Privacy Policy

1. Introduction

[APP_NAME] is a lightweight TV remote control application for Garmin smartwatches and Apple Watch. The app is designed to minimize data collection and prioritize your privacy. This policy explains what limited data we collect and how it's used.

Questions? Contact us at teitfoens@gmail.com.

2. What Data We Collect

Minimal Personal Data

[APP_NAME] is designed to be privacy-first. We collect very little personal information:

• Email address (optional, for app registration and updates)
• Smartwatch device type (Garmin or Apple Watch model)
• Operating system version
• App version and installation status

Functionality Data

• Remote control commands sent (volume, channel, power)
• Paired TV/streaming device model (local storage only)
• Connection logs (frequency of use, duration)

Technical & Diagnostic Data

• App crash reports and error logs
• Performance metrics (response time, connection stability)
• Device identifiers (UUID, watch ID)
• Bluetooth connection status

What We Do NOT Collect

• No location tracking or GPS data
• No TV viewing history or content watched
• No personal browsing data
• No voice recordings or audio data
• No health data from your smartwatch
• No biometric data
• No behavioral tracking across apps

3. How We Use Your Data

• App Functionality: Enabling the remote to function and communicate with your TV
• Device Compatibility: Ensuring the app works with your specific smartwatch model
• Bug Fixes: Analyzing crash reports to improve stability and performance
• Service Improvement: Understanding general usage patterns to enhance features
• Updates & Support: Notifying you about app updates and providing customer support
• Legal Compliance: Responding to legal requests if required

4. Legal Basis for Processing

We process data under these GDPR legal bases:

• Legitimate Interests: App functionality, bug fixes, service improvement
• Consent: Optional email registration for updates
• Legal Obligation: Responding to legal requests

5. Data Retention

• Local Device Data: Stored only on your smartwatch; deleted when you uninstall the app
• Registration Data: Retained while the app is installed; deleted within 30 days of uninstall
• Crash Logs: Retained for 30 days for analysis; then automatically deleted
• Connection Logs: Aggregated and anonymized after 7 days
• Error Reports: Deleted after 90 days or once issue is resolved

6. Local Storage & Offline Operation

[APP_NAME] is designed to work primarily on your smartwatch with minimal cloud dependency:

• Local Pairing: TV/device pairing information is stored locally on your watch
• Offline Control: The app can control your TV via local Bluetooth/Wi-Fi without sending data to our servers
• No Cloud Save: Your preferences and pairings are not backed up to cloud servers by default
• Optional Cloud Sync: If enabled, syncing between devices uses encrypted communication

7. Third Parties & Data Sharing

We share minimal data with:

• Smartwatch Platforms: Apple and Garmin receive device/OS data (per their app store policies)
• Analytics Services: Aggregated, anonymized crash reports (Sentry or similar)
• Hosting Providers: Cloud infrastructure for app updates and error reporting
• Legal Authorities: Only if required by law with proper legal process

We never sell data or share it with advertisers.

8. User Rights (GDPR)

You have the following rights:

• Access: Request a copy of any data we hold
• Deletion: Request deletion of your registration data
• Portability: Receive your data in a portable format
• Objection: Opt-out of analytics and error reporting
• Complaint: File a complaint with your data protection authority

To exercise any right, email teitfoens@gmail.com.

9. Cookies & Tracking

[APP_NAME] is a native app and does not use traditional cookies. However:

• The smartwatch operating system (Garmin Connect, Apple Health) may store app preferences
• Error reporting may include anonymized device identifiers
• You can disable optional analytics in the app settings

10. Security

We protect your data with:

• Local storage encryption on the smartwatch
• TLS/SSL encryption for any data sent to our servers
• Secure Bluetooth pairing protocols
• No passwords stored on the watch (if applicable)
• Regular security audits

11. Children's Privacy

This app is designed for adults and is not intended for children under 13. We do not knowingly collect data from children. If we discover a child has registered, we will delete the data immediately.

12. International Data Transfers

Your data is primarily processed within the EU. If transferred outside the EU/EEA for hosting or analytics, we use Standard Contractual Clauses or other legal mechanisms to ensure protection.

13. No Advertising or Profiling

• No targeted advertising in the app
• No behavioral profiling or tracking
• No selling data to marketers
• No cross-app tracking

14. Policy Changes

We may update this policy periodically. For significant changes, we will notify users via email or in-app notification. Your continued use of the app implies acceptance.

15. Contact Us

For privacy questions or to exercise your rights:

• Email: teitfoens@gmail.com
• Company: Xoens ApS
• Location: Vanløse, Copenhagen, Denmark
• CVR: 46225430

We are committed to responding to privacy inquiries within 30 days.