1. Data Controller
Email: giulio.palumboschiavone@gmail.com
The Data Controller is the individual who determines the purposes and means of processing your personal data within this application.
2. What We Do NOT Collect
All PDF processing happens exclusively on your device (on-device). Your files remain under your control at all times.
The Data Controller does not collect, transmit, or store on any server:
- The content of the PDF files you process
- The passwords you enter
- Any data relating to the documents you open or export
3. Data Collected by Third Parties
A. Google AdMob (advertising — free version only)
The free version displays ads provided by Google LLC (2 Google Way, Mountain View, CA 94043, USA) via the Google Mobile Ads SDK. The SDK may collect:
Legal basis: consent (Art. 6(1)(a) GDPR) for IDFA; legitimate interest (Art. 6(1)(f) GDPR) for minimal technical data.
Transfer: Google LLC (USA) — covered by Standard Contractual Clauses.
More info: policies.google.com/privacy
You can withdraw ATT consent at any time: Settings → Privacy & Security → Tracking → Unlock my PDF.
B. Apple StoreKit (in-app purchases)
Purchases and subscriptions are managed by Apple Inc. The Developer only receives minimal transaction status data. Full payment details are handled by Apple: apple.com/legal/privacy
4. Purposes and Legal Bases
- Providing the app service — performance of a contract (Art. 6(1)(b) GDPR)
- Advertising via AdMob — consent for personalization; legitimate interest for contextual ads
- In-app purchases — performance of a contract (Art. 6(1)(b) GDPR)
5. Data Retention
The Data Controller does not store personal data on its own servers. Data collected by Google AdMob is retained by Google according to its own policies. Data relating to Apple purchases is retained by Apple under its own terms.
6. Recipients
- Google LLC — ad delivery (AdMob)
- Apple Inc. — in-app purchase management
- Public authorities — where required by applicable law
The Data Controller does not sell or share your data for marketing purposes beyond the recipients listed above.
7. International Transfers
Both Google LLC and Apple Inc. are based in the United States. Transfers are carried out in compliance with Arts. 44–49 GDPR, through Standard Contractual Clauses approved by the European Commission.
8. Minors
This service is not directed to users under 16 years of age (the threshold applicable in Italy under Art. 2-quinquies of Legislative Decree 196/2003). The Data Controller does not knowingly collect data from minors under 16. If you believe a minor has provided us with personal data, please contact us at giulio.palumboschiavone@gmail.com.
9. Your Rights (GDPR)
Pursuant to Arts. 15–22 GDPR, you have the right to:
To exercise your rights: giulio.palumboschiavone@gmail.com
You also have the right to lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or the supervisory authority of your EU Member State.
10. Changes to This Policy
The Data Controller reserves the right to update this policy at any time. The revision date at the top of this page indicates the latest update. Continued use of the App after changes are published constitutes acceptance of the updated policy.
11. Contact
For any questions about this privacy policy or the exercise of your rights:
giulio.palumboschiavone@gmail.com