PRIVACY POLICY

PRIVACY POLICY

Crypto Signals — Educational Crypto App

Last Updated: July 17, 2026

⚠ IMPORTANT NOTICE — EDUCATIONAL PURPOSE ONLY

This application ("Crypto Signals" or the "App") is provided strictly for educational and informational purposes only. Nothing in this App constitutes financial advice, investment advice, trading advice, or any other type of advice. The crypto market data, signals, and analysis presented are intended solely to help users learn about cryptocurrency markets. You should not make any financial or investment decisions based on the information provided by this App. Always consult a qualified financial advisor before making any investment decisions.

1. Introduction

This Privacy Policy explains how Dragos Andries, operating as a sole trader (Einzelunternehmer) registered in Germany ("we", "us", or "our"), collects, uses, stores, and protects your personal data when you use the Crypto Signals mobile application on Android devices (the "App" or "Service").

As a business registered and operating in Germany, we are subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the German Federal Data Protection Act (Bundesdatenschutzgesetz — BDSG). We take your privacy seriously and process your data only on lawful grounds as defined by Article 6 GDPR.

By downloading and using the App, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The controller responsible for your personal data within the meaning of Art. 4(7) GDPR is:

Dragos Andrei Andries

Operating as: DA Apps

Address: c/o flexdienst – #20886, Kurt-Schumacher-Straße 76, 67663 Kaiserslautern, Germany

Contact Email: Luvrufashion@gmail.com

Tax Number (Steuernummer): 154/201/01772

3. What Data We Collect

3.1 Usage and Technical Data

We automatically collect certain technical information when you use the App:

• IP address (anonymised where possible)

• Device type, model, and manufacturer

• Operating system version

• Unique device identifiers (e.g. Android Advertising ID, if applicable)

• App version and crash/diagnostic reports

• Timestamps of interactions with the App

3.2 Subscription and Payment Data

If you subscribe to the "PRO" tier of the App, payments are processed exclusively via Google Play In-App Billing. We do not receive, store, or process your payment card details. Google LLC acts as the payment processor and data controller for payment transactions. We receive only confirmation of subscription status (active, expired, cancelled) from Google.

3.3 Data We Do NOT Collect

We do not collect:

• Account data — the App does not offer or require user accounts, registration, usernames, or passwords

• Push notification tokens — the App does not register your device for push messaging; signal alerts are generated on your device

• Precise GPS or location data

• Contacts, calendar, or camera data

• Data from users under the age of 18 (see Section 10)

• Sensitive personal data as defined in Art. 9 GDPR (health, biometric, political opinions, etc.)

4. Legal Basis for Processing (GDPR Art. 6)

We process your personal data only where we have a valid legal basis under the GDPR:

• Performance of a contract (Art. 6(1)(b) GDPR): Processing your subscription status is necessary to provide the PRO tier of the Service to you.

• Consent (Art. 6(1)(a) GDPR): In the EEA and UK, analytics and personalised advertising are activated only with your explicit consent given via the in-app consent form. You may withdraw this consent at any time via "Privacy options" in the app's Settings.

• Legitimate interests (Art. 6(1)(f) GDPR): We process technical/usage data to maintain security, diagnose bugs, and improve the App. This interest is not overridden by your rights and freedoms.

• Legal obligation (Art. 6(1)(c) GDPR): We may retain certain data to comply with German tax, commercial, and regulatory obligations (e.g. §§ 238, 257 HGB; §§ 140, 147 AO).

5. How We Use Your Data

We use the data collected for the following purposes:

• To verify and manage your PRO subscription status

• To display educational crypto market signals, price alerts, and notification history in the App

• To monitor App performance and diagnose technical issues

• To improve the App's features and content

• To comply with our legal and regulatory obligations under German and EU law

• To respond to your support inquiries

We will never sell your personal data to third parties, nor use it for automated profiling or decision-making that produces legal or similarly significant effects on you.

6. Data Sharing and Third-Party Services

We share your data with third parties only where strictly necessary:

6.1 Google LLC (Firebase / Play Billing / AdMob)

We use services provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA):

• Google Play Billing: for processing in-app purchases. Google acts as an independent data controller for payment data.

• Google Analytics for Firebase: for app usage analytics (see Section 12). In the EEA and UK, analytics is switched off until you give consent via the in-app consent form, and remains off if you decline. Data may be transferred to the USA under Google's Standard Contractual Clauses (SCCs) as approved by the European Commission.

• Google AdMob: for serving advertisements to free-tier users (banner, interstitial, app-open, native, and optional rewarded ads). In the EEA and UK, we request your consent through Google's certified consent form (IAB Transparency & Consent Framework) before ads are requested. AdMob may process your IP address, device information, and Android Advertising ID. You can change your consent choice at any time via "Privacy options" in the app's Settings, and reset or delete your Advertising ID in your Android device settings.

Google's privacy policy is available at: https://policies.google.com/privacy

6.2 Supabase (Backend Hosting)

Our signal delivery backend is operated on Supabase (Supabase, Inc.). The backend provides the signal feed and the notification history shown in the App; price alerts you create are stored without any account or user identifier. As with any internet service, our backend provider technically processes your IP address in order to deliver responses to your device. Supabase processes data only on our behalf under a Data Processing Agreement (DPA) as required by Art. 28 GDPR. Where data is processed outside the EEA, the safeguards described in Section 7 apply.

