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Privacy Policy - SomaliBTJ

Effective date: 5 September 2025

Apps Foundry Labs Ltd (“AFL”, “we”, “us”, “our”) respects your privacy. This Privacy Policy explains how we handle information when you or your child use the Somali BTJ mobile application (the “App”).

By using the App, you agree to this Privacy Policy. If you do not agree, please do not use the App.

1) Who We Are (Controller)

Apps Foundry Labs Ltd
Company Number: 16288141
Incorporated: 3 March 2025
Nature of Business (SIC): 58290 – Other software publishing
Registered Address: Unit 7, 97 Western Road, Southall, England, UB2 5HN
Email: privacy@appsfoundrylabs.com

We are the data controller under the UK GDPR and the Data Protection Act 2018.

2) Scope

This policy covers the App on iOS and Android. It explains what data we (and our processors) collect, why we collect it, how long we keep it, your rights, and how to contact us.

3) Summary (Kid-Friendly)

  • No ads. No behavioural profiling.
  • App works mostly offline; content is stored on your device.
  • One-time purchase unlocks all content; Apple/Google process the payment—we never see your card details.
  • We use RevenueCat only to validate/restore the lifetime purchase across devices.
  • If you email us for support, we use your email only to help you.

4) Data We Collect and Why

4.1 Data You Provide

  • Support emails (optional): If you contact us, we process your email address and message to respond and keep support records.
    Lawful basis: performance of a contract (support), legitimate interests, or consent (where applicable).

4.2 Data Collected Automatically (Minimal)

  • Purchase data (via Apple/Google & RevenueCat): product identifier, transaction/receipt details, platform, region/country, and a non-identifying app user ID.
    Why: to verify your lifetime access, enable restore purchases, prevent fraud, and meet accounting obligations.
    Lawful basis: performance of a contract, legitimate interests (fraud prevention, troubleshooting), and legal obligation (tax/accounting).

4.3 We Do Not Collect

  • No account sign-up in the App.
  • No precise location data.
  • No advertising IDs or tracking for ads.
  • No access to contacts, photos, microphone, or camera (unless a future feature explicitly asks—then we’ll request permission first).

5) Children’s Privacy

The App is designed for children with parental purchase/supervision.

  • We do not knowingly collect personal data directly from children.
  • Purchases are made through the adult’s Apple/Google account.
  • If a child contacts us and shares personal data, email us and we will delete it.

We aim to comply with applicable children’s privacy laws (e.g., COPPA in the U.S.). Parents/guardians may contact us to review or delete any support correspondence.

6) Payments & Processors

App Stores (Apple/Google)

  • Process payments and tax under their own privacy policies.
  • We never receive card numbers.

RevenueCat (Purchase Validation)

  • We use RevenueCat to verify entitlements (e.g., lifetime unlock), manage receipts, and support restore on new devices.
  • RevenueCat acts as our processor and receives purchase metadata (e.g., product IDs, receipts, platform, non-identifying app user ID).
  • We configure RevenueCat to the minimum necessary data for entitlements.

If we add more processors (e.g., crash reporting) in future, we will update this policy.

7) How We Use Data

  • Provide and maintain App functionality, including unlocking and restoring lifetime access.
  • Troubleshoot issues, prevent fraud/abuse, comply with law, and maintain financial records.
  • Respond to support requests.

We do not use data for targeted advertising.

8) Data Storage & Retention

  • On-device content: stored locally; delete by uninstalling the App.
  • Purchase/receipt data (via RevenueCat/App stores): retained as long as needed to provide lifetime access and to meet tax/accounting rules (typically up to 6 years in the UK).
  • Support emails: retained as needed to resolve your query and for our legitimate record-keeping (normally up to 24 months, unless required longer by law).

9) International Transfers

We are UK-based but may use processors that store data outside the UK/EEA. When we do, we rely on appropriate safeguards (e.g., UK adequacy regulations or Standard Contractual Clauses) to protect your data.

10) Security

We use administrative, technical, and organisational measures to protect personal data (e.g., limited access, HTTPS, role-based permissions). No method is 100% secure, but we work to protect your information.

11) Your Rights (UK/EEA)

You can:

  • request access, correction, or deletion of your personal data;
  • object to or restrict processing;
  • request data portability;
  • withdraw consent where processing is based on consent.

To exercise rights, email privacy@appsfoundrylabs.com. We may ask for proof of identity. You can also complain to the UK Information Commissioner’s Office (ICO) or your local authority.

12) California (CCPA/CPRA) Notice

We do not sell or share personal information for cross-context behavioural advertising. California residents may request access, correction, or deletion. Contact privacy@appsfoundrylabs.com.

13) Do Not Track

The App does not respond to “Do Not Track” signals (not applicable to native apps), and we do not conduct cross-site tracking.

14) Third-Party Links

If the App or our site links to third-party services, their privacy practices apply when you use them.

15) Changes to This Policy

We may update this policy to reflect changes in the App, our practices, or the law. We will post updates in-app or on our website and update the “Effective date” above.

16) Contact Us

privacy@appsfoundrylabs.com
Apps Foundry Labs Ltd
Unit 7, 97 Western Road
Southall, England, UB2 5HN