Privacy Policy
1. Introduction and scope
This Privacy Policy describes how personal data is handled in connection with the Onda mobile application (the “Application”) and the website located at musiconda.web.app (the “Website”), together referred to as the “Services”.
This Policy applies to all users of the Services worldwide. It does not apply to any third-party service that a user may access separately, including the Apple App Store, which is governed by Apple’s own privacy policy.
2. Controller and contact details
The Services are provided by Maksim Shvyrkov, acting as an individual developer (the “Provider”, “we”, “us”).
All enquiries relating to this Policy, including requests concerning data protection rights, should be addressed to aihelphelp1@gmail.com. We aim to respond to substantive requests within thirty (30) days.
3. Summary
The Application does not collect, transmit or store personal data. It requires no account, no registration and no sign-in. It contains no analytics, advertising, attribution or crash-reporting components, and no third-party software development kits that collect data. Payment transactions are conducted exclusively by Apple.
4. Personal data collected by the Application
None. The Application does not request, receive, generate or transmit any personal data or persistent identifiers. In particular, it does not access the device’s contacts, photographs, calendar, location, microphone, camera, health data or advertising identifier.
5. Information stored locally on the device
For the Application to function correctly between launches, a small number of technical values are written to storage on the user’s own device:
| Value | Purpose |
|---|---|
| Introduction completed | To avoid repeating the introductory sequence on every launch |
| Selected interface language | To preserve the user’s language choice |
| Free listening time used today | To administer the daily free-use allowance |
These values remain on the device, are not transmitted to the Provider or to any third party, and are not accessible to the Provider. They are deleted when the Application is removed from the device. In the browser version of the Services, equivalent values are stored in the browser’s local storage and are deleted when the user clears site data.
Because these values are strictly necessary for the operation of the Services and are not used for analytics, profiling or advertising, no consent is required for their storage under applicable electronic-communications legislation.
6. Purchases and payment processing
Subscriptions and one-time purchases within the Application are transacted by Apple Inc. and its affiliates, which act as seller of record. Apple collects and processes all payment information, including payment-card details and account identifiers. The Provider does not receive, and has no means of obtaining, such information.
The Provider receives from Apple only aggregated, non-identifying commercial reports, such as the number of units sold in a given territory during a given period. Apple’s processing of personal data is governed by the Apple Privacy Policy.
7. Website hosting and server logs
The Website is hosted on Firebase Hosting, a service operated by Google LLC. In common with all web servers, the hosting infrastructure automatically records technical request data, including the Internet Protocol address of the requesting device, the user-agent string, the resource requested, and the date and time of the request.
The Provider does not use these records to identify individuals and does not combine them with any other data set. Where such records constitute personal data, the lawful basis for their processing is the legitimate interest of the Provider in maintaining the security, availability and integrity of the Website (Article 6(1)(f) of the General Data Protection Regulation). Retention is determined by the hosting provider in accordance with its own terms.
8. Cookies and similar technologies
The Services do not use cookies, web beacons, pixels, fingerprinting techniques or any other technology for the purposes of analytics, profiling, advertising or cross-site tracking.
9. Disclosure of personal data
The Provider does not sell, share, rent, license or otherwise disclose personal data to any third party, for the reason that no such data is collected. No personal data is disclosed for purposes of targeted advertising, and no personal data is transferred to data brokers.
10. International transfers
As the Provider collects no personal data through the Application, no international transfer of such data takes place. Server-log data described in section 7 is processed by the hosting provider on infrastructure that may be located outside the user’s country of residence, subject to the safeguards implemented by that provider.
11. Data security
Values stored locally on the device are protected by the security mechanisms of the device operating system. Since the Provider holds no personal data relating to users of the Application, no such data can be exposed by any incident affecting the Provider.
12. Children’s privacy
The Services are suitable for users of all ages and contain no content directed at harming minors. The Provider does not knowingly collect personal data from any user, including children, since no personal data is collected at all. Consequently, no parental consent mechanism is required under the Children’s Online Privacy Protection Act or equivalent legislation.
13. Rights of data subjects
Users located in the European Economic Area, the United Kingdom, Switzerland and other jurisdictions with comparable legislation are entitled to request access to their personal data, its rectification or erasure, restriction of or objection to its processing, and data portability, and to lodge a complaint with a competent supervisory authority.
Residents of the State of California are entitled, under the California Consumer Privacy Act as amended, to know the categories of personal information collected, to request deletion or correction of that information, and to opt out of its sale or sharing.
The Provider holds no personal data concerning users of the Application. Accordingly, any request for access, rectification, erasure or portability will be answered to that effect. Requests concerning payment data must be directed to Apple, which acts as controller of that data. Requests may be submitted to aihelphelp1@gmail.com.
14. Amendments to this Policy
Should the Services begin to collect any personal data, this Policy will be amended and published prior to the release of the version concerned, and the version number and effective date above will be updated accordingly. The Provider will not commence the collection of personal data without such prior amendment.
15. Governing law
This Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates, without prejudice to any mandatory consumer-protection or data protection rights available to the user under the law of the user’s country of residence.