Privacy Policy

At PhoneGuide, we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and website. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the application.

PhoneGuide is the data controller responsible for your personal information. We are committed to complying with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy laws.

Information We Collect

Personal Data

We may collect personal information that you voluntarily provide when you register for an account, including:

  • Name and email address
  • Account credentials
  • Profile information
  • Payment information (processed securely through third-party providers)
  • Communication preferences

Usage Data

We automatically collect certain information when you use our application:

  • Device information (type, operating system, unique device identifiers)
  • Location data (GPS coordinates when using tours)
  • App usage statistics and interactions
  • Tour download and playback history
  • Crash reports and error logs

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. You can control cookie preferences through our cookie consent manager.

How We Use Your Information

We use the information we collect for the following purposes, based on the legal grounds listed:

  • Provide, operate, and maintain our services (Legal basis: Contract performance)
  • Improve and personalize your experience (Legal basis: Legitimate interest)
  • Process transactions and send related information (Legal basis: Contract performance)
  • Send you technical notices, updates, and support messages (Legal basis: Contract performance)
  • Respond to your comments and questions (Legal basis: Contract performance)
  • Provide customer service and support (Legal basis: Contract performance)
  • Monitor and analyze usage patterns and trends (Legal basis: Legitimate interest)
  • Detect, prevent, and address technical issues or fraudulent activity (Legal basis: Legitimate interest and legal obligation)
  • Send you marketing communications (Legal basis: Consent - you can opt out at any time)
  • Comply with legal obligations and enforce our terms (Legal basis: Legal obligation)

Location Data

Our app uses GPS location data to provide audio tour functionality. Location data is:

  • Used only when you actively use a tour
  • Processed locally on your device when possible
  • Stored temporarily to improve tour synchronization
  • Not sold or shared with third parties for advertising
  • Can be disabled in your device settings (though this will limit tour functionality)

Sharing Your Information

We may share your information in the following circumstances:

  • With service providers who perform services on our behalf (hosting, analytics, payment processing)
  • With your consent or at your direction
  • To comply with legal obligations or respond to lawful requests
  • To protect our rights, privacy, safety, or property
  • In connection with a business transfer (merger, acquisition, or asset sale)

We do not sell your personal information to third parties.

Data Security

We implement appropriate technical and organizational measures to protect your personal information. These include:

  • Encryption of data in transit and at rest
  • Secure authentication through Firebase
  • Regular security assessments
  • Access controls and authentication requirements
  • Secure data storage practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

  • Account data: Retained while your account is active and for up to 30 days after deletion
  • Transaction records: Retained for 7 years for tax and accounting purposes
  • Support communications: Retained for 3 years after your last interaction
  • Marketing data: Retained until you opt out or request deletion
  • Analytics and logs: Retained for up to 26 months in aggregated or anonymized form

When you delete your account, we will delete or anonymize your personal information, though some data may be retained for legal compliance, fraud prevention, or dispute resolution.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

European Union (GDPR) Rights

  • Right of Access: Request a copy of the personal information we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete information
  • Right to Erasure (Right to be Forgotten): Request deletion of your personal information
  • Right to Restriction of Processing: Request limitation of processing of your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent at any time without affecting lawful processing before withdrawal
  • Right to Lodge a Complaint: File a complaint with your local data protection authority

California (CCPA/CPRA) Rights

  • Right to Know: Know what personal information we collect, use, disclose, and sell
  • Right to Delete: Request deletion of personal information we have collected
  • Right to Opt-Out: Opt out of the sale or sharing of personal information (Note: We do not sell personal information)
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Limit: Limit the use and disclosure of sensitive personal information
  • Right to Non-Discrimination: Not receive discriminatory treatment for exercising your privacy rights

Other U.S. State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with privacy laws have similar rights to access, delete, correct, and opt-out of certain data processing activities.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days (or as required by applicable law). You will not be discriminated against for exercising your rights.

To protect your privacy, we may need to verify your identity before processing your request. We may ask for additional information to confirm your identity.

Children's Privacy

Our services are not intended for children under 13 years of age (or under 16 in the European Union). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States and other countries that may have different data protection laws.

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions recognizing equivalent data protection
  • Data Processing Agreements with service providers
  • Technical and organizational security measures
  • Regular compliance assessments

If you are in the European Economic Area (EEA), UK, or Switzerland, we ensure transfers comply with GDPR requirements through appropriate safeguards.

Do Not Sell My Personal Information

We do not sell your personal information to third parties for monetary consideration. We do not share your personal information with third parties for cross-context behavioral advertising. If our practices change, we will update this Privacy Policy and provide you with the right to opt-out of such sales or sharing.

We honor Do Not Track (DNT) signals and Global Privacy Control (GPC) signals where applicable.

Automated Decision-Making and Profiling

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects. Any personalization features (like tour recommendations) are based on aggregated usage patterns and do not result in legal consequences.

Third-Party Services

Our application may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

  • Firebase (Authentication and Analytics)
  • Google Maps (Navigation and location services)
  • Payment processors
  • Analytics providers

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. For material changes, we will provide prominent notice (such as email notification or a notice within the app) at least 30 days before the changes take effect. We encourage you to review this Privacy Policy periodically. The "Last Updated" date at the top indicates when the policy was last revised.

Your continued use of the application after the changes take effect constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, please stop using our services and contact us to delete your account.

Contact Us

If you have questions or concerns about this Privacy Policy, wish to exercise your privacy rights, or want to submit a complaint, please contact us:

Oleksandr Shemyakin

ul. Czyżówka 14 lok. 0.3, 30-526 Kraków, Poland

NIP:
5252923043
REGON:
523081083

Email: [email protected]

Alternatively, you can reach us through the contact form on our website.

For GDPR-related inquiries, you may contact our Data Protection Officer (DPO) at [email protected].

We will respond to your inquiry within 30 days (or within the timeframe required by applicable law). If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

Privacy Policy - Data Protection | PhoneGuide