Privacy Policy

sAssist Shopping List

1. Who We Are

sAssist Shopping List (the “App”) and its associated website (the “Website”) are operated by:

Altnitro Ltd Cyprus Email: info@altnitro.com

In this Privacy Policy, “we”, “us” and “our” refer to Altnitro Ltd. We act as the data controller for personal data processed in connection with the App and Website, except where a third-party provider processes data independently for its own purposes.

This Privacy Policy explains what personal data we collect, how we use and protect it, and what rights you have under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

2. Information We Collect

The information we collect depends on how you use the App or Website.

2.1 Account Information

When you create or use an account, we may process:

• Your email address and account identifier.
• Authentication information necessary to verify your identity and provide access to your account.
• Other account details you choose to provide, if applicable.

Authentication is handled using our account infrastructure, which uses Google Firebase services.

We do not intend to collect more personal information than is necessary to provide the App's functionality.

2.2 Shopping Lists and App Content

sAssist Shopping List allows you to create and manage shopping lists and individual list items.

The information you save may include:

• Shopping list names and item names.
• Item quantities, categories, and other details you enter.
• List settings and related information required to provide the App's functionality.

This information is stored in cloud infrastructure to enable the App to provide its intended features and, where supported, synchronise your lists across devices.

Your shopping lists are intended for your personal organisation. Please avoid entering sensitive personal information into list fields.

2.3 Usage Data and Diagnostics

We use Google Firebase Analytics to understand how the App is used and to improve its functionality and reliability.

Depending on the configuration of the App and Firebase, this may involve:

• App interactions and feature usage.
• App instance identifiers and technical information.
• Device, operating system and app version information.
• Usage events and related diagnostic information.

The precise information collected depends on the Firebase configuration and the permissions and privacy choices applicable to your device.

We do not use this information to sell your personal data to advertisers.

2.4 Push Notifications

The App may send push notifications to remind you about shopping list items or related tasks.

If you enable notifications, we may process a device push token, app or device identifiers, and the information needed to deliver and manage notifications.

Remote push notifications are supported through Google Firebase Cloud Messaging or associated services, depending on the App's implementation.

You can manage notification permissions through your device settings. Disabling notifications may prevent you from receiving reminders.

2.5 Website Information

When you visit our Website, technical information may be processed to deliver and secure the Website, including:

• IP address and connection information.
• Browser, device and operating system information.
• Requested pages, timestamps and technical logs.
• Information relating to website security and suspicious traffic.

The Website is hosted using services provided by STRATO and uses Cloudflare for DNS and security proxy services.

The processing of technical information depends on the services used and their configuration.

2.6 Email Signups

We may offer a form through which you can subscribe to updates about sAssist Shopping List, including launch announcements and product news.

If you subscribe, we collect your email address and use it to send the communications you requested.

Our planned email marketing infrastructure uses Mautic, a self-hosted email marketing platform. Until this integration is implemented, the actual service used to collect and manage signups may differ.

You can unsubscribe from marketing emails at any time using the unsubscribe link provided in the message or by contacting us at info@altnitro.com.

We do not sell email subscriber lists.

3. Why We Process Your Information

We process personal data only where we have an applicable legal basis.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

4. Cookies and Website Analytics

Our Website uses Google Analytics 4 (GA4) to understand how visitors interact with the Website and to help us improve its content and functionality.

GA4 may process information such as page views, interactions, browser and device information, approximate location derived from technical information, and online identifiers.

We use a cookie consent mechanism to manage non-essential cookies and similar technologies.

Where consent is required, non-essential analytics technologies should not be activated before you provide valid consent. You should be able to reject non-essential cookies as well as accept them, and change your preferences later.

You can also manage cookies through your browser settings. Blocking certain cookies may affect website functionality.

Cloudflare is used for DNS and security proxy services. Depending on the configuration, Cloudflare may process technical connection information to route traffic and protect the Website against malicious activity.

We do not currently use Meta Pixel or Facebook Pixel for advertising tracking. If we introduce advertising pixels or additional tracking technologies in the future, we will update this Privacy Policy and implement any required consent mechanisms before activating them.

5. Third-Party Service Providers

We use third-party providers to operate and maintain the App and Website.

These providers may process personal data on our behalf or, depending on the service, determine certain processing purposes independently.

Google Firebase and Google services

Firebase provides backend and app functionality, including cloud services, analytics and remote push notifications where enabled.

Google may process relevant technical and usage information in connection with these services. The exact services and data involved depend on our implementation.

Google privacy information: https://policies.google.com/privacy

Firebase privacy information: https://firebase.google.com/support/privacy

Google Analytics 4

GA4 helps us understand Website usage and improve the user experience.

