Privacy Policy

1. Data Controller

Jevgenij Noskov
Nanette-Bald-Str. 41, 81245 Munich, Germany
Email: info@jevolution.de

2. Data Protection Officer

A Data Protection Officer is not legally required and has not been appointed.

3. Processing Purposes and Legal Basis

App Operation (Da. Safety Check-in)

• Check-in times and intervals — Art. 6(1)(b) GDPR (performance of contract)
• Emergency contacts (Watchers) — Art. 6(1)(b) GDPR
• User authentication — Art. 6(1)(b) GDPR
• Location data (Plus plan only, only when enabled) — Art. 6(1)(a) GDPR (consent). To the extent that location data processed during an alarm may constitute health-related data by inference, processing is additionally based on explicit consent pursuant to Art. 9(2)(a) GDPR.

Website Operation (da-app.eu)

• Server log data (IP, user agent, timestamp) — Art. 6(1)(f) GDPR (legitimate interest: security and error analysis)

Analytics

• Plausible Analytics (aggregated page views, no personal data, no cookies) — Art. 6(1)(f) GDPR (legitimate interest)

Payment Processing

• RevenueCat, Stripe, and Apple App Store / Google Play Store process payment data according to their own privacy policies — Art. 6(1)(b) GDPR

Push Notifications

• Apple Push Notification Service (APNs) and Google Firebase Cloud Messaging (FCM) — Art. 6(1)(b) GDPR. The storage of device tokens on your device is carried out pursuant to Section 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG) on the basis of contract performance.

4. Legitimate Interests

Where we rely on Art. 6(1)(f) GDPR (server logs, Plausible Analytics), our interests in the security and proper operation of our services outweigh your interests, as the processing is minimal and does not enable tracking of individual persons.

5. Recipients and Categories of Recipients

• Supabase (Hosting): PostgreSQL database hosted on Hetzner Germany — servers in Falkenstein, DE
• Hetzner Online GmbH: Server hosting in Germany
• Plausible Analytics: Aggregated website data, servers at Hetzner in Germany
• Apple Inc.: Push notifications (APNs), App Store payments
• Google LLC: Push notifications (FCM), Play Store payments
• RevenueCat Inc.: Subscription management and payment processing
• Stripe Inc.: Payment processing (where not billed through app stores)

6. Third-Country Transfers

Apple Inc., Google LLC, RevenueCat Inc., and Stripe Inc. are based in the USA. Transfers are based on Standard Contractual Clauses (SCC) of the EU Commission pursuant to Art. 46(2)(c) GDPR and, where applicable, the EU-US Data Privacy Framework (adequate level of protection).

Apple Inc., Google LLC, and Stripe Inc. are certified under the EU-US Data Privacy Framework (see dataprivacyframework.gov).

All other processing takes place exclusively in Germany / the EU.

7. Retention Periods

• Account data: Until account deletion + 30-day safety retention period
• Check-in history (Free/Plus): 7-day rolling window
• Check-in history (Family): 30-day rolling window
• Location data (alarm): 48 hours after alarm trigger, then automatically deleted
• Alarm history: 30-day rolling window, then automatically deleted
• Server logs: 7 days, then automatically deleted
• Payment data: 10 years (tax retention obligation under Section 147 German Tax Code)

8. Your Rights (Art. 15-22 GDPR)

• Art. 7(3): Right to withdraw consent at any time with effect for the future
• Art. 15: Right of access to processed data
• Art. 16: Right to rectification of inaccurate data
• Art. 17: Right to erasure ("right to be forgotten")
• Art. 18: Right to restriction of processing
• Art. 20: Right to data portability
• Art. 21: Right to object to processing based on legitimate interests

To exercise your rights, contact: info@jevolution.de

9. Withdrawal of Consent

Consents (e.g. location sharing) can be withdrawn at any time with effect for the future — in the app under Settings or by email to us.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

11. Obligation to Provide Data

Providing personal data is required for using the Da. app. Without registration (email address), the service cannot be provided. There is no statutory obligation to provide data.

12. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

Plausible Analytics

This website uses Plausible Analytics, a privacy-friendly analytics tool. Plausible does not use cookies, does not create user profiles, and does not process personal data. All data is aggregated and anonymised. Servers are located at Hetzner in Germany. More: plausible.io/data-policy