Privacy Policy

Controller: First Line Softsearch LLC, 4481 Nyíregyháza, Előd utca 6, Hungary (represented by József Nyerges)
Contact: [email protected]

1. Introduction & Scope

1.1. This Privacy Policy describes how we collect, use, disclose, transfer, and protect personal information when you use our iOS application (the “App”) and related services (the “Services”). It applies to data we collect directly from you, data you authorize us to receive from third parties (e.g., social networks), and data generated automatically by your device while using the App

1.2. We may update this Privacy Policy. We will post the updated version in the App and/or on our website and adjust the effective date above. Your continued use of the App indicates your acceptance of the updated Policy. If you disagree with any part, please discontinue use of the App.

1.3. Platform focus: This version addresses Apple App Store requirements. If you distribute on other platforms, those versions may include platform‑specific annexes.

2. Definitions

2.1. “Personal Information” (or “personal data”) means any information relating to an identified or identifiable natural person (e.g., name, email, identifiers, precise location).

2.2. “Processing” means any operation performed on personal information (collection, storage, use, disclosure, deletion, etc.).

2.3. “Controller” means the entity that determines the purposes and means of processing (see “Controller details” below).

2.4. “Service Providers/Processors” are vendors that process personal data on our behalf under contract.

2.5. “Tracking” (ATT) means linking user or device data collected from the App with third‑party data for targeted advertising or measurement, or sharing data with data brokers.

3. Controller Details

3.1. Controller: First Line Softsearch LLC
Address: 4481 Nyíregyháza, Előd utca 6, Hungary
Representative: József Nyerges
Email: [email protected]
(If you appoint a Data Protection Officer or add a dedicated privacy contact, include their details here.)

4. Categories of Data We Collect

4.1. We may collect the following categories (actual collection depends on the features you use):

• 4.1.1. Contact Information: name, email address, phone (if provided).
• 4.1.2. Identifiers: user ID, device ID, Apple IDFA (only if you grant ATT consent), IP address.
• 4.1.3. Account & Profile Data: credentials (hashed), settings, preferences, saved items.
• 4.1.4. Usage Data: app interactions, feature usage, logs, crash diagnostics.
• 4.1.5. Location Data: approximate or precise location if you grant permission.
• 4.1.6. Device Data: device model, OS version, language, time zone, network.
• 4.1.7. Purchase & Billing Data: in‑app purchase history, subscription status, payment tokens (Apple handles card data; we do not receive full card details).
• 4.1.8. Content You Provide: feedback, support requests, attachments, UGC (if applicable).
• 4.1.9. Photos/Camera/Microphone/Contacts/Calendars/Bluetooth: only if a feature requires it and you grant permission.

4.2. We present just‑in‑time purpose explanations on iOS when requesting each permission. You can change permissions at any time in iOS Settings.

5. Sources of Personal Information

5.1. Directly from you (registration, forms, feedback, support).

5.2. Automatically from your device (logs, diagnostics, usage).

5.3. From third parties with your authorization (e.g., social logins; see also “Sign in with Apple”).

6. Purposes & Legal Bases (GDPR/UK GDPR)

6.1. We process data for the following purposes and legal bases:

6.2. Where we rely on consent, you may withdraw it at any time in the App and/or iOS Settings; this does not affect prior lawful processing.

7. Tracking, Advertising, and ATT (Apple)

7.1. We do not access Apple IDFA or engage in tracking without your explicit ATT consent when iOS prompts you (“Allow App to Track?”).

7.2. If you decline, we will not use IDFA and will limit advertising/measurement to non‑tracking methods.

7.3. You can later change your choice in Settings › Privacy & Security › Tracking.

7.4. We do not link personal information to advertising identifiers without your consent.

7.5. Push notifications: We send push notifications only if you opt in.
Promotional pushes are sent only with your explicit consent. You can disable notifications at any time in iOS Settings

8. Sign in with Apple

8.1. If the App offers third‑party logins (e.g., Google, Facebook), we also support Sign in with Apple, which allows you to hide your email via Apple’s relay. You can revoke access in your Apple ID settings.

9. Disclosures of Personal Information

9.1. We share personal information only as described below:

• 9.1.1. Service Providers (Processors): hosting, analytics, messaging, customer support, payment/subscription status, crash reporting. They are bound by contracts and process data solely on our instructions.
• 9.1.2. Analytics & Measurement Partners: to understand feature usage and improve the App. If any partner would involve tracking, it is used only with your ATT consent.
• 9.1.3. Advertising Partners (if enabled): to deliver ads or measure performance with ATT consent. We do not sell personal information.
• 9.1.4. Affiliates and Corporate Transactions: if we reorganize, merge, or sell assets, data may transfer under the same privacy commitments.
• 9.1.5. Legal & Safety: to comply with law, enforce terms, or protect rights, safety, and property.

9.2. We provide a current list of major processors/SDKs in Appendix B.

10. Data Retention & Deletion

10.1. We retain personal data only as long as necessary for the purposes described above or as required by law. We apply the following default retention schedule (unless legal requirements dictate otherwise):

10.2. In‑app account deletion (Apple requirement): You can delete your account directly in the iOS App (Settings › Delete Account). After initiating deletion, we remove or anonymize your personal data within reasonable timeframes, except where retention is required for legal claims, accounting, fraud prevention, or compliance.

