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Dowelly privacy policy
1. Who is the controller
The controller of your personal data is company name, address, tax ID (NIP) number ("we"). Contact on personal data: privacy email or by post to the address above. We have not appointed a data protection officer.
2. In short
- The app works without an account. Without an account your projects stay on your device only and nothing reaches us.
- An account is optional. With an account we store your email, name and projects so they work on several devices.
- We keep the data on a server in the European Union. Traffic to the server passes through the Cloudflare network (section 6).
- No ads, tracking, analytics or AI. We do not sell data, do not profile you, and do not send projects to artificial intelligence models.
- You delete your account in the app (Account → "Delete account"): the account and all projects are removed from the server.
3. What data, why, and on what legal basis
3.1. Without an account: data on the device only
The app saves this data in your device's storage. It does not send it to us.
| Data | Why |
|---|---|
| Projects (rooms, dimensions, wardrobes, names, notes) | working on a project offline |
| Selected app language | showing the app in your language |
You remove the data from the device by uninstalling the app.
3.2. With an account: data on our server
| Data | Source | Why | Legal basis (GDPR) | How long |
|---|---|---|---|---|
| Email address | you, or Apple/Google | creating the account, signing in, contact about the account (e.g. changes to the terms) | Art. 6(1)(b): the contract for keeping the account | until the account is deleted |
| Name (the name entered at sign-up or passed by Apple/Google) | you, or Apple/Google | showing it in the app | Art. 6(1)(b) | until the account is deleted |
| Password, stored only as a hash; we do not know the password | you | signing in | Art. 6(1)(b) | until the account is deleted |
| Whether the email is verified; account creation and change dates | the system | running the account | Art. 6(1)(b) | until the account is deleted |
| Profile picture (image address), if Google passes one | stored by the sign-in library; the app does not use it | Art. 6(1)(b) | until the account is deleted | |
| Sign in with Apple/Google: account identifier at the provider, access tokens passed by the provider | Apple / Google | signing in through the provider | Art. 6(1)(b) | until the account is deleted |
| Session: session token, IP address, browser/system name (user agent), sign-in and expiry time | the system at sign-in | keeping you signed in, account security | Art. 6(1)(b) and (f): our legitimate interest in protecting accounts | until expiry or sign-out, at most session length |
| Projects: name, project file (room, dimensions, wardrobes, notes), version number, change time | you | syncing between devices | Art. 6(1)(b) | until the account is deleted |
| Device identifier: a random number the app assigns at the first sync (not a hardware or advertising identifier) | the app | telling which device saved a project and resolving conflicts | Art. 6(1)(b) | together with the project |
| IP address with each request (sign-in attempt counter in server memory) | the system | protection against password guessing | Art. 6(1)(f): security | in memory only, a few seconds; gone after a server restart |
| Email verification and password reset codes (once we enable these features) | the system | confirming the address, resetting the password | Art. 6(1)(b) | until the code is used or expires |
Your clients' data in projects. A project may contain information about your client (e.g. an address in the project name or a note). We do not need it; please do not enter it unless you have to. If you do, you decide about that data and we store it on your behalf.
3.3. Contacting us
If you write to us (support, a complaint, a data request), we process your email address and the message to reply: Art. 6(1)(b) (complaint, contract) or (f) (answering a question) or (c) (handling your GDPR rights). We keep the correspondence for period.
3.4. In-app purchases
Payments are handled by the App Store or Google Play. We do not receive card or payment details. Apple and Google process payment data as separate controllers under their own privacy policies. From the Store we receive only the purchase information needed to unlock features: purchase data (e.g. transaction identifier, product, subscription expiry date).
3.5. What we do not collect
- We do not use analytics, ads or tracking tools.
- We do not collect location, contacts, photos or camera data.
- We do not send data to artificial intelligence models. The app has no AI features.
- We do not make solely automated decisions with legal effects on you (Art. 22 GDPR) and do not profile you.
4. Do you have to provide data
No. The app works without an account. To create an account we need an email address (and a name and password when signing up with email); without them we cannot create the account.
5. Where the data is
- The server with the database is in server country and city at server provider (European Union).
- Database backups: on the same server (period) and in off-server backup location in the EU (e.g. Cloudflare R2 with EU jurisdiction), kept for at most backup retention period.
- The connection to the server is encrypted (HTTPS/TLS).
6. Who receives the data
We do not sell data. Only companies that help us provide the service have access, under data processing agreements (Art. 28 GDPR):
| Recipient | Role | What data | Where |
|---|---|---|---|
| server provider | server and database hosting | all data from section 3.2 | country (EU) |
| Cloudflare, Inc. | sits in the traffic to the server (attack protection, DNS, certificate), and in future stores backups (R2) | network traffic: IP address, requests and responses (including data from section 3.2 in transit) | global network; R2 backups with EU jurisdiction |
| email provider (once we enable emails) | sending emails (address verification, password reset, notices) | email address, message content | country |
Separate controllers (not acting on our behalf) are:
- Apple and Google: when you sign in through them (Sign in with Apple, Google sign-in), and for app downloads and Store payments. Their policies: www.apple.com/legal/privacy/, policies.google.com/privacy.
- Public authorities: only when the law requires it.
Outside the European Economic Area. Cloudflare, Inc. is a US company. The transfer is based on transfer basis (e.g. the European Commission decision on the EU-US Data Privacy Framework or standard contractual clauses). You can get a copy of the safeguards by writing to privacy email.
7. Your rights
You have the right to:
- access your data and get a copy,
- rectify your data (you change your name and projects in the app),
- erase your data: the simplest way is deleting your account (section 8),
- restrict processing and data portability (you can also export projects to PDF and CSV in the app),
- object to processing based on our legitimate interest (Art. 6(1)(f)).
Send your request to privacy email. We reply within one month. We may ask you to confirm that you own the account (e.g. a message from the account's address).
You also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl).
8. Deleting your account
- In the app: Account → "Delete account", then your password or signing in again.
- Without the app: the form at dowelly.app/en/delete-account/ or an email to privacy email from the account's address.
- Deleting the account immediately removes from the server: the account, sessions, the link to Apple/Google and all projects. The app also removes the projects from the device on which you deleted the account.
- Data in backups disappears when the backups expire, at the latest after backup retention period. If we restore the server from a backup, we delete the previously deleted accounts from it again.
- Deleting the account does not cancel a Store subscription; do that in the App Store or Google Play settings.
- If you signed in with Apple, you can also disconnect Dowelly in your Apple ID settings.
9. Security
- Encrypted connection (TLS) between the app and the server.
- We store passwords only as a cryptographic hash.
- The database is not reachable from the internet; only our API server connects to it.
- Sign-in attempt limits protect against password guessing.
- The sign-in token is stored in the app's private storage on the device; signing out removes it.
10. Children
The app is meant for furniture designers and carpenters. It is not directed at children. An account can be created by a person aged age or over.
11. Cookies and similar technologies
The app does not use cookies for tracking or ads. It stores on the device only what it needs to work: the sign-in token, a random device identifier, the sync state and the selected language.
12. Changes to this policy
We will tell you about significant changes in the app and by email (users with an account) before they take effect. Previous versions are available at archive address.
Last changed: date.