Albumio
Privacy Policy

Albumio is published by QuneticLabs LLC, a limited liability company registered in Wyoming, United States, at 1021 E Lincolnway 10578, Cheyenne, WY 82001. For any question about privacy, write to info@quneticlabs.com.

Your collection is not sent to us and we hold none of it. For the advertising data described in § 06, we are a data controller together with Google.

Albumio is not offered in the European Economic Area or the United Kingdom, and we do not direct it at people there. If that changes, this section will name our local representatives before the app becomes available in those countries.

Our representative in Serbia under Article 44 of the Serbian Law on Personal Data Protection is Djordje Krstic, Belgrade, Serbia, reachable at info@quneticlabs.com. If you are in Serbia, you can contact him about anything in this policy, in Serbian, instead of writing to us in the United States.

This policy covers the Albumio mobile application only; the app's Terms of Service are separate. The QuneticLabs privacy policy covers our website and our other products.

Everything the app knows is in a database on your own device:

• your albums, and for each sticker whether you have it, need it, or have it twice
• your trade history
• family mode profiles — the names and pictures of the collectors sharing the phone. These are stored on the phone only. They are not passwords: anyone who can unlock the phone can switch between them
• your settings, such as language and theme

None of this is sent to us, and we could not read it if we wanted to. If you uninstall the app, it goes with it.

Trading works between two phones standing next to each other. One shows a QR code, the other reads it with the camera, and both work out the swap on the device.

Nothing about a trade reaches us or any server. There is no account involved, so there is nothing that could identify either collector.

The app uses the camera for three things: reading a QR code from another collector's phone, reading sticker numbers from a page so you do not have to type them, and — if you want one — taking a cover photo for an album so you can recognise it in the list.

All three happen entirely on your phone, and nothing is uploaded. The app never asks for the microphone.

• For the QR code and the sticker numbers, photographs are not saved — only the numbers you confirm are added to your album.
• A cover photo is saved, because that is the point of it: it is stored in the app's own storage on this phone and shown on the album. It is not sent anywhere, it is deleted when you remove it or uninstall the app, and it is not included in your backup file — a backup you move to another phone brings the album back without the photo.
• You can also pick a cover photo from your photo library instead of taking one. The app then asks the system for a photo, and only the photo you pick is given to it — the app cannot browse the rest of your library.

You can export a backup of your collection from Settings → Save backup. The file is written wherever you choose to send it, and from that point it is yours to look after — we never see it and never have a copy.

That also means we cannot restore your collection. If you lose the phone without a backup, the collection is gone. Export a backup before you change phones or delete the app.

The app shows ads. They are served by Google AdMob, and they are the reason everything in the app can stay free.

To choose and deliver an ad, AdMob receives from your device:

• an advertising identifier — a number your phone gives to apps, which you can reset or delete at any time in your phone's settings
• your IP address, from which an approximate location, usually the country or the city, can be worked out
• basic technical information about the device and about the ad itself, such as whether it was shown and whether it was tapped

Google is a separate company and decides on its own what it does with this information. That is described at business.safety.google/privacy.

We do not receive any of it. In our AdMob account we see only totals — how many ads were shown and how much was earned. There is no way for us to go from those numbers back to a person.

Who never gets personalised ads. A personalised ad is one chosen using what is known about a device from other apps and sites. It is switched off for:

• anyone who tells us they are under 16
• anyone who has not answered the age question
• every phone using family mode, because more than one person shares it and we cannot tell which of them is looking

Those devices get contextual ads only — chosen without any profile — and their ad requests are marked as child-directed, so Google must treat them that way too. They also never get full-screen ads.

The age question. The first time an ad is about to appear, the app asks which year you were born. The answer stays on this phone. It is not sent to us, to Google, or to anyone else; the app uses it only to decide how to mark the ad request. If you close the question without answering, the app treats you as under 16 — the careful option — and does not ask again.

