Notomo Privacy Policy

1. Who We Are

2. Information We Collect

2.1 Information You Provide

• Account Data: Name, email, profile picture.
• Content: Audio recordings, files, notes, or other content you upload or create.
• Support Requests: Information you provide when contacting support.

2.2 Information We Collect Automatically

• Usage Data: Features used, session duration, device and app information.
• Technical Data: IP address, device type, operating system, error/crash logs.
• Cookies & Similar Technologies: Essential for authentication, security, and improving user experience.

3. How We Use Your Information

We use your data to:

• Provide and maintain the Notomo app.
• Personalize your experience.
• Communicate with you about updates, security, or support.
• Monitor and improve our service (including analytics and debugging).
• Comply with legal obligations.

4. Legal Bases for Processing

We process your data on the following bases:

• Performance of a contract: To provide the Notomo service.
• Legitimate interests: To improve and secure our app.
• Consent: For optional features (you may withdraw at any time).
• Legal obligation: For compliance with laws (e.g., payment records).

6. International Data Transfers

Some providers process data outside the EU. When this happens, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses, GDPR-compliant agreements).

7. Cookies and Tracking

We use only essential cookies:

• Essential Cookies: For authentication, security, and core functionality.

You can manage cookie preferences in your browser settings. Disabling cookies may affect app functionality.

8. Data Retention

• Account Data: Retained while your account is active and up to 5 years after deletion (for legal/accounting).
• Content: Retained until you delete it or your account is closed.
• Analytics/Logs: Retained up to 26 months.
• Payment Records: Retained for 10 years (EU tax law).

9. Your Rights

Under GDPR and applicable law, you have the right to:

• Access your data.
• Correct inaccurate data.
• Delete your data ("right to be forgotten").
• Restrict or object to processing.
• Data portability (receive your data in a portable format).
• Withdraw consent at any time.

To exercise your rights, contact [email protected]. We may need to verify your identity for security.

10. Data Security

We use strong technical and organizational measures to protect your data, including:

• AES-256 encryption at rest.
• TLS encryption in transit.
• Access controls and regular security audits.

11. Changes to This Policy

We may update this Privacy Policy. We will notify you of significant changes via the app or email. The latest version will always be available in the app.

12. Contact Us

For privacy questions or to exercise your rights:

You may also contact the Croatian Data Protection Agency (AZOP) if you have concerns about our data practices.