Privacy Policy

1. Controller

Controller within the meaning of the GDPR:

For privacy questions you can reach us at: datenschutz@romo-app.com

Full provider details are in the legal notice.

2. Which data we collect in the app

When you register with an e-mail address, we store your first name, optionally your last name, your e-mail address, your country and your confirmation that you are at least 16 years old. Your name is used only for display in your own profile. In our database it is stored exclusively with end-to-end encryption and cannot be read there by anyone but you. We never show it to other users; in the app they only ever see your username.

If you sign in with Google or Apple, that provider sends us your name and e-mail address, and Google additionally the web address of your Google profile picture. We do not store the picture itself: the app loads it directly from Google only to display it in your profile. ROMO has no profile photo of its own.

Your name and e-mail address are also held in your sign-in account at Firebase Authentication (Google Ireland Limited), which we use as a processor for login (see section 10).

Usage data such as timer sessions (duration, time, result), credits and goals are stored locally on your device and synchronised via Firebase with end-to-end encryption.

Which apps you block is stored exclusively on your device and never leaves it.

We do not collect location data and do not access contacts or photos. The app records anonymised usage statistics only if you explicitly consent (see section 2a).

2b. Events and proof of participation

If you join a ROMO event via an organiser's QR code, we store for that event your username, the platform (iOS or Android) and the status of your participation (planned, started, completed, cancelled) with timestamps. In the ROMO admin portal the organiser only sees participant counts per status.

After a successfully completed event the app shows a QR code with a random proof code. If you show it to an organiser and they scan it, they see the event name, the date, your username and the completion time. If the organiser confirms the proof, we record that and when the code was redeemed; later scans show that time. Your username is only visible to someone who has entered the event's organiser PIN. For those organisers we store a technically necessary cookie in the browser that remembers the PIN entry for that event for three days; it contains no personal data. The legal basis is the performance of the user agreement (Art. 6(1)(b) GDPR); whether you show the code is up to you.

Some events can only be started on site. Only for these events, when you tap "Start timer", the app asks once for your location and compares it on your device with the venue. The location is neither stored nor transmitted to us or the organiser. If you do not allow location access, you cannot start that event; all other functions remain available. You can revoke the permission at any time in your device settings.

2a. Usage statistics in the app (consent only)

To understand which ROMO features are used, the app uses Firebase Analytics by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – exclusively with your consent. Collection is off by default. After the permissions step the app asks once whether it may measure usage; you can accept or keep measurement switched off under "Settings".

With your consent, Firebase Analytics records which screens and features you use, how often timers are started, device type, operating system, app version and approximate region. The contents of your timers, appointments or messages are not recorded. The data is pseudonymised (random app instance ID) and not linked to your account. Google may transfer it to the USA; Google LLC is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).

The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time in the app under Profile → Settings → "Measure usage". From then on nothing is recorded and the analytics data collected on the device is discarded. Google deletes data already transferred from our Analytics account after 14 months at the latest.

3. Website and hosting

The website romo-app.com is operated on a server of Hetzner Online GmbH (Germany). When you access the site, technically necessary server logs are created. They record the IP address, the time of access, the page requested and the browser identifier (user agent).

The purpose is the secure and stable operation of the website and the prevention of abuse. The legal basis is our legitimate interest in trouble-free operation (Art. 6(1)(f) GDPR). The logs are rotated daily and automatically deleted after 7 days at the latest; they are not merged with other data.

The website does not set technically necessary cookies. Fonts are loaded from our own server and not from Google Fonts or any other service. Your decision on audience measurement (see section 3b) is stored locally in your browser; this entry contains no personal data and is not transmitted to us.

If you submit the newsletter form, the request goes to our own API at api.romo-app.com, which also runs at Hetzner in Germany. No data is transmitted to third parties.

3a. Our own cookie-free page counter

To know how often our pages are viewed, we run our own very minimal counter. When a page loads, your browser only transmits the path of the page (for example "/imprint") to our API api.romo-app.com. All that is stored is how often which page was viewed on which day.

No cookies are set, no identifiers are assigned and neither IP address nor browser identifier is stored. It is therefore impossible to attribute views to a person or recognise a returning visitor. The counter runs independently of your choice in the cookie notice.

The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in understanding website usage in aggregated form. The counts contain no personal data and are kept indefinitely.

3b. Audience measurement with Google Tag Manager and Google Analytics

On romo-app.com we use – only with your consent – Google Tag Manager and Google Analytics 4. Both services are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

On your first visit, a notice at the bottom of the screen asks whether we may measure how the site is used. As long as you have not consented, no Google script is loaded, no cookies are set and no data is transmitted to Google. If you choose "Essential only", it stays that way. If you choose "Accept", the browser loads Google Tag Manager, which in turn starts Google Analytics.

Google Analytics then records which pages you visit, how long you stay, which page you came from, and technical details such as browser, operating system, screen size and approximate region. Google uses your IP address only to determine location and does not store it permanently (Google Analytics 4 works without IP storage). We have disabled the advertising features of Google Analytics; there is no linking with Google accounts or advertising IDs.

Google Analytics sets cookies with a lifetime of up to two years to recognise returning visits. The analyses are aggregated and help us improve the website and understand which content is used.

The legal basis is your consent (Art. 6(1)(a) GDPR and § 165(3) Austrian Telecommunications Act 2021). You can withdraw it at any time via the "Cookie settings" link in the website footer; from then on nothing is loaded on future visits. You can delete Google cookies already set in your browser.

Google may transfer data to the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework; the legal basis for the transfer is the adequacy decision of the EU Commission (Art. 45 GDPR). A data processing agreement with Google is in place (Google Ads Data Processing Terms). Further information: policies.google.com/privacy and support.google.com/analytics/answer/6004245.

