Introduction

Your privacy matters to us. This Privacy Policy explains how Boom App ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application and related services (collectively, the "Service"). By using Boom App, you agree to the collection and use of information in accordance with this Policy.

We are committed to complying with applicable privacy laws worldwide, including the General Data Protection Regulation (GDPR) in the EU/EEA and UK, and the California Consumer Privacy Act (CCPA) in California. We strive to be transparent about our practices so you can make informed choices about your data.

Information We Collect

We collect several types of information from and about users of Boom App, including:

• Information You Provide Directly: When you create an account or use the App, you may provide personal information such as your name, email address, username, and password. You might also provide additional information on your profile (like a profile photo) if you choose. Additionally, any content you create or upload to Boom App - such as text entries, photos, videos, voice notes, or other "memories" and activity logs from your past days - is collected and stored as part of the Service.
• Content and Activity Data: Boom App's core feature is to help you recall past activities or content. To enable this, we store information about your usage and activity within the App. For example, we keep a log of dates/times you added entries, the content of those entries, and your interactions with the App's features (like when you revisit a memory or use a specific function). This data allows us to deliver personalized memory reminders or insights based on your past activities.
• Device and Technical Information: We automatically collect certain information about the device and software you use to access Boom App. This includes data like your device type/model, operating system version, unique device identifiers, browser type (if using a web version), and the Boom App version. We also collect usage data such as your IP address, timestamps of use, pages or features viewed, app crash reports, and other diagnostic information. This technical data helps us troubleshoot issues, improve compatibility, and understand how users interact with our Service.
• Location Information: Boom App may collect or infer information about your general location (such as country or city) based on your IP address. We do not collect precise GPS location from your device unless you explicitly opt-in to a feature that needs it (and we will explain why such data is needed at that time). Any location-based feature will be strictly optional.
• Cookies and Similar Technologies: If you use any Boom App web interface or visit our website, we may use cookies and similar tracking technologies to remember your preferences and gather usage statistics. Cookies are small text files stored on your device. For example, we might use cookies to keep you logged in on our web portal or to understand which website pages are most popular. You can control or delete cookies through your browser settings. Note that disabling cookies might affect some website features (though core functionality of the mobile app will still work).

How We Use Your Information

We use the information we collect for purposes consistent with this Privacy Policy, including to:

• Provide and Improve the Service: We process your data to operate Boom App's core functions. This includes using your information to create and maintain your account, authenticate you when you log in, store and retrieve your saved memories and content, and provide the features you expect. We also use data (like app usage and feedback) to debug, optimize, and personalize your experience, ensuring the App works properly on different devices and refining features based on what users find useful.
• Recall and Personalization: The data you enter (your memories and activity logs) is used to power our memory-based features. For example, Boom App might remind you of "On this day, here's what you did" or help you search your past entries. We may analyze your stored content to make these features relevant - for instance, highlighting noteworthy moments or trends in your activity.
• Communication: We may use your email or other contact info to send you service-related messages such as account confirmations, password reset emails, important updates about the App, or responses to customer support requests. If you opt in (or as permitted by law), we might also send occasional newsletters or product updates about new Boom App features or promotions. You can opt out of marketing emails at any time by clicking the unsubscribe link in those emails or by contacting us.
• Security and Fraud Prevention: We use information (especially technical and usage data) to protect the integrity of the Service and our users. This includes monitoring for suspicious or fraudulent activity, enforcing our Terms of Use, detecting breaches or attacks, and preventing misuse of the App. If necessary, we will use data to investigate potential violations and to take action to mitigate any harm.
• Legal Compliance: We may process and retain your data as needed to comply with our legal obligations. For example, we might keep records to comply with tax laws, or disclose information when required by law enforcement or to address legal claims.
• We also use data to enforce our agreements (like the Terms of Use) and to protect the rights and safety of our users and others.
• Aggregated or De-Identified Data: We may use your information to create aggregated, anonymized statistics that do not identify you personally. For instance, we might compile data to see how often users in general use certain features or what time of day the app is most used. This helps us understand usage patterns and improve the app. We may also share these aggregated insights with partners or the public (for example, in a transparency report), but they will not contain any personal information.

Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we must have a valid legal basis to process your personal data. Depending on the context, Boom App may rely on the following legal bases:

• Consent: We will rely on your consent where required. For example, we ask for your consent to send marketing emails or to collect certain data via cookies. When you sign up for Boom App and provide personal information, you consent to our collection and use of that data as explained in this Policy. You have the right to withdraw your consent at any time.
• Contract: We process some data because it is necessary to perform our contract with you - specifically, to provide the Boom App service and features as described in our Terms of Use. For instance, we need your user account information and content in order to provide you with access to your saved memories.
• Legitimate Interests: We may process your data for our legitimate interests, provided those interests are not outweighed by your data protection rights. For example, we have a legitimate interest in analyzing and improving our products and services, ensuring security, and promoting our services to users who might be interested. When we rely on this basis, we consider any potential impact on you and ensure that we do not infringe on your rights and freedoms.
• Legal Obligation: In some cases, we need to process your personal information to comply with a legal obligation, such as keeping proper business records, responding to lawful requests by public authorities, or complying with applicable laws and regulations.

Sharing of Information

We understand that your personal information and content are important, and we are not in the business of selling it. We share user data only in the following circumstances:

• Service Providers: We may share information with trusted third-party companies that help us operate and provide the Service. For example, we use cloud storage providers to host data (so your memories are saved securely and accessible across devices), email service providers to send account notifications, analytics services to understand how our app is used, and payment processors to handle subscription transactions. These providers act on our behalf and are contractually obligated to safeguard your data and use it only for the purposes we specify.
• Business Transfers: If Boom App or its parent company is involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will ensure the confidentiality of any personal information involved in such transactions and provide notice before your personal information is transferred and becomes subject to a different privacy policy.
• Legal Compliance and Protection: We may disclose your information if we believe in good faith that it's necessary to comply with a legal obligation (for example, a law, regulation, valid legal process, or government request). We might also share information if necessary to enforce our Terms of Use or other agreements, or to protect the rights, property, or safety of Boom App, our employees, our users, or others. This could include sharing information with law enforcement or other trusted parties (like attorneys or auditors) in line with applicable law.
• With Your Consent or Direction: We will share your personal information with third parties if you explicitly direct us to do so or consent to the sharing. For instance, if Boom App enables a feature where you can share a memory entry to a social media platform or collaborate with another app, we will share data with those platforms only when you choose to do so. Similarly, if you participate in an event or promotion in partnership with another organization (and you give consent), we might share your contact details with them as part of that specific program.
• Affiliates: We may share your information with our affiliates (companies that are under common ownership or control with Boom App) to help provide, maintain, or improve the Service. Any such affiliate will treat your information in accordance with this Privacy Policy.

No Sale of Personal Information: We do not sell your personal information to third parties for their own marketing or advertising purposes. If this policy ever changes, we will update you and provide any required opt-in or opt-out options (as per laws like CCPA).

International Data Transfers

Boom App is a global service. The personal information we collect may be transferred to and processed in countries other than your own. In particular, our servers and service providers may be located in the United States and other countries. These countries might have data protection laws that differ from those in your jurisdiction (and may not be deemed "adequate" under EU law).

Rest assured, we take steps to ensure appropriate safeguards when we transfer your data internationally. If you are in the EEA, UK, or Switzerland, we rely on approved mechanisms for cross-border transfers, such as the European Commission's Standard Contractual Clauses, or we transfer data to countries that have been officially recognized as providing an adequate level of protection. By using Boom App or providing information to us, you consent to the transfer of your personal data to countries outside of your own as needed to provide the service, subject to the safeguards described in this Policy.

Data Retention

We keep your personal information only for as long as necessary to fulfill the purposes for which we collected it, including providing the Service and meeting any legal, accounting, or reporting requirements.

• Account Data: We retain the personal information associated with your account (like your profile info and content) for as long as your account is active. If you delete your account, we will delete or anonymize your personal data within a reasonable time frame (generally within 30 days), except for data we are required or permitted to retain by law.
• Memories and User Content: Content you add to Boom App (posts, logs, etc.) is stored until you choose to delete that content or delete your account. You can delete individual entries at any time, and they will be removed from our active databases. However, deleted content might persist for a short period in our backups before those backups are securely destroyed.
• Transactional and Payment Information: If you make purchases or subscribe to premium features, we will retain records of transactions, subscription status, and payment history as long as needed for our financial records and compliance (for example, to comply with tax and audit requirements). Typically, financial records are kept for a number of years as required by law.
• Analytics and Logs: We retain app usage logs and analytics data in aggregate form for a longer period to help us understand user engagement and improve the Service. This data is usually de-identified, meaning it cannot easily be linked back to an individual user.

