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PRIVACY POLICY — CITY MONKEY MOBILE APPLICATION

USABILITYLAB s.r.o. ("Company", "we", "us"), IČO 05334942, registered at Lidická 450/35, Drahovice, 360 01 Karlovy Vary, Czech Republic, is the data controller for personal data processed through the City Monkey mobile application ("Application"). By installing or using the Application you ("User", "you") confirm that you have read and understood this Privacy Policy ("Policy").

1. KEY TERMS

• Personal Data — information that can identify or be linked to an individual.

• Processing — any action performed on Personal Data (collection, storage, deletion, etc.).

• GDPR — General Data Protection Regulation (EU) 2016/679.

2. DATA WE COLLECT

• Identity and contact: Google account name and email address.

• Transactions: purchase IDs, payment status, purchase history.

• Usage metrics: screen taps, feature use statistics, crash logs.

• Location: GPS data only when you enable location services.

• Device specs: model, operating‑system version, unique device identifiers.

3. WHY WE USE YOUR DATA (LEGAL BASIS IN BRACKETS)

3.1 Run core app functions [Article 6(1)(b)].

3.2 Handle payments and unlock premium content [Article 6(1)(b)].

3.3 Respond to support requests [Article 6(1)(b)].

3.4 Improve performance and troubleshoot [Article 6(1)(f)].

3.5 Prevent fraud and enforce our Terms [Article 6(1)(f)].

3.6 Fulfil legal duties, for example tax records [Article 6(1)(c)].

3.7 Promote our own similar services with opt‑out [Article 6(1)(f)].

Opt‑out mechanism: Turn off marketing in Settings ➔ Notifications or click "unsubscribe" in any marketing email. Your preference is applied instantly.

4. DATA SOURCES

We obtain data directly from you or generate it automatically while you use the Application. We do not purchase data from third parties.

5. WHO SEES YOUR DATA

We never sell Personal Data. We share it only with:

• Processors: Google Play Billing, EU‑based hosting, each bound by Article 28 GDPR contracts.

• Public authorities when required by law.

• Professional advisers such as lawyers, auditors, and insurers, under confidentiality agreements.

A live list of processors is published at https://citymonkey.app/subprocessors.

6. INTERNATIONAL TRANSFERS

Our primary servers are in the European Union. If data moves outside the EEA, we rely on an adequacy decision or on Standard Contractual Clauses (Articles 45–46 GDPR).

7. RETENTION PERIODS

We keep Personal Data only as long as needed for the purposes above or for mandatory retention (for example, ten years under Czech tax law). Afterwards, data is securely deleted or anonymised.

8. SAFEGUARDS

Security measures include TLS encryption, strict access controls, and periodic security audits.

9. MINORS

The Application targets users 16 years and older. We do not knowingly collect data from children under 16.

10. YOUR RIGHTS UNDER GDPR

You can request access, rectification, erasure, restriction, portability, objection, or withdrawal of consent. Submit requests to info.citymonkey@gmail.com. We answer within one month. For complex cases we may extend this by up to two additional months and will inform you.

11. AUTOMATED DECISION‑MAKING

We do not use automated decisions or profiling that have legal or similarly significant effects (Article 22 GDPR).

12. THIRD‑PARTY SDKS

• Google Play Services — login and purchases — https://policies.google.com/privacy

• Leaflet Maps — maps and geolocation — https://leafletjs.com/privacy.html

These providers may collect device identifiers, usage metrics, or location data under their own policies.

13. ACCOUNT DELETION

Send a request to info.citymonkey@gmail.com. Verified accounts are erased within one month unless retention is legally required.

14. DATA BREACH PROCEDURE

If a breach risks your rights or freedoms, we will notify the Czech Data Protection Authority and, where required, affected users without undue delay.

15. COMPLAINTS

You may contact the Czech Data Protection Authority (ÚOOÚ, Pplk. Sochora 27, 170 00 Prague 7) or your local authority.

16. GOVERNING LAW

This Policy is governed by Czech law. Disputes fall under Czech courts, subject to mandatory GDPR rules.

17. POLICY UPDATES

We may revise this Policy at any time. The latest version is always at https://citymonkey.app/policy and takes effect on publication. Continued app use equals acceptance. For major changes we may provide extra notice in‑app or by email.

18. LANGUAGE

English is the controlling language. Translations are courtesy copies only. If inconsistencies arise, the English version prevails.

Last updated: 7 May 2025

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