4. Newsletter

If you sign up for the newsletter on romo-app.com, we use your e-mail address exclusively to send you news about ROMO. The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by ticking the checkbox in the form.

We store:

• your e-mail address,
• the time and wording of your consent (proof under Art. 7(1) GDPR),
• your IP address exclusively as a salted SHA-256 hash for abuse detection – the plain IP is not stored,
• the browser identifier (user agent) and the source of the sign-up.

We use double opt-in: after signing up you receive an e-mail with a confirmation link. Only when you click this link does your sign-up take effect and you receive news from us. Without the click, the entry remains unconfirmed and is not used for mailings. We store the time of confirmation and the IP address at the click as a salted hash in order to prove your consent.

Every e-mail we send contains a personal unsubscribe link. For the confirmation and unsubscribe links we store one random identifier each for your address, as well as the time the confirmation e-mail was sent.

We keep this data until you withdraw your consent. You can withdraw at any time via the unsubscribe link in one of our e-mails or informally by e-mail to datenschutz@romo-app.com. After withdrawal we no longer use your address for mailings; we keep a record of the unsubscription itself and how it was made as proof.

The newsletter list is stored on a server of Hetzner Online GmbH in Germany. It is not passed on to third parties and not used for third-party advertising.

5. Best of the Month (optional)

Participation in the monthly country ranking "Best of the Month" is voluntary and disabled by default. The legal basis is your consent (Art. 6(1)(a) GDPR).

Only when you enable the ranking under Profile → Screen Time do your username, your country (taken automatically from your device region, e.g. "AT") and your credits for the current month become visible to other ROMO users. Your name, e-mail address, timer times, goals and the apps you block are never published.

If you switch participation off again, we delete your ranking entry immediately – it then disappears for all other users as well.

6. Legal bases of processing

The processing of your data is based on the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR): registration, account management, timer functions, credits, synchronisation.
• Consent (Art. 6(1)(a) GDPR): push notifications and motivational messages – you give this consent in the app settings and can withdraw it there at any time. Likewise the newsletter sign-up, participation in the "Best of the Month" ranking, audience measurement on the website with Google Tag Manager and Google Analytics (section 3b) and usage statistics in the app with Firebase Analytics (section 2a).
• Legitimate interest (Art. 6(1)(f) GDPR): anonymised analysis to improve app stability, the secure operation of the website (server logs) and the cookie-free page counter (section 3a).

7. Purpose of processing

We process your data for the following purposes:

• Providing the app features: account management, timer history, statistics and cross-device synchronisation.
• Sending push notifications, if you have enabled them.
• Sending the newsletter, if you have signed up for it.
• Providing and securing the website.

Your data is never sold to third parties or processed for advertising purposes.

8. Storage and security

Local data is kept in the app sandbox on your device.

For cloud synchronisation ROMO encrypts your usage data (timers, credits, goals) with AES-256-GCM before it reaches Firebase. The key is stored exclusively in your device's secure key store (iCloud Keychain on iOS, encrypted app storage on Android). Neither we nor Google can read the encrypted data.

Cloud data is stored on Firebase servers in the EU (region europe-west). Transmission is additionally encrypted in transit (TLS 1.2+). The website and the newsletter form are also served exclusively over HTTPS.

Payment data is processed directly by the app stores (Apple via StoreKit, Google via Google Play). We have no access to credit card or bank account data.

9. Retention period

We store your data as long as your account is active. When you delete your account, all personal cloud data is irrevocably deleted within 30 days. You remove local data on your device by uninstalling the app.

Newsletter data is kept until you withdraw your consent (see section 4). Website server logs are deleted after 7 days at the latest (see section 3).

Google Analytics data is automatically deleted from our Analytics account after 14 months; Google Analytics cookies expire after two years at the latest (see section 3b). Firebase Analytics data in the app is likewise deleted after 14 months at the latest (see section 2a).

Anonymised statistical data without personal reference may be retained beyond account deletion.

10. Third parties and data transfers

Firebase (Google Ireland Limited): authentication and encrypted data storage. Google is certified under the EU-U.S. Data Privacy Framework. The legal basis for transfers to the USA is the adequacy decision of the EU Commission (Art. 45 GDPR).

Google Ireland Limited: Google Tag Manager and Google Analytics 4 on the website – exclusively after your consent (section 3b). Data transfer to the USA on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR).

Google Ireland Limited: Firebase Analytics in the app – exclusively after your consent (section 2a), off by default. Data transfer to the USA on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR).

Apple Inc.: processing of in-app purchases via StoreKit and provision of the Screen Time API (FamilyControls).

Hetzner Online GmbH (Germany): hosting of the website romo-app.com, the API api.romo-app.com and the newsletter list. The data stays within the EU. A data processing agreement under Art. 28 GDPR is in place with Hetzner.

We use no other third-party services on the website. Your encrypted usage data cannot be read without your personal key – not even by Firebase.

11. Your rights

You have the following rights:

• Access to stored data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure of your data (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability – export as JSON (Art. 20 GDPR)
• Objection to processing (Art. 21 GDPR)
• Withdrawal of consent with effect for the future (Art. 7(3) GDPR)

You can delete your account and all cloud data in the profile settings. You can export your data there as a JSON file. For newsletter matters an e-mail to datenschutz@romo-app.com is sufficient.

12. Right to lodge a complaint

If you believe that the processing of your data violates the GDPR, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The supervisory authority responsible for us is the Austrian Data Protection Authority (dsb.gv.at).

Privacy contact

datenschutz@romo-app.com