Privacy Policy for MAXKOG SRL's "Gyroplane Watch Face" App

This Privacy Policy describes how MAXKOG SRL ("we," "us," or "our") collects, uses, and discloses information when you use our mobile application, **"Gyroplane Watch Face" (com.watchfacestudio.gyroplane)** (the "App"), available on the Google Play Store. This App is designed for and directed at users of all ages, including children under the age of 13 ("Children").

We are deeply committed to protecting the privacy of all our users, especially Children. We strictly adhere to the Children's Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR) regarding children's data, and Google Play's Families Policy Requirements. By using our App, you agree to the collection and use of information in accordance with this policy.

1. Information Collection and Use

Our "Gyroplane Watch Face" App is designed to provide a watch face experience without collecting any personal data from its users, particularly Children. We believe in collecting only the absolute minimum data necessary for the App's functionality, performance, and improvement, always in a way that respects user privacy.

Personal Data (NOT Collected from Children)

We **do not knowingly collect any personally identifiable information** (such as name, email address, phone number, physical address, persistent identifiers used for tracking across sites/apps, or precise geolocation data) directly from any user, and especially not from Children under the age of 13 within our App. Our App does not include features that allow users to input personal information in free-text fields or user-generated content.

If we discover that we have inadvertently collected such information from a Child without proper verifiable parental consent (which our App is not designed to do), we will promptly delete it.

Usage Data & Device Information (Aggregated & Non-Personal, for Internal Operations Only)

We may collect anonymous, aggregated, and non-personal information about how our App is used ("Usage Data"). This data helps us understand general usage patterns, identify and fix bugs, and improve app performance and stability. This Usage Data is collected in a way that **cannot be used to identify any individual user or Child.**

This Usage Data and device information may include, but is not limited to:

• **Device Type:** (e.g., specific watch model, phone model)
• **Operating System Version:** (e.g., Wear OS version, Android version)
• **App Version:**
• **Crash Logs:** Information about app crashes (e.g., crash time, device state at crash), which are anonymized.
• **General Usage Statistics:** Non-precise data about how often the watch face is active, or basic interactions within the watch face settings (e.g., theme changes). This data is aggregated and anonymized.
• **Approximate Device Location:** Derived from IP address (e.g., country, city), but **never precise geolocation data.** This is used for aggregated analytics to understand regional usage, not for individual tracking.
• **Non-Resettable Device Identifiers:** If any non-resettable device identifiers are accessed by third-party SDKs, they are strictly used only for **support for internal operations** of the App, such as contextual advertising, capping ad frequency, analytics, and fraud prevention, and **never for personalized advertising or user profiling for Children.**

All collected Usage Data is used solely for **internal operations** of the App to:

• Maintain or analyze the functioning of the App.
• Perform network communications.
• Ensure the security and integrity of the App.
• Serve contextual advertising (non-personalized, based on app content), if applicable.
• Analyze and improve app performance and user experience.

Tracking Technologies & Cookies (NOT for Personalized Advertising for Children)

Our App **does not use cookies or persistent identifiers for personalized advertising or user profiling, especially for Children**. Any third-party services integrated into our App are carefully selected and configured to ensure they are compliant with COPPA and Google Play's Families Policy, meaning they also **do not collect personal data from Children for advertising or profiling purposes.**

Any tracking technologies (like SDKs) used are solely for internal operations, such as:

• Supporting internal operations (e.g., maintaining or analyzing the functioning of the app, performing network communications, authenticating users, ensuring security, or serving contextual ads).
• Contextual advertising (non-personalized, based on app content).

2. How We Use Your Information

MAXKOG SRL uses the collected non-personal, aggregated, and anonymized Usage Data for the following purposes, always prioritizing the safety and privacy of all users, especially Children:

• To provide and maintain the functionality of the "Gyroplane Watch Face" App.
• To improve and optimize the App's performance, stability, and user experience (e.g., fixing bugs, enhancing features).
• To monitor the usage of the App (e.g., understanding popular features, identifying areas for improvement).
• To detect, prevent, and address technical issues and crashes.
• To serve contextual (non-personalized) advertisements, if applicable, in compliance with Google Play's Families Policy.

3. Disclosure of Your Information

We **do not share, sell, rent, or trade any personal information of any user, especially Children, with third parties for their marketing or advertising purposes.** We may disclose aggregated, anonymized, or non-personal Usage Data that cannot be used to identify any individual. This limited sharing is typically with service providers for internal operations (e.g., crash reporting, analytics).

In limited circumstances, we may disclose information if required to do so by law or in the good faith belief that such action is necessary to:

• Comply with a legal obligation (e.g., a court order or subpoena).
• Protect and defend the rights or property of MAXKOG SRL.
• Prevent or investigate possible wrongdoing in connection with the App.
• Protect the personal safety of users of the App or the public.
• Protect against legal liability.

4. Security of Data

The security of your data is important to us. We implement reasonable administrative, technical, and physical safeguards designed to protect the information we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

5. Third-Party Service Providers and SDKs

We may employ third-party companies and individuals to facilitate our App ("Service Providers"), to provide services on our behalf (e.g., crash reporting), or to assist us in analyzing how our App is used. These third parties are carefully vetted to ensure their compliance with COPPA, GDPR, and Google Play's Families Policy. We ensure that any SDKs or services used in our App that are directed to Children are certified as COPPA compliant (e.g., by PRIVO, kidSAFE Seal Program, or similar) or are configured to operate in a COPPA-compliant manner.

These third parties have access to your data **only to perform these tasks on our behalf and are strictly obligated not to disclose or use it for any other purpose, especially not for personalized advertising or profiling of Children.** We specifically **do not integrate third-party SDKs that collect persistent identifiers or personal data from Children for purposes other than supporting internal operations of the App.**

Examples of Approved Service Providers we might use (configured for child-directed apps):

• **Analytics (Anonymized):** Google Analytics for Firebase (configured to disable advertising features, user IDs, and other features that could collect personal data from children).
• **Crash Reporting:** Firebase Crashlytics (collects only anonymized crash logs, no personal data).
• **Contextual Advertising:** Google AdMob (configured for non-personalized ads only, in full compliance with Google Play's Families Policy).

6. Links to Other Sites

Our App is a watch face and does not contain direct links to external websites or services. If, in future updates, any external links are introduced, they will be placed behind a neutral gate or parental gate to prevent Children from accessing them without parental supervision. We strongly advise parents and guardians to review the Privacy Policy of any site or service their Child visits.

7. Children's Privacy (Specifics for "Gyroplane Watch Face")

The "Gyroplane Watch Face" App is designed for and directed at Children under the age of 13. We are fully compliant with the Children's Online Privacy Protection Act (COPPA) and Google Play's Families Policy Requirements regarding children's online privacy.

• **No Personal Information Collection:** As stated, we do not collect personal information from Children.
• **No Behavioral Advertising:** We do not serve interest-based (behavioral) advertising to Children. Any advertising displayed in our App is strictly contextual and non-personalized, and comes from Google Play certified ad networks for families.
• **No User Profiling:** We do not build user profiles of Children for commercial purposes.
• **Parental Rights:** Parents and legal guardians have the right to inquire about any information collected from their Child (if any, with verifiable consent), request its deletion, and refuse to permit further collection or use of that information. To exercise these rights, please contact us using the information below.

8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page. If we make significant changes to how we handle Children's personal information, we will provide direct notice to parents as required by law.

9. Contact Us

If you have any questions about this Privacy Policy, our data practices, or your Child's privacy, please contact us:

By email: office@maxkog.ro

Effective Date: 01.07.2025