Privacy Policy

AURELLO CODE SOFTWARE GROUP LTD is providing this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personal information received from users of (i) this website, (ii) any other website owned and operated by AURELLO CODE SOFTWARE GROUP LTD or its affiliates, and (iii) any mobile application owned or published by AURELLO CODE SOFTWARE GROUP LTD(the "Apps"). The websites and Apps are referred to together as the "Services". In this Privacy Policy, "you" or "your" refers to the person using the Services, and "we", "us", "our" or the "Company" refers to AURELLO CODE SOFTWARE GROUP LTD and its affiliates.

We may update this Privacy Policy periodically, and each version applies to information collected while it is in effect. We will notify you of any material changes by posting the new Privacy Policy on this page. Please check this page from time to time. Before using the Services or submitting any personal information to us, please read this Privacy Policy carefully and contact us at contact@aurello.app if you have any questions. By using the Services, you accept this Privacy Policy, which is incorporated by reference into our Terms of Service. Please do not use the Services if you do not agree with this Privacy Policy.

Per-app differences.The data elements listed in this policy are a superset covering all our Apps. Each app publishes an app-specific data summary in its store listing (Apple App Store ► "App Privacy"; Google Play ► "Data Safety"). If an app's store disclosure shows a data type as "Not Collected", that data type is not collected in that app, even if it is mentioned elsewhere in this policy.

1. Who we are (data controller)

The operator of the Services, and the party responsible under data protection law for the processing of personal data in this context, is:

AURELLO CODE SOFTWARE GROUP LTD
Griva Digeni, 78
2nd floor, Flat/Office V1
Neapoli, 3101, Limassol, Cyprus

Email: contact@aurello.app

We are the "controller" of your personal data within the meaning of the EU General Data Protection Regulation (GDPR). We are not required to appoint a data protection officer; you can reach the person responsible for privacy matters at contact@aurello.app, or by post at the address above marked "privacy".

2. Information we collect and how we use it

We collect personal information in order to provide the Services to you, to communicate with you, and to administer your account if you have one. Depending on the app and the features you use, we may collect the following categories:

• Registration information. Where an app requires an account, we collect basic registration details such as your email address, a username and a password.
• Third-party sign-in. If we offer the option to sign in with a third-party account such as Apple or Google and you choose to use it, we receive basic profile information from that provider, such as your name and email address, to create and secure your account. We do not receive the password for your third-party account.
• Contact information. When you write to us through the website or by email, we collect your name, email address and the content of your message.
• Content you create. Content you create or upload in our apps, such as videos, songs, images, learning progress or game saves. Wherever we can, this stays on your device; where a feature requires it to be processed on our systems or by a service provider, we keep it only as long as needed to deliver that feature. Where a feature generates or modifies content using AI, your input is processed by third-party AI providers as described in section 7.
• Technical and navigational information. Information about your interaction with the Services, such as device type, unique device identifiers for mobile devices, operating system version, app version, language, browser, pages visited, crash reports and aggregate usage statistics.
• Advertising information.In apps that are ad-supported, the third-party advertising SDKs we embed collect information directly from your device — including your advertising identifier (Apple's IDFA or Android's Advertising ID), IP address, coarse device information and how you interact with ads — in order to select, deliver and measure advertising. See section 8 for detail and your choices.
• Purchase information. Purchases and subscriptions in our apps are processed by Apple (App Store) and Google (Google Play). We do not receive or store your payment card details; we may receive transaction confirmations needed to unlock what you bought.
• Permissions you grant. Where a feature needs access to your photos, camera, microphone or location, we ask for your permission first and only use that access for the feature you requested. You can withdraw it at any time in your device settings.
• Other information. Feedback, questions, comments or suggestions you choose to send us.

Log data. When you access our website, our servers automatically record information that browsers transmit, such as your IP address, browser type, the pages you viewed and the time of your visit. We use this log data to operate and secure the Services and for technical administration.

We use the information above to provide and maintain the Services, to answer your enquiries, to give you administrative updates such as changes to our terms and policies, to understand how the Services are used so we can improve them and develop new features, to protect against fraud, abuse and security incidents, to show and measure advertising where an app is ad-supported, and to comply with legal obligations. We do not sell your personal data.