If you are in Switzerland, the EEA or the UK. You are shown a consent dialog provided by Google before the first ad. Ads are requested only after it is answered; if consent is refused, no ad is requested at all. The app is not offered in the EEA or the UK, but the same dialog appears there if you use it anyway — for example while travelling. That choice can be changed later from the same dialog, and refusing it does not take away any part of the app.

Turning ads off. The app may offer Settings → Remove ads, a one-off purchase that switches off every ad for good; if you do not see it in Settings, it is not available yet. The payment goes through your app store, and we never see your card, your name or your address. The purchase is checked by RevenueCat (RevenueCat, Inc., USA), which handles in-app purchases for us and receives a random identifier the app creates for this purpose only, the store receipt, basic technical information and the IP address — nothing from your collection. See revenuecat.com/privacy. Nothing else changes when you buy it, and nothing else in the app is behind a payment.

Our legal basis. Your collection, your trades and your backup never reach us, so for them there is nothing that needs a legal basis. For the advertising data described in § 06:

• where the consent dialog is shown — Switzerland, and the EEA and the UK when you travel there — the basis is your consent, and without it no ad is requested
• elsewhere, the basis is our legitimate interest in keeping the app free by showing ads, limited as described in § 06: contextual ads only for anyone under 16, anyone who has not answered the age question, and every phone in family mode

For checking a Remove ads purchase, where the app offers it, the basis is the purchase itself: we need it to give you what you paid for.

Your rights. Depending on where you live — for example in Serbia or Switzerland — you have the right to access, correct or delete your personal data, to object to or restrict its processing, to receive it in a portable form, and to withdraw consent at any time.

We hold no personal data about you, so there is nothing for us to hand over or delete. What you can do yourself:

• change or withdraw your ad consent from Settings → Ad privacy settings (shown where the consent dialog applies)
• reset or delete your advertising identifier in your phone's settings
• stop all ads with Settings → Remove ads, where the app offers it
• ask Google about the advertising data it holds, as described at business.safety.google/privacy

For anything else, write to info@quneticlabs.com or, in Serbia, to our representative named in § 01; we will answer within one month. You also have the right to complain to your data protection authority — in Serbia the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik), in Switzerland the Federal Data Protection and Information Commissioner (FDPIC) — and you do not have to come to us first.

• We do not collect analytics or usage statistics of our own.
• We do not build a profile of you, and we do not give anyone your collection, your trades or your settings. What the ad provider receives, and what the purchase service receives if you buy Remove ads, is listed in § 06, and nothing else leaves the app.
• We do not ask for your location, and the app never reads GPS. An approximate location can be worked out from your IP address by the ad provider, as it can from any internet connection.
• We do not read your contacts or anything else on the phone. Your photo library is opened only when you pick a cover photo yourself, and only the photo you pick reaches the app.
• We do not sell data, because we do not have any.

This app is made for collectors, and many of them are children. That is exactly why this version has no account and no messaging: a child using this app is not connected to any stranger. Trading requires both phones to be physically in the same place, so the other collector is someone the child is standing next to.

We ask for no name, no email address and no photograph, and we still hold nothing about any child on any server of ours.

What does happen is advertising, and children are treated differently from adults:

• no personalised ads, ever — a child's device is never profiled and never matched against what is known about it from other apps
• no full-screen ads
• ad requests from that device are marked as child-directed, which obliges Google to apply the same limits at its end
• only ads rated suitable for everyone are allowed

The same applies to anyone who has not answered the age question, and to every phone using family mode.

A child still sees ordinary banner ads, and we would rather say so plainly than imply otherwise: switching them off for anyone who says they are young would simply teach people to say they are young.

A later version of the app is planned to offer an optional account, so collectors who are not in the same place can find each other and swap by post. That version will have its own, longer privacy policy, and it will be published here before the feature exists.

The offline part of the app will keep working without an account, exactly as it does now. We do not intend to put album tracking or trading in person behind a sign-in.

If we change this policy we will publish the new version at this address. If a change ever means the app starts collecting something, we will say so in the app before it takes effect — not quietly in a document.