Privacy Policy

Effective Date: August 13, 2026

1. Data Controller and General Information

This Privacy Policy (the “Policy”) describes how Mediartis LTD and Alphyn Apps DOO (“Company”, “we”, “us”, “our”) collects, uses, processes, stores and protects information in connection with the Hungry Apollo mobile application (the “Application”).

This Policy applies to users of the Application worldwide, subject to applicable data-protection and privacy laws.

The Application is jointly owned by Mediartis LTD and Alphyn Apps DOO.

For the purposes of applicable data-protection law, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Mediartis LTD acts as the data controller in relation to the processing described in this Policy.

Mediartis LTD
Registration No. HE 433075
2407 Nicosia
Republic of Cyprus
Email: info@mediartis.eu

We follow a data-minimisation approach and seek to process only information reasonably necessary to operate, maintain, secure, analyse and improve the Application and provide its functionality.

The Application does not require Users to provide their name, email address, telephone number or other directly identifying information in order to use its core functionality.

However, certain technical information, device or application identifiers and usage information may constitute personal data under applicable law even where such information does not directly identify a User by name.

2. No Account Registration

The Application does not currently require the creation of a separate User account with the Company.

Users may access the Application without providing a name, email address, password or other account-registration information.

Because no Company account is required, the Company may not be able to associate technical information collected by the Application with the real-world identity of an individual User unless the User voluntarily provides additional identifying information.

3. Information We May Collect

Depending on the User’s Device, operating system, Application version, settings, use of the Application and services enabled within it, we may process the following categories of information.

Device and Technical Information

This may include:

• Device type and model;
• operating system and operating-system version;
• Application version;
• language and locale settings;
• country or general region derived from Device or Application settings;
• time zone;
• technical identifiers associated with an installation or Application instance;
• technical information concerning the operation of the Application.

Usage and Analytics Information

We may automatically collect information concerning how the Application is used, including:

• Application launches and sessions;
• screens or features viewed or used;
• interaction with facts, quizzes and other Content;
• navigation and engagement events;
• frequency and duration of Application use;
• general usage patterns;
• Application performance information;
• analytics identifiers and similar technical identifiers.

We use this information to understand how the Application is used, evaluate performance, identify popular or underused functionality, improve Content and functionality and develop the Application.

Crash and Diagnostic Information

If the Application experiences an error, crash or other technical problem, diagnostic information may be processed, including:

• crash reports;
• error information;
• Application state at the time of an error;
• Device and operating-system information;
• Application version;
• technical identifiers;
• diagnostic and performance information reasonably necessary to identify and investigate technical problems.

Subscription and Purchase Information

Payments are processed by Apple App Store, Google Play or another authorised App Store.

The Company may receive limited information necessary to determine whether a User is entitled to Paid Features, such as subscription or purchase status, product or subscription type, entitlement information and transaction-related identifiers.

The Company does not receive or store the User’s full payment-card details.

Notification Information

Where push notifications are enabled, the Application or its service providers may process:

• notification permission status;
• push-notification registration tokens or technical identifiers;
• information reasonably necessary to deliver and manage notifications.

The User may manage notification permissions through the Device settings.

Information Voluntarily Provided to Us

If a User contacts the Company, we may process information voluntarily included in that communication, including:

• name, if provided;
• email address or other contact details;
• the content of correspondence;
• screenshots;
• Device or technical information supplied by the User;
• information relating to a complaint, support request, intellectual-property notice, refund matter or other enquiry.

The User is not required to provide information unrelated to the purpose of the communication.

Information Stored Locally on the Device

Certain Application functionality may store information locally on the User’s Device.

For example, saved favourites or similar personal selections may be stored locally and may not be transmitted to or stored on the Company’s servers.

Locally stored information may be lost if the Application is deleted, the Device is replaced or reset, local storage is cleared or other technical circumstances affect such data.

