Privacy Policy
Updated and effective as of September, 2025
This Privacy Policy governs the manner in which explains the privacy rules applicable to all information collected or submitted when you access, install or use our services.
By visiting our website, by submitting your personal data to us, also by accessing, installing and/or using our services you confirm that you have read and agree to be bound by this Privacy Policy and that you enter into a legally binding relationship with CARAMBOLICO LTD, a Cyprus company (hereinafter, "we" or "us").
Please read the following Privacy Policy carefully to understand our practices regarding your information and how we will use it. All definitions and terms used in this Privacy Policy are defined in our Terms of Service. If any User does not agree with this Privacy Policy in general or any part of it, such User should not access or use our services.
The data controller of your personal data, as described in this Privacy Policy, is CARAMBOLICO LTD, email: [email protected]. If you disagree with the rules of this Privacy Policy, please do not use our services. If you have any questions about this Privacy Policy or your privacy, please contact us by email at [email protected].
Processing of Your Data
Our top priority is the security of customer data. We process user data only to a very limited extent, only to the extent absolutely necessary to provide our services, process payments for our services and operate our website and mobile application.
We guarantee a strict no-logs policy for our services, meaning that activities conducted using our services are provided by automated technical processes and are not monitored, recorded, logged, stored or passed to any third-party.
Data Collected
We collect and process the following types of personal data:
a) Automatically Collected Data
When using the app or website, we may collect certain technical information automatically:
- Device type and OS version
- Unique device identifiers
- Language and location (if enabled)
- IP address (for network diagnostics)
- App performance data (e.g., crashes, load times)
- Interactions with app features
b) Information You Provide Voluntarily
- Name and email address (if registering or contacting support)
- Photos and camera input (submitted for app features – processed locally or in the cloud and not stored without consent)
- Subscription or purchase information (processed via third-party providers (e.g., App Store / Google Play) for subscription handling. We do not store credit card numbers or billing data.)
Purpose of Data Processing
- To enable core app features
- To send personalized reminders and notifications
- To analyze app usage and improve performance and user experience
- To respond to user inquiries and provide technical support
- To process subscriptions and handle billing
- To send marketing communications, if the user has opted in
Targeted Advertising
We may partner with third-party advertising networks to display ads in our services. These partners may collect certain information from your device automatically, including:
- Device identifiers
- Operating system and browser type
- Language, time zone, and country
- Referring pages and app interactions
- Usage patterns across devices and sessions
- Other information
This data may be collected through cookies, pixel tags, and similar tracking technologies in our app, website, or in advertising shown on third-party platforms. The information is used to deliver personalized ads that better match your interests. If you would like to understand your opt-out choices, please visit the website of the National Advertising Initiative here. You may still see ads even if you opt out of personalized advertising; however, those ads may be less relevant.
Please understand that we do not control these third party cookies, and you should check the privacy policies of third party advertising networks to see whether and how they use cookies.
Here is our business collaborator with whom we exchange user details and data related to site and app usage:
Admob, located in the United States. For more details, please follow the link: https://support.google.com/admob/answer/6128543?hl=en
Grounds for Data Processing
We may rely on the following legal bases for processing your personal data, in accordance with applicable data protection laws (including GDPR):
Consent: We may process your personal data where we have obtained your prior, explicit consent. This basis is used only for processing that is entirely voluntary — for example, receiving marketing communications or uploading photos for app features.
Contractual Necessity: We process your data when it is necessary for the performance of a contract with you, including providing access to core app functionality, managing your subscriptions, or responding to support inquiries.
Compliance with Legal Obligations: In certain cases, we may process your personal data where required to comply with applicable laws, such as financial or regulatory obligations.
Legitimate Interest: We may process your data where it is in our legitimate interests to do so, and where those interests are not overridden by your fundamental rights and freedoms. This may include activities such as app analytics, security monitoring, or sending non-promotional service notifications.
Sharing Your Personal Data
We will not share your personal data with any third-parties except as expressed in this Privacy Policy.
We use third-party data processors only for processing of payment data, emailing services, marketing and basic website and app analytics.
Your Personal Data Protection Rights
As a user, you have the following rights in relation to your personal data, subject to applicable data protection laws:
Right of access: You may request information about the personal data we hold about you.
Right to rectification: You may ask us to correct inaccurate or incomplete data.
Right to erasure ("right to be forgotten"): You may request that we delete your personal data, provided there is no legal obligation or overriding legitimate interest to retain it.
Right to restrict processing: You may request that we restrict processing of your data under certain conditions.
Right to object: You may object to certain types of processing, such as marketing.
Right to data portability: Where applicable, you may request a copy of your data in a structured, commonly used, and machine-readable format, and ask us to transfer it to another data controller.
Right to withdraw consent: If processing is based on your consent, you may withdraw it at any time by contacting us.
To exercise any of these rights, please email us at: [email protected]
We may request additional information to verify your identity before fulfilling your request.
If you disagree with your data processing by us, you are free not to use our services, and to discontinue using it at any time. If you wish to use our services again, you will have to accept and agree to this Privacy Policy anew.
Opt-out
If you wish to unsubscribe from our communication, you can opt out at any time by clicking the "unsubscribe" link at the bottom of each email or contacting us at [email protected].
Cookies
You can control the use of cookies at the individual browser level on your device. To disable cookies, follow your browser's instructions on how to block or clear cookies.
Term for Storing Personal Data
We store limited personal data for the whole period during which our services are used and for no longer than necessary and in no case more than 2 years after last use of the app and/or the services.
Other Terms
This Privacy Policy may be modified and updated at any time, at our sole discretion, for any or no reason, and without liability, as indicated below. We ask all users to ensure that they are familiar with the most current wording of the Privacy Policy. The amendment of the Privacy Policy may be communicated to you by publishing the updated Privacy Policy on our website. Please consider reviewing the Privacy Policy each time you use our services. Updates of the Privacy Policy come into force as of the moment when they are published.
This Privacy Policy shall be governed by and construed in accordance with the laws of Cyprus. Any disputes shall be subject to the exclusive jurisdiction of the courts in Cyprus.
Contact Us
Please contact us by email if you have any questions about our Privacy Policy or you want to enforce any of your rights related to your privacy.
CARAMBOLICO LTD
Address: Demostheni Severi 12, 6th floor, office 601, 1080 Nicosia, Cyprus
Email: [email protected]