Privacy Policy
This policy explains what data is processed when you use the Rateo Currency Converter app for iPhone (the "App") and this website, who processes it and what choices you have.
In short. The App has no accounts and no analytics. The developer does not collect, store or sell your personal data. Your currencies, amounts and settings stay on your device. Ads in the App are provided by Google AdMob, which processes device and usage data to show ads. Where the law requires it, Google asks for your consent first, and on iOS the App asks for permission before any tracking. Purchases are handled by Apple.
- Who we are
- Data stored on your device
- Exchange rate requests
- Advertising (Google AdMob)
- Consent in the EEA, UK and Switzerland
- App Tracking Transparency
- Purchases
- Crash reports
- This website
- Legal bases
- Retention and transfers
- Your rights in the EEA, UK and Switzerland
- Your rights in California and other US states
- Children
- Changes to this policy
- Contact
1. Who we are
The App is published by Aleksandr Topchienko, an individual entrepreneur registered in Georgia ("we", "us"). For data processed by the App itself we are the controller. Google and Apple act as independent controllers for the data they process, as described below.
Aleksandr TopchienkoAirport Highway 186, 7th Floor, Apartment 33, Batumi 6010, Georgia
eqlapps@gmail.com
2. Data stored on your device
The App saves your chosen currencies, the last amounts, your own exchange rates, display settings, the last downloaded exchange rates and the status of your purchase. This data is stored only on your device, is not sent to us and is deleted when you delete the App. Version 1.0 contains no analytics SDK and creates no account or user profile.
3. Exchange rate requests
To update rates, the App sends requests to the Frankfurter service at frankfurter.dev, which republishes reference rates from the European Central Bank and other central banks. Like any internet request, it reveals your IP address and basic technical data (such as time of the request) to that service and to its network provider Cloudflare. The request does not include any identifier, your amounts or your currencies list beyond the base currency. Frankfurter states that it does not log IP addresses or keep request logs. We do not receive this data.
4. Advertising (Google AdMob)
The App shows ads through the Google Mobile Ads SDK (Google AdMob), provided by Google Ireland Limited for users in the EEA, UK and Switzerland and by Google LLC elsewhere. The SDK runs inside the App and sends data directly to Google. We do not receive personal data from it, only aggregated reports on ad performance.
According to Google's disclosure for the iOS SDK, it may process:
- your IP address and coarse location derived from it;
- device identifiers: the Identifier for Advertisers (IDFA) only if you allow tracking (section 6), and app-scoped identifiers;
- advertising data, such as ads you have seen or tapped;
- product interaction data, such as app launches and taps on ads;
- diagnostic and performance data, such as crash logs and load times;
- device information, such as model, operating system version and language.
Google uses this data to show ads, to measure them, to limit how often you see the same ad and to prevent fraud and abuse. If you have given consent or allowed tracking, ads can be personalized. Otherwise Google shows non-personalized or limited ads, which still use the data above for delivery, frequency capping, measurement and fraud prevention.
We have blocked ad categories that are not suitable for a general audience, such as adult content and gambling. Each ad carries Google's AdChoices icon, where you can see why it was shown and report it.
More information:
- How Google uses information from sites or apps that use its services
- Google Privacy Policy
- Google Mobile Ads SDK data disclosure
5. Consent in the EEA, UK and Switzerland
If you are in the European Economic Area, the United Kingdom or Switzerland, the App shows a consent message from Google's User Messaging Platform (UMP) before any personalized ads. The message is registered under the IAB Transparency and Consent Framework. You can accept, reject or choose purposes and vendors. Rejecting is as easy as accepting, and the App works the same either way.
You can change or withdraw your choice at any time in the App: open the menu and tap Privacy settings. Withdrawal does not affect processing that took place before it.
Where Google offers messages for US state privacy laws, the same Privacy settings item lets you opt out of the sharing of your data for targeted advertising.
6. App Tracking Transparency
On iOS, the App asks for your permission through Apple's App Tracking Transparency prompt before Google can access the IDFA or link data from the App with data from other companies' apps and websites for advertising. In the EEA, UK and Switzerland this prompt appears after the consent message.
If you tap "Ask App Not to Track", the IDFA is not available, ads are not personalized based on tracking and every feature of the App keeps working. You can change your choice at any time in iOS Settings, Privacy & Security, Tracking.
