PRIVACY POLICY

1. DEFINITIONS

For purposes of this Privacy Policy:

“Application” or “App” means the 320 Guide mobile software application distributed via the Apple App Store and Google Play Store.

“Company,” “we,” “us,” or “our” refers to 320 Guide and its owner, Ben Riecken.

“User” or “you” means any individual who downloads, installs, or uses the Application.

“Personal Data” means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or device.

2. SCOPE OF THIS POLICY

This Privacy Policy describes how we collect, use, process, and disclose information in connection with your use of the Application.

This Policy applies solely to the Application and does not apply to third-party platforms such as Apple Inc. or Google LLC, which operate under their own privacy policies.

3. INFORMATION COLLECTED

The Application does not require account registration and does not directly request names, email addresses, or contact details from Users.

However, certain information is collected automatically through integrated third-party service providers.

3.1 Automatically Collected Data

The following categories of data may be collected:

• Device information (model, operating system, version)

• Anonymous device identifiers

• IP address (which may imply approximate geographic location)

• Application usage data

• Feature interaction data

• Session duration

• Crash reports and diagnostic data

• Subscription and transaction status

• Purchase validation identifiers

This information may constitute Personal Data under certain laws.

4. THIRD-PARTY SERVICE PROVIDERS

We utilize third-party service providers necessary for operation of the Application, including:

• Google LLC (Firebase, Google Analytics for Firebase, Firebase Cloud Messaging)
• Apple Inc. (App Store Analytics, In-App Purchases, Apple Push Notification Service)
• RevenueCat, Inc. (subscription management and entitlement validation)

These providers may process data on our behalf or as independent controllers under their own privacy frameworks.

We do not control the independent data practices of Apple or Google.

5. SUBSCRIPTION AND PAYMENT PROCESSING

The Application offers paid subscriptions processed exclusively through:

• Apple In-App Purchases
• Google Play Billing

We do not collect or store full payment card information.

RevenueCat processes anonymous user identifiers and transaction metadata solely for subscription validation and entitlement management.

6. PURPOSES OF PROCESSING

We process collected data for legitimate business purposes, including:

• Operating and maintaining the Application

• Subscription validation

• Performance monitoring and diagnostics

• Improving functionality and content

• Analyzing aggregated usage trends

• Delivering push notifications

• Preventing fraud and abuse

We do not sell Personal Data.
We do not use collected data for behavioral advertising.

7. PUSH NOTIFICATIONS

The Application may send push notifications through:

• Apple Push Notification Service (APNs)
• Firebase Cloud Messaging (FCM)

These services utilize device tokens generated by the operating system. Device tokens are anonymized identifiers.
Users may disable notifications through device settings at any time.

8. DATA RETENTION

We do not maintain a proprietary database of user accounts.

Data retention is governed by the policies of our third-party service providers. We retain only such data as necessary for legitimate operational purposes.

9. INTERNATIONAL DATA TRANSFERS

Because we utilize service providers headquartered in the United States and other jurisdictions, data may be transferred to and processed outside of your country of residence.

By using the Application, you acknowledge and consent to such transfers.

10. DATA SECURITY

We rely on commercially reasonable safeguards implemented by our service providers to protect data from unauthorized access, disclosure, alteration, or destruction.

No electronic system can guarantee absolute security.

11. YOUR RIGHTS

Depending on applicable law, you may have rights including:

• Right of access

• Right of deletion

• Right to correction

• Right to restrict processing

• Right to object

• Right to data portability

California residents may have rights under the California Consumer Privacy Act (CCPA).
European Economic Area residents may have rights under the General Data Protection Regulation (GDPR).
Requests may be submitted using the contact information below.

12. CHILDREN’S PRIVACY

The Application is not directed to children under the age of 13.
We do not knowingly collect Personal Data from children.
If we become aware that such information has been collected, we will take reasonable steps to delete it.

13. NO SALE OF PERSONAL INFORMATION

We do not sell, rent, trade, or otherwise transfer Personal Data to third parties for monetary consideration.

14. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time.
Material changes will be reflected by updating the Effective Date above.
Continued use of the Application constitutes acceptance of any modifications.

15. CONTACT INFORMATION

If you have questions regarding this Privacy Policy, please contact:

Ben Riecken
320 Guide

ben@A320guide.com