Privacy policy

1 · Who we are

Turn the Year is published by Lustig Fairchild Ltd., a company registered in Bulgaria, in the European Union, with its seat and address of management at 14 Aleksandar Malinov str., apt. 7, Varna 9000, Bulgaria.

It is registered in the Commercial Register of the Registry Agency, Republic of Bulgaria under 208942846.

For the purposes of the General Data Protection Regulation we are the controller for the limited processing this policy describes. Being established in the European Union, we are not required to appoint a representative under Article 27, and the nature and scale of the processing do not require a Data Protection Officer under Article 37. Neither appointment is made, and this policy says so rather than leaving you to infer it.

2 · What this policy covers

This policy covers Turn the Year on Android, as distributed through Google Play, together with its two home-screen widgets and its notification. They are parts of the same download and behave the same way for the purposes of this policy.

The App Store edition of the app is not covered here and will have its own policy. The two editions are distributed by different companies, ask for different permissions and are backed up by different systems, and one document cannot be true of both.

On Google Play the app is listed as Turn the Year - Countdown. This policy is the one linked from that listing.

3 · What the app keeps on the device

The app keeps your settings in one small preferences file in its own storage: the theme and display format, the sound, vibration and particle switches, whether it should wake for midnight or show a notification in the final hour, a random number that varies the celebration, and — if you chose one — a reference to your song for midnight, with the file's name and length.

We never see any of it. It is not sent to us, and there is no code in the app that could send it.

The app keeps no history, no record of how often or how long you use it, and no identifier of any kind. It has no database and writes no other files.

4 · Your settings in Android's backup

If backup is turned on for your device, Android includes the app's settings in the backup it makes to your Google Account. The app tells Android to back up that one preferences file and nothing else, and the same file is all that moves when you transfer to a new phone.

That backup is made by the operating system, stored by Google under your Google Account, and restored by Android when you set up a device. We do not receive it, cannot read it and cannot delete it. Google provides it to you, under your agreement with Google — it is not something we do with your data.

The practical consequences, stated rather than implied:

• Your settings leave the device only inside that backup, and only if backup is on.
• The backup includes the name of the song you chose and a reference to where the file was — not the song itself.
• Uninstalling the app removes the settings from the device. A copy can remain in your backup until Android replaces it or Google deletes it; you manage it in your device's backup settings.
• The only controls over this are Android's and Google's. The app has no switch of its own for it.

5 · Permissions, and why each is asked

Two permissions are asked for, each only when you turn on the feature that needs it — never at first launch:

• Notifications, for the optional notification in the final hour before midnight. Decline, and everything else works as before.
• Alarms and reminders, for the optional setting that wakes the app for midnight to the second. If exact alarms are not allowed, the app says so, and the countdown itself is unaffected.

Two more are granted by Android at installation, without a prompt, because neither reaches any personal data: vibration, for the last ten seconds, and permission to run after the device restarts, so the widgets and any midnight alarm are set again after a restart, as they are after a change of time or time zone.

The app asks for nothing else: no network access, no location, no contacts, no camera, no microphone, no photos, no calendar, and no access to your files beyond the one song you choose.

6 · The song you choose for midnight

If you choose a song, you pick the file yourself, in Android's own file picker. The app is given permission to read that one file, keeps a reference to it, and plays it at midnight. It does not copy the song, upload it or read any other file.

If the file lives in a cloud service — Google Drive, for example — that service's own app fetches it when it is played. That is the storage provider's network activity, under your arrangement with them; the app itself makes no request.

Removing the song in the app's settings makes the app forget the reference. The file itself is yours and stays where it was.

7 · The app makes no request of its own

Turn the Year contains no networking code and does not ask Android for network access. It has no analytics, no advertising, no crash reporting, no tracking and no software development kit from any third party. It is built from Google's open-source Android libraries, which run on the device, and our own code. It does not use Google Play services.

Two rows in its settings hand you over to somewhere else, and only when you tap them:

• Recommend Another App opens one of our other apps in Google Play. Google Play's own terms and privacy policy apply there.
• Privacy policy opens this page in your browser.

