Privacy Policy

Effective date & last updated: 18 October 2026

TUDORAN TECHNOLOGY & DEVELOPMENT S.R.L. ("Company", "the studio") respects your privacy and is committed to protecting personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation — "GDPR") and applicable Romanian data protection legislation. This Privacy Policy explains how personal data is handled across this website (tudorandev.ro) and all published iOS, iPadOS, and macOS applications.

1. Data Controller Identification

The data controller responsible for processing personal data described in this notice is:
TUDORAN TECHNOLOGY & DEVELOPMENT S.R.L.
Fiscal Registration Code (CUI): 51792746
Trade Register Number (Nr. Reg. Com.): J2025034640000
Sediu social: Jud. Brașov, Municipiul Brașov, Str. Nicolae Iorga, Nr. 1, Oficiul Poștal Brașov 1, CP 8, România
Email: [email protected]
Telephone: +40 746 989 473

2. Purposes of Processing, Categories of Data & Legal Bases

The software is designed from the ground up to minimize data collection. Below is a breakdown of the specific situations in which data may be processed, the categories of data involved, and the applicable legal basis under Article 6 of the GDPR:

2.1 Customer Support & Direct Inquiries

• Data Processed: Your email address, telephone number (if calling by phone), name or alias, the content of your inquiry, and any screenshots or diagnostic logs voluntarily attached.
• Purpose: Responding to questions, troubleshooting technical issues, processing consumer requests, and improving application quality.
• Legal Basis: Performance of a contract or taking steps at your request prior to entering into a contract (Article 6(1)(b) GDPR), the legitimate interest in providing effective customer support (Article 6(1)(f) GDPR), and compliance with legal obligations regarding consumer and statutory requests (Article 6(1)(c) GDPR).

2.2 Website Delivery & Security Logs (tudorandev.ro)

• Data Processed: Standard HTTP connection metadata processed automatically when your browser requests a page, including IP address, date and time of request, requested URL, HTTP status code, and browser user-agent string.
• Purpose: Delivering static website content reliably, mitigating distributed denial-of-service (DDoS) attacks, and maintaining infrastructure security.
• Legal Basis: Legitimate interest in operating a secure, resilient website (Article 6(1)(f) GDPR).
• Cookies & Tracking Technologies (Law no. 506/2004): This website is a static informational portal and does not set non-essential analytics, behavioral advertising, or cross-site tracking cookies.

2.3 On-Device & iCloud Application Data

• Local On-Device Storage: By default, user-generated content and preferences created inside iOS, iPadOS, and macOS applications are stored locally on your Apple device. There is no technical access to local data stored on your device.
• Apple iCloud Synchronization (Where Applicable): Where an application offers cross-device synchronization, it uses Apple's native CloudKit framework to store data inside your personal, private iCloud database associated with your Apple Account. That data is transmitted directly between your devices and Apple's iCloud infrastructure; no intermediary servers operate to access your private iCloud database. If any future application feature requires shared/public containers or custom server-side processing, that architecture and its specific legal basis will be disclosed in the application's dedicated privacy notice and App Store Privacy Nutrition Label prior to use.

2.4 In-App Purchases & Subscriptions

• Data Processed: Cryptographic transaction receipts and subscription entitlement status provided on-device via Apple's StoreKit framework. Payment card numbers, bank account details, or billing addresses are never received or stored by the studio.
• Purpose: Validating purchase entitlements and unlocking licensed features inside the applications.
• Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).

2.5 Crash Reports & Diagnostic Metrics

• Data Processed: If you explicitly choose to enable "Share With App Developers" in your Apple device privacy settings, Apple collects and provides crash logs and diagnostic reports (such as stack traces, application version, operating system version, and device hardware model). Although these reports do not contain your name, email address, or Apple Account identifier, technical diagnostic data may constitute pseudonymized data under the GDPR.
• Purpose: Diagnosing software crashes, resolving bugs, and optimizing application performance.
• Legal Basis: Your consent configured in your device operating system settings (Article 6(1)(a) GDPR) and the legitimate interest in ensuring software stability (Article 6(1)(f) GDPR). You may withdraw this consent at any time in your iOS/macOS Privacy & Security settings.

