Privacy Policy

1. Introduction

This Privacy Policy explains how Elvista Media Solutions ("Elvista", "we", "our", or "us") collects, uses, and protects personal information when you use our mobile applications, websites, and related services.

Elvista Media Solutions is a trading name operated by Kseniia Troitskaia, a self‑employed individual registered in the United Kingdom (VAT number GB494058465).

By using our applications or websites, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

• Device information: device model, operating system version, and unique device identifiers (such as advertising ID, IMEI, or GUID).
• Usage data: interactions with the app, session duration, in‑app behaviour, performance metrics, and crash logs.
• Log data: IP address, browser type, pages visited, and timestamps.
• Account identifiers: hashed Google Account, Apple ID, or social network IDs (if used for authentication).
• Advertising & analytics: information provided by third‑party SDKs such as Google, Firebase, Appodeal, or similar providers.

We do not intentionally collect sensitive personal data such as health, political opinions, or biometric information.

3. How We Use Collected Information

• operate and improve our apps and websites;
• provide personalised or contextual advertising (with user consent, where required);
• analyse performance and user engagement;
• prevent fraud and technical issues;
• communicate with you if you contact our support team.

We may aggregate non‑personal data (such as general usage statistics) to understand trends and improve user experience.

4. Legal Bases for Processing (for EU/UK Users)

For users located in the European Union (EU), European Economic Area (EEA), or United Kingdom (UK), we process personal data under the following legal bases:

• Consent: for advertising and analytics where required by law.
• Legitimate interest: to maintain app functionality, security, and service improvement.
• Legal obligation: where processing is necessary to comply with applicable law.

5. Sharing of Information

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

• Service providers: with trusted partners (such as analytics or ad networks) who process data on our behalf and according to our instructions.
• Legal compliance: to respond to lawful requests (e.g., subpoenas or court orders).
• Business transfers: if Elvista is merged or acquired, users will be notified before data is transferred under a new policy.

6. Data Transfers Outside the EU/EEA

Your data may be transferred and processed outside the European Union (EU) or European Economic Area (EEA), including in the United Kingdom and other countries where our partners operate (e.g., the United States). We ensure that such transfers are made using appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.

7. Data Retention

We keep personal data only for as long as necessary to provide our services, comply with legal obligations, or resolve disputes. Non‑personal or aggregated data may be retained for analytics purposes.

8. Your Rights (EU/UK Users)

If you are located in the EU, EEA, or UK, you have the following rights regarding your personal data:

• Access and receive a copy of your data;
• Request correction or deletion;
• Restrict or object to processing;
• Withdraw consent at any time (for advertising or analytics);
• Lodge a complaint with your local Data Protection Authority.

To exercise these rights, please contact us at support@elvista.net.

9. EU Representative (Article 27 GDPR)

At this time, Elvista Media Solutions has not appointed a representative in the EU under Article 27 GDPR due to the limited and incidental nature of data processing involving EU users. However, we respond to all EU and EEA data inquiries promptly and in good faith.

10. Data Security

We take appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse. While no system is completely secure, we continually monitor and update our practices to maintain a reasonable level of protection.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be announced by posting an updated version on our website.

12. Contact Us

If you contact us about your personal data, please include the name of the app and your platform (iOS/Android) so we can assist you faster.