Last Updated: August 1, 2025
Effective Date: August 1, 2025
Developer: Asim Ronkubacrem
Contact Email: asimronkubacrem@gmail.com
1. Our Commitment to Your Privacy
File Smart Manager ("we," "us," "our") is a file management application designed to respect your privacy and your data. This Privacy Notice describes the very limited ways in which the App may interact with information on your device and is designed to comply with stringent international privacy standards, including the GDPR, CCPA, VCDPA, and others.
We want to be unequivocally clear: We do not collect, store, or transmit your personal files or their contents. Your data remains on your device under your control.
2. Information Handling Practices
A. Data We Absolutely Do Not Access or Collect:
File Contents: The contents of your documents, photos, videos, audio files, and any other personal data.
File and Folder Names: The specific names of your personal folders and files.
Personally Identifiable Information (PII): Information such as your name, contact list, email address (unless you provide it for support), or location.
Device Identifiers: We do not collect your hardware serial number, IMEI, or other unique device identifiers.
B. Anonymous Information for App Functionality:
To maintain and enhance the App's performance, we may process the following anonymous information:
Aggregated Interaction Events: We may record anonymous events such as "search initiated," "file type filtered," or "settings changed." These events are completely detached from any identifying information and are never linked to your identity or your specific files.
Performance Diagnostics: In the event of an app malfunction, you may have the option to send an anonymous crash report. This report contains technical data like your device's OS version, available memory, and the error log, which helps us identify and fix bugs.
Basic Analytics: We use privacy-preserving analytics to understand general usage patterns (e.g., "30% of users use the sort feature"). This data is aggregated and anonymized, providing no insight into individual user behavior.
3. Legal Bases for Processing (For EEA/UK Users)
Under the General Data Protection Regulation (GDPR), we rely on the following legal bases to process the minimal anonymous data described above:
Legitimate Interests: Processing for analytics and crash reporting is necessary for our legitimate interest in improving the stability and user experience of our App, provided that this interest is not overridden by your fundamental rights and freedoms.
Consent: For any processing that is not essential to the app's core functionality, we will seek your explicit consent before proceeding.
4. Your Privacy Rights
Various data protection laws grant you rights regarding your personal information. Since we do not collect your personal files, our response to most requests will be that we hold no personal data about you. Your rights may include:
Right to Know & Access: The right to request information about the personal data we have collected about you.
Right to Delete: The right to request the deletion of any personal data we have about you.
Right to Correct: The right to correct inaccurate personal data we may hold.
Right to Opt-Out of Sale/Sharing: We DO NOT SELL personal data. We DO NOT SHARE personal data for cross-context behavioral advertising.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
To Exercise These Rights: Please contact us at asimronkubacrem@gmail.com with the subject line "Privacy Rights Request." We will respond to verifiable consumer requests within the timeframe required by applicable law (typically 45 days).
5. Data Retention
We retain the anonymous technical data and analytics information for a period necessary to fulfill the purposes outlined in this notice, generally not exceeding 12 months. Any correspondence via email is kept only as long as needed to address your inquiry.
6. International Data Transfers
Our operations are based in India. The anonymous data we process may be stored or processed on servers located in India or other countries. Any such transfer of anonymous data is managed in accordance with appropriate safeguards to ensure a level of protection equivalent to the laws of your home country.
7. Children's Privacy
File Smart Manager is not directed to children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without verified parental consent, we will take steps to delete that information.
8. Changes to This Privacy Notice
We may update our Privacy Notice from time to time. We will notify you of any changes by updating the "Last Updated" date at the top of this document. Changes become effective upon posting. We encourage you to review this notice periodically.
9. Contact Us
For any questions, concerns, or requests regarding this privacy notice or our data practices, you may reach us at:
Email: asimronkubacrem@gmail.com