After the retention period expires or if the data is no longer needed, we will either delete your information or anonymize it (so it can no longer be associated with you). If immediate deletion is not possible (for instance, because the data is in backup archives), we will securely store the data and isolate it from further use until deletion is feasible.

Data Security

We employ a variety of security measures to protect your personal information and maintain the integrity of Boom App. These include industry-standard practices such as encryption (both in transit and at rest for sensitive data), firewalls, secure server infrastructures, and regular security audits and testing. We also limit access to personal data to employees and contractors who need access to perform their job duties, and they are bound by strict confidentiality obligations.

Despite our efforts, no security measure is perfect or impenetrable. The internet by its nature poses risks, and thus we cannot guarantee the absolute security of your data. You also play a vital role in security: protect your account credentials and avoid sharing them. Use a strong, unique password for Boom App, and be cautious about phishing attempts or unusual requests for your personal information.

If you suspect any unauthorized access to your account or any security breaches, please notify us immediately at security@boomapp.com (or privacy@boomapp.com). We will investigate and notify users and authorities of data breaches as required by law.

Your Rights and Choices

You have rights and choices regarding your personal information. Depending on your jurisdiction, these may include:

• Access & Portability: You can request a copy of the personal data we hold about you. We will provide this in a common digital format so you can review it or even transfer it to another service.
• Correction: You have the right to ask us to correct or update any inaccurate or incomplete personal information. You can also update most of your basic account details directly in the app.
• Deletion: You can request that we delete your personal data. For example, you can delete specific content in the app, or delete your account entirely. Keep in mind, deleting your account will remove your data from our active systems (though some information may persist in backups or as required by law, as noted above).
• Withdrawal of Consent: If we process your information based on consent, you have the right to withdraw that consent at any time. For instance, you can opt out of marketing emails by clicking "unsubscribe" in those emails or adjusting your app settings if we offer in-app consent toggles. Withdrawal of consent will not affect the lawfulness of processing that was based on consent before it was withdrawn.
• Objection & Restriction: You may have the right to object to or request the restriction of our processing of your personal information in certain cases. For instance, you can object to processing for direct marketing or ask us not to process your data for certain purposes when you feel it impacts your rights.
• Do Not Sell (CCPA): If you are a California resident, the CCPA gives you the right to direct a business that sells personal data to stop selling it. As noted above, Boom App does not sell personal information. We treat any "Do Not Sell" requests accordingly and ensure your data is not shared in a way that would be considered a sale.
• Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. This means we won't deny you the use of our service or provide you a different level of service just because you made a privacy request.

To exercise your rights, please contact us at privacy@boomapp.com with your request. We may need to verify your identity before fulfilling certain requests (to protect your privacy and security). For example, we might verify your email address or ask for information that matches our records. We will respond to your request within the timeframe required by applicable law (typically within 30 days for most requests). If we need more time or cannot comply with your request (due to legal obligations or other reasons), we will inform you and explain the reason.

If you are in the EEA/UK, you also have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns. Similarly, California residents can reach out to the California Attorney General for CCPA complaints. Of course, we encourage you to contact us first so we can try to resolve any issues directly.

Children's Privacy

Boom App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use the App or send us any personal information.

For teenagers who are old enough to use the App (e.g., 13 or older in the U.S., or the equivalent minimum age in other countries), we still recommend parental guidance and supervision. If we learn that we have collected personal data from a child under 13 (or under the applicable age threshold in certain regions) without verifiable parental consent, we will promptly delete that information.

If you are a parent or guardian and you discover that your child under 18 has created an account or provided us with personal information without your consent, please contact us at privacy@boomapp.com. We will take steps to delete the account and any associated information as appropriate.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes, we will update the "Last Updated" date at the top of this Policy. If the changes are significant, we will provide a more prominent notice (such as an in-app notification or an email to you).

We encourage you to review this Policy periodically to stay informed about how we are protecting your information. Your continued use of Boom App after any changes to this Privacy Policy means you accept the updated Policy, unless additional consent is required by law.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please reach out to us. We're here to help.

• Email: privacy@boomapp.com
• Mail: Privacy Team - Boom App Inc., 116 Gadstonos, 3032, M. Kyprianou, House 3&4 Floor, Limassol, Cyprus

We will do our best to respond promptly and address your concerns. Thank you for trusting Boom App with your memories. We are dedicated to protecting your privacy and helping you get the most out of our service in a safe and transparent way.