Privacy Policy

This Privacy Policy describes how Trilobytes ("we," "us," or "our") handles personal information in connection with our mobile applications available on Google Play and the Apple App Store (collectively, "Apps").

By downloading, installing, or using any of our Apps, you agree to the practices described in this Policy. If you do not agree, please do not use our Apps.

Who We Are

Trilobytes is a software development studio based in the Philippines. We build mobile applications and web systems. For questions about this policy, see Section 13 - Contact Us.

Summary of Key Points

• We collect only the data necessary to operate and improve our Apps.
• Our Apps display ads served by third-party advertising networks, primarily Google AdMob.
• We do not sell your personal data to third parties.
• You can opt out of personalized advertising at any time through your device settings.
• We take security seriously and apply industry-standard protections.
• Children under 13 (or the applicable age in your jurisdiction) are not permitted to use our ad-supported Apps without parental consent.

We collect information in three ways: information you provide directly, information collected automatically when you use the App, and information received from third parties (such as advertising partners).

2.1 Information You Provide

• Account data (if applicable): username, email address, and password when you create an account.
• User-generated content: notes, preferences, exam scores, or other content you enter into the App.
• Communications: content of messages when you contact our support team.
• Feedback & ratings: reviews, bug reports, or feature requests you submit.

2.2 Information Collected Automatically

• Device identifiers: advertising ID (GAID on Android, IDFA on iOS), device model, OS version, and unique device identifiers.
• Usage data: features used, screens viewed, session duration, tap events, and in-app navigation paths.
• Performance data: crash reports, error logs, and app load times.
• Network data: IP address, approximate geographic location (city/country level derived from IP), and connection type (Wi-Fi/cellular).
• App interaction data: ad impressions, ad clicks, and ad revenue attribution identifiers from our advertising SDK.

2.3 Information from Third Parties

• Advertising networks: Google AdMob and other ad partners may share aggregated or pseudonymous data about ad performance and targeting segments.
• Analytics providers: Firebase Analytics may collect behavioral and engagement data to help us understand how users interact with the App.
• App stores: Google Play and Apple App Store may share aggregate download statistics and review data.

2.4 Information We Do Not Collect

• We do not collect your precise GPS location unless the App's core feature requires it, and only after requesting your explicit permission.
• We do not collect contacts, call logs, or SMS data.
• We do not collect payment card or banking information. In-app purchases are handled entirely by Google Play or the Apple App Store.
• We do not access your camera, microphone, or files unless a specific feature requires it and you have granted permission.

We use collected information for the following purposes:

Purpose	Data Used	Legal Basis
Provide & operate the App	Account data, usage data, device identifiers	Contract
Serve in-app advertisements	Advertising ID, device info, approximate location	Legitimate Interest / Consent
Improve App performance	Crash reports, error logs, performance data	Legitimate Interest
Analyze usage patterns	Usage data, navigation events	Legitimate Interest
Personalize user experience	User preferences, in-app progress	Contract
Respond to support requests	Communications, account data	Contract
Comply with legal obligations	Varies by obligation	Legal Obligation
Prevent fraud & abuse	Device identifiers, IP address, usage patterns	Legitimate Interest

Our free Apps are supported by advertising revenue. We use third-party ad networks to display advertisements within the App. These networks may collect and use data to serve you relevant ads.

4.1 Google AdMob

Our primary advertising partner is Google AdMob, a service operated by Google LLC. AdMob may collect the following information to serve ads:

• Advertising ID (GAID / IDFA) and associated pseudonymous user profile
• Device information (model, OS version, screen resolution, language)
• Approximate location (country/city derived from IP address)
• Ad interaction data (impressions, clicks, view time)
• Interest segments inferred from your broader app usage across Google's partner network

Google AdMob uses this data to serve contextual and/or interest-based (personalized) ads. Google's use of data is governed by the Google Privacy Policy.

4.2 Other Third-Party SDKs

Service	Provider	Purpose	Policy
Firebase Analytics	Google LLC	App analytics & crash reporting	Google
Firebase Crashlytics	Google LLC	Crash reporting & diagnostics	Google
Google Play Billing	Google LLC	In-app purchases & subscriptions	Google
App Store Connect	Apple Inc.	iOS distribution & analytics	Apple

4.3 Opting Out of Personalized Ads

• Android: Go to Settings → Privacy → Ads → Opt out of Ads Personalization
• iOS 14+: Go to Settings → Privacy & Security → Tracking and toggle off "Allow Apps to Request to Track"
• iOS (older): Go to Settings → Privacy → Advertising → Limit Ad Tracking
• In-app: Use the "Consent" or "Ad Preferences" option in the App's settings menu, where available

We do not sell, rent, or trade your personal information. We may share your data only in the following limited circumstances:

5.1 Service Providers

We may share data with trusted third-party service providers who assist us in operating our Apps, including cloud hosting providers, analytics platforms, and customer support tools. These providers are contractually bound to use data only to perform services on our behalf.

5.2 Advertising Partners

As described in Section 4, data such as the Advertising ID and device information is shared with ad networks (primarily Google AdMob) for the purpose of serving advertisements. This data is pseudonymous and governed by the ad network's own privacy policy.

5.3 Legal Requirements

We may disclose your information if required by applicable law, court order, government regulation, or to protect the rights, property, or safety of Trilobytes, our users, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred. We will notify you before your data becomes subject to a different privacy policy.