6.3 Legal Disclosure

We may disclose your personal data if required to do so by law or in response to a valid request from public authorities in Germany or the EU (e.g. courts, police, tax authorities).

6.4 No Sale of Data

We do not sell, rent, or trade your personal data to any third party for marketing or commercial purposes.

7. International Data Transfers

Some of our third-party service providers, such as Google LLC, are located outside the European Economic Area (EEA). Where data is transferred outside the EEA, we ensure that appropriate safeguards are in place in accordance with Chapter V GDPR, including:

• Standard Contractual Clauses (SCCs) adopted by the European Commission (Art. 46(2)(c) GDPR)

• Adequacy decisions where applicable

You may request details of the specific safeguards in place by contacting us at the address in Section 2.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Subscription data: retained for up to 10 years to comply with German commercial and tax record-keeping obligations (§ 257 HGB, § 147 AO).

• Analytics and usage data: retained by Google Analytics for a maximum of 14 months, then deleted automatically; other technical logs are retained for a maximum of 12 months, then anonymised or deleted.

• Price alerts: stored on our backend without any account or user identifier and deleted when you remove them in the App.

9. Your Rights Under the GDPR

As a data subject in the EU/EEA, you have the following rights under the GDPR. You may exercise these rights at any time by contacting us at the email address in Section 2:

• Right of access (Art. 15 GDPR): You have the right to receive a copy of the personal data we hold about you.

• Right to rectification (Art. 16 GDPR): You may request correction of inaccurate or incomplete data.

• Right to erasure / 'Right to be forgotten' (Art. 17 GDPR): You may request deletion of your data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.

• Right to restriction of processing (Art. 18 GDPR): You may request that we restrict processing of your data in certain circumstances.

• Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format.

• Right to object (Art. 21 GDPR): You have the right to object to processing based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.

• Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

• Right to lodge a complaint (Art. 77 GDPR): You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

10. Children's Privacy

This App is not directed at, and is not intended to be used by, anyone under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us immediately at the address in Section 2. Upon verification, we will promptly delete such data.

The financial and cryptocurrency content in this App is intended for adult audiences only. Use of the App by persons under 18 is strictly prohibited.

11. Security of Your Data

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, in accordance with Art. 32 GDPR. These measures include:

• Encrypted data transmission (HTTPS/TLS)

• Access controls limiting data access to authorised personnel only

• Regular review of security practices

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours as required by Art. 33 GDPR, and affected users without undue delay where required by Art. 34 GDPR.

12. Analytics and Tracking

The App uses Google Analytics for Firebase ("Firebase Analytics"), a service of Google LLC, to understand how users interact with the App. The data collected includes: which screens are viewed, which signal mode is selected (scalping / strong / pro), whether a premium subscription is active, session and engagement statistics, device type and operating system version, a pseudonymous app-instance identifier, and approximate location derived from your IP address (country/city level). No cookies are placed on your device via a web browser in the context of this mobile application.

Legal basis and consent (EEA/UK): Analytics is disabled by default. It is activated only after you give consent in the consent form shown when you first launch the App (Art. 6(1)(a) GDPR). If you decline — or until you make a choice — no analytics data is collected or transmitted. You can withdraw or change your choice at any time via "Privacy options" in the app's Settings; withdrawal disables analytics collection immediately. Outside the EEA/UK, we operate analytics on the basis of our legitimate interest in understanding and improving the App (Art. 6(1)(f) GDPR).

Analytics data is retained by Google for a maximum of 14 months and then deleted automatically. Aggregated statistics that cannot be linked to a device may be retained longer.

13. Educational Disclaimer

This App is designed and intended solely as an educational tool. All crypto signals, market data, price indicators, and analysis features are provided for the purpose of helping users understand cryptocurrency market dynamics. They do not constitute and should not be interpreted as:

• Financial advice

• Investment recommendations

• Trading signals intended to guide actual trades

• Any form of regulated financial service

Past performance of any cryptocurrency or signal is not indicative of future results. Cryptocurrency markets are highly volatile and involve significant risk of loss. You should always perform your own due diligence and consult a licensed financial advisor before making any investment decisions. We accept no liability for any financial losses arising from reliance on information provided by this App.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App's features, or applicable law. We will notify you of material changes by:

• Updating the "Last Updated" date at the top of this document

• Displaying an in-App notification on your next App launch

We encourage you to review this Privacy Policy periodically. Continued use of the App after any changes constitutes your acceptance of the revised Privacy Policy.

15. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our data processing practices, please contact us:

Email: Luvrufashion@gmail.com

Business Name: DA Apps (Dragos Andrei Andries, Einzelunternehmer)

Address: c/o flexdienst – #20886, Kurt-Schumacher-Straße 76, 67663 Kaiserslautern, Germany

We aim to respond to all data subject requests within 30 days as required by Art. 12 GDPR.

This Privacy Policy was prepared in accordance with GDPR (EU) 2016/679 and the German BDSG.