Privacy Policy

The short version

• No account. We don’t ask for your name, email or phone number to use the App.
• Your stats, custom sets and mnemonics stay with you: on your device and, if you use iCloud, in your own private iCloud storage. We can’t see them.
• The App is free because it shows ads from Google AdMob. Ads are personalised only if you agree in Google’s consent form, where it is shown, and allow tracking in Apple’s prompt.
• We measure how the App is used with Google Analytics for Firebase, without any user ID. Where Google’s consent form is shown, this happens only if you agree.
• You can review your ad choices at any time in Settings → Manage Consent, and tracking in iOS Settings.

1. Who we are

Atomic Tab (the “App”) is developed and published by Federica Benacquista, an individual developer, Via del Lido 106, 04100 Latina (LT), Italy (“we”, “us”). For any personal data we decide how to use, we are the data controller under Regulation (EU) 2016/679 (the “GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Contact for every privacy matter: support@copycut.it. We have not appointed a Data Protection Officer because we are not legally required to.

2. Scope

This policy covers the Atomic Tab app for iPhone and iPad and this website. It explains what information is involved when you use them, who processes it, why, and what rights you have.

Atomic Tab is a training tool for memorising the periodic table. It has no user accounts and no server of ours: the App does not send your data to us.

3. Data on your device and in your iCloud

The App stores the following information on your device, inside the App’s private storage:

• Your training statistics: your answers per element (right, wrong, streaks), scores, session results and the “often wrong” list built from them.
• Your saved game setups: quiz, table-match and card configurations you save.
• Your own content: the custom sets you create (their names and the elements in them) and any custom mnemonics you write.
• Preferences and App state: language, reminder setting, tutorial progress, whether you have seen the privacy step, and counters used to space out ads.
• Purchase status: whether you own Atomic Tab Pro, cached in your device’s Keychain.

iCloud sync. If you are signed in to iCloud, the App uses Apple’s CloudKit to mirror your statistics, saved setups, custom sets and mnemonics to the private iCloud database of your own Apple Account, so they stay in step across your devices. That database belongs to your iCloud account: we cannot see, access or export it. Apple stores it under its own terms. If iCloud is not available, the App keeps everything on the device only. Preferences and purchase status are not synced this way.

Deleting it. You can delete custom sets and mnemonics in the App. Deleting the App removes the data on that device. To remove the iCloud copy, go to iOS Settings → [your name] → iCloud → Manage Storage (or Storage) → Atomic Tab and delete its data. Your data may also be included in your own device backups, which Apple, not us, controls.

Training reminders

If you turn on Training reminders, the App asks for permission to send notifications and schedules local notifications on your device, roughly every two to three days. They are created on the device and never go through any server of ours. You can turn them off in the App’s Settings or in iOS Settings → Notifications → Atomic Tab.

4. Data processed by Apple and Google when you use the App

4.1 Advertising: Google AdMob

The free version of the App shows banner ads, occasional full-screen ads between sessions, and rewarded ads you can choose to watch (for example, to open your detailed statistics or get an extra custom-set slot). Ads are provided by Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and its affiliates, including Google LLC). When no Google ad is available, the App may show links to other apps by the same developer.

• Consent first. On first launch the App explains its choices, then shows Google’s consent form, where your region requires it (for example in the European Economic Area, the UK and Switzerland), and then Apple’s tracking prompt. The Google Mobile Ads SDK is not started, and no ads from Google are requested, until a consent result allows it.
• Personalised only with your permission. Ads are personalised (chosen using information about your interests) only if you agree in Google’s consent form, where it is shown, and allow tracking in Apple’s prompt. Otherwise the App asks Google for non-personalised ads, which are not selected on the basis of a profile of you.
• What Google may process to deliver ads: your IP address (and an approximate location derived from it), device and operating-system information, the App’s identifier, the identifier for vendors (IDFV), the advertising identifier (IDFA) only if you allow tracking in Apple’s prompt, and information about ads shown, tapped and completed. Google uses this to serve ads, cap how often you see them, measure performance and detect fraud.
• If you decline, Google may still show non-personalised or limited ads that use only the data strictly needed to deliver and protect ads, as described in Google’s policies.

For data Google processes for its own purposes, Google acts as an independent controller. See How Google uses information from sites or apps that use its services and the Google Privacy Policy.

4.2 Usage statistics: Google Analytics for Firebase

The App uses Google Analytics for Firebase (Google Ireland Limited) to understand, in aggregate, how the App is used and which features, game modes and offers work. Collection is switched off when the App starts and stays off until your consent choice is known:

• Where Google’s consent form is shown, it is switched on only if you agree to storing information on your device and to measurement. If you don’t, events are discarded.
• Where no consent form is required, it is switched on by default.