5.5 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you.

We retain personal data for as long as necessary to fulfill the purposes outlined in this Policy, or as required by law.

Data Type	Retention Period	Reason
Account data	Until account deletion + 30 days	Account recovery grace period
Usage & analytics data	Up to 26 months	Trend analysis & improvement
Crash & diagnostic logs	90 days	Bug investigation & fix
Support communications	3 years	Dispute resolution
Ad interaction data	Per AdMob's own policy (typically 60–90 days)	Ad billing & fraud prevention
Financial/purchase records	7 years	Tax & legal compliance

Account Deletion

You may request account deletion at any time through the App's settings or by contacting us at privacy@trilobytes.ph. Your data will be removed or anonymized within 30 days, except where retention is required by law.

Depending on your location, you may have the following rights regarding your personal data:

7.1 Universal Rights (All Users)

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct inaccurate or incomplete data.
• Deletion: Request that we delete your personal data, subject to legal retention requirements.
• Opt out of personalized ads: Disable interest-based advertising through device settings (see Section 4.3).
• Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

7.2 GDPR Rights (EEA, UK, Switzerland)

• Right to restriction: Request that we restrict processing of your data in certain circumstances.
• Right to portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests.
• Right to lodge a complaint: File a complaint with your local data protection authority (DPA).

7.3 CCPA Rights (California Residents)

• Right to know: Know what personal information we have collected, used, or disclosed.
• Right to delete: Request deletion of personal information we have collected from you.
• Right to opt out of sale: We do not sell personal information, so no opt-out is needed.
• Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights.

7.4 Philippine Data Privacy Act Rights (DPA of 2012)

• Right to be informed: Know how your data is collected and used.
• Right to object: Object to processing of your personal data.
• Right to erasure or blocking: Suspend, withdraw, or order the blocking, removal, or destruction of your personal data.
• Right to damages: Be indemnified for damages caused by inaccurate, incomplete, or falsely used data.
• Right to data portability: Obtain your data in an electronic or structured format.

8.1 Age Restriction

Our Apps that display third-party advertisements are rated for general audiences (13+) on app stores. If you are under 13, you must not use our ad-supported Apps without verifiable parental consent.

8.2 Parental Consent

Where our Apps are designed for or likely to be used by children under 13, we will:

• Only serve non-personalized (contextual) ads that do not use behavioral tracking.
• Not collect persistent identifiers for purposes other than support for internal operations.
• Obtain verifiable parental consent before any data collection from children, as required by COPPA and applicable law.
• Provide parents with the ability to review, delete, or refuse further collection of their child's data by contacting us.

8.3 Discovered Child Data

If we discover that we have inadvertently collected personal information from a child under 13 without appropriate consent, we will promptly delete that information. Contact us at privacy@trilobytes.ph if you believe we have your child's data.

We implement reasonable technical, administrative, and physical safeguards to protect your data from unauthorized access, disclosure, alteration, and destruction.

Security Measures We Apply

• Encryption in transit: All data transmitted between the App and our servers is encrypted using TLS 1.2 or higher (HTTPS).
• Encryption at rest: Sensitive data stored on our servers is encrypted using AES-256 or equivalent standards.
• Access controls: Access to personal data is restricted to employees and contractors who need it, enforced through role-based access controls.
• Secure development practices: We follow secure coding guidelines and conduct periodic security reviews of our codebase.
• Incident response: We maintain a data breach response plan and will notify affected users and relevant authorities as required by law.

Data Breach Notification

In the event of a data breach posing a risk to your rights, we will notify the relevant data protection authority within 72 hours (as required by GDPR and the Philippine Data Privacy Act of 2012), and affected individuals without undue delay.

Trilobytes is based in the Philippines. If you use our Apps from outside the Philippines, your data may be transferred to and processed in the Philippines and other countries where our service providers operate (e.g., the United States for Google services).

Where required by applicable law (such as GDPR), we ensure appropriate safeguards are in place for international transfers, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Transfers to countries with an adequacy decision from the European Commission
• Other appropriate safeguards as permitted by applicable data protection law

Our Apps may contain links to third-party websites, services, or content (including links within advertisements). We are not responsible for the privacy practices of those third parties.

When you leave our App by clicking an ad or external link, you are subject to the privacy policy of the destination. We encourage you to review the privacy policies of any third-party services you interact with.

The presence of a third-party link or advertisement in our App does not constitute an endorsement of that third party's privacy practices.

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Display a prominent notice within the App
• Send an email notification (if we have your email address and the change is significant)
• For major changes, require fresh acknowledgment or consent within the App before continued use

Your continued use of the App after the effective date of the revised Policy constitutes your acceptance of the changes.

We encourage you to periodically review this page for the latest information on our privacy practices.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach out to us. We are committed to addressing your concerns promptly.

Data Protection Officer

For GDPR-related inquiries, email dpo@trilobytes.ph with the subject line "DPO Inquiry."

National Privacy Commission (Philippines)

If you are a Philippine resident and believe your privacy rights have been violated, you may file a complaint with the National Privacy Commission:

• Website: www.privacy.gov.ph
• Email: info@privacy.gov.ph
• Address: NPC Building, C.P. Garcia Ave., Diliman, Quezon City

Supervisory Authority (EEA)

If you are an EEA resident, you have the right to lodge a complaint with your local supervisory authority. A list of EEA data protection authorities is available at edpb.europa.eu.