Google privacy information: https://policies.google.com/privacy

Cloudflare

Cloudflare provides DNS and security proxy services to help route and protect Website traffic.

Cloudflare privacy information: https://www.cloudflare.com/privacypolicy/

STRATO

STRATO provides Website hosting and may process technical information required to deliver and maintain the Website.

STRATO privacy information: https://www.strato.com/

Apple

Apple processes information relating to App distribution, Apple account services and in-app purchases.

If you subscribe to Plus through Apple's in-app purchase system, Apple handles the purchase transaction under its applicable terms and privacy practices. We may receive subscription status and related transaction information needed to provide your purchased features.

Apple privacy information: https://www.apple.com/legal/privacy/

Mautic

We plan to use a self-hosted Mautic installation to manage email subscriptions and marketing communications.

If implemented, Mautic will be used to store and manage subscriber information, such as email addresses, and send requested communications. Its hosting environment and any associated service providers will be determined by our implementation.

Mautic is a planned integration and should not be interpreted as an active service until it has been deployed.

We do not currently intend to share personal data with advertising networks for behavioural advertising.

6. International Data Transfers

Some of our service providers may process personal data in countries outside the European Economic Area (EEA).

Where personal data are transferred internationally, we will ensure that the transfer complies with applicable data protection laws. Depending on the circumstances, this may involve an adequacy decision adopted by the European Commission, Standard Contractual Clauses or another lawful transfer mechanism.

For further information about relevant safeguards, contact us at info@altnitro.com.

7. How Long We Keep Your Data

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, subject to applicable legal requirements.

In general:

• Account information: retained while your account is active and for a reasonable period afterwards where necessary for security, legal compliance or dispute resolution.
• Shopping lists: retained in cloud storage while needed to provide the service, subject to deletion requests and applicable retention requirements.
• Analytics information: retained according to the applicable analytics configuration and retention settings.
• Technical and security logs: retained for a period appropriate to security, troubleshooting and operational requirements.
• Email subscribers: retained until you unsubscribe or the information is no longer needed for the purpose for which it was collected, subject to necessary suppression records and legal obligations.
• Subscription and transaction records: retained as necessary to manage subscriptions, address disputes and comply with financial or legal obligations.

Specific retention periods depend on the type of information and the service involved. Where appropriate, data will be deleted or anonymised when it is no longer required.

8. Account Deletion and Your Data Rights

Under applicable data protection law, you may have the right to:

• Request access to your personal data.
• Request correction of inaccurate or incomplete information.
• Request deletion of your personal data.
• Request restriction of processing.
• Object to processing based on legitimate interests.
• Receive certain personal data in a portable format.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with a competent data protection supervisory authority.

To exercise these rights, contact info@altnitro.com. We may need to verify your identity before responding.

We will respond within the time limits required by applicable law. Some information may need to be retained where we have a lawful obligation or other valid legal basis to do so.

Deleting your account does not necessarily cancel an Apple subscription. You should manage or cancel subscriptions separately through your Apple account.

Account deletion: We intend to provide a process for users to delete their accounts and associated personal data. The availability and exact operation of this feature depend on the current App implementation. Please contact us if you need assistance.

9. Security

We use appropriate technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, secure connections, service-provider security features and appropriate operational safeguards.

No method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we take reasonable steps to protect the information entrusted to us.

10. Children's Privacy

sAssist Shopping List is intended for users aged 13 and older.

We do not knowingly seek to collect personal data from children below the permitted age for using the service. Where parental authorisation is required by applicable law, we will comply with the relevant requirements.

The age at which a child can independently consent to the processing of personal data for online services varies under EU law. If you believe that a child has provided personal data in circumstances where this was not permitted, contact info@altnitro.com so that we can review the situation.

11. No Sale of Personal Data

We do not sell personal data.

We use service providers to operate the App and Website, deliver functionality, secure our systems, measure usage where permitted, and manage communications.

We do not currently intend to share personal data with advertising networks for targeted advertising. Any future introduction of advertising or tracking technologies will be assessed for compliance with applicable privacy and consent requirements.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the App, Website, our service providers, applicable law or our data processing practices.

The latest version will be published on our Website with its updated date. Where required by law, we will notify users of material changes or obtain additional consent.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact:

Altnitro Ltd Email: info@altnitro.com

You may also lodge a complaint with the competent data protection supervisory authority in your country of residence, place of work or the place of the alleged infringement.

For Cyprus, the relevant authority is the Office of the Commissioner for Personal Data Protection:

Website: https://www.dataprotection.gov.cy/