11. Your Privacy Rights

11.1. EU/EEA/UK

• 11.1.1. Right of access; rectification; erasure; restriction; data portability; objection (including to direct marketing); and the right not to be subject to decisions based solely on automated processing. You may withdraw consent at any time. You also have the right to lodge a complaint with your supervisory authority.

11.2. United States (state laws)

• 11.2.1. California (CCPA/CPRA): right to know, access, correct, delete, and opt out of sale/sharing; right to limit use of sensitive personal information; non‑discrimination.
• 11.2.2. Colorado / Connecticut / Virginia / Utah / others: access, correction, deletion, portability, and the right to opt out of targeted advertising, sale, and certain profiling. Some states provide an appeals process if we deny a request.

11.3. To submit a request, contact us at [email protected] . We will verify your identity and respond within statutory timeframes. Authorized agent procedures are available where required.

11.4. App Store privacy label: In addition to these rights, you can review the App’s Privacy Label on the App Store listing to see high‑level data categories, whether they are linked to you, and whether they are used for tracking.

12. International Data Transfers

12.1. If personal data is transferred outside the EU/EEA/UK, we use appropriate safeguards (e.g., adequacy decisions or Standard Contractual Clauses) and supplementary measures where necessary.

13. Security

13.1. We use administrative, technical, and physical safeguards appropriate to the risks, including encryption in transit, access controls, least‑privilege principles, vulnerability management, and secure development practices. No method is 100% secure. If we learn of a breach that affects your information, we will notify you and regulators as required by law.

14. Children’s Privacy

14.1. The App is not directed to children under 13. We do not knowingly collect personal information from children under 13 (COPPA). If you believe a child has provided information, please contact us; we will promptly delete it. Where GDPR applies, we do not target users under the relevant age of digital consent.

15. Cookies, SDKs, and Similar Technologies

15.1. We do not use browser cookies inside the native iOS App. If the App displays web content (in‑app browser/WebView), third‑party sites may use their own cookies or trackers—please review their policies. The App may use software development kits (SDKs) that collect device or usage data to provide functionality (analytics, crash reporting, messaging). See Appendix B for an overview.

16. Emails and Marketing Communications

16.1. We may send transactional emails (e.g., receipts, service messages). Marketing emails or push notifications are sent only with your consent and include an option to unsubscribe. You can manage push notification preferences in iOS Settings.

17. User‑Generated Content and Moderation (if applicable)

17.1. If the App allows posting content, you must follow our content rules. We may moderate, block, or remove content that violates laws, intellectual property, or our terms. We provide reporting mechanisms and reserve the right to restrict or terminate accounts for violations.

18. Financial Information & In‑App Purchases

18.1. Purchases are processed via Apple’s In‑App Purchase system. We receive limited transactional metadata (e.g., product, timestamp) but do not receive full card details. Subscription terms, auto‑renewal, trial periods, and cancellation procedures are disclosed at purchase and in your Apple ID settings

19. External Links

19.1 The App may link to third‑party websites/services. We are not responsible for their privacy or security practices. Review their policies before providing information.

20. Changes to This Policy

20.1. We may amend this Policy to reflect operational, legal, or regulatory changes. Material changes will be highlighted in‑App and/or by other reasonable means.

21. Contact

21.1. Questions or requests? Contact [email protected] or use the Delete Account option in the App.

Appendix A — App Store Privacy Labels Mapping

This table maps our data practices to Apple’s privacy label categories. Confirm based on actual features/SDKs deployed at release.

Appendix B — Processors, SDKs, and Key Third Parties (Sample/Template

• Hosting/Backend: [Vendor], processing region, purpose.
• Analytics: [Vendor], version/SDK, data points (e.g., events, device info), retention, opt‑out.
• Crash Reporting: [Vendor], data (stack traces, device state).
• Messaging/Push: Apple Push Notification service (APNs); [Vendor] for in‑app messaging.
• Attribution/Ads (if enabled): [Vendor]; used only with ATT consent; data shared for measurement.
• Support/Helpdesk: [Vendor] (ticket metadata, email).

For each vendor, we maintain a data processing agreement and require appropriate security safeguards.

Appendix C — Regional Disclosures (Detailed)

• EU/EEA/UK: Controller, legal bases (see Section 6). International transfers via SCCs or adequacy. Right to lodge a complaint with your data protection authority.
• California (CPRA): We do not sell personal information. If we “share” personal information for cross‑context behavioral advertising, you may opt out. Sensitive personal information is used only as permitted by law
• Colorado/Connecticut/Virginia/Utah (and similar laws): rights to access, correct, delete, portability, and opt out of targeted advertising, sale, and certain profiling. Appeals instructions provided upon request.

Appendix D — Retention Rationale & Minimization

We apply data minimization and purpose limitation principles. Retention aligns with operational needs and legal obligations (e.g., tax, accounting, fraud prevention). Aggregation or anonymization is used where feasible to reduce privacy risk.