1. Data Controller and Contact Information
ABV TIPS (“the Company”, “we”, “us”, “our”) is owned and operated by ABV TIPS LTD, EIK 207020776, with registered address: Bulgaria, Plovdiv 4000, Central District, 24 Knyaz Aleksandar I Str.
Privacy contact: abvtips2022@gmail.com.
Supervisory authority: Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria.
2. Categories of Data We Process
You can use ABV TIPS without providing your name, email, or phone number. We use pseudonymous identifiers to operate the app, remember preferences, manage subscriptions, and measure product usage.
• Pseudonymous identifier: A UUID is generated by our backend (Supabase) to recognize your app session, subscription status, and preferences.
• Purchase and subscription data: Managed through RevenueCat and app stores. We do not store card or bank details. We receive purchase tokens, product status, expiry data, and subscription lifecycle events linked to your UUID. When advertising attribution is enabled for your device, RevenueCat may also process limited attribution identifiers needed to send subscription conversion data to our measurement partner.
• Technical usage and attribution data: Device type, OS version, language/locale, app lifecycle events, screen views, feature usage events, notification-open events, purchase funnel events, app diagnostics, security logs, and IP address or network metadata that may be processed by our service providers for security, diagnostics, attribution, and conversion reporting where permitted. We also use a persistent pseudonymous analytics identifier to measure activity tied to the app install and, when your consent and platform settings allow it, limited advertising or attribution identifiers for campaign attribution and conversion reporting. On iOS, full advertising attribution may rely on App Tracking Transparency permission. If permission is not granted, we may rely on privacy-preserving attribution such as SKAdNetwork where available. We do not use session recordings or automatic touch capture, and we do not use email or phone-number matching for advertising measurement.
• Push tokens: Anonymous Expo push token used to deliver notifications.
• Support chat content: Messages sent through in-app support integrations (including Telegram bot relay) are processed as support communications.
3. Legal Bases and Purposes (GDPR Art. 6)
• Contract performance (Art. 6(1)(b)): to provide core app functionality, premium access, and account-state continuity via UUID.
• Consent (Art. 6(1)(a)): to send push notifications, enable optional advertising attribution measurement, share limited attribution identifiers where permitted, and request platform-level tracking permission where required.
• Legitimate interests (Art. 6(1)(f)): fraud prevention, service security, diagnostics, pseudonymous product analytics, product improvement, and internal performance reporting.
• Legal obligation (Art. 6(1)(c)): accounting and tax compliance relating to digital purchases.
4. Processors and Third-Party Services
• Supabase: infrastructure and database hosting (EEA-focused hosting where available).
• RevenueCat: subscription management, validation, and, when attribution is enabled for your device, transmission of limited subscription attribution data to our measurement partner.
• Apple App Store / Google Play: independent controllers for billing and payment processing.
• PostHog: pseudonymous product analytics, manual event measurement, manual screen tracking, and in-app usage reporting using a persistent pseudonymous app-install identifier. We do not use session replay or touch autocapture.
• Singular: mobile measurement partner used to attribute ad-driven installs, sessions, selected conversion events, and privacy-aware postbacks to advertising partners. Depending on your consent choices and platform state, Singular may operate either in full attribution mode or in a privacy-preserving limited-data mode.
• Meta: advertising attribution, campaign measurement, and conversion reporting based on limited device identifiers, privacy signals, and selected subscription-related conversion data when permitted by your consent choices and platform permissions. On iOS, attribution may rely on App Tracking Transparency permission and privacy-preserving store attribution.
• Expo: delivery of push notifications.
• Telegram (support relay): support communication processing through Telegram bot infrastructure.
Where international transfers occur, we rely on contractual and legal safeguards required by applicable law.
5. Retention Periods
• Subscription and transaction records: retained up to 5 years where required for legal and tax compliance.
• Technical logs, diagnostics, pseudonymous analytics events, and attribution events: retained up to 12 months for security, troubleshooting, product improvement, and campaign performance reporting, subject to shorter or longer retention applied by our service providers where legally required.
• UUID and push tokens: deleted within 30 days of a valid erasure request, or after prolonged inactivity under our retention rules.
6. Your Rights
You may have the right to access, erase, restrict, or object to certain processing, and to lodge a complaint with your local authority. Because we do not rely on name/email identity for core use, requests may require your in-app UUID for verification. To exercise rights, contact abvtips2022@gmail.com.
7. Security
Data in transit is protected with TLS/SSL encryption. Data at rest is protected using provider security controls and restricted-access operational practices
© 2023 ABV TIPS LTD. All right reserved. Website developed by Skyeystudio
