Privacy Policy

Ondia (the "Provider," "we," or "us") establishes this Privacy Policy (the "Policy") regarding the handling of information about users of our application "Stretch Navi" (the "App") as set forth below. We are the controller of personal data processed through the App.

Article 1 (Operator Information)

Operator / Data Controller: Ondia
Location: Japan
Contact: See Article 14

Article 2 (Basic Policy)

The App does not provide user registration or login functionality offered by us.
When you use the Premium Plan, billing is processed through the platforms on which the App is distributed (including Google Play and the Apple App Store; collectively, the "Distribution Platforms"), and purchase-related information may be transmitted accordingly.
We may collect information about users, or transmit such information to external service providers, for the purposes of providing and improving the App, delivering advertisements, analyzing usage, investigating issues, and managing the Premium Plan.

Article 3 (Information We Collect)

We may collect the following information through the App, or transmit such information to external service providers.

1. Information about use of the App

Status of initial use of the App
Frequency of use
Screens viewed
Operation history
In-app event information
Statistical information used to understand usage trends

2. Device and communication information

Device type
OS type and version
App version
Language settings
IP address
Advertising identifiers and other similar identifiers

3. Crash and error information

Crash logs
Date and time of errors
Device information at the time of an issue
OS information
Information about the state of the App

4. Information voluntarily provided when contacting us

Email address
Body of the inquiry
Other information voluntarily provided by the user

5. Premium Plan and billing information

Purchase history for the Premium Plan
Subscription status (active, inactive, in trial, etc.)
Purchase date and next renewal date
Purchase tokens and transaction identifiers issued by the Distribution Platforms (Google Play, Apple App Store, etc.)
Free trial usage history

Article 4 (Purposes of Use and Legal Bases)

We use the information we collect for the following purposes. For users in the European Economic Area, the United Kingdom, or other jurisdictions with similar requirements, the relevant legal basis under Article 6 of the GDPR (or equivalent local law) is indicated in parentheses.

To provide, maintain, and improve the App (legitimate interests; contract performance for Premium users)
To improve stretching menus, screen layouts, and features (legitimate interests)
To analyze usage of the App (legitimate interests; consent where required by local law)
To investigate defects, respond to incidents, and improve quality (legitimate interests)
To deliver advertisements, measure advertising effectiveness, and prevent fraudulent use (consent where required by local law; legitimate interests otherwise)
To process Premium Plan billing, manage subscriptions, and prevent fraud related to purchases (contract performance; legitimate interests)
To respond to inquiries (legitimate interests; consent)
To address violations of the Terms of Service and to otherwise operate the App properly (legitimate interests; legal obligation)

Article 5 (Third-Party Services Used)

The App may use the following external services. As a result, information about users may be transmitted to the respective service providers.

1. Google AdMob

Purpose: Advertising delivery, measurement of advertising effectiveness, and fraud prevention

2. Google Analytics for Firebase

Purpose: Usage analysis and improvement of the App

3. Firebase Crashlytics

Purpose: Crash analysis, incident response, and quality improvement

4. Distribution Platform billing services

Services: Google Play Billing, Apple App Store (In-App Purchase), and similar billing services
Purpose: Premium Plan billing, subscription management, refund processing, and fraud prevention

For details on how each external service handles information, please refer to the privacy policy and other terms provided by each service provider.

Users may also be able to reset their advertising identifier or limit personalized advertising through their device settings. For details, please check the settings of your device or operating system.

Article 6 (International Data Transfers)

The external service providers identified in Article 5 (including Google LLC and Apple Inc.) are primarily based in the United States or operate globally. As a result, information may be transferred to, and processed in, countries outside your country of residence, including countries whose data protection laws may differ from those of your country.

Where required by applicable law (such as the GDPR or the UK GDPR), such transfers are made subject to appropriate safeguards, including Standard Contractual Clauses or other mechanisms maintained by the relevant service providers. For more details, please refer to each provider's privacy documentation linked above.

Article 7 (Provision to Third Parties)

We will not provide information about users to third parties except in the following cases:

When the user has given consent
When required by laws or regulations
When it is necessary to protect the life, body, or property of a person and it is difficult to obtain the user's consent
When it is particularly necessary for improving public health or promoting the sound development of children and it is difficult to obtain the user's consent
When it is necessary to cooperate with a national agency, local government, or a person entrusted by them in carrying out duties prescribed by laws and regulations, and obtaining the user's consent would impede the execution of such duties
When information is transmitted to an external service provider in connection with the use of the external services set forth in Article 5

We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA), except to the extent that the use of advertising identifiers and similar technologies by our advertising partners may constitute "sharing" under that law. California residents have the rights described in Article 11.

Article 8 (Information Management)

We will take necessary and appropriate measures within a reasonable scope to prevent leakage, loss, or damage of the information we collect, and otherwise to ensure its safe management.

Article 9 (Retention Period)

We will retain the information we collect only to the extent necessary to achieve the purposes of use and as required by applicable laws and regulations, after which we will delete, anonymize, or otherwise appropriately handle the information within a reasonable period.
Information relating to Premium Plan billing and transactions may be retained for the period required by applicable tax, accounting, and consumer protection laws (up to seven years in some jurisdictions).

Article 10 (On-Device Data)

The App may store settings, favorites, usage history, and other data related to the use of the App on the user's device.
Such data may be lost due to deletion of the App, change of device, reinstallation of the operating system, or other circumstances.

Article 11 (Your Rights)

Subject to applicable law, you have the following rights with respect to personal information we hold about you:

Right of access — to obtain confirmation of whether we process your personal data and a copy of that data
Right to rectification — to request correction of inaccurate or incomplete data
Right to erasure ("right to be forgotten") — to request deletion of your data in certain circumstances
Right to restrict processing — to request that we limit how we use your data
Right to data portability — to receive your data in a structured, machine-readable format
Right to object — to object to processing based on legitimate interests or for direct marketing
Right to withdraw consent — where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing
Right to lodge a complaint with a data protection supervisory authority in your country of residence (for users in the EEA, the UK, and other jurisdictions with similar authorities)

For California residents: You also have the right to know what personal information we collect, to request its deletion or correction, to opt out of the sale or sharing of personal information, and not to be discriminated against for exercising these rights. We do not knowingly sell personal information for monetary consideration.

To exercise any of these rights, please contact us using the contact information in Article 14. We will respond within the period required by applicable law.

Article 12 (Children's Privacy)

The App is not directed to, and we do not knowingly collect personal information from, children under the age of 13 (or under the age required to consent to processing of personal data under the laws of the user's country of residence, which may be higher, for example 16 in parts of the European Economic Area).
Minors above the applicable age threshold must obtain the consent of a parent or other legal guardian before using the App.
If you believe that a child has provided us with personal information without appropriate consent, please contact us using the information in Article 14, and we will take reasonable steps to delete the information.

Article 13 (Changes to this Policy)

We may change this Policy in the event of changes in laws and regulations, changes in the App's features, operational necessity, or other reasonable circumstances.
For material changes, we will announce the details and effective date of the changes within the App or on a website operated by us.
The amended Policy will take effect on the effective date separately determined by us.