This Privacy Policy explains what information we collect, why we collect it, and how you can control it. We aim to be clear and concise — and we treat your data the way we'd want our own treated.
01Introduction
D&A SPED M DOO ("Company", "we", "our", "us"), a company registered in Montenegro at Tanasija Pejatovića 33, 84210 Pljevlja, is committed to protecting your privacy. This Privacy Policy describes how we collect, use, process, store, and disclose your personal information when you use our mobile applications, websites, and related services (collectively, "Services").
By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of our Services immediately.
02Information We Collect
2.1 Information You Provide Directly
- Contact information (name, email address, phone number) when you fill out forms or contact us
- Account registration data if our applications require user accounts
- Communication content when you send us messages, feedback, or support requests
- Payment information processed through Apple's In-App Purchase system (we do not directly store credit card numbers)
- User-generated content you create within our applications
2.2 Information Collected Automatically
- Device information: device model, operating system version, unique device identifiers (IDFV), screen resolution, and language settings
- Usage data: app launch times, session duration, feature usage patterns, screens visited, and interaction logs
- Crash reports and performance diagnostics via Apple's crash reporting framework or third-party analytics tools
- Network information: IP address, internet service provider, connection type (Wi-Fi, cellular)
- Location data only if explicitly authorized by you through iOS permissions — we never collect location data without clear consent
2.3 Information from Third Parties
- Analytics data from services such as Apple App Analytics, Firebase Analytics, or similar platforms
- Information from Apple regarding your app subscription or purchase status
03Legal Basis for Processing (GDPR)
We process your personal data based on the following legal grounds:
- Consent: Where you have given explicit consent for specific processing activities
- Contract: Where processing is necessary for the performance of a contract with you
- Legitimate Interest: Where processing is necessary for our legitimate interests, provided these are not overridden by your rights
- Legal Obligation: Where processing is required to comply with applicable laws
04How We Use Your Information
- Provide, operate, maintain, and improve our applications and Services
- Process transactions and manage subscriptions
- Respond to your inquiries, comments, feedback, or questions and provide customer support
- Send technical notices, updates, security alerts, and administrative messages
- Monitor and analyze usage trends, preferences, and activities to improve user experience
- Detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal activities
- Comply with legal obligations, resolve disputes, and enforce our agreements
- Develop new products, features, and services
- Personalize the Services and provide content or features that match your interests
05Data Sharing and Disclosure
We do not sell, rent, or trade your personal information. We may share information in the following circumstances:
- Service Providers: With trusted third-party service providers who assist us in operating our Services (hosting, analytics, customer support), bound by data processing agreements
- Legal Requirements: When required by law, subpoena, or other legal process, or to protect our rights, property, or safety
- Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets
- With Your Consent: We may share information with third parties when you have provided explicit consent
06Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When personal data is no longer needed, we securely delete or anonymize it. Specific retention periods depend on the type of data and the purposes for which it was collected.
For details on how to request deletion of your data, see our User Data Deletion page.
07Data Security
We implement industry-standard technical and organizational security measures to protect your personal data, including encryption in transit (TLS/SSL), secure data storage, access controls, and regular security assessments. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
08International Data Transfers
Your information may be transferred to, and maintained on, servers located outside your country of residence, including countries that may not have the same data protection laws as your jurisdiction. When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.
09Your Rights
Depending on your location and applicable laws (including GDPR, CCPA, and other data protection regulations), you may have the following rights:
- Right of Access: Request a copy of the personal data we hold about you
- Right to Rectification: Request correction of inaccurate or incomplete personal data
- Right to Erasure: Request deletion of your personal data under certain circumstances
- Right to Restrict Processing: Request limitation of processing under certain conditions
- Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format
- Right to Object: Object to processing based on legitimate interests or for direct marketing
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
- Right to Lodge a Complaint: File a complaint with the relevant data protection authority
To exercise any of these rights, please contact us at da.sped.m.doo@gmail.com. We will respond to verified requests within 30 days.
10Children's Privacy
Our Services are not directed to children under the age of 16 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children under this age. If we become aware that we have inadvertently collected personal data from a child under the applicable age, we will take steps to delete such information as quickly as possible. Parents or guardians who believe their child may have provided personal information to us should contact us immediately.
11Third-Party Links and Services
Our Services may contain links to third-party websites, services, or applications that are not operated by us. We are not responsible for the privacy practices of these third parties. We strongly encourage you to review the privacy policies of any third-party services you access through our applications.
13California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt-out of the sale of personal information. We do not sell personal information as defined by the CCPA. To exercise your CCPA rights, contact us at the address below.
14Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the updated policy on this page and updating the "Last updated" date. Your continued use of our Services after changes are posted constitutes your acceptance of the revised policy.
15Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Email: da.sped.m.doo@gmail.com
Address: D&A SPED M DOO, Tanasija Pejatovića 33, 84210 Pljevlja, Montenegro