Privacy Policy

1. Who we are and what this covers

This Privacy Policy is issued by Zentrovaapps (SMC-Private) Limited ("Zentrovaapps", "we", "us" or "our"), a Single Member Private Limited company incorporated under the Companies Act, 2017 of Pakistan and registered with the Securities and Exchange Commission of Pakistan under Incorporation Number 0344416.

This policy applies to every mobile application we publish on Google Play (each an "App", together the "Apps"), including our range of universal smart-TV and streaming-device remote control applications, and to this website at zentrovaapps.com. Where a particular App handles data differently from what is described here, that difference will be disclosed inside the App itself and in its Google Play Data safety section.

We are the data controller for the limited processing described in this policy. By downloading, installing or using an App, you confirm that you have read and understood this policy.

2. Privacy at a glance

3. What we do not collect

To be explicit, our Apps do not collect, request, transmit or store:

• Your name, email address, postal address, phone number or date of birth;
• User accounts, passwords or authentication credentials — there is no sign-up or login;
• Precise or approximate geographic location from GPS or location services;
• Your contacts, calendar, call logs, SMS messages or photo and media library;
• Audio or video recordings, except where an App expressly offers a voice-search feature that you actively trigger, as described in section 6;
• Health, financial, biometric or other special-category personal data;
• A record of what you watch, which channels you tune to, or the content displayed on your television.

We do not sell your personal information, and we do not share it with data brokers.

4. Information collected automatically

Because our Apps are free and supported by advertising, our third-party advertising partner collects a limited set of technical data from your device when ads are requested and displayed. This collection is performed by Google AdMob, not by us — we do not receive this data in an identifiable form.

We receive only aggregated, non-identifying reports from Google — for example the total number of ad impressions or total revenue for a given day. These reports do not allow us to identify any individual user.

5. Local network and device data

Our remote control Apps work by talking directly to a television or streaming device on the same Wi-Fi network as your phone. To do that, an App may read and store the following on your device only:

• The local IP address, port, device name, model and unique device identifier broadcast by the TV or streaming device you choose to control;
• Pairing tokens, access keys or session certificates issued to your phone by that device so it does not have to be re-paired every time;
• Your in-app preferences — saved devices, favourite apps or channels, button layout, theme, haptic and sound settings.

6. Permissions and why they are used

Android permissions requested by our Apps are limited to what is technically necessary. Not every App requests every permission listed below; you can always review the exact list on the App's Google Play listing and in your device settings.

You can revoke any runtime permission at any time in Settings → Apps → [App name] → Permissions. Revoking a permission may disable the specific feature that depends on it.

7. Third-party services

Our Apps integrate the following third-party services. Each operates under its own privacy policy, and we encourage you to read them:

We do not embed any analytics, attribution, crash-reporting, social-media or profiling SDK beyond the services listed above. If we add one in future, this policy and the App's Data safety declaration will be updated before the change ships.

Additional information on how Google uses data from apps that use its services is available at policies.google.com/technologies/partner-sites.

8. Advertising and your ad choices

Our Apps display banner, interstitial, native and rewarded advertisements supplied by Google AdMob. Ads may be personalised (selected using your advertising ID and inferred interests) or non-personalised (selected using only coarse contextual signals such as country and the content of the App).

Consent in the EEA, UK and Switzerland

If you are located in the European Economic Area, the United Kingdom or Switzerland, the App will show a consent message on first launch using Google's User Messaging Platform, in line with Google's EU User Consent Policy and the IAB Transparency and Consent Framework. You may choose to consent to personalised advertising or to refuse it, and you can change your decision at any time from the App's Settings → Privacy options screen. If you refuse, you will continue to see ads, but they will be non-personalised.

Controlling your advertising ID

• Open Settings → Google → All services → Ads on your Android device;
• Select Delete advertising ID to stop apps from receiving it, or Reset advertising ID to disassociate it from past activity;
• You can also opt out of personalised advertising across Google services at adssettings.google.com.

Removing ads entirely

Every App offers a paid option that removes advertising. Once an ad-free entitlement is active, no ad requests are made and no advertising data is collected by AdMob for that App. See the Subscription Policy for details.

9. In-app purchases and subscriptions

Our Apps offer optional in-app purchases, including auto-renewing subscriptions, a free trial period on selected plans, and a one-time lifetime purchase. All payments are processed exclusively by Google Play.

• We never see, receive, handle or store your card number, bank details, billing address or any other payment credential. These are handled entirely by Google under its own terms and privacy policy.
• Google provides our App with a purchase token, product identifier and entitlement status so the App can unlock the features you paid for and restore them if you reinstall.
• Your subscription status is validated against Google Play and cached on your device. We do not maintain a customer database linking purchases to identifiable individuals.

Full terms covering renewal, cancellation, price changes and refunds are set out in our Subscription Policy.

