Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how [Аудиотора- комментарии к недельным главам Торы] ("App," "we," "our," or "us") collects, uses, discloses, and otherwise processes personal information in connection with the Torah audio recording application available on the Google Play Store.

We are committed to protecting your privacy and ensuring you have a positive experience on our App. Please read this Privacy Policy carefully. By downloading, accessing, or using this App, you consent to the practices described in this Policy.

Last Updated: December 9, 2025


2. Information We Collect

2.1 Information You Provide

Content and Preferences:

·       Bookmarks or saved audio portions

·       Playback history and preferences

·       User-generated notes or annotations

·       Language preferences

2.2 Information Automatically Collected

Device Information:

·       Device type and model

·       Operating system and version

·       Unique device identifier (Android Advertising ID)

·       Device settings and configuration

App Usage Information:

·       App features accessed and usage patterns

·       Audio playback statistics (duration, portions accessed)

·       App performance data and crash logs

·       Pages or content viewed within the App

Network Information:

·       IP address

·       Internet connection type (WiFi, mobile data)

·       Approximate location (based on IP address)

Analytics Data:

·       Session duration and frequency of use

·       Time spent on specific content

·       User interaction patterns

·       Referral source

2.3 Information NOT Collected

This App does NOT:

·       Collect biometric data

·       Collect health or fitness information

·       Collect financial or payment information (unless explicitly stated)

·       Require camera or microphone permissions beyond app audio playback

·       Collect contacts or call history

·       Collect files or media library contents


3. How We Use Your Information

We use collected information for the following purposes:

Service Delivery:

·       Providing, maintaining, and improving the App

·       Enabling audio playback and content delivery

·       Managing user accounts and preferences

·       Technical support and customer service

Analytics and Improvement:

·       Understanding user behavior and usage patterns

·       Analyzing app performance and functionality

·       Identifying technical issues and bugs

·       Optimizing content and user experience

Communication:

·       Sending important updates about the App

·       Responding to user inquiries and support requests

·       Notifying users of changes to this Policy or Terms of Service

Legal Compliance:

·       Complying with applicable laws and regulations

·       Enforcing our Terms of Service

·       Protecting against fraud and abuse


4. Third-Party Sharing

4.1 Data Shared with Third Parties

We may share your information with the following categories of third parties:

Analytics and Crash Reporting Services:

·       Google Firebase Analytics

·       Firebase Crashlytics

·       Purpose: App analytics, performance monitoring, and error tracking

·       Data shared: App usage statistics, crash logs, device information

Content Delivery and Hosting:

·       Cloud service providers (hosting, storage, and streaming)

·       Purpose: Delivering audio content reliably

·       Data shared: Minimal usage data necessary for service delivery

Google Play Services:

·       Google Play Store framework

·       Purpose: App distribution and functionality

·       Data shared: Device identifier, analytics data

4.2 Data NOT Shared

We do not:

·       Sell your personal data to third parties

·       Share data with advertising networks for targeted advertising (unless explicitly disclosed)

·       Share data with data brokers

·       Share personally identifiable information without explicit consent (except as required by law)

4.3 Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. Please review their privacy policies before providing personal information.


5. Data Security

5.1 Security Measures

We implement industry-standard security measures to protect your information, including:

·       Encryption of data in transit (HTTPS/TLS)

·       Secure server infrastructure

·       Access controls and authentication

·       Regular security assessments

5.2 Limitations of Security

While we strive to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security. Users access and use the App at their own risk.


6. Data Retention

6.1 Retention Period

We retain your personal information for as long as necessary to provide the App's services and to comply with legal obligations:

Active User Data:

·       Stored while your account remains active

·       Retained for 12 months after your last activity

Analytics and Crash Data:

·       Automatically aggregated and anonymized after 90 days

·       Detailed logs retained for 30 days for debugging purposes

Usage History:

·       Playback history retained for 24 months

·       Can be cleared at any time by the user

6.2 Data Deletion

Users can request deletion of their personal information by contacting us at [your contact email]. We will process deletion requests within 30 days, except where retention is required by law.


7. User Rights and Controls

7.1 Access and Portability

You have the right to:

·       Request access to your personal information

·       Receive a copy of your data in a structured, portable format

·       Request deletion of your information (subject to certain legal exceptions)

7.2 App Settings

Within the App, you can:

·       Clear your playback history and bookmarks

·       Reset your preference settings

·       Opt out of analytics (limited functionality may be affected)

·       Manage permissions through device settings

7.3 Device-Level Controls

You can manage data collection through Android system settings:

·       Disable location services in device settings

·       Reset Android Advertising ID

·       Revoke app permissions through device settings

·       Uninstall the App to prevent further data collection


8. Children's Privacy

This App is designed for educational and religious purposes. We do not knowingly collect personal information from children under 13 years of age without verifiable parental consent.

If we become aware that we have collected information from a child under 13 without parental consent, we will delete such information promptly. Parents who believe their child's information has been collected should contact us immediately.

For users in the EU under GDPR, we comply with requirements for processing information of minors.


9. International Data Transfers

Your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have different data protection laws than your home country.

By using the App, you consent to the transfer of your information to countries outside your country of residence, including countries that may not have the same level of data protection.


10. Your Rights Under Privacy Laws

Depending on your location, you may have additional rights:

10.1 GDPR (European Union)

If you are located in the EU/EEA, you have the right to:

·       Access, rectify, and erase your personal data

·       Restrict processing and data portability

·       Object to processing and withdraw consent

·       File a complaint with your supervisory authority

10.2 CCPA (California)

If you are a California resident, you have the right to:

·       Know what personal information is collected

·       Know whether personal information is sold or shared

·       Delete personal information

·       Opt out of the sale or sharing of personal information

·       Non-discrimination for exercising your rights

10.3 Other Jurisdictions

We comply with applicable privacy laws in your jurisdiction. Please contact us for specific questions about your rights.


11. Policy Updates

We may update this Privacy Policy at any time. Changes will be effective upon posting to the App or our server. Your continued use of the App following notification of changes constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how we protect your information.


12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Developer/Provider: Arseniy Finberg

Email Address: [myshyak@gmail.com]

Mailing Address:
Pryrichna 1, apt .12
Kyiv,04210
Ukraine

Response Time: We will respond to privacy inquiries within 30 days.


13. Entire Agreement

This Privacy Policy, together with the App's Terms of Service, constitutes the entire agreement between you and us regarding privacy and personal information. If any provision of this Policy is found to be unenforceable, the remaining provisions will remain in full force and effect.


14. Governing Law

This Privacy Policy is governed by the laws of Ukraine, without regard to its conflict of law provisions.


Appendix A: Data Safety Form Reference

This Privacy Policy aligns with the information you must provide in Google Play's Data Safety Form:

Data Types Collected:

·       App activity (usage, features accessed)

·       Device or other IDs (device identifier)

·       Approximate location (IP-based)

Data Safety & Security:

·       Data encrypted in transit

·       User can request deletion

·       No third-party sharing for advertising

Sensitive Permissions:

·       Internet connection (essential)

·       Phone state access (if applicable)


Version History:

·       v1.0 - December 9, 2025 - Initial policy creation