3. Why we process your data (legal bases)

We process personal data only where the GDPR allows it:

• Performance of a contract (Art. 6(1)(b) GDPR): to provide the apps and their features, including purchases you make, and to take steps at your request before entering into a contract.
• Legitimate interests (Art. 6(1)(f) GDPR): to answer your enquiries, keep the Services secure, fix bugs and improve our products, where your interests, rights and freedoms do not override ours.
• Consent (Art. 6(1)(a) GDPR): where a feature asks for it explicitly, for example access to your photos or microphone, or your permission to use your advertising identifier for personalised ads. You can withdraw consent at any time.
• Legal obligations (Art. 6(1)(c) GDPR): to comply with accounting, tax and other statutory requirements under Cyprus and EU law.
• Vital interests (Art. 6(1)(d) GDPR): in the rare case that processing is necessary to protect the vital interests of you or another person.

4. Whether you have to give us your data

You are never obliged by law to give us personal data. Some data is simply necessary for something you have asked for: to answer a message you send us we need your email address, and to provide a feature you have chosen we need the information that feature works with. If you do not provide it, we cannot reply to you or that feature will not be available, but this has no other consequence and you can continue to use everything else.

5. Automated decision-making

We do not make decisions about you that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing, and we do not carry out profiling for those purposes within the meaning of Art. 22 GDPR.

6. Cookies and tracking

Strictly necessary cookies. This website uses only technologies that are strictly necessary to deliver the site and, where an app offers a login, to keep you signed in. These are essential for the Services to work and do not require your consent.

Optional cookies. We use analytics cookies that let us count how many people visit and understand how they move around, so we can improve how the Services work. These give us aggregate traffic metrics rather than information that identifies you personally. Where the law requires it, we ask for your consent before setting them, and you can withdraw that consent at any time.

Advertising cookies. Some of our apps show advertising, and our advertising partners may set cookies or use similar technologies through the ads they serve. See section 8 for more on advertising and how to opt out.

Your choices. Most browsers let you see, block or delete cookies through their settings or Help section. Please note that blocking strictly necessary cookies may stop parts of the site from working.

Do Not Track.We do not currently respond to "Do Not Track" browser signals. If that changes, we will update this policy to explain how.

7. Information sharing and disclosure

Service providers. We use trusted third parties to run parts of the Services on our behalf, such as website hosting, form handling and the infrastructure our apps rely on. We share personal data with them only to the extent needed to perform those functions, and only under contracts that require them to keep your information confidential and secure and to process it solely on our instructions.

AI service providers. Some app features generate or modify content using artificial intelligence. To produce your result, the input you provide for that feature — such as a prompt, photo, voice recording or other content — is sent to third-party AI providers who process it on our behalf, solely to generate your output and not to identify you. We share only what the feature needs, under contracts that require them to keep it confidential and process it only on our instructions.

Apple and Google. When you download our apps or make an in-app purchase, Apple and Google process data under their own privacy policies. Where you request a refund from Apple for an in-app purchase, we may share data about your use and consumption of the purchased content with Apple so that Apple can make an informed decision on your request. We share only what is necessary for that purpose.

Legal compliance and law enforcement. We may disclose personal data to courts, government or law enforcement authorities, or private parties where we reasonably believe it is necessary to comply with a legal obligation or lawful request, to enforce our Terms of Service, to investigate suspected fraud or illegal activity, to protect the rights, property or safety of any person, or to establish, exercise or defend legal claims.

Business transfers. If we are involved in a merger, acquisition, reorganisation, sale of assets or insolvency, personal data may be transferred as part of that transaction. We will tell you if your data becomes subject to a different privacy policy.

Affiliates. We may share personal data with companies that control us, are controlled by us or are under common control with us. Our affiliates use that data in line with this Privacy Policy.

Other users. Where an app offers sharing or public features, the content and profile details you choose to share become visible to other people. Please think carefully about what you share, as we cannot control how others use information you have made visible to them.

Advertising partners. Where an app is ad-supported, we and our advertising providers may share limited information needed to deliver and measure ads, as described in section 8.

We do not sell your personal data, and apart from the advertising described in section 8 we do not share it with third parties for their own marketing purposes.