3. Recipients & Data Processors

Personal data is never sold, rented, or traded to third parties or data brokers. Personal data is shared only with the following categories of service providers acting as processors or independent controllers where strictly necessary:

• Cloudflare, Inc. — Provides DNS resolution, content delivery network (CDN), and static web hosting infrastructure for tudorandev.ro.
• Apple Inc. / Apple Distribution International Ltd. — Provides App Store software distribution, in-app purchase processing (StoreKit), optional device crash reporting, user-controlled CloudKit storage, and Apple iCloud+ email hosting for the official support address ([email protected]).
• Public Authorities & Legal Advisors: Where disclosure is required by mandatory Romanian or European Union law (such as fiscal or consumer protection authorities).

4. International Data Transfers

While TUDORAN TECHNOLOGY & DEVELOPMENT S.R.L. is established in Romania (European Economic Area), external infrastructure providers (Cloudflare and Apple) operate globally distributed networks and may process technical or support communications on servers located outside the EEA, including in the United States.

Where personal data is transferred outside the EEA, such transfers are protected by appropriate safeguards in accordance with Chapter V of the GDPR, specifically:

• European Commission Adequacy Decisions pursuant to Article 45 GDPR (including the EU–U.S. Data Privacy Framework for certified U.S. entities); and/or
• Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to Article 46(2)(c) GDPR incorporated into the providers' applicable Data Processing Addenda.

5. Data Retention Periods

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected:

• Customer Support Communications: Support emails and related correspondence are retained for the time needed to resolve your request and for up to 3 years thereafter (corresponding to the general statutory limitation period under Romanian civil law) to maintain context for follow-up support or address potential legal claims, unless earlier deletion is requested and no statutory retention duty applies.
• Website Security & Edge Logs: Processed transiently by Cloudflare in accordance with standard security and operational log-rotation periods.
• Statutory & Accounting Records: If any direct commercial or accounting documentation is generated outside Apple's standard App Store settlement flow, fiscal records are retained for the periods mandated by Romanian accounting and tax law (generally 5 to 10 years).
• On-Device & iCloud App Data: Remains under your control and is retained until you delete the data within the app, uninstall the app, or remove the application's data from your personal iCloud settings.

6. Your Rights Under the GDPR

Under Articles 15–22 of the GDPR, you have the following rights regarding your personal data, subject to the conditions set out in applicable law:

• Right of Access (Art. 15): Obtain confirmation as to whether personal data is processed and receive a copy of that data.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to Erasure (Art. 17): Request deletion of your personal data (e.g., support email history) where there is no overriding legal obligation to retain it.
• Right to Restriction of Processing (Art. 18): Request the restriction of processing under specific statutory circumstances.
• Right to Data Portability (Art. 20): Receive personal data previously provided in a structured, commonly used, machine-readable format where processing is based on consent or contract.
• Right to Object (Art. 21): Object at any time, on grounds relating to your particular situation, to processing based on legitimate interests (Article 6(1)(f) GDPR).
• Right to Withdraw Consent (Art. 7(3)): Where processing relies on your consent, withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please send an inquiry to [email protected]. Verifiable requests receive a response within one month in accordance with Article 12(3) GDPR.

7. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right under Article 77 GDPR to lodge a complaint with a data protection supervisory authority—in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement. In Romania, the competent supervisory authority is:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
Address: B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, cod poștal 010336, București, România
Website: www.dataprotection.ro

8. Mandatory vs. Optional Data & Automated Decision-Making

• Provision of Data: Browsing this website and using the applications does not require providing personal contact details directly. When contacting customer support, providing an email address and description of the issue is necessary to reply and resolve the inquiry; without this information, responding to the request is not possible.
• No Automated Decision-Making: Personal data is not used for automated decision-making or profiling producing legal or similarly significant effects within the meaning of Article 22 GDPR.

9. Updates to This Policy & App-Specific Disclosures

This Privacy Policy may be updated to reflect new applications, technical changes, or legal requirements. The current version and effective date are always displayed at the top of this page. In addition to this general Privacy Policy, each published application's specific data practices are summarized in its App Store Privacy Nutrition Label and product page.