLC) maintain industry-standard security certifications, including ISO 27001 and SOC 1/2/3 compliance
• We conduct periodic reviews of our data processing practices and security measures

Despite these measures, no method of data transmission or storage is completely secure. In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify the ANSPDCP within 72 hours and inform affected individuals without undue delay, in accordance with Articles 33 and 34 of the GDPR.

13.1 Advertising Consent

Upon first launch of the App, or at any time upon changes to your consent preferences, we will present you with a consent dialog asking for your permission to serve personalised advertisements through Google AdMob.

• Consent is freely given, specific, informed, and unambiguous, in accordance with Art. 7 GDPR
• Pre-ticked boxes or implied consent are not used
• You may withdraw your consent at any time through the App's settings or through your device's privacy settings, and withdrawal is as easy as providing consent
• If you do not provide consent for personalised ads, you may still see non-personalised advertisements

13.2 Analytics

Firebase Analytics data collection is based on our legitimate interest (Art. 6(1)(f) GDPR) to improve app functionality and user experience. You may object to this processing at any time by contacting us at [email protected] or by disabling analytics through your device settings.

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or third-party services. When material changes are made:

• The "Last Updated" date at the top of this document will be revised
• A notice will be provided within the App, where appropriate
• If the changes materially affect the way we process your personal data, we will seek your renewed consent where required

We encourage you to review this Privacy Policy periodically. Continued use of the App after changes have been posted constitutes your acknowledgement of the updated Privacy Policy.

For your convenience, below are links to the privacy policies and data practices of the third-party services integrated into the App:

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

We aim to respond to all legitimate inquiries within 30 days. If your request is particularly complex, we will notify you and may extend the response period by up to 60 additional days in accordance with Art. 12(3) GDPR.