Privacy Policy

01 Who is responsible

The controller of personal data described in this policy is:

References to “we”, “us”, and “our” in this policy mean the company named above. References to “you” mean a visitor to this website or a user of an application we publish.

We are not required to appoint a data protection officer under Article 37 of the GDPR. Data protection matters are handled directly by the company at the address above.

02 What this policy covers

This policy applies to:

• this website at bratanov.net, including every page on it;
• every mobile application we publish on Google Play under the publisher name Bratanov Autosolaris Enerdzhi EOOD; and
• correspondence you send to apps@bratanov.net.

It does not cover Google Play itself, your device operating system, your network provider, or any third-party website or service you reach from a link. Those are governed by their own policies.

03 Our baseline commitments

These apply to this website and to every application we publish, without exception:

• There are no user accounts. Nothing to register for, and no application we publish asks for a name, an email address, or a password.
• We do not sell personal data. Not to data brokers, and not to anyone else.
• We collect the minimum required. If a feature can work entirely on your device, we keep it on your device.
• We run no tracking of our own. We operate no server that receives data from our applications. What leaves your device goes to Google, for the analytics and advertising described in sections 4 and 7, and nowhere else.
• We do not use dark patterns to obtain consent, and declining analytics or advertising never disables a feature of the wallpaper.

04 Information we process

4.1 This website

This website is a set of static pages. It sets no cookies of its own, contains no tracking pixels or advertising tags, runs no analytics, and loads its fonts, stylesheets, scripts, and images only from bratanov.net. There is no account and no form that submits data to us.

The one exception is the map in the contact section, which is embedded from Google Maps. Loading that frame contacts Google, which receives your IP address and may set its own cookies. It is described in section 7.

The site is served through a hosting provider that, like any web server, processes technical connection data such as your IP address, the requested URL, the time of the request, the response status, and your browser's user-agent string. This is standard server operation, is used for delivering the site, security, and abuse prevention, and is retained by the provider under its own arrangements. We do not build profiles from it and we do not combine it with any other data.

4.2 Applications we publish

Our applications are live wallpapers. They have no accounts and no sign-in, and we operate no server of our own that they talk to. What they process is the following, and the Data safety section of each Google Play listing states precisely which of these apply to that application.

4.3 Analytics, in detail

Our applications use Google Analytics for Firebase. It tells us how many people install an application, which Android versions and devices are worth continuing to support, which settings are actually used, and where an application is failing to work properly.

Because we operate no accounts, none of it is tied to your identity. There is no name, email address, phone number, or account identifier attached, and we hold none of those to attach. What identifies a record is an app instance identifier — a random value Google generates for that installation of that application on that device. It is not shared between our applications, and uninstalling and reinstalling an application replaces it with a new one.

Alongside it, Google records the device model, the Android version, the application version, the device language, and the country or region worked out from your IP address.

An identifier tied to a device is still personal data under the GDPR, even without a name attached to it. We treat it as such, which is why it is described here and why the rights in section 10 apply to it. Google's handling of this data is described in Privacy and Security in Firebase.

4.4 Advertising, in detail

Our applications carry banner advertising from Google AdMob, shown on the settings screen. There is no advertising in the wallpaper itself.

To select and measure an ad, Google receives your Android advertising ID, your IP address, information about your device, and whether you saw or interacted with the ad. For that processing Google acts as an independent controller under its own policies, described at business.safety.google/privacy.

The advertising ID belongs to your device, not to us, and you control it. Under Settings → Privacy → Ads on Android you can reset it, or delete it entirely. Deleting it turns off personalised advertising across every application on the device, ours included.

If you are in the European Economic Area, the United Kingdom, or Switzerland, the application asks for your choice about advertising and analytics before either begins, and records that choice. You can change it at any time from the application's settings screen. Declining does not restrict any feature of the wallpaper.

4.5 What we never collect

No application we publish collects any of the following, and none of them requests the Android permission that would make it possible:

• names, email addresses, passwords, or any other account or contact detail;
• device location, beyond the country or region Google derives from your IP address;
• contacts, call logs, or SMS messages;
• photos, files, camera images, or microphone audio;
• health, fitness, financial, or biometric data;
• anything you type, other than the settings you choose inside the application itself.

