Privacy Policy

Last updated: 12 September 2026

1. Who we are and scope

Osavus Technology Ltd, registered in Estonia as Osavus Technology OÜ ("Osavus", "we" or "us"), is the controller of the personal data we handle as described below.

Registry code 12514773 · Estonian Business Register
Narva mnt 5, 10117 Tallinn, Estonia
Privacy contact: app@osavus.com

This policy covers our company website and the applications, games and related services that link to it. A service supplied with its own privacy policy is covered by that policy. Additional information shown within a feature explains any specific handling relevant to that feature.

At the date above, our released apps do not use Osavus user accounts or store users' app content on Osavus servers. Website delivery and messages you send us still involve personal data, as explained below.

2. Data on your device

Local features process the content you enter or create, your progress and your settings on your device. Using those features does not send that content to us. We do not have remote access to your local app data.

You control local data through the app, your device's settings and any exports or backups you create. Device or cloud backups you enable are handled by the backup provider. Removing an app may leave exported files or backups behind.

If you choose a feature that connects to an external service, the information sent and the recipient must be explained before you use it. A device permission alone is not consent to upload your content. Declining an optional connection may prevent that connected feature from working, but does not authorise other uses of your information.

3. Website visits

Our company website is hosted using Microsoft Azure. To deliver a page or file, the hosting infrastructure processes your IP address and technical request information, such as the requested address, time, browser information and response status. This information is used to deliver and protect the website and investigate technical problems. Our legal basis is our legitimate interest in operating a reliable, secure website.

We do not add advertising trackers, visitor analytics, tracking pixels or session-recording tools to this website. Its pages do not set cookies or use browser storage to track you. Fonts and artwork are served with the site. Pointer movement used by the animations is processed temporarily in your browser and is not recorded or transmitted to us.

Following a link to another website or an app store sends a request to that destination. Its operator handles the visit under its own privacy policy.

4. Contact and support

When you contact us, we receive your email address or other contact details, your message, its delivery metadata (such as sender, recipient and date), and any attachments or technical information you choose to provide. We use them to reply, investigate the issue and keep track of the request. Please send only what is necessary; we do not need your passwords or a complete copy of your app data.

General enquiries and voluntary feedback are handled on the basis of our legitimate interest in communicating with you and supporting our work. Support necessary to provide a service you have contracted for is processed to perform that contract. Handling statutory privacy requests, consumer complaints or required business records relies on the relevant legal obligation.

You choose whether to contact us and what to include. We may be unable to answer or resolve an issue without the information needed to understand it. We do not add support contacts to a marketing mailing list.

5. Providers and sharing

We do not sell personal data or share it for targeted advertising. Access is limited to what is needed for the following purposes:

• Website hosting and delivery. Microsoft Azure processes the technical requests described above.
• Email and business administration. Our email service providers process correspondence to deliver and store messages. Microsoft handles incoming mail delivery for our domain. Professional advisers may receive relevant records when needed for accounting, compliance or a legal matter.
• App stores and external services you use. A store handles downloads, store accounts, reviews and any purchases under its own terms. We do not receive your full payment-card details. If you send us a receipt for support, we use it to handle that request. An external service you choose through an app handles the information described in that feature's notice.
• Legal requirements and claims. We may disclose relevant information to a competent authority where legally required, or where necessary to establish, exercise or defend a legal claim. A disclosure for a legal claim relies on our legitimate interest in protecting our legal rights.

Providers processing personal data on our behalf are required to protect it and use it only for the agreed services, under applicable data-protection obligations. Providers acting independently are responsible for their own processing. See Microsoft's Privacy Statement, Google's Privacy Policy and Apple's Privacy Policy for their respective services.

6. International processing

We are established in the European Economic Area (EEA). Our website uses an Azure resource in the United States, with content delivered through Microsoft's infrastructure. Hosting and email delivery can involve processing outside the EEA, including in the United States.

For Microsoft's hosting and email-delivery services, transfers outside the EEA are covered by its implemented standard contractual clauses and other applicable safeguards described in its Data Protection Addendum. Contact app@osavus.com for information about a transfer involving your data or a copy of the applicable safeguards.

7. Retention and security

We keep personal data only while it is needed for the purpose for which it was obtained or to meet a legal requirement. The criteria differ by type of information:

• Local app content: it remains on your device or in backups you control until you remove it. We hold no server copy of that local content.
• Support correspondence: while the request is being handled and for the follow-up needed to resolve it. Records relevant to a complaint or dispute are retained while that matter remains open and for any applicable legal-claims period.
• Technical records: we do not maintain a separate visitor analytics database or export website access logs. Microsoft processes technical service records to operate, troubleshoot and secure its infrastructure. Retention depends on the record's purpose and sensitivity, operational need, and legal or contractual requirements, as explained in Microsoft's retention information. We can help direct requests about those records to Microsoft.
• Legally required records: for the period required by the relevant law. This applies to information needed for accounting, consumer obligations or demonstrating how a privacy request was handled.

When information is no longer needed, it is deleted or anonymised. Deleted correspondence may remain in service-provider backups until those backups are rotated under the provider's retention process. If a deletion request affects retained records or backups, we explain the applicable reason and retention arrangements in our response.

We use technical and organisational measures appropriate to the information and the risk, including access restrictions and secure service connections. No system guarantees absolute security. Keep your devices and backups secure, and avoid sending sensitive information that is not needed for a support request.

8. Your rights and deletion

Under applicable data-protection law, you can request access to your personal data, correction of inaccurate information, erasure, restriction of processing and, where applicable, a portable copy. You can object to processing based on legitimate interests. Where processing relies on consent, you can withdraw it at any time without affecting the lawfulness of earlier processing.

We do not use the processing described in this policy to make solely automated decisions that have legal or similarly significant effects on you.

Request deletion or exercise another privacy right: email app@osavus.com. Tell us which service or correspondence your request concerns. Use the email address you previously contacted us from where possible, and do not send a password. We ask for further identity information only where reasonably necessary.

There are currently no Osavus app accounts to delete. You can delete local app data directly without contacting us. We can handle requests for information we hold, such as support correspondence, but cannot remotely erase files on your device or copies held by a provider you use independently.

We respond without undue delay and normally within one month. If a lawful extension is needed because of the complexity or number of requests, we explain it within that first month. If we cannot fulfil a request in full, we explain the reason and your options.

You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the supervisory authority in your place of habitual residence, work or the alleged infringement.

9. Children

Product age ratings and eligibility requirements apply to the relevant service. Local-only app use does not require a child to create an Osavus account or send us personal content. If you believe a child has sent us personal information that should be removed, contact app@osavus.com so we can investigate and take appropriate action. Any feature that requires parental consent must obtain it before the relevant processing begins.

10. Changes to this policy

We update this policy when our practices change and revise the date above. Before introducing accounts, server synchronisation or another new use of personal data, we will provide the relevant information, including the data, purposes, legal basis, recipients and retention. Significant changes will be brought to your attention through the website or the affected service as appropriate.

A policy update does not itself provide consent for new processing. Where consent is required, we ask for it separately.