Privacy Policy

1. Controller

The controller responsible for data processing under the GDPR is:

TANO TRADING LTD OOD
ul. "Hadhizi Dimitar" 3
4701 Smolyan
Bulgaria

Registered in the Bulgarian Commercial Register
Registration Number (EIK): 204784209

Represented by the Managing Director:
ВЕСКА НИКОЛОВА БОЯДЖИЕВА

Contact for privacy inquiries:
[email protected]

2. Purpose of the App

The App is designed to help teachers and educational staff create and manage classroom seating plans.

The App allows users to organize seating arrangements and classroom layouts for educational purposes.

3. Data Entered by Users

The App may process information entered manually by the user, such as:

• student names
• class names
• seating arrangements
• seating preferences between students

This data is entered voluntarily by the user (typically a teacher or educational staff member).

The App developer does not collect or receive this data directly.

4. Data Storage

Information entered in the App may be stored:

• locally on the user's device
• within the user's personal iCloud account via Apple CloudKit

When iCloud synchronization is enabled, data is stored in the user's private CloudKit database associated with their Apple ID.

This means:

• the data belongs to the user's iCloud account
• the developer does not have access to the stored data
• the developer cannot read or analyze the stored data

5. Use of Apple CloudKit

The App uses Apple CloudKit, a cloud service provided by Apple Inc., to store and synchronize data across devices.

CloudKit operates within the user's iCloud account and stores data in a private database controlled by the user.

Apple may process data in accordance with its own privacy policies.

Apple Privacy Policy:
https://www.apple.com/privacy/

6. iCloud Account

Certain features of the App may require an active Apple iCloud account in order to enable synchronization via CloudKit.

The availability of these features depends on the user's iCloud settings.

7. Data Access by the Developer

The developer does not collect, access, transmit, or store personal data on external servers.

All data processing occurs either:

• locally on the user's device, or
• within the user's personal iCloud account via Apple CloudKit.

The developer cannot access the content of seating plans or student information stored by users.

8. Data Retention

Data entered into the App remains stored only as long as the user chooses to keep it in the App or in their iCloud account.

Users can delete stored information at any time by removing it from the App or managing their iCloud storage.

9. Children's Data

The App is intended for use by teachers, schools, or educational staff.

Student information entered into the App is entered by the teacher or institution responsible for managing the classroom.

The developer does not directly collect personal data from children.

Schools and teachers are responsible for ensuring that the use of the App complies with applicable school policies and data protection regulations.

10. Legal Basis under GDPR

The processing of personal data within the App occurs only for the purpose of providing the App's functionality.

The legal basis typically applies as:

Article 6(1)(b) GDPR
Processing necessary for the provision of a service requested by the user.

Where applicable, processing may also rely on:

Article 6(1)(f) GDPR
Legitimate interest in providing the App's functionality.

11. User Rights

Under the GDPR, users may have the following rights:

• right of access (Art. 15 GDPR)
• right to rectification (Art. 16 GDPR)
• right to erasure (Art. 17 GDPR)
• right to restriction of processing (Art. 18 GDPR)
• right to data portability (Art. 20 GDPR)
• right to object to processing (Art. 21 GDPR)

Because the developer does not directly store personal data, these rights can generally be exercised by the user through their device settings or iCloud account management.

12. Right to Lodge a Complaint

Users have the right to lodge a complaint with a competent data protection supervisory authority if they believe that personal data is being processed unlawfully.

13. Data Security

The App is designed following privacy-by-design and privacy-by-default principles.

Data stored through Apple CloudKit benefits from Apple's security infrastructure, including authentication mechanisms and encrypted communication.

14. Third-Party Services

The App does not use advertising networks, tracking technologies, or third-party analytics services.

The only external infrastructure used is Apple CloudKit for optional data synchronization.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

If changes are made, the updated version will be published with a revised "Last updated" date.

16. Contact

For questions regarding this Privacy Policy, please contact:

TANO TRADING LTD OOD
ul. "Hadhizi Dimitar" 3
4701 Smolyan
Bulgaria

Email: [email protected]