Puff Punk Privacy Policy

Puff Punk ("App") is published by Mykola Mykal, who is responsible for processing your personal data as the data controller. You can reach me at support@puffpunk.app.

As I am located in the European Union, the processing of personal data is governed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

A. TABLE OF CONTENTS

The personal data processed (part B)
The purposes of the processing of personal data, legal bases and periods of processing (part C)
Sharing of personal data (part D)
Your rights in data processing and how to exercise them (part E)
The possibility to lodge a complaint (part F)
Amendments to this document (part G)

B. PERSONAL DATA PROCESSED

When you use the App, personal data may be processed. As the data controller, I process the following categories of personal data:

Identifiers – such as uid, device's advertising identifier, IP address.
Contact info – such as e-mail address only if you contact customer support.
Purchases information – such as payments related solely to the App.
User content – such as customer support requests.
Usage data – such as app launches, taps, scrolling information, or other information about how you interact with the App.
Diagnostics data – such as crash logs, timezone ID, language, iOS/Android version or other technical information about your device.
Customer support data – such as identification of issue, messages between you and me, attached files and additional information, information about resolution of your issues.
Marketing data – such as marketing ID, device information, information about viewed ads (only if ads are displayed in the App).

Please, do not use the App to upload any sensitive information about you, such as health data, genetic data, biometric data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning sexual orientation.

The App is not designated for children. By downloading or installing the App, you declare that you are older than 13 years old and are solely responsible for any damage or loss that may result from an untruthful declaration.

C. PURPOSES OF THE PROCESSING OF PERSONAL DATA

C.1 Provision of App functionalities

I process personal data to provide you with the App and related services. This includes authenticating you as the user, enabling features, customizing what you see and use, performing customer support, ensuring functionality of the App, and sending essential notifications.

Data processed: Identifiers, Contact info, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
Legal basis: Performance of the contract between you and me.
Retention: Duration of the relationship, up to 3 years from the last activity in the App.

C.2 Improving the App

I may process data about how you use the App to better understand trends and improve features.

Data processed: Identifiers, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
Legal basis: Legitimate interest in improving the App.
Retention: Up to 3 years from the date of collection.

C.3 Internal records, statistics, and protection of rights

I may process your data for keeping internal records, generating statistics, protecting my rights, and ensuring compliance with the App's terms.

Data processed: Identifiers, Contact info, Purchases information, Usage data, Diagnostics data, Customer support data.
Legal basis: Legitimate interest in internal records and protection of rights.
Retention: Up to 10 years after the last activity in the App (or longer in the event of a dispute), or up to 5 years if no contract was concluded.

C.4 Support and promotion of products and services

I may process data you provide when using the App to inform you about other products, services, promotions, or updates.

Data processed: Identifiers, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
Legal basis: Legitimate interest in supporting and promoting services.
Retention: Up to 2 years after termination of the contract.

C.5 Fulfilling legal obligations

I may process your personal data to comply with tax, accounting, and legal obligations, and to cooperate with state authorities if required.

Data processed: Identifiers, Contact info, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
Legal basis: Fulfillment of legal obligations.
Retention: For the period required by law.

C.6 Third-Party advertising

If you give consent via a pop-up screen, I may share your personal data with third-party advertisers to display ads.

Data processed: Identifiers, Usage data, Diagnostics data, Marketing data.
Legal basis: Consent.
Retention: Duration of relationship, maximum 1 year from giving consent.

D. SHARING OF PERSONAL DATA

I may share your personal data with trusted third-party service providers who help me operate the App (e.g., cloud hosting, analytics, customer support, and advertising providers). These parties act as data processors and process data on my behalf within the scope of this Privacy Policy.

I may also share your data with public authorities if required by law, or with others if necessary to protect my rights.

Where personal data is shared outside the European Economic Area (EEA), I only do so where adequate safeguards are in place (such as Standard Contractual Clauses).

E. YOUR RIGHTS IN PROCESSING AND HOW TO EXERCISE THEM

You have the right to:

Request access to your personal data
Withdraw your consent
Request rectification of inaccurate data
Request erasure of your personal data ("right to be forgotten")
Request restriction of processing
Request portability of your data
Object to processing based on legitimate interests
Lodge a complaint with the supervisory authority

You can exercise your rights by contacting me at support@puffpunk.app.

Requests will be processed without undue delay, within 1 month. In exceptional cases, this period may be extended by up to 2 months, and you will be informed accordingly.

F. RIGHT TO FILE A COMPLAINT

You also have the right to file a complaint with the relevant supervisory authority for data protection in your country of residence. For Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD), located at Av. D. Carlos I, 134, 1200-651 Lisbon, Portugal.

G. CHANGES TO THIS POLICY

This Privacy Policy is effective as of 16/09/2025. It may be updated from time to time, so please check it regularly. Any changes will be posted on the App or communicated in another appropriate way.