4. How We Use Information

We may process information for purposes including:

• providing and operating the Application;
• providing Content and Application functionality;
• determining access to Free Features and Paid Features;
• verifying subscription or purchase status;
• maintaining Application functionality and compatibility;
• analysing Application usage and engagement;
• understanding how Users interact with Content and features;
• improving Content, functionality, interface and User experience;
• identifying and correcting errors, crashes and technical problems;
• monitoring technical performance;
• maintaining security and preventing misuse, fraud or abuse;
• delivering push notifications where enabled;
• responding to enquiries, complaints, support requests and legal notices;
• protecting the Company’s legal rights and the rights of Users and third parties;
• complying with applicable legal, regulatory, accounting or other obligations.

We do not use personal data for purposes incompatible with those described in this Policy unless permitted or required by applicable law.

5. Legal Bases for Processing

Where the GDPR or similar data-protection legislation applies, the legal basis for processing depends on the nature and purpose of the processing.

We may process information where processing is necessary:

• for the performance of a contract with the User or to provide functionality requested by the User;
• for the Company’s legitimate interests, including operating, maintaining, analysing, securing and improving the Application, understanding its use, preventing abuse, diagnosing technical problems, responding to enquiries and protecting legal rights;
• to comply with a legal obligation;
• on the basis of consent where consent is requested or required for a particular type of processing; or
• on another legal basis recognised by applicable law.

Where processing is based on legitimate interests, we seek to balance those interests against the rights and interests of Users.

Where processing is based on consent, the User may withdraw that consent in accordance with applicable law.

6. Analytics, Firebase and Other Third-Party Services

The Application uses third-party technologies and service providers to operate, analyse, maintain and improve the Application.

These may include:

Google Analytics for Firebase (Firebase Analytics)
Used to analyse Application usage, interaction, engagement and performance. Firebase Analytics may process Application-instance or installation identifiers, Device and Application information and information about events and interactions within the Application.

Firebase Crashlytics
Used to identify, diagnose and analyse crashes, errors and technical problems. Crashlytics may process crash information, diagnostic information, Device and Application information and technical identifiers associated with an Application installation.

Firebase Cloud Messaging
Used to support the delivery of push notifications and related functionality. This service may process technical registration tokens and identifiers necessary for notification delivery.

Cloud, hosting and technical infrastructure providers
We may use third-party providers to support the operation, security, storage, delivery or technical infrastructure of the Application.

Third-party service providers may process information on our behalf or otherwise in connection with the services they provide.

The exact categories of information processed by a third-party service may depend on the Application configuration, Device, operating system, service configuration and the User’s interaction with the Application.

Third-party providers may maintain their own privacy documentation describing their processing practices.

We take reasonable steps to use service providers that provide appropriate data-protection and security safeguards.

7. Payments and Subscriptions

Purchases, subscriptions, renewals, cancellations and payment processing are handled through Apple App Store, Google Play or another authorised App Store through which the relevant transaction is made.

The relevant App Store may process payment information in accordance with its own privacy policy and terms.

The Company does not receive or store full payment-card information.

We may receive limited transaction, purchase, subscription or entitlement information necessary to verify a purchase, determine subscription status, restore access or provide Paid Features.

Refund requests may also be processed through the relevant App Store.

8. Disclosure of Information

We may disclose or make information available to:

• service providers that operate or support the Application;
• analytics, diagnostic, notification, cloud and infrastructure providers;
• Apple, Google or other App Store operators where relevant to purchases, subscriptions, Application distribution or platform requirements;
• professional advisers where reasonably necessary for legal, accounting or other professional purposes;
• governmental, judicial, regulatory or law-enforcement authorities where disclosure is required by applicable law or a legally binding request;
• another entity in connection with a merger, acquisition, corporate restructuring, transfer of the Application or similar transaction, subject to applicable law.

