Privacy Policy

Effective Date: 23 February 2026

1. Introduction

This Privacy Policy explains how Poldero Apps ("the App") collects, uses, and protects your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable platform requirements.

The App enables users to perform a daily check-in. If a check-in is missed, an SMS notification is sent to a designated emergency contact.

2. Personal Data We Collect

We collect only the minimum personal data necessary to provide the App’s functionality:

• Name – to identify the user.
• User Phone Number – to associate the user with their record and enable system functionality.
• Emergency Contact Phone Number – to send SMS alerts if a check-in is missed.

The App does not require account registration, usernames, or passwords.

3. How We Use Your Data

We process your personal data strictly for the following purposes:

• To monitor whether a daily check-in has been completed.
• To trigger and send an SMS alert to your emergency contact if a check-in is missed.
• To maintain service continuity even if your device is offline or has no battery.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent (Article 6(1)(a)) – by providing your data and using the App.
• Vital Interests (Article 6(1)(d)) – processing is necessary to protect your vital interests in situations where you may be unable to respond.

You are responsible for ensuring that your emergency contact has consented to being designated and contacted.

5. Data Storage and Architecture

Your data is securely stored in our database to ensure that emergency SMS notifications can be sent even if your device is turned off, offline, or has a depleted battery.

We implement appropriate technical and organizational measures to safeguard your data, including:

• Encryption in transit and at rest (where applicable)
• Access controls and authentication
• Minimal data retention principles

6. Data Sharing

We do not sell or rent your personal data. We may share your data only with:

• SMS service providers (e.g., telecom or messaging providers), solely for sending emergency notifications
• Service providers who support the operation of the App (under strict data processing agreements)
• Authorities, if required by law

All third-party processors are contractually obligated to comply with GDPR requirements.

7. International Data Transfers

If your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs)
• Transfers to countries with an adequacy decision by the European Commission

8. Data Retention

We retain your personal data only as long as necessary to provide the App’s functionality. If you stop using the App or request deletion, your data will be deleted within a reasonable timeframe, unless retention is required by law.

9. Your Rights

Under GDPR, you have the following rights:

• Right of access – to obtain a copy of your data
• Right to rectification – to correct inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing

To exercise your rights, contact us at: privacy@poldero.com

10. Security

We take appropriate technical and organizational measures to protect your personal data. However, no system can guarantee absolute security.

11. Children’s Privacy

The App is not intended for children under the age of 16 (or the applicable minimum age in your jurisdiction). We do not knowingly collect data from children.

12. App Store Compliance

• The App collects only data necessary for its core functionality.
• No data is used for tracking, advertising, or profiling.
• No third-party analytics or advertising SDKs are used (unless explicitly added and disclosed).
• Users are informed about data usage before providing personal data.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be reflected by revising the Effective Date.

14. Contact

If you have any questions regarding this Privacy Policy or your data, contact us at privacy@poldero.com