Privacy Policy

1. Controller

Halona Trading GmbH

Address: Hauptstrasse 59, 50259 Pulheim, Germany

Email: ops+legal@halona.trading

2. Scope

This Privacy Policy explains how Halona Trading GmbH ("we", "us", or "our") processes personal data in connection with the Outta Bed mobile application (the "App") and the Outta Bed landing page (the "Website").

The App does not require user account creation. However, when you use the App, subscribe, visit the Website, or contact us, certain personal data may still be processed.

3. Categories of data we process

We may process the following categories of personal data:

Usage and analytics data, such as app interactions, device information, approximate usage patterns, and technical identifiers collected through Firebase Analytics.

Subscription and transaction-related data, such as product identifiers, subscription status, purchase history, trial status, renewal and expiration dates, store-related transaction information, and pseudonymous app user identifiers processed through RevenueCat and the relevant app store.

Technical website and hosting data, such as IP address, browser type, device information, date/time of requests, referring pages, and server log data generated when you visit the Website hosted on Vercel.

Communications data, such as your name, email address, and the contents of messages you send to us if you contact support or make a legal/privacy request.

4. Purposes and legal bases

We process personal data for the following purposes and legal bases under applicable law, including the GDPR where applicable:

To operate, secure, and improve the App and Website. Legal basis: legitimate interests in providing and improving our services, Article 6(1)(f) GDPR.

To measure usage and performance and understand how the App and Website are used. Legal basis: where required, your consent under Article 6(1)(a) GDPR; otherwise, our legitimate interests under Article 6(1)(f) GDPR.

To provide subscription features, verify purchases, manage trials, and determine entitlement status. Legal basis: performance of a contract under Article 6(1)(b) GDPR and, where needed, legitimate interests under Article 6(1)(f) GDPR.

To comply with legal obligations, including tax, accounting, fraud-prevention, and consumer law requirements. Legal basis: Article 6(1)(c) GDPR.

To establish, exercise, or defend legal claims and enforce our Terms. Legal basis: legitimate interests under Article 6(1)(f) GDPR.

5. Analytics and consent

If required by applicable law, we will only activate analytics after obtaining your consent. The App does not currently offer an in-app control to withdraw analytics consent. This point should be reviewed with legal counsel before launch in any jurisdiction where consent-based analytics requires an easy withdrawal mechanism.

6. Payment and subscription processing

The App offers paid subscriptions through the Apple App Store and/or Google Play. Purchases are billed by the relevant store through your store account.

We use RevenueCat as a processor/service provider to help us manage subscription offerings, paywalls, purchase validation, and subscription status across supported platforms.

We do not receive or store your full payment card details. Payment processing is handled by the relevant app store.

7. Processors and recipients

We may share personal data with the following categories of recipients as necessary for the purposes described above:

Google / Firebase (analytics and related infrastructure).

RevenueCat (subscription and entitlement management).

Apple and/or Google, as the operators of the applicable app store and payment platform.

Vercel (website hosting and related infrastructure).

Professional advisers, auditors, authorities, courts, or other recipients where legally required or reasonably necessary.

8. International transfers

Some of our service providers may process personal data outside your country, including outside the European Economic Area. Where required, we use appropriate safeguards for such transfers, such as adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms.

9. Data retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Analytics and technical data are retained for as long as needed to measure, secure, and improve the App and Website.

Subscription and transaction-related data may be retained as long as necessary for subscription administration, accounting, fraud prevention, dispute handling, and legal compliance.

Communications may be retained for as long as necessary to process your request and for follow-up, record-keeping, or legal purposes.

10. Your rights

Depending on applicable law, you may have the right to request access to your personal data, rectification, erasure, restriction of processing, data portability, and to object to certain processing.

Where processing is based on consent, you may withdraw consent at any time with effect for the future.

You may also lodge a complaint with a competent data protection authority.

To exercise your rights, contact us at ops+legal@halona.trading.

11. Children

The App and Website are not directed to children under the age required by applicable law to validly consent to data processing without parental involvement. If you believe that a child has provided personal data to us unlawfully, please contact us.

12. Security

We use reasonable technical and organizational measures intended to protect personal data against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on the Website and/or in the App and update the effective date above. Material changes may also be highlighted in-app or on the Website where appropriate.