7. Purchases
In-app purchases, such as Remove Ads and any future subscription, are processed by Apple through the App Store. We never receive your name, Apple Account, payment card or billing address. Through Apple's StoreKit the App only learns which products are active on your Apple Account so it can turn off ads. Apple processes payment data under the Apple Privacy Policy. App Store Connect gives us aggregated sales reports that do not identify you.
8. Crash reports
If you have turned on "Share With App Developers" in iOS Settings, Privacy & Security, Analytics & Improvements, Apple shares crash reports and basic diagnostics about the App with us. Apple does not include your name or contact details. We use these reports only to fix bugs. You can turn this off in the same place.
9. This website
This website uses no cookies, analytics or ads. Like any web host, the hosting provider, Cloudflare, processes your IP address and request data in server logs to deliver pages and keep the service secure. We do not use these logs to identify you.
If you email us, we use your email address and message only to answer you and keep the conversation for up to two years, unless the law requires longer.
10. Legal bases
Where the GDPR, UK GDPR or Swiss law applies, we rely on:
- consent for storing and reading information on your device and for personalized ads (section 5), and for tracking (section 6);
- legitimate interests for delivering exchange rates, showing non-personalized ads that fund the free App, measuring ads, preventing fraud and fixing bugs;
- performance of a contract for providing in-app purchases you made;
- legal obligations for keeping records required by tax or other law.
You can object to processing based on legitimate interests at any time (section 12).
11. Retention and international transfers
We do not keep personal data from the App. Data on your device is deleted when you delete the App. Google and Apple keep data for the periods set out in their own privacy policies. Your consent choices are stored on your device until you change them or delete the App.
Google and Apple may process data in the United States and other countries. Transfers from the EEA, UK and Switzerland rely on safeguards such as adequacy decisions, including the EU-US Data Privacy Framework, or Standard Contractual Clauses, as described in their policies. We are based in Georgia.
12. Your rights in the EEA, UK and Switzerland
You have the right to access your personal data, to have it corrected or erased, to restrict or object to its processing, to data portability and to withdraw consent at any time. You also have the right to lodge a complaint with your local data protection authority. Residents of Georgia may contact the Personal Data Protection Service of Georgia.
Because we do not hold personal data from the App, most requests are best handled on your device (Privacy settings in the App, Tracking in iOS Settings) or directly with Google at My Ad Center and Apple at privacy.apple.com. You can always write to us and we will help within one month.
13. Your rights in California and other US states
This section applies to residents of California and other US states with comprehensive privacy laws, to the extent those laws apply to us.
| Category | Source | Disclosed to |
|---|---|---|
| Identifiers (IP address, IDFA if allowed, app-scoped identifiers) | Your device, through the Google Mobile Ads SDK | Google, for advertising |
| Internet or other electronic network activity (ad views and taps, app launches) | Your device, through the Google Mobile Ads SDK | Google, for advertising |
| Approximate geolocation derived from IP address | Your device, through the Google Mobile Ads SDK | Google, for advertising |
| Commercial information (purchase status) | Apple | Not disclosed; used on your device only |
We do not sell personal data for money. Making identifiers and ad activity available to Google for personalized ads may count as "sharing" for cross-context behavioral advertising or "targeted advertising" under these laws. We do not collect sensitive personal information and do not use personal data for profiling with legal or similarly significant effects.
You have the right to know what personal data is processed, to access and delete it, to correct it and to opt out of sharing or targeted advertising. To opt out, choose "Ask App Not to Track" or turn off tracking in iOS Settings, and use Privacy settings in the App where available. You can also email us. We will not discriminate against you for using these rights. You may use an authorized agent, and we may need to confirm the request with you.
14. Children
The App is a general audience utility. It is not directed to children under 13, or under 16 where local law sets a higher age for consent, and is not listed in the App Store Kids category. We do not knowingly collect personal data from children. Ads in the App are limited to content suitable for a general audience. If you believe a child has provided personal data through the App, contact us and we will help remove it with Google.
15. Changes to this policy
We will update this policy before any release that changes how data is processed, for example if analytics or another ad network is added. The effective date at the top shows the latest version. If a change requires your consent, the App will ask for it again.
16. Contact
For any privacy question or request, write to eqlapps@gmail.com or to the postal address in section 1. We reply within one month.