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Privacy Policy

LED Remote

This Privacy Policy explains how personal data is processed when you use the LED Remote mobile application (the "App"). It is written to satisfy Regulation (EU) 2016/679 (the "GDPR") and applies to all users of the App.

1.Data Controller

The controller of your personal data is ASO Positive, s. r. o., Rovniankova 11, 851 02 Bratislava, Slovakia, Company ID (IČO): 57393630, VAT ID: SK2122694486, registered in the Obchodný register Mestského súdu Bratislava III, oddiel: Sro, vložka č. 195020/B (the "Controller", "we" or "us").

You may contact us in any matter relating to the processing of your personal data at multibusinesseu@gmail.com.

2.Summary

The App requires no account and no registration. Everything you create in the App is stored on your device and is not transmitted to us. The App does, however, integrate third-party services for advertising, analytics and subscription management, and those services process limited data as described below.

3.Data Stored Solely on Your Device

The following is stored in the App's local storage on your device, is never transmitted to us, and is permanently deleted when you uninstall the App:

• Saved remotes, including the remote layout and code set you selected
• Recorded scenes and banner presets
• Banner text, colours and playback settings
• Application preferences such as haptic feedback and keep-screen-awake
• A local activity history of recent actions

We have no access to this data at any time and cannot retrieve it on your behalf.

4.Data Processed by Third-Party Services

The App integrates the following processors. Each acts under its own privacy policy, which we encourage you to read.

Google AdMob (advertising)
Processes your advertising identifier, device and application information, coarse location derived from your IP address, and interaction with advertisements, for the purpose of serving and measuring ads. Where consent is required, advertising identifiers are processed only if you have given consent. Purchasing a Pro subscription removes advertising entirely.

Google Firebase Analytics (analytics)
Processes device model, operating system version, application version, coarse region, and aggregate interaction events such as application opens and sessions. Your advertising identifier is processed only if you have given consent for advertising purposes; where consent is withheld, analytics continues in a form that does not identify you.

RevenueCat (subscription management)
If you purchase a subscription, processes a pseudonymous application user identifier and your purchase and entitlement history, for the purpose of validating the subscription and restoring it across your devices.

Google Play Billing (payments)
Payment is processed exclusively by Google. We never receive or store your payment card details or billing address.

We do not sell personal data and we do not combine data from these services to build profiles of individual users.

5.Legal Bases for Processing

We process personal data on the following legal bases under Article 6(1) GDPR:

• Consent (Art. 6(1)(a)) — for personalised advertising and for the processing of advertising identifiers, where consent is required. You may withdraw consent at any time, with effect for the future.
• Performance of a contract (Art. 6(1)(b)) — for processing necessary to provide and restore a subscription you have purchased.
• Legitimate interests (Art. 6(1)(f)) — for aggregate, non-identifying analytics used to maintain and improve the App, and for the security and integrity of the App.

6.Permissions Requested

The App requests only the following Android permissions:

• TRANSMIT_IR — to send infrared commands, used solely for controlling your lighting hardware
• INTERNET and ACCESS_NETWORK_STATE — for advertising, analytics and subscription validation
• VIBRATE — for haptic feedback on key presses

The App does not request access to your location, camera, microphone, contacts, photo library, Bluetooth or nearby devices.

7.Retention

Data stored on your device is retained until you delete it within the App or uninstall the App. Data processed by the third-party services listed in Section 4 is retained in accordance with their respective retention policies; analytics data is generally retained for a period not exceeding fourteen (14) months.

8.International Transfers

The processors named in Section 4 may transfer personal data outside the European Economic Area, including to the United States. Such transfers are carried out on the basis of the European Commission's adequacy decisions or standard contractual clauses adopted under Article 46 GDPR.

9.Your Rights

Subject to the conditions set out in the GDPR, you have the right to:

• Access your personal data and obtain a copy of it (Art. 15)
• Have inaccurate data rectified (Art. 16)
• Have your data erased (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing carried out on the basis of legitimate interests (Art. 21)
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal (Art. 7(3))

To exercise any of these rights, contact us at multibusinesseu@gmail.com. We will respond within one month of receiving your request.

You may change or withdraw your advertising consent at any time within the App under Settings → Privacy & ad settings. You may also reset or delete your advertising identifier in your Android system settings.

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence. The competent authority for the Controller is the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Hraničná 12, 820 07 Bratislava, Slovakia.

10.Children

The App is not directed at children under the age of 13, and we do not knowingly process the personal data of children. If you believe a child has provided us with personal data, please contact us and we will delete it.

11.Automated Decision-Making

We do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 GDPR.

12.Changes to this Policy

We may update this Privacy Policy from time to time. The date at the top of this document indicates when it was last revised. Material changes will be notified within the App before they take effect.

13.Contact

multibusinesseu@gmail.com