Privacy Policy

1. Introduction

Algorion OÜ ("we," "our," or "us") operates the Book Reader mobile application (the "App"). We are committed to protecting your privacy and ensuring you have control over your data. This Privacy Policy explains how we collect, use, and share information when you use our App on Android and iOS devices.

Company Information (Data Controller):
Algorion OÜ
Tartu, Kaunase pst 1
Estonia
Contact Email: hi@hetko.eu

2. Information We Collect

We believe in data minimization. We do not collect your real name, email address, phone number, or precise geographic location (GPS). However, to maintain the App’s functionality, analyze performance, and show advertisements, we and our third-party partners may collect certain pseudonymized data.

A. Automatically Collected Data

When you use the App, the following data may be collected automatically via third-party SDKs:

• Device Information: Device model, operating system version, time zone, language settings, and IP address (coarse location only, e.g., country/city level).
• Identifiers: Advertising ID (GAID on Android, IDFA on iOS) and Device IDs.
• Usage Data: Interactions with the app, buttons clicked, pages viewed, and time spent in the app.
• Crash Data: Crash logs and stack traces to help us fix bugs.

B. User-Generated Content (Local Only)

• Book Files: The App processes book files (e.g., PDF, EPUB) that you explicitly select. We do not have access to your file system. We only access specific files or folders you select via the system's file picker. These files remain on your device or your personal cloud storage. We do not upload your books to our servers.

3. How We Use Your Information

We process this data for the following purposes:

1. To Provide the Service: Ensuring the app functions correctly on your specific device.
2. Analytics: Understanding how users interact with the app to improve features (e.g., identifying which features are popular).
3. Advertising: Displaying advertisements to support the free version of the App.
4. Monetization: Processing subscriptions and in-app purchases.
5. Debugging: identifying and fixing app crashes.

4. Third-Party Services

We use third-party services for analytics, advertising, and payments. These partners may access data such as your Advertising ID or IP address. Please review their privacy policies below.

A. Advertising & Mediation

We use Appodeal to mediate and display ads. Through Appodeal, the following ad networks may collect data to serve personalized ads:

• Appodeal: Privacy Policy
• Google AdMob: Privacy Policy
• Unity Ads: Privacy Policy
• Meta Audience Network (Facebook): Privacy Policy
• AppLovin: Privacy Policy
• Yandex Ads: Privacy Policy

B. Analytics

We use these tools to analyze app usage trends:

• Google Firebase & Google Analytics: Privacy Policy
• Mixpanel: Privacy Policy
• Facebook Analytics: Privacy Policy

C. Crash Reporting

• Firebase Crashlytics: Collects stack traces and device state information when the app crashes.

D. Payments & Subscriptions

We use RevenueCat to manage subscription infrastructure. All financial transactions are processed directly by the Apple App Store or Google Play Store. We do not process or store your credit card information.

• RevenueCat: Privacy Policy
• Apple StoreKit: Subject to Apple's Privacy Policy.
• Google Play Billing: Subject to Google's Privacy Policy.

E. Cloud Synchronization

The App allows you to sync reading progress or files via your own personal cloud accounts.

• Google Drive / iCloud Drive: The App interacts with these services using official APIs. We do not have access to your login credentials. The data flows directly between your device and your cloud provider.

5. Your Rights & Data Control

GDPR (European Union / EEA Users)

Since we are based in Estonia, we adhere strictly to the GDPR. Your rights include:

• Right to Access & Portability: You can request a copy of the pseudonymized data we hold about you (if linked to an identifier we can verify).
• Right to Deletion: You can request that we delete data associated with your device ID.
• Consent Management:
  • Ads: We use Google's User Messaging Platform (UMP) to ask for your consent to show personalized ads. You can withdraw this consent at any time in the App Settings.
  • Tracking: On iOS, we adhere to the App Tracking Transparency (ATT) framework. We will not track you across other apps and websites without your explicit permission.

Opting Out of Targeted Ads

You can limit ad tracking in your device settings:

• iOS: Go to Settings > Privacy > Tracking.
• Android: Go to Settings > Google > Ads > Delete Advertising ID.

6. Children’s Privacy

Our App is intended for a general audience and is not directed at children. We do not knowingly collect personal information from children under the age of 13 (or 16 in the EEA). If we become aware that we have collected personal data from a child without parental consent, we will take steps to remove that information.

7. Data Retention

We retain data collected via third-party analytics/ad services only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law. Most aggregated analytics data is retained for a limited period (e.g., 14-26 months) by the third-party providers before being deleted.

8. International Data Transfers

Since we use third-party providers (like Google, Facebook, Mixpanel) that may be based in the United States, your pseudonymized data may be transferred outside of the European Economic Area (EEA). We ensure these providers utilize Standard Contractual Clauses (SCCs) or the EU-US Data Privacy Framework to ensure your data is protected.

9. Changes to This Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

10. Contact Us

If you have any questions or suggestions about our Privacy Policy, or if you wish to exercise your GDPR rights, please contact us at:

Algorion OÜ
Email: hi@hetko.eu
Address: Tartu, Kaunase pst 1, Estonia