ciapp privacy policy
This is a translation. The Polish version is legally binding.
§ 1. General provisions
- This privacy policy (the "Policy") sets out how personal data is processed in connection with the use of the ciapp application for Android and Windows (the "App") and of the ciapp account deletion web page (the "Account Deletion Page"), together referred to as the "Service".
- This Policy fulfils the information obligations laid down in Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR").
- The processing of personal data on the rgdev.pl website is governed by the separate rgdev.pl privacy policy.
§ 2. Controller
- The controller of personal data is Radosław Gajewski (the "Controller").
- The Controller can be contacted on any matter relating to the processing of personal data at radoslawgajewskii@gmail.com.
- The Controller has not appointed a data protection officer.
§ 3. Categories of personal data
The Controller processes the following categories of personal data of users of the Service (each a "User"):
- Account data: e-mail address, display name, username, account identifier, the dates of account creation and last sign-in and, where the User signs in with a Google account, the address of the Google profile photo. Account passwords (for e-mail sign-in) are handled exclusively by Firebase Authentication; the Controller does not know them and does not store them in the Service's database.
- Public profile: display name, username, profile photo and public encryption key. This data is visible to other signed-in Users so that they can find the User and send a friend request. The username of a new account is derived from the display name and may be changed in the App settings. For accounts created earlier, the username may have been derived from the part of the e-mail address preceding the "@" sign; in that case the App suggests changing it. E-mail addresses are never disclosed to other Users.
- User content: events, notes, to-dos, timetables, categories and App settings. Events and notes remain private until the User shares them with selected friends or a group. To-dos and timetables are always private.
- Events imported from the device calendar or an .ics file: the User may import events into the App from another calendar. On Android, the App requests permission to access the device calendar for this purpose. The calendar is read locally on the device only, and only when the User starts the import; the App makes no changes to it. The User may also load an .ics file, for example one exported from Google Calendar or Outlook. Only events from the calendars selected by the User are stored, limited to: title, description, location, date, time, duration and recurrence rule. Imported events are saved to the User's account as the User's private events. The names of calendars and accounts on the device are not stored. Calendar access may be revoked at any time in the device settings.
- Note edit requests: where a recipient of a note shared on a read-only basis requests permission to edit it, the Controller stores the request for the note's owner, limited to the requester's name and, where the requester proposes changes, the proposed title and content. A request is deleted when the owner accepts or rejects it, when the requester withdraws it, or when the note or the account of either person is deleted. Where the owner grants permission to edit, the note records the persons authorised to edit it.
- Friends and groups: friend requests, the friends list, the groups the User belongs to and the User's role in them.
- Chat: messages are end-to-end encrypted on the User's device. The server stores only the encrypted message content and the data necessary for its delivery: the conversation, sender, recipients and time of sending. The Controller has no access to the content of messages. The User's private key is stored on the device; the copy kept in the User's account is encrypted with the User's chat password, which the Controller does not know. The User's account also stores the key fingerprints of the User's friends and a record of which of them have been verified.
- Blocks and reports: the list of persons blocked by the User. When a user or a message is reported, the Controller stores the reason for the report, the reporter's description, the identifiers of the reporter's account and of the reported account and, for a reported message, its content, which the reporter thereby discloses to the Controller.
- Technical data: in connection with sign-in and connections to the server, the infrastructure provider, Google Firebase, processes the User's IP address and basic device and browser information, including for the purpose of preventing abuse. The Service uses no analytics, advertising or tracking tools. The App and the Account Deletion Page do not set their own cookies.
- Push notification token (Android): where the User allows the App to display notifications, the Controller stores the device token (an identifier issued by Firebase Cloud Messaging) in order to send notifications about a new message, a friend request, being added to a group or a request to edit the User's note. A notification contains only the name of the person concerned and, for a group, the group name; it never contains the content of a message or note. The token is deleted when the User signs out, disables notifications in the App settings or deletes the account.
- Data stored on the device: the App keeps on the device a copy of the User's data for offline use, basic account data, settings and the chat private key. Event reminders are scheduled locally by the device's operating system, without involving the server. Signing out removes from the device the offline copy of the User's data, the chat private key, scheduled reminders, the App's notifications, and event and data-copy files prepared for saving or sharing. The Android App is excluded from Android backups (such as Google Drive) and is not transferred to a new device; on a new device the User signs in again.
