Privacy Policy | App Comin

This Privacy Policy explains how App Comin ("we", "us", "our", including the brands LUXSANK/LUXSAM/App Comin) collects, uses, discloses, and protects information across our website (www.appcomin.com), our mobile apps and watch faces on Google Play, and any other services that refer to this Policy ("Services"). For questions, contact us at: contact@appcomin.com

WHO WE ARE (CONTROLLER)

App Comin - Nova Prata/RS, Brazil
Privacy contact: contact@appcomin.com

DATA WE COLLECT

Device and app data: app version, OS/version, device model, language, country/region, time zone, basic events (opens, crashes).
Identifiers: Android Advertising ID or App Set ID (ads/anti-fraud), Firebase Instance IDs, consent status tokens (Google UMP / Osano).
Location (only if you grant permission): approximate or precise location for features such as weather or geo-features.
Usage and diagnostics: crash reports and performance metrics (e.g., Firebase Crashlytics/Analytics).
Support/contact: the email and message content you voluntarily send to us.
Payments (if applicable): purchases via Google Play. We receive non-financial confirmations (product IDs, purchase tokens). We do not receive card data.

We do not knowingly collect sensitive categories of personal data.

HOW WE OBTAIN DATA

Directly from you: when you contact support, send feedback, or change settings.
Automatically: via SDKs and cookies in our apps and website.
From platforms: Google Play billing status and technical or aggregated information.

PURPOSES AND LEGAL BASES

Provide core features (e.g., app and watch-face functionality, location features). Legal basis: contract and/or legitimate interest.
Measure and improve (diagnostics, performance, anti-abuse). Legal basis: legitimate interest.
Advertising (personalized or non-personalized ads, frequency capping, fraud prevention). Legal basis: consent in EEA/UK/CH; legitimate interest/contract where permitted elsewhere.
Compliance (legal requests, terms enforcement, misuse prevention). Legal basis: legal obligation and/or legitimate interest.
Support (reply and troubleshooting). Legal basis: contract and/or legitimate interest.

You can withdraw consent at any time as described below.

SHARING AND DISCLOSURES

We do not sell personal data. We share limited data with:

Service providers/processors: Google AdMob/Ad Services, Firebase (Analytics, Crashlytics, Cloud Messaging), hosting/CDN, and email/helpdesk tools, strictly to operate the Services.
Legal and safety: to comply with law, protect rights, and prevent fraud or abuse.
Business transfers: in case of merger, acquisition, or asset sale (we will notify when required).

INTERNATIONAL TRANSFERS

We operate globally. When data is transferred outside your country (including to Brazil or the United States), we rely on appropriate safeguards such as standard contractual clauses or equivalent. You can contact us for details.

YOUR CHOICES AND CONTROLS

In the apps (EEA/UK/Switzerland): we use Google's User Messaging Platform (AdMob UMP) to request and store your ad choices. You may change or withdraw consent in the app's privacy/ads settings, or by resetting the device's advertising ID and consent settings. Without consent, ads are non-personalized and processing is limited.
On the website: we use Osano CMP to collect, store, and honor cookie and processing preferences. Use the cookie banner or the "Cookie Settings" link in the footer to adjust choices.
Device settings: you can disable location permission at any time (some features may stop working) and manage ad personalization in your Google settings.
Email/support: request access, deletion, or other actions via contact@appcomin.com

YOUR PRIVACY RIGHTS

Depending on your location, you may have the rights to access, rectify, erase, restrict, object, port, and withdraw consent.

How to exercise: email contact@appcomin.com with the subject "Privacy Request". We may ask you to confirm your identity.

You may also complain to your local data protection authority (EEA/UK/CH; in Brazil, ANPD).

Brazil (LGPD) notice: we honor LGPD rights. Our legal bases include consent, contract, and legitimate interest.

RETENTION

We retain data only as long as necessary for the purposes described above, then delete or anonymize it. Typical examples: crash logs for about 90-180 days; consent records as required by law; support emails for as long as needed to resolve the case.

SECURITY

We apply reasonable administrative, technical, and organizational measures (encryption in transit, access controls, least-privilege). No method of transmission or storage is 100% secure.

CHILDREN

Our Services are not directed to children under 13 (or the applicable age in your region). We do not knowingly collect personal data from children. If you believe a child provided data, contact us so we can delete it.

CHANGES TO THIS POLICY

We may update this Policy from time to time. We will update the "Last updated" date and, where required, notify you in the app or on the website. Continued use of the Services means you accept the updated Policy.

CONTACT

App Comin - Privacy
Email: contact@appcomin.com