4.6 When you write to us

If you email apps@bratanov.net we receive your email address, your name if you give it, and whatever you choose to put in the message. We use it to answer you and to keep a record of the matter. Please do not include sensitive personal information in a support message unless it is genuinely necessary.

05 Purposes and legal bases

Under Article 6 of the General Data Protection Regulation (EU) 2016/679, we rely on the following:

Where we rely on consent, withdrawing it is as easy as giving it: change your choice on the application's settings screen, turn off Android's diagnostics setting, or write to us. Withdrawal does not affect processing that already took place lawfully.

06 Device permissions

Live wallpapers need very little from the system, and our applications reflect that. They do not request any of Android's runtime permissions — there is no request for your camera, microphone, location, contacts, photos, or files, because no feature we ship uses them. Motion effects respond to the accelerometer, which Android exposes to any application without a permission and which reveals nothing about who or where you are.

Our applications do declare network access, which Android grants at install time and does not prompt for. It is used to load advertising, to send the analytics described in section 4.3, and for nothing else.

Should a future application need a runtime permission, it will be requested at the moment the feature needs it, never as a blanket request on first launch, and the reason will be shown before the system dialog appears. Declining will only disable the specific feature that needs it.

You can review and revoke permissions at any time in Settings → Apps → [application] → Permissions on your device.

07 Third parties

We keep the number of third parties as small as the work allows. Those that may be involved are:

• Google Ireland Limited / Google LLC — distribution of our applications through Google Play, payment processing through Google Play Billing, and crash and performance reporting through Google Play Console. Google acts as an independent controller for much of this and applies its own privacy policy.
• Google Analytics for Firebase — usage analytics inside our applications, as described in section 4.3.
• Google AdMob — the banner advertising shown on the settings screen of our applications, as described in section 4.4. Google acts as an independent controller for advertising.
• Our website host — serves the static pages of bratanov.net and processes connection data as described in section 4.1.
• Google Maps — the contact section of bratanov.net embeds a Google Maps frame showing our address. When that frame loads, Google receives your IP address and may set cookies under its own privacy policy. The map is not used to identify you, and no other page of this website embeds third-party content. If you would rather not load it, block third-party frames in your browser or open our address in a map application of your choice.
• Our email provider — carries and stores correspondence sent to and from apps@bratanov.net.
• Professional advisers and authorities — accountants, auditors, or public authorities, where we are legally required to disclose information.

Where a party processes personal data on our instructions, a written data processing agreement under Article 28 of the GDPR is in place. We do not grant any third party the right to use your personal data for its own marketing.

If an individual application uses an additional third-party service, that service is named in the application's Google Play Data safety section and in its in-app privacy notice before the feature is used.

08 International transfers

We are based in Bulgaria and prefer providers that process data inside the European Economic Area. Some providers, notably Google, may process data outside the EEA, including in the United States.

Where that happens, the transfer is covered by an adequacy decision of the European Commission or by Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR, together with any supplementary measures the provider applies. You can request details of the safeguards used by writing to us.

09 How long we keep data

When a retention period ends, data is deleted or irreversibly anonymised. Where a legal obligation requires us to keep a record, we keep only that record and restrict its use to that purpose.

10 Your rights

If you are in the European Economic Area, the GDPR gives you the following rights over your personal data:

• Access — a copy of the personal data we hold about you, and information about how it is used (Article 15).
• Rectification — correction of inaccurate or incomplete data (Article 16).
• Erasure — deletion of your data where there is no overriding reason to keep it (Article 17).
• Restriction — a pause on processing while a dispute about accuracy or lawfulness is resolved (Article 18).
• Portability — data you gave us, in a structured, commonly used, machine-readable format (Article 20).
• Objection — to processing based on legitimate interests, on grounds relating to your situation (Article 21).
• Withdrawal of consent — at any time, where consent is the basis we rely on (Article 7(3)).

To exercise any of these, write to apps@bratanov.net and tell us which right you are exercising and which application it concerns. We will respond within one month of receiving the request, as Article 12(3) requires. That period may be extended by two further months for complex requests, in which case we will tell you within the first month and explain why.

