Privacy policy

1. Who is responsible

The controller of any personal data described here is Triste media s. r. o., SNP 819/15, 078 01 Sečovce, Slovakia, company ID 52326632, Tax ID 2120977705, registered in the Commercial Register of the Municipal Court Košice, section Sro, insert 46081/V. You can reach us at [email protected].

We have not appointed a data protection officer. The processing described in this policy does not meet the conditions in Article 37 of the General Data Protection Regulation that would require one, because there is no large scale processing, no systematic monitoring and no special category data.

2. What the app does on the device

Ashore plays sound through the speaker and, on one screen, listens through the microphone. Everything it computes is computed on the phone. There is no server that belongs to us, no account to create, no sign-in, no cloud sync and no user profile. A proposal that needed any of those would be a change to how this product is built, not a feature we could add quietly.

Cleaning works with no network connection at all and asks for no permission of any kind.

3. The microphone

The sound level screen uses the microphone. Nothing else in the app does.

Ashore asks you before it asks the operating system. Its own request names the permission and says what the screen does with it, and offers two actions: continue to the system prompt, or close. Closing makes no system request and changes nothing.

While that screen is measuring, each block of audio is reduced in memory to a single loudness value and the audio itself is discarded immediately. No audio is recorded, no audio is written to a file, no audio is transmitted, and no speech is processed or recognised. When you stop measuring, or leave the screen, the recorder is disconnected and the audio session is deactivated.

The legal basis is your consent under Article 6(1)(a). You can withdraw it at any time in the operating system settings for Ashore, and the rest of the app carries on working.

4. Notifications

Ashore may ask whether you want a few messages about the paid capabilities of the full version: the speaker test, the tone generator and the sound level. They are promotional. If you agree, there are at most four, never at night, and they stop as soon as you buy. They are scheduled by the operating system on your own device. Ashore has no push service, holds no device token, and sends nothing to any notification provider. Turning them off in the app or in system settings ends them.

The legal basis is your consent under Article 6(1)(a).

5. Purchases

If you buy the full version, the payment is taken and processed by Apple or by Google, not by us. We never see your card details, your name, your email address or your billing address, and no such data is sent to us at any point.

To know whether a purchase is active, the app uses RevenueCat, Inc., 1032 E Brandon Blvd #3003, Brandon, Florida, United States, acting as our processor under a data processing agreement. When the app starts and when you buy or restore, RevenueCat receives:

• the purchase and receipt information the store issues;
• an anonymous identifier that the app generates on your device;
• on iPhone, the identifier for vendor, a device identifier that Apple gives each app publisher and that is different for every publisher;
• the device model, the operating system and app version, your preferred languages and the country of your store account;
• your IP address, which every connection over the internet carries.

None of this is linked to a name or an account, because there is none. The app sends RevenueCat no name, no email address and no custom attributes, and neither RevenueCat nor we use any of it to track you or to advertise to you.

We use it for two things: to unlock the paid capabilities you bought, and to see aggregate purchase figures, such as how many people chose each option, in RevenueCat's dashboard.

This involves a transfer of data to the United States. It takes place under the European Commission's standard contractual clauses, incorporated into that agreement.

The legal basis for checking a purchase is performance of a contract under Article 6(1)(b): without this check the paid capabilities cannot be unlocked. The legal basis for the aggregate figures is our legitimate interest under Article 6(1)(f) in understanding which options people buy.

RevenueCat is the only third party the app contacts, and nothing else in the app connects to the network.

6. What is stored on your device

Ashore keeps ten values in its own storage on the phone. This is the complete list, and none of it is transmitted anywhere.

• onboarding.seen - whether you have been through the introduction.
• entitlement.lastKnownActive - the last known purchase state, so that opening the app without a connection neither revokes nor grants access.
• notify.presentations - how many times the app has asked about notifications.
• notify.lastPresentedAt - when it last asked, so that it waits fourteen days before asking again.
• notify.sent - how many notifications have already been sent, so that the app keeps to its own limit.
• notify.lastRunAt - when your most recent cleaning run was, which is what the notification schedule is measured from.
• notify.enabled - your notification switch in settings.
• rate.asked - whether the app has already asked you to rate it, so that it never asks twice.
• offering.lastSkus - the prices the store last showed, so that the purchase screen can show them without a connection.
• rate.given - whether you gave a rating, which declining the ask is not.

None of these identifies you. Apart from the single timestamp above, which the notification schedule needs, there is no record of your cleaning runs, no usage log and no history of any kind. The purchase software described in section 5 keeps its own anonymous identifier on the device as well, and that is the whole of what anything else stores. Deleting the app deletes all of it.

7. What Ashore does not do

• No analytics and no profiling of any person.
• No advertising. There is no advertising software in the app and no code path that could show one.
• No tracking, no advertising identifier, and no App Tracking Transparency prompt, because there is nothing it could ask for.
• No sale of personal data and no sharing of personal data for advertising.
• No location data. Ashore neither requests nor uses your location.
• No contacts, no photos, no calendar, no health data, no files.
• No consent management platform, because there is no advertising consent to collect.

8. How long anything is kept

The ten values above stay on your phone for as long as the app is installed and are removed when you delete it. Purchase records are kept by Apple or Google and by RevenueCat for as long as the store requires and for as long as we need to honour and account for the purchase. Audio is kept for no time at all: it is turned into a number and discarded in the same moment.

9. Your rights

Where the General Data Protection Regulation applies to you, you have the right to access your personal data, to have it corrected or erased, to restrict or object to its processing, to data portability, and to withdraw consent at any time without affecting processing that already happened.

There is a practical limit worth stating plainly rather than burying. Because Ashore holds no account and no identifier for you, we usually cannot connect a request to a person, and Article 11 of the Regulation applies: we are not required to obtain extra data purely in order to identify you. If your request concerns a purchase, tell us the store, the approximate date and the receipt or order number, and we can act on it.

You may also complain to a supervisory authority. In Slovakia that is the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava, dataprotection.gov.sk. You can also complain to the authority where you live or work.

10. California residents

Under the California Consumer Privacy Act as amended, we do not sell personal information and we do not share it for cross-context behavioural advertising. We have not done so in the preceding twelve months. The only personal information the app itself causes to be collected is the purchase check described in section 5, which is used to provide the full version and not for advertising. Exercising your rights will never lead to worse treatment, and there is no financial incentive attached to your data because there is no programme that uses it.

11. Children

Ashore is a utility for a phone owner and is not directed at children. It asks no one for their age or identity and holds no profile of anyone; the only data that leaves the device is the purchase check in section 5. The app contains no age gate, because it has nothing to gate: there is no profile, no account and no content addressed to a person.

12. This website

This site sets no cookies, runs no analytics and loads nothing from another domain: the typeface, every image and every script are served from here. Nothing on it profiles you and there is no consent banner because there is no consent to ask for.

The site is delivered through Cloudflare, Inc., 101 Townsend Street, San Francisco, California, United States, which acts as our processor for content delivery and protection against attacks, and is hosted by our hosting provider. Both process your IP address, the page requested, the time and your browser identification, for the technical operation and security of the site. Cloudflare's processing involves a transfer to the United States, under the EU-US Data Privacy Framework and the European Commission's standard contractual clauses. The legal basis is our legitimate interest under Article 6(1)(f) in keeping the site running and secure. These logs are kept for a short period and are not used to build any profile.

13. Changes and contact

If this policy changes, the date at the top changes with it, and a change that affects you materially will be announced in the app. Questions about anything here go to [email protected].