Nothing is sent to us in either case.

8 · What we never do

We do not collect, and have never collected, personal data through this app. We run no servers of our own. We do not sell, share, rent or trade anything, because we hold nothing to trade. There is no profiling and no automated decision-making. The app does not read the advertising ID and is not enrolled in any attribution or measurement framework.

This is why the Google Play listing's Data safety section reads “No data collected” and “No data shared with third parties”. The question there is what is transmitted off the device to the developer or to third parties, and the answer is nothing. It is not the same statement as “your data never leaves your device”, which would be untrue here — section 4 says what does, and where.

9 · The role of Google

Google is not our processor and does not act on our instructions.

• As the distributor of the app through Google Play, Google has its own relationship with you, under the Google Play terms of service and its own privacy policy. The app is free, so no purchase or payment is involved.
• As your backup provider, Google holds the Android backup described in section 4 under your Google Account and your agreement with Google.

Google's handling of your data under either relationship is governed by Google's privacy policy, at policies.google.com/privacy, not by this one.

10 · Legal bases for processing

For the app itself, we process no personal data, so no legal basis arises. What the app keeps stays on the device, except that Android may include your settings in the backup it makes to your own Google Account; that backup is made and held by Google for you, under your arrangement with Google, and never reaches us.

Where you write to us, the basis is Article 6(1)(f), our legitimate interest in responding to correspondence about our software. You may object at any time by asking us to stop, and we will.

11 · Your rights, and how to exercise them

Under the GDPR and the UK GDPR you have rights of access, rectification, erasure, restriction and objection, and the right not to be subject to automated decision-making. Write to support@lustigfairchild.com. We answer within one month, which is the period Article 12(3) allows.

It is worth being concrete about what such a request would be about here, rather than listing rights and leaving you to guess.

Not what is in the app. Your settings sit on your device and, if Android backup is on, in your own Google Account's backup — never with us. Uninstalling the app removes them from the device; the backup is yours to manage in your device's backup settings. There is nothing for us to produce, correct or erase, because we never had it.

Your correspondence, if you have written to us. That we do hold, and it is what a request would concern: what we have, correcting it, deleting it, or asking us to stop. Ask and we will do it.

That is the whole of it. We hold nothing else about you, so for anything beyond those two the honest answer to a request is that there is nothing to give you.

One right genuinely does not apply: portability under Article 20 covers processing based on consent or on a contract, and we process correspondence on the basis of legitimate interests. We would rather say so than list a right we could not honour.

12 · Children

The app is suitable for all ages. It asks no one their age, because it collects nothing from anyone. We do not knowingly process children's personal data, and there is no mechanism in the app by which we could.

13 · Retention, security and international transfers

We retain nothing from the app, so there is nothing to schedule for deletion. Support correspondence is kept for 24 months.

The app's own data never reaches us, so we make no international transfer of it and hold nothing of yours on any server of ours to secure. The security of your Android backup, and where in the world Google stores it, are matters for Google's privacy policy; on the device, the app relies on the operating system's own protection of app data.

14 · Notice for residents of the United States

We do not sell or share personal information as those terms are used in the California Consumer Privacy Act, and we have no personal information from this app to sell or share. We do not use or disclose sensitive personal information beyond what is permitted. No financial incentive is offered for personal information, and nobody is treated differently for exercising a right.

The same holds under the comparable laws of other US states. You may contact us at the address in the last section in any case.

15 · Other jurisdictions

Where local law gives you stronger rights than this policy describes, those rights apply, and nothing here limits them.

16 · Changes to this policy

Every version is dated and numbered, and superseded versions stay published at /legal/archive/ so you can read what applied before. Where a change affects you, the version number moves by a whole number rather than a decimal.

This is the first version of this policy. It covers the Google Play edition only; the App Store edition, when it is released, will have its own.

17 · Contact, and how to complain

support@lustigfairchild.com, or by post at the address in section 1.

You also have the right to complain to a data protection supervisory authority, and you do not have to come to us first. Ours is the Commission for Personal Data Protection in Bulgaria, at cpdp.bg. You may instead complain to the authority in the country where you live or work.