Privacy Policy

1. Who we are

Roomy is published by Trevica LTD, which is the data controller for the app and this website.

"We" and "us" mean Trevica LTD. "The App" means Roomy for iPhone.

2. Summary

We do not sell your personal data. We do not collect your name, email address or phone number through the App.

3. What stays on your iPhone

The cleaning features run entirely on your device. When you allow access to your photo library, the App reads it through Apple's Photos framework and does all comparisons locally:

• Similar and duplicate photos: grouping and the Best suggestion are calculated on the device.
• Screenshots and videos: the lists are built from information iOS already holds about your library.
• Video compression: the clip is re-encoded on the device.
• Background removal: the photo you add is processed on the device.

Your photos, videos, their metadata and the results of a scan are never sent to us, to AppsFlyer, to Firebase or to anyone else. Temporary files such as thumbnails and comparison data stay on the device and are removed when you delete the App.

4. Third-party analytics and attribution

The App contains three third-party services: AppsFlyer, Firebase Analytics and Firebase Crashlytics. None of them receive any content from your photo library.

4.1 AppsFlyer

AppsFlyer Ltd. provides install attribution. It tells us which of our advertising campaigns led to an install or a subscription, so we can measure and pay for our advertising. AppsFlyer does not collect the advertising identifier (IDFA). It may collect:

• the identifier for vendor (IDFV) and an AppsFlyer ID created for your install;
• device model, iOS version, app version, language, time zone and IP address;
• install, launch and in-app events, including subscription purchases and their price;
• information about the ad or campaign that led to the install.

Campaign results for iOS come from Apple's SKAdNetwork, which reports installs to us in aggregate without identifying you. We do not use AppsFlyer to link your activity in the App with data from other companies' apps or websites, and we do not share data with data brokers. AppsFlyer privacy policy: appsflyer.com/legal/services-privacy-policy.

4.2 Firebase Analytics

Google LLC provides Firebase Analytics, which shows us how the App is used so we can improve it. It may collect:

• an app instance ID (not the advertising identifier);
• device model, iOS version, app version and language;
• approximate location (country, region or city) derived from your IP address;
• screens viewed, time spent in the App, and events such as completing onboarding or opening the subscription screen;
• in-app purchase events.

Firebase privacy information: firebase.google.com/support/privacy. Google privacy policy: policies.google.com/privacy.

4.3 Firebase Crashlytics

Google LLC provides Firebase Crashlytics, which sends us a report when the App crashes so we can find and fix the problem. A report may contain:

• the stack trace and the state of the App at the moment of the crash;
• device model, iOS version, app version, free memory and disk space, device orientation;
• a Crashlytics installation ID created for your install;
• the last in-app analytics events before the crash, for context.

Crash reports are not used for tracking or advertising, and they never contain your photos, videos or scan results. Crashlytics privacy information: firebase.google.com/support/privacy.

4.4 Apple

Payments are processed by Apple. We never see your card details. Apple confirms to the App whether your subscription is active. If you share analytics with developers in iOS settings, Apple may also provide us with crash reports and aggregated App Store statistics.

5. Tracking and your choices

Roomy does not track you. Under Apple's definition, tracking means linking data from the App with data from other companies' apps, websites or offline sources for targeted advertising or advertising measurement, or sharing it with data brokers. We do neither:

• the App does not access the advertising identifier (IDFA), so it does not show the iOS App Tracking Transparency prompt;
• advertising results come from Apple's SKAdNetwork in aggregate form;
• we do not show third-party ads in the App and do not share data with data brokers.

You can turn off personalised ads from Apple and reset other advertising settings at any time in Settings > Privacy & Security > Apple Advertising. If the App ever starts using the advertising identifier, it will first ask for your permission through the iOS prompt, and this policy will be updated before that happens.

To ask us to delete analytics data linked to your install, email [email protected]. We will ask only for the details needed to find your install, such as your device model and the date you installed the App.

6. Device permissions

• Photos: needed to find similar photos, duplicates, screenshots and videos, to compress a video, to remove a background and to delete what you select.
• Notifications: optional, used only for messages about the App.

You can withdraw any permission in Settings > Privacy & Security. The feature that relies on it will stop working. Nothing is deleted as a result.

7. Why we use data and on what basis

Where the UK GDPR or EU GDPR applies, we rely on:

• Contract: to provide the App's features and your subscription.
• Consent: for access to your photo library. You can withdraw it at any time as described in section 6.
• Legitimate interests: for app analytics that help us fix problems and improve the App, and for measuring our advertising in aggregate.
• Legal obligation: to keep transaction records where tax law requires it.

8. Who receives data

• AppsFlyer Ltd. and Google LLC (Firebase), as described in section 4;
• Apple, for distribution, payments and subscriptions;
• Cloudflare, which hosts this website and processes visit logs, including IP addresses, for security;
• our email provider, for messages you send us.

We may also disclose data where the law requires it or to establish or defend legal claims.

9. International transfers

AppsFlyer, Google and Cloudflare may process data outside the United Kingdom and the EEA, including in the United States. Where this happens, the transfer is protected by the UK International Data Transfer Addendum, the European Commission's Standard Contractual Clauses or an applicable adequacy decision.

10. How long data is kept

• Photos and scan results: never leave your device. They are removed when you delete the App or the items.
• AppsFlyer data: kept for the retention period in AppsFlyer's terms, then deleted or anonymised.
• Firebase Analytics data: kept for up to 14 months, then deleted automatically.
• Crashlytics crash reports: kept for 90 days, then deleted automatically.
• Emails: kept for as long as needed to answer you, and no longer than 24 months after the conversation ends.
• Transaction records: as long as tax law requires.

11. Your rights

Depending on where you live, you can ask us for access to your data, correction, deletion, restriction, portability, or object to processing, and withdraw consent at any time. Write to [email protected]. We reply within one month.

If you are in the UK you can complain to the Information Commissioner's Office at ico.org.uk. If you are in the EU you can complain to your local data protection authority.

If you are a California resident: we do not sell personal information. We do not share personal information for cross-context behavioural advertising.

12. Children

The App is not directed to children under 13 (or under 16 in the EEA), and we do not knowingly collect their data. If you believe a child has used the App and data about them has been collected, contact us and we will delete it.

13. Security

Data sent to AppsFlyer and Firebase travels over encrypted connections. Access to analytics and crash dashboards is limited to the people who need it.

14. Changes

We will update this policy whenever the App starts collecting something new or stops collecting something. The date at the top shows the latest version.

15. Contact

Trevica LTD, INTERNATIONAL HOUSE, 307 Cotton Exchange Building, Old Hall Street, LIVERPOOL, England L3 9LQ, United Kingdom
Privacy: [email protected]
Support: [email protected]