8. Advertising

Ad serving.Some of our apps are ad-supported. In those apps we embed third-party advertising SDKs (for example Google AdMob) that collect data directly from your device — including your advertising identifier (Apple's IDFA or Android's Advertising ID), IP address, coarse device and usage information and how you interact with ads — to select, deliver and measure advertising, and may combine it with information obtained from third parties. On Apple devices, ads that use your advertising identifier for tracking are shown only if you allow it through Apple's App Tracking Transparency prompt.

Advertising and cookies. Some of our third-party advertising partners may place cookies or similar identifiers in the ads served to our users. Once an ad has been delivered to us, we do not access or control those cookies.

Affiliate advertising. We may take part in affiliate marketing and allow affiliate links to be included on some of our pages. That means we may receive a commission if you click such a link or make a purchase through it.

Your choices and opt-out.Where the law requires consent for personalised advertising, we ask for it before showing you personalised ads, and you can change your mind at any time. On mobile devices you can also limit ad tracking in your device settings — under Privacy & Security on iOS, and under Ads in Google settings on Android. To opt out of interest-based advertising from participating companies on the web, you can use optout.aboutads.info or optout.networkadvertising.org.

9. Third-party services and links

The Services may link to or work with websites and services we do not operate, including the App Store, Google Play and any service you choose to connect to an app. If you use them or give them information, that use is governed by their own privacy policies and terms. We are not responsible for the privacy practices of any third party.

10. International users and data transfers

We are located in Cyprus and your data is processed in the European Union wherever possible. Some of our service providers are located outside the European Economic Area (for example in the United States). Where that is the case, we rely on an adequacy decision of the European Commission or on appropriate safeguards such as the EU Standard Contractual Clauses, so that your data continues to receive an appropriate level of protection and your rights remain protected. You can obtain a copy of the safeguards we rely on, or information about where they are available, by contacting us at contact@aurello.app.

11. How long we keep your data

We keep personal data only as long as necessary for the purposes set out in this policy, for as long as we have a valid business reason, or for as long as the law requires, whichever is longer. In practice: contact enquiries are kept for as long as needed to handle your request and a reasonable period afterwards; account data is kept while your account is active and deleted after you close it; and records we must keep under Cyprus law, such as accounting records, are kept for the statutory retention period. Content you create in our apps and store locally remains on your device under your control, and deleting the app removes it.

12. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you (Art. 15);
• have inaccurate data corrected (Art. 16);
• have your data erased (Art. 17);
• restrict processing (Art. 18);
• object, on grounds relating to your particular situation, to processing based on our legitimate interests, and object at any time to any processing for direct marketing (Art. 21);
• receive your data in a portable format (Art. 20); and
• withdraw any consent you have given us, at any time. Withdrawing consent does not affect the lawfulness of the processing we carried out on the basis of your consent before you withdrew it.

Withdrawing consent is as easy as giving it. To exercise any of these rights, contact us at contact@aurello.app; we will respond within one month. You also have the right to lodge a complaint with a supervisory authority: in Cyprus, the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy), or the authority of your EU country of residence or place of work.

13. California privacy rights

If you are a California resident, you may be entitled to know which categories of personal information we collect about you, the purposes for which it was collected and the sources it came from; to access the specific personal information we hold about you; to know whether we have disclosed personal information for business purposes; to request deletion of your personal information in certain circumstances; to opt out of the "sale" of your personal information; and not to be discriminated against for exercising these rights. We do not sell personal information. To make a request, contact us at contact@aurello.app.

14. Children

The Services are not intended for people under 18 years of age, and we do not knowingly collect personally identifiable information from children under the age of 18. If a parent or legal guardian discovers that their child has given us personal information without their permission, they should contact us at contact@aurello.app. If we become aware that a child under the age of 18 has shared personally identifiable information with us, we will delete such information from our records.

15. Security

We take appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and the principle of collecting as little data as possible in the first place. No method of transmission or storage is completely secure, so while we work hard to protect your information we cannot guarantee absolute security.

16. Changes to this policy

We may update this policy from time to time, for example when we release new apps or features. The current version is always available on this page, and material changes will be highlighted in the apps or on this website.

17. Contact us

If you want to have access to your personal data that is processed by AURELLO CODE SOFTWARE GROUP LTD and/or if you have any questions about the processing of personal data, please send an email to contact@aurello.app.