Exercising these rights is free. We may ask for information to confirm your identity, but only what is necessary, and only where we could not otherwise identify you with reasonable certainty.

11 Deleting your data

We do not operate user accounts, so there is no account to close. How deletion works depends on where the data sits.

11.1 Data held on your device

The settings our applications hold stay on your device. Clearing the application's storage, or uninstalling it, removes them. Go to Settings → Apps → [application] → Storage → Clear storage, or uninstall the application. Once removed this way it cannot be recovered by us, because we never had a copy.

11.2 Analytics and advertising data

There are no accounts to delete, and we hold no database of users — we operate no server that our applications send data to. The only records connected to your use of an application are the analytics and advertising data held by Google, described in sections 4.3 and 4.4.

The fastest routes are in your own hands, and they take effect immediately:

• Uninstalling the application deletes everything it held on your device and retires its app instance identifier, so no further analytics can be linked to that installation.
• Resetting or deleting your advertising ID under Settings → Privacy → Ads breaks the link between your device and the advertising data held about it.
• Withdrawing consent on the application's settings screen stops any further analytics or advertising collection.

If you would rather we handle it, email apps@bratanov.net with the subject line Data deletion request and the name of the application concerned. Include your app instance identifier or advertising ID if you have it — without one of them there may be no way to single out your records, since we hold nothing else that identifies you. We confirm receipt of the request and complete the deletion, or instruct Google to complete it, within 30 days.

11.3 Purchases

Purchase and subscription records are held by Google as part of your Google account. Manage them at play.google.com/store/account/subscriptions. We cannot delete records held in your Google account.

12 Children

Our applications are directed at a general audience and are not designed for or targeted at children. Unless an application's Google Play listing states otherwise, our applications are not intended for use by children under 16, which is the age of digital consent set by Bulgarian law under Article 8 of the GDPR.

We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, write to apps@bratanov.net and we will delete it promptly and confirm once it is done.

Where an application is listed in a family programme on Google Play, it complies with the Google Play Families policy and any additional requirements are stated in that application's listing.

13 Security

We apply technical and organisational measures appropriate to the risk, as Article 32 of the GDPR requires:

• all traffic to this website and to any service we operate is encrypted in transit with HTTPS;
• application releases are signed, and distributed only through Google Play;
• access to any system holding personal data is limited to the people who need it and protected by strong authentication;
• we keep the number of systems that hold personal data as small as possible, which is the most effective control available to us.

No system is perfectly secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Commission for Personal Data Protection within 72 hours as Article 33 requires, and inform affected users directly where Article 34 requires it.

14 Google Play Data safety

Every application on Google Play carries a Data safety section in its store listing. It states, for that specific application, what data is collected, whether it is shared, whether it is encrypted in transit, and whether you can request deletion.

For our applications those declarations cover app activity and device identifiers, which correspond to the analytics and advertising described in sections 4.3 and 4.4, along with the crash and performance data described in section 4.2.

We keep those declarations accurate and update them whenever an application changes what it processes. If you ever find a discrepancy between an application's Data safety section and this policy, tell us at apps@bratanov.net — we will correct whichever is wrong and confirm the outcome to you.

15 Changes

We may update this policy when our applications change, when we add or remove a service provider, or when the law changes. The version number and the date at the top of this page always reflect the current text.

For changes that materially affect how your personal data is handled, we will give notice in the affected application or on this website before the change takes effect, and where the law requires it we will ask for your consent again. Continuing to use an application after a change takes effect means the updated policy applies.

Superseded versions are available on request from apps@bratanov.net.

16 Contact and complaints

For any question about this policy, or to exercise a right described in section 10:

If you believe we have handled your personal data unlawfully, we would like the chance to put it right first. You also have the right to complain to a supervisory authority at any time. The competent authority for Bulgaria is:

Commission for Personal Data Protection (Комисия за защита на личните данни)
2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
www.cpdp.bg

If you live in another EEA country, you may instead complain to the supervisory authority where you live or work, or where the alleged infringement took place.