§ 4. Purposes and legal bases of processing
- Provision of the Service: maintaining the account, storing and synchronising content, sharing it with the persons chosen by the User, and operating the chat and notifications (Article 6(1)(b) GDPR, performance of a contract).
- Security and moderation: preventing abuse, handling reports and blocking accounts that breach the terms of use (Article 6(1)(f) GDPR, the Controller's legitimate interest in the secure operation of the Service).
- Communication with the User: responding to messages, complaints and requests (Article 6(1)(c) and (f) GDPR).
- Legal claims: the establishment, exercise or defence of legal claims (Article 6(1)(f) GDPR).
Providing an e-mail address is a condition of creating an account. Providing any other data is voluntary. The Controller does not take decisions based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.
§ 5. Recipients of personal data
- Google Ireland Limited and Google group companies, as the provider of the Firebase services (Authentication, Cloud Firestore, Cloud Functions, Cloud Messaging, Hosting), processing data on behalf of the Controller. The Service's database and server functions run in the europe-central2 region (Warsaw).
- Google as an independent controller: where the User signs in with a Google account, the User also uses a Google service, which processes the data under its own terms as an independent controller (Google Privacy Policy).
- Other Users, to the extent of the User's public profile, the content the User shares with them and the messages the User sends to them.
- Public authorities, only where required by law.
The Controller does not sell personal data and does not disclose it to advertisers.
§ 6. Transfers outside the European Economic Area
- The sign-in service (Firebase Authentication) and the push notification service (Firebase Cloud Messaging) operate globally and may process data outside the European Economic Area, including in the United States.
- Such transfers are based on Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 on the adequate level of protection of personal data under the EU-US Data Privacy Framework (Article 45 GDPR) or on standard contractual clauses adopted by the European Commission (Article 46(2)(c) GDPR).
- On the same basis, the data from the previous version of the App referred to in § 7(4) is stored in the United States until 31 December 2026.
§ 7. Retention periods
- Account data and User content are retained for as long as the User holds an account. When the account is deleted, this data is deleted without delay (details). Of the messages sent by the User, only an empty "message deleted" marker, without content, remains in the conversations.
- Reports are retained until they have been handled, and for no longer than 12 months.
- Correspondence with the Controller is retained for as long as necessary to handle it and thereafter until the expiry of the limitation period for any claims.
- The Controller does not make ongoing backups of account data; deleted data cannot be restored. Data from the previous version of the App (as of before 27 September 2026) is held in a locked database and in a one-time copy in Google Cloud in the United States (region us-west1), solely as a safeguard following its migration to the new database. This data is not used and will be deleted no later than 31 December 2026.
§ 8. Rights of the User
- The User has the right of access to their data and to obtain a copy of it (Article 15 GDPR), the right to rectification (Article 16 GDPR), erasure (Article 17 GDPR), restriction of processing (Article 18 GDPR) and data portability (Article 20 GDPR), and the right to object to processing based on the Controller's legitimate interest (Article 21 GDPR).
- Some of these rights can be exercised directly in the App: a copy of the User's content can be downloaded under Settings → Data copy, and the account can be deleted under Settings → Account or as described on the account deletion page.
- All other requests should be sent to radoslawgajewskii@gmail.com. The Controller responds within one month of receipt of a request; this period may be extended as provided in Article 12(3) GDPR. The Controller may ask for confirmation that a request comes from the account holder.
- The User has the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl) or with the supervisory authority of the EU Member State of the User's habitual residence.
§ 9. Security
- Connections to the server are encrypted using TLS. Access to the database is restricted by server-side security rules: a User's content is accessible only to that User and to the persons with whom the User has shared it. The chat is end-to-end encrypted.
- No safeguard provides absolute protection. In the event of a personal data breach, the Controller will act in accordance with the GDPR, including, where required, notifying the supervisory authority and the data subjects concerned.
§ 10. Minors
The Service is intended for persons aged 16 and over. The Controller does not knowingly collect personal data from younger persons and will delete any such account upon becoming aware of it.
§ 11. Changes to this Policy
- The Controller will announce material changes to this Policy in the App or on this page before they take effect.
- The current version of this Policy is always available at this address.
- The English version of this Policy is a translation. In the event of any discrepancy, the Polish version prevails.