Privacy Policy
This privacy policy is applicable to the Penki app (hereinafter referred to as "Application") for mobile devices, which was developed by Michal Maciejewski (hereinafter referred to as "Service Provider") as a a Freemium service. This service is provided "AS IS".
What information does the Application obtain and how is it used?
Analytics
- Processor: Service Provider (in-house)
- Data collected: In-app user events
- Purpose: Improving content and collecting user feedback
- Retention: 180 days
- Identifies User: No
- Storage location: Server in Austria
Crash reports
- Processor: Service Provider (in-house)
- Data collected: In-app crash events
- Purpose: Improving stability and fixing bugs
- Retention: 180 days
- Identifies User: No
- Storage location: Server in Austria
Billing
- Processor: Apple/Google
- Data collected: In-app purchase history
- Purpose: Unlocking premium content
- Retention: See Processor Privacy Policy
- Identifies User: Yes
- Storage location: On device
Is registration required?
No. You don't need to register to use the Application.
Does the Application collect location information of the device?
No.
Does any collected data can be used to identify user or device?
No. All data that can identify user or device is being removed before sending out to Processors.
Does the Application use cookies?
No.
Does the Application display advertising?
No.
How can I request collected data deletion?
Please contact us at [email protected] and we will respond in a reasonable time. Please note that Billing History is required in order for the Application to access premium content.
Children's Privacy
The Penki app is designed for children of any age. We are committed to protecting children's privacy and complying with applicable laws, including the Children's Online Privacy Protection Act (COPPA) in the United States.
- Limited Data Collection: We intentionally limit the data we collect from all users, including children.
- No Personal Information: We do not knowingly collect personally identifiable information from children under 13 without verifiable parental consent.
- Parental Controls: For users under 13, we recommend that parents or guardians supervise their use of the Application.
- In-App Purchases: Any in-app purchases require account holder authentication, which should be managed by parents or guardians.
- Educational Content: The content provided in our Application is designed to be age-appropriate for children 4+.
- No Third-Party Marketing: We do not use children's data for third-party marketing purposes.
- Parental Rights: Parents or guardians have the right to review, delete, or refuse further collection of their child's information. To exercise these rights, please contact us at [email protected].
Legal Basis for Processing Personal Data
For users from the European Economic Area (EEA), United Kingdom, or other regions where similar laws apply, we want to clarify the legal basis for processing your data:
- Contractual Necessity: We process certain data because it is necessary for the performance of our contract with you (providing the Penki app's functionality and services).
- Legitimate Interests: We process some data based on our legitimate business interests, which include improving our app, fixing bugs, understanding user patterns, and developing new features. Our legitimate interests are balanced against your privacy rights.
- Legal Compliance: In some cases, we may process data to comply with our legal obligations.
For each category of data we collect (Analytics, Crashlytics, Billing), the specific legal basis is as follows:
- Analytics: Legitimate Interest
- Crashlytics: Legitimate Interest
- Billing: Contractual Necessity
If you are an EEA resident, you have the right to object to processing based on legitimate interests. Please contact us at [email protected] if you wish to exercise this right.
Security
The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provide physical, electronic, and procedural safeguards to protect information we process and maintain. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Changes
This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
This privacy policy is effective as of 2025-03-09
Your Consent
By using the Application, you are giving your consent to the Service Provider processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means collecting, storing, deleting, using and combining information.
Contact us
If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at [email protected].