We may also disclose information where reasonably necessary to establish, exercise or defend legal claims, investigate fraud or abuse, protect the security of the Application or protect the rights or safety of the Company, Users or third parties.

We do not sell personal data.

9. International Data Transfers

The Application and its service providers operate internationally.

As a result, information may be processed in countries outside the European Economic Area (“EEA”), including countries whose data-protection laws may differ from those applicable within the EEA.

Where personal data subject to the GDPR is transferred outside the EEA and applicable law requires safeguards for such transfer, we rely on legally recognised transfer mechanisms where appropriate, which may include:

• an adequacy decision;
• Standard Contractual Clauses approved by the European Commission;
• contractual, organisational or technical safeguards; or
• another lawful transfer mechanism available under applicable data-protection law.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it is processed, subject to applicable legal requirements.

The applicable retention period may depend on:

• the nature of the information;
• the purpose for which it is processed;
• the duration of the User’s use of the Application;
• technical and security requirements;
• settings and retention periods applied by relevant service providers;
• the need to investigate or resolve technical problems, complaints or legal claims;
• applicable statutory, regulatory, tax, accounting or other retention requirements.

Analytics and diagnostic information may be retained in accordance with the settings and retention periods applicable to the relevant Firebase or other service.

Communications and complaints may be retained for a reasonable period where necessary to respond to the matter, maintain appropriate records, establish or defend legal rights or comply with applicable law.

Information stored only locally on the User’s Device remains subject to the storage and deletion mechanisms of that Device and the Application.

When information is no longer reasonably required, it may be deleted, anonymised or otherwise processed in a manner permitted by applicable law.

11. User Rights

Depending on the User’s location and applicable law, the User may have rights concerning personal data, including the right to:

• request information about personal data being processed;
• request access to personal data;
• request correction of inaccurate personal data;
• request deletion of personal data;
• request restriction of processing;
• object to certain processing;
• request data portability where applicable;
• withdraw consent where processing is based on consent;
• lodge a complaint with a competent data-protection supervisory authority.

Requests may be submitted to:

info@mediartis.eu

Because the Application does not require account registration and the Company generally does not seek to identify individual Users, in some circumstances we may not be able to identify which technical data relates to a particular person solely on the basis of their name or email address.

Where reasonably necessary, we may request information sufficient to identify the relevant data or verify a request, subject to applicable law.

Nothing in this Policy restricts any data-protection right that cannot lawfully be restricted.

12. Security

We implement reasonable technical and organisational measures intended to protect personal data against unauthorised access, disclosure, alteration, loss, destruction or misuse.

Access to information is limited where reasonably appropriate to persons and service providers requiring access for legitimate operational purposes.

However, no software, Device, network, transmission method or storage system can be guaranteed to be completely secure.

13. Children

The Application is not intended for individuals under the age of 16.

We do not knowingly seek to collect personal data directly from individuals under the age of 16.

If we become aware that personal data has been collected from an individual under 16 in circumstances where such processing is not permitted, we may take reasonable steps to delete or otherwise address the information in accordance with applicable law.

A parent or legal guardian who believes that a child has provided personal data to the Company may contact us at info@mediartis.eu.

14. Automated Decision-Making

The Application may use automated or algorithmic processes for purposes such as determining the order or selection of Content, analysing usage or operating Application functionality.

The Company does not use personal data to make decisions producing legal effects or similarly significant effects on Users through solely automated processing, unless otherwise disclosed or permitted by applicable law.

15. Changes to this Privacy Policy

We may update this Policy from time to time to reflect changes in the Application, our processing practices, third-party services, legal requirements, technology or other relevant circumstances.

The current version of the Policy will be made available within the Application or through another reasonably accessible means.

The Company may specify an effective date for an updated Policy.

Where a change materially affects the processing of personal data and applicable law requires notice, consent or another action, we will handle the change in accordance with applicable legal requirements.

Changes to this Policy do not affect rights that Users have under mandatory applicable data-protection law.