10. How information is used

The limited information described in this policy is used only to:

• Discover, pair with and send commands to the device you choose to control;
• Remember your saved devices and preferences between sessions;
• Display advertising that funds the free version of the App;
• Deliver, restore and manage purchases and subscriptions;
• Diagnose faults reported to us by email and improve reliability and performance;
• Prevent fraud, abuse and violations of our Terms of Use;
• Comply with applicable law and enforce our legal rights.

We do not use your data for automated decision-making producing legal or similarly significant effects.

11. Legal bases for processing

Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases:

• Consent (Art. 6(1)(a)) — for personalised advertising, and for optional permissions such as microphone access. You may withdraw consent at any time.
• Performance of a contract (Art. 6(1)(b)) — to provide the App's core functionality and to deliver purchases and subscriptions you have bought.
• Legitimate interests (Art. 6(1)(f)) — to serve non-personalised advertising, to keep the Apps secure and free from fraud, and to fix defects. We balance these interests against your rights and freedoms.
• Legal obligation (Art. 6(1)(c)) — where processing is required by law.

12. Sharing and disclosure

We do not sell, rent or trade personal information. Information is disclosed only in these situations:

• Service providers — Google, in its capacity as advertising and payments provider, as described in sections 7 to 9;
• Legal requirement — where we are compelled by a valid order of a court or competent authority, or where disclosure is necessary to comply with applicable law;
• Protection of rights — where reasonably necessary to investigate fraud or abuse, or to establish, exercise or defend legal claims;
• Corporate transaction — in the event of a merger, acquisition or transfer of assets, in which case you will be notified through the App or this website before any information becomes subject to a different privacy policy.

13. Retention and deletion

Because we do not operate user accounts or store personal data on our own servers, there is no account for us to delete. Data is retained as follows:

Support correspondence is retained for no longer than 24 months unless a longer period is required to resolve a dispute or comply with law. To request deletion of anything you have sent us, write to support@zentrovaapps.com with the subject line "Data deletion request".

14. Security

We apply measures appropriate to the very limited data our Apps handle. Data stored on your device is held in the App's private storage area, which other applications cannot read. Where a device protocol supports encryption, our Apps use the encrypted transport (for example TLS or the device's own secure pairing channel). Communication with advertising and billing services uses HTTPS.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your device, its screen lock and your Wi-Fi network secure.

15. Children's privacy

Our Apps are general-audience products intended for users aged 13 and over and are not directed to children. We do not knowingly collect personal information from children under 13 (or under the minimum age of digital consent in your jurisdiction, which is up to 16 in parts of the EEA).

None of our Apps participates in the Google Play Families programme. If you believe a child has provided us with personal information, contact support@zentrovaapps.com and we will delete it promptly.

16. International transfers

Zentrovaapps is established in Pakistan. Our advertising and billing providers process data on infrastructure located in the United States, the European Union and other countries. Where personal data of EEA or UK users is transferred outside those territories, Google relies on the European Commission's Standard Contractual Clauses and equivalent UK transfer mechanisms. By using the Apps you acknowledge that this limited technical data may be processed in countries whose data protection laws differ from those of your own country.

17. Your privacy rights

Depending on where you live, you may have the right to:

• Access the personal data held about you and obtain a copy of it;
• Rectify inaccurate or incomplete data;
• Erase your data ("right to be forgotten");
• Restrict or object to processing, including objecting to direct marketing and profiling;
• Data portability;
• Withdraw consent at any time, without affecting processing carried out before withdrawal;
• Lodge a complaint with your local supervisory authority.

California residents

Under the California Consumer Privacy Act as amended by the CPRA, you have the right to know what personal information is collected, to request deletion, to correct inaccurate information, and to opt out of the "sale" or "sharing" of personal information. We do not sell personal information. Sharing of an advertising identifier for cross-context behavioural advertising can be stopped by refusing personalised ads in the App, deleting your advertising ID, or purchasing the ad-free option. We will not discriminate against you for exercising any of these rights.

How to exercise your rights

Because our Apps hold no account identifying you, most rights are exercised directly on your device using the controls described in sections 8 and 13. For anything else, write to support@zentrovaapps.com. We respond to verifiable requests within 30 days. There is no charge unless a request is manifestly unfounded or excessive.

18. Changes to this policy

We may update this Privacy Policy to reflect changes in our Apps, our service providers or applicable law. The "Last updated" date at the top of this page always shows the current version. Where a change is material — for example if we begin collecting a new category of data — we will give notice inside the affected App before the change takes effect and, where required, obtain your consent. Continuing to use an App after an update takes effect means you accept the revised policy.

19. Contact us

For any question, request or complaint about this policy or your privacy, contact us:

Trademark notice: Zentrovaapps is an independent software developer and is not affiliated with, endorsed by, sponsored by or certified by any device manufacturer or platform operator. All trademarks and brand names are the property of their respective owners and are used, where referenced, only to describe device compatibility.