Retro Mode - Privacy Policy

I’m committed to protecting your personal information and your right to privacy. If you have any questions or concerns about my policy, or my practices with regards to your personal data (the term “personal data” comprises all data that can be used to personally identify you), please contact me at android@moertel.app, anytime!

Don’t just take my word for it; this Privacy Policy governs the privacy policies and practices of my apps “Retro Mode - Icon Pack” and “Retro Mode - Weather”, available at the Google Play Store. Please read it carefully as it will help you make informed decisions about sharing your personal information with me. <3

I last updated this Privacy Policy on 23rd October 2023.

1. An overview of data protection

Data Recording in my Apps

Who is the responsible party for the recording of data in my apps (i.e. the "controller")?

I AM THE CONTROLLER. Ok, sorry, but for real: who comes up with these terms? The data in my apps is processed by the operator of the apps, whose contact information is available under section “Information Required by Law” on this website. (Spoiler: It’s me.)

How Do I Record Your Data?

I collect the following data:

Your device name, operating system version, app version and app configuration when you install and use the app.
For Retro Mode - Icon Pack: The Android package name of apps installed on your device, their name and their icon, if (and only if) you choose to submit an icon request via the “Request Icon” section and only for those apps that you select.
For Retro Mode - Weather: The Advertising Identifier (AdId) for displaying ads and for fraud prevention.
For Retro Mode - Weather: Your current location (determined by latitude and longitude) if and only if you enable "Dynamic Location" for one of the widgets.

What are the purposes I use your data for?

All of the purposes should be clear in the context of where I ask for the data: E.g. your apps’ names and icons when you submit an (otherwise completely anonymous) icon request. Some less obvious purposes are using your device model, version, app configuration and log data to reproduce errors that happened when you used my apps.

A portion of the information is generated to guarantee the error free provision of my apps and some data is used to analyse your user patterns (e.g. which icons or wallpapers you enable) so I know which content is interesting and which isn’t.

For Retro Mode - Weather, your location data (latitude and longitude) will never be shared with third-parties. It is handled by my servers located in the EU solely for obtaining accurate weather information, is never stored outside of the server memory (ephemeral), and discarded immediately after weather data is sent back to your device.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact me at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues.

For Retro Mode Weather, a dedicated Data Deletion form is available inside the app via "Settings" -> "Request Data Deletion" and will trigger an automatic deletion of all data associated with you within 48 hours upon receipt.

Analysis tools and tools provided by third parties

There is a possibility that your app usage patterns will be statistically analysed when you install, open and use my apps. Such analyses are performed primarily with what I refer to as analysis programs.

For detailed information about these analysis programs please consult my Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

Some data which the apps access (e.g. wallpapers, themes and a list of implemented icons) is hosted by an external service provider (host). Personal data collected when accessing these resources are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with my potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and efficient provision of my online services by a professional provider (Art. 6 para. 1 lit. f GDPR).

My host will only process your data to the extent necessary to fulfil its performance obligations and to follow my instructions with respect to such data.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, I have concluded an order processing contract with my host.

Cloudflare

I use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your mobile device and certain resources loaded by my app is technically routed via Cloudflare’s network. This enables Cloudflare to analyse data transactions between your device and my app’s resources and to work as a filter between my servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognise Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on my legitimate interest in a provision of my service offerings that is as error free and secure as possible (Art. 6 Sect. 1 lit. f GDPR).

For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, I have concluded an order processing contract with Cloudflare.

3. General information and mandatory information

Data Protection

The operator of the app takes the protection of your personal data very seriously. Hence, I handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use my apps, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data I collect as well as the purposes I use this data for. It also explains how, and for which purpose the information is collected.

I herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Information about the responsible party (referred to as “controller” in the GDPR)

The data processing controller on this website is:

Stefanie Grunwald
Steinschanze 6
20457 Hamburg

E-mail: android@moertel.app

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Information on data transfer to the USA

My apps use, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. I must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. I have no influence over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given me. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, I WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS I AM IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to Data Portability

You have the right to demand that any data I automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to me as the app operator, my apps use either an SSL or a TLS encryption program. If the SSL or TLS encryption is activated, data you transmit to me cannot be read by third parties.

