Privacy Policy

Last updated: January 5, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party.

• Application means the software program provided by the Company downloaded by You on any electronic device

• Company (referred to as either "the Company", "We", "Us" or "Our") refers to DR-Online LLC, Aleje Jerozolimskie 155/U3, 02-326 Warsaw, Poland.

• Country refers to: Poland.

• Device means any device that can access the Service.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes the data on behalf of the Company.

• Usage Data refers to data collected automatically through the use of the Service.

• You means the individual using the Service, or the entity on behalf of which such individual is using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

We do not collect personally identifiable information (PII) through the Application. However, if You voluntarily contact Us via email, we may process Your email address and name to respond to You.

Usage Data

Usage Data is collected automatically when using the Service. It may include:

• Your Device's IP address
• Browser type/version
• Time and date of access
• App screens visited and session duration
• Mobile device identifiers

Analytics Data

We use Google Firebase Analytics to collect anonymized, aggregate data about how the Application is used. Firebase may collect:

• Device information (model, OS version, resolution)
• Screens visited
• Session durations
• App crash events
• Country- or city-level location (based on IP)

Firebase Analytics does not collect personally identifiable information, nor do We use it for profiling or targeted advertising.

Processing of such data is based on our legitimate interest (Art. 6(1)(f) GDPR) in maintaining and improving the Application. You may opt out via Application settings.

For more information, see: https://policies.google.com/privacy

Advertising

We display advertisements in the Application using Google AdMob. AdMob may collect and process certain data to serve ads, including:

• Advertising identifiers (Google Advertising ID on Android, IDFA on iOS)
• Device information (model, OS version, screen size)
• IP address (for approximate location)
• App usage and interaction data

Depending on your consent choices, you may receive:

• Personalized ads: tailored to your interests based on your activity across apps and websites
• Non-personalized ads: not based on your personal data, but may still use contextual information such as general location

You can manage your ad preferences at any time through the Application settings ("Manage Ad Preferences") or through your device settings:

• On Android: Settings → Google → Ads
• On iOS: Settings → Privacy → Tracking

Processing of advertising data is based on your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time, which will result in non-personalized ads being shown.

For more information about how Google uses data for advertising, see: https://policies.google.com/technologies/ads

Legal Basis for Processing Personal Data (GDPR)

We process your data only when we have a legal basis, including:

• Your consent (Art. 6(1)(a) GDPR)
• Contractual necessity (Art. 6(1)(b) GDPR)
• Our legitimate interests (Art. 6(1)(f) GDPR), such as Application improvement
• Legal obligations (Art. 6(1)(c) GDPR)

Your Rights under GDPR

Under GDPR, You have the right to:

• Access your personal data
• Rectify inaccuracies
• Request deletion (right to be forgotten)
• Restrict or object to processing
• Data portability
• Withdraw consent at any time
• Lodge a complaint with the data protection authority (UODO in Poland)

To exercise your rights, contact us at: [email protected]

Use of Your Personal Data

We may use Personal Data for:

• Providing and maintaining the Service, including to monitor the usage of our Service.

• Managing user accounts: to manage Your registration as a user of the Service.

• Contacting You: To contact You by email regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.

• Analyzing how the Service is used via Firebase Analytics to improve our Application and Services.

• Displaying advertisements: To show you relevant ads through Google AdMob, based on your consent preferences.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We do not share your personal data with third parties except in the following cases:

• With service providers (e.g. Firebase Analytics, Google AdMob): We may share Your personal information with Service Providers to monitor and analyze the use of our Service and to display advertisements.
• With affiliates under common control: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
• If legally required (e.g. court orders): Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.
• During a business transfer or merger: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With your explicit consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We retain usage data as long as necessary for analysis or legal compliance. Firebase retains analytics data per its policies. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Firebase and its infrastructure may transfer data outside the European Economic Area. Such transfers are secured by standard contractual clauses or other legal mechanisms accepted under GDPR.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

We use reasonable safeguards to protect Your information. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service is not intended for users under 13. We do not knowingly collect data from children under 13. If you believe we have, please contact us to delete it.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update this Privacy Policy. Updates will be posted here and, where appropriate, notified to you via the Application or email.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: [email protected]