Privacy Policy

1. Controller and contact

The controller of personal data processed in connection with Zuqelio is Marek Kondziela, ul. Popieluszki 29, 45-601 Opole, Polska. Privacy contact: markonopole@gmail.com.

This policy applies to the Zuqelio app offered in the European Union, the United States and Canada.

2. Guest mode and local data

Core features work without an account. Checklist progress, settings, the ICE card, family emergency plan and a local copy of Pro status are stored in the app storage on the device.

Zuqelio does not send the ICE card, family emergency plan or checklist progress to the controller’s servers. This information may nevertheless be included in an operating-system backup if the user has enabled backups with Apple or Google.

At the user’s explicit request, the app can create a PDF or an encrypted .zuqelio package. Files are created locally, and the user selects the destination app or device through the system share sheet. Zuqelio receives neither the file nor its password. Protection after sharing depends on the selected channel and recipient.

The ICE card may contain health and emergency-contact information entered at the user’s discretion. It is not protected by a separate Zuqelio password, so users should secure their phone with a screen lock.

3. Zuqelio account

Creating an account is optional. Firebase Authentication processes the email address, profile name, UID, email-verification status and technical authentication data required for sign-in, security and password resets.

For users in the EU, processing is based on performing the agreement or taking steps requested by the user and on the legitimate interest in account security and support.

4. Location and camera

Location is obtained after the user opens the GPS tool or map and grants system permission. The current position is not sent to the controller’s server. Named markers are stored locally on the device.

When a map is displayed, the default provider OpenFreeMap or another provider configured by the publisher receives technical tile requests, including the IP address and approximate area being viewed. The current provider is identified in Third-Party Services and Licences.

Camera access is used only to control the LED for the flashlight and SOS signal. Zuqelio does not take or save photographs and does not record audio.

5. Purchases and Zuqelio Pro

Purchases are processed by Apple App Store or Google Play. In a version with the RevenueCat service enabled, the app checks the offer and Pro status at startup, including in guest mode and before a purchase. RevenueCat processes a pseudonymous guest identifier or the Firebase account UID and technical request data. Using the app without an account does not mean that it makes no connections to the purchase service.

When purchasing or restoring Pro, RevenueCat also processes the product identifier, entitlement status, transaction data and receipt information. These data support Pro verification and restoration, fraud prevention and purchase reporting in the RevenueCat dashboard. Signing in may link the guest profile to the UID, so a pseudonymous identifier is not fully anonymised.

Zuqelio does not send an email address or profile name to RevenueCat as customer attributes. It does not request advertising-identifier collection and disables automatic collection for advertising attribution. It does not use these data for advertising or tracking across apps.

Neither Zuqelio nor RevenueCat receives the full payment-card number. Payment details remain under the control of the relevant store.

6. Recipients and international transfers

Providers may process data outside the user’s country, including in the United States. For EU data, transfers rely on mechanisms made available by the providers and applicable law, such as adequacy decisions or standard contractual clauses.

• Google/Firebase — authentication, account security and the private data-deletion request queue;
• RevenueCat — purchase-profile identification from startup in a version with the service enabled, Pro verification and restoration, and purchase reporting;
• map provider — delivery of online map styles and tiles;
• Apple or Google Play — app distribution, payments, refunds and purchase history;
• infrastructure providers and advisers only where needed for support or legal obligations.

7. Retention

• local data — until deleted in the app, the app is uninstalled or app data is cleared in the operating system;
• Firebase account — until the user deletes it, subject to provider backups and security logs;
• purchase status and records — as required to restore purchases, prevent fraud and meet legal obligations;
• support correspondence — for up to 24 months after closure, unless longer retention is required to establish, exercise or defend legal claims.

8. User rights

Depending on where the user lives, they may request access, correction, deletion, restriction, portability, withdrawal of consent or objection. Requests can be sent to markonopole@gmail.com. We may request reasonable identity verification.

EU users may complain to their competent supervisory authority; in Poland this is the President of the Personal Data Protection Office. Canadian users may contact the Office of the Privacy Commissioner of Canada or the competent provincial authority.

9. Notice for United States users

Zuqelio does not sell personal information or share it for cross-context behavioural advertising. It contains no advertising and does not track users across apps. Residents of states granting relevant rights may request information, correction and deletion without discrimination for exercising those rights.

10. Children

Zuqelio is not directed to children under 13. An account may be created only by a person aged 16 or older. Younger users may use guest mode under a parent’s or guardian’s supervision without providing account information to the controller.

11. Security and policy changes

We use data minimisation, encrypted provider connections and access restrictions. No protection method can guarantee complete security.

Material policy changes will be communicated in the app or by email where required. The effective date and version appear at the beginning of this document.

12. Data-deletion requests

Firebase Firestore is used solely for a private data-deletion request queue: UID, email, language, time, source, status and schema version. Its database is located in europe-west3 (Frankfurt). It does not synchronise plans or store family data. In the EU the basis is fulfilling data-subject rights obligations and securing request handling.

The publisher and authorised administrators can access the queue; a signed-in user can create and read only their own request. We delete the entry after completing the case and sending confirmation. Account deletion is immediate after confirmed request storage, whereas associated RevenueCat erasure is handled manually, normally within one month. See “Account and Data Deletion” for copies, timeframes, exceptions and request methods.