Subscriptions and In-App Purchases

As far as you make an in-app purchase on an Android device in the Google Play Store, settlement and payment are made solely between you and the Google Play Store, based on the applicable terms and conditions and privacy policy that you can access here: https: //play.google.com/intl/en_en/about/play-terms.html and https://www.google.com/intl/en/policies/privacy/.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact me at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact me at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the correctness of your data archived by me, I will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that I restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
If I do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and my rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

4. Recording of data In my apps

Google Firebase

I use the “Google Firebase” service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. For the services I use (Firebase Analytics, Firebase Crashlytics and Firestore) the personal data is limited to so-called “instance IDs”. Firebase instance IDs are unique and thus allow the linking of different events or processes. These data are neither personally identifiable information nor do I make any effort to personalise it retrospectively. I process this aggregated data to analyse and optimise usage behavior, app functionality and reproduce and fix errors.

In addition to the “Instance ID” described above, Google also uses the advertising ID of the device for Firebase Analytics. In the device settings of your Android device you can restrict the use of the advertising ID via “Settings” > “Google” > “Ads” > “Reset Advertising ID”

I do not use Firebase services that use personally identifiable information, such as IP addresses, email addresses, telephone numbers or passwords. For more information about Firebase’s privacy and security, please visit https://firebase.google.com/support/privacy/. Whenever possible I use servers with a location within the EU. However, it can not be ruled out that data may also be transferred to the USA.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this app has a legitimate interest in the analysis of user patterns to optimise both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract Data Processing

I have executed a contract data processing agreement with Google and am implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics for Firebase.

Archiving Period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymised or deleted after 90 days. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

Google AdMob (only in Retro Mode Weather)

I use the “Google AdMob” service provided by Google AdMob Inc., to display advertisements within the app. Google AdMob uses the device’s advertising ID to provide targeted advertising based on your interests and previous interactions with ads. This service may also collect data regarding the frequency and duration of ad interactions. While this data can be used to create user profiles, it is not tied to personal identifiers like name or email address.

In the device settings of your Android device, you can restrict the use of the advertising ID via “Settings” > “Google” (or “Privacy”) > “Ads” > “Reset Advertising ID” or opt out of personalized advertising entirely.

This advertising service is used based on Art. 6 Sect. 1 lit. f GDPR. The operator of this app has a vested interest in displaying relevant ads to support the ongoing development and maintenance of the app. If consent is required (e.g., agreement to the storage of cookies), processing is based on Art. 6 para. 1 lit. a GDPR; consent can be withdrawn at any time. Further details on how Google uses data in advertising can be found at: https://www.google.com/policies/technologies/ads/.

RevenueCat (only in Retro Mode Weather)

For in-app subscription management, I utilize the services of RevenueCat, Inc. RevenueCat assists in processing and managing subscription-related functionalities, ensuring seamless user experience. While RevenueCat does handle data regarding purchase events, subscription status, and related transactions, it does not store or process personal data like your name, address, or payment details. It does store the email address associated with your Google account if and only if you choose to subscribe to Retro Mode Weather.

All data processed by RevenueCat is treated with robust security measures, and the company adheres strictly to best practices in data protection. The utilization of RevenueCat is grounded in Art. 6 Sect. 1 lit. f GDPR, as it enables a legitimate interest in providing and managing subscription services efficiently for users. If a specific consent has been acquired (e.g., agreement to certain data processing actions), the processing occurs exclusively based on Art. 6 para. 1 lit. a GDPR; such consent can be revoked anytime. For comprehensive insights on RevenueCat's data practices, you are encouraged to visit their Privacy Policy page at: https://www.revenuecat.com/dpa/

Contract Data Processing

I have executed a contract data processing agreement with RevenueCat and am implementing the stringent provisions of the German data protection agencies to the fullest when using RevenueCat.

Contact Form

If you submit inquiries to me via my contact form, the information provided in the contact form as well as any contact information provided therein will be stored by me in order to handle your inquiry and in the event that I have further questions. I will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on my legitimate interest in the effective processing of the requests addressed to me (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with me until you ask me to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after I have concluded my response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

Icon Requests (only in Retro Mode Icon Pack)

If you submit an icon request from within the app, then the requested app’s name, package name, icon and the current timestamp will be stored by me in order to handle your request. I never share this information with anyone and the requests are handled completely anonymously.