When it is on:

• The App records events about how you use it: screens viewed, game mode, difficulty and training set chosen, whether an answer was right or wrong, games started and finished, tutorials, language changes, opening leaderboards, achievements or statistics, custom sets created, edited or played, ads requested, shown, tapped or completed, the Pro page, purchase and restore attempts and their result, taps on links to other apps, and whether you have Pro. Firebase adds standard technical events such as first open, session start and engagement time.
• Firebase may process a random app-instance identifier, the IDFV, device model, operating-system version, language, App version and country or region derived from your IP address.
• We do not send any user ID, name, email, the names of your custom sets or the text of your mnemonics.
• The advertising signals (ad storage, ad user data, ad personalisation) follow your answers: they are granted only if you agree in Google’s consent form, where it is shown, and ad user data and ad personalisation also need your permission in Apple’s tracking prompt. If you allow tracking, Firebase may also collect the advertising identifier (IDFA).
• Link with AdMob. Our Firebase project is linked to our Google AdMob account. When the advertising signals above are granted, Google may use these usage events, together with the IDFA, to measure and personalise ads. For those advertising uses Google acts as an independent controller under its own terms; for measurement it acts as our processor, as described below.

For this service Google acts as our data processor under the Firebase Data Processing and Security Terms.

4.3 Leaderboards and achievements: Apple Game Center

If you are signed in to Game Center, the App sends your scores to Atomic Tab’s Game Center leaderboards, reports the achievements you unlock and reads your own rank. This is handled by Apple under its own terms and privacy policy. Depending on your Game Center settings, other players may see your Game Center nickname, avatar and scores. We do not send your Game Center identity to any server of ours. You can sign out of Game Center in iOS Settings.

4.4 Purchases: Apple App Store

If you buy Atomic Tab Pro, the purchase is handled entirely by Apple under its own terms and privacy policy. We never receive your name, Apple ID, payment card or billing details. The App checks with Apple, on your device, whether your purchase is valid. No receipt is sent to any server of ours.

4.5 When you contact us

If you write to us, for example with Contact us in the App’s Settings, the App opens an email draft in your Mail app. When you send it, we receive your email address, your message and any screenshots you attach. To help us fix problems, the draft includes technical details: App name, version and build, iOS version and build, device model, language, region, time zone, whether Low Power Mode is on, and the time of the message. You can see and remove any of these before you press Send.

5. Purposes and legal bases

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

6. What we never do

• We never sell your personal data.
• We never send the names of your custom sets or your mnemonics to advertisers or analytics providers.
• We never ask for access to your contacts, photos, location, camera or microphone.
• We never ask you to create an account.

7. International transfers

Google may process data in the United States and other countries outside the European Economic Area. Where that happens, transfers rely on the EU-U.S. Data Privacy Framework, under which Google LLC is certified, and on the European Commission’s Standard Contractual Clauses included in Google’s data-processing terms. Apple’s processing, including iCloud and Game Center, is governed by Apple’s own safeguards.

8. How long data is kept

• Data on your device: until you delete it or delete the App.
• Your iCloud copy: until you delete it from your iCloud storage (section 3) or close your iCloud account.
• Analytics data: event-level data is kept for the retention period set in our Google Analytics settings, and in any case no longer than 14 months, then deleted. Aggregated reports contain no personal data.
• Advertising data: according to Google’s retention policies, which Google describes in its privacy policy.
• Game Center and purchase records: according to Apple’s policies.
• Support emails: up to 24 months after the conversation ends, unless we must keep them longer to meet a legal obligation or defend a legal claim.

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and receive a copy (Art. 15);
• rectify inaccurate data (Art. 16);
• erase your data (Art. 17);
• restrict processing (Art. 18);
• data portability (Art. 20);
• object to processing based on legitimate interest (Art. 21);
• withdraw consent at any time, without affecting processing carried out before you withdrew it (Art. 7(3)).

Because your App data stays on your device and in your own iCloud, you can exercise most of these rights directly in the App, in iOS Settings or by deleting the App. For anything we hold (mainly support correspondence), write to support@copycut.it. We will reply within one month, extendable by two further months for complex requests as allowed by Art. 12(3) GDPR. We may ask for information to confirm it is really you. For data Google or Apple process as independent controllers, you can also contact them directly.

You have the right to lodge a complaint with a supervisory authority, in particular in the EU country where you live or work. In Italy this is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it. We would appreciate the chance to address your concern first.

10. Your choices and controls

• Consent: where Google’s consent form applies to you, review or change your ads and analytics choices in the App under Settings → Manage Consent.
• Tracking: allow or deny tracking for Atomic Tab at any time in iOS Settings → Privacy & Security → Tracking. If tracking is denied, the advertising identifier is not shared and ads are not personalised.
• Reminders: turn Training reminders on or off in the App’s Settings, or manage notifications in iOS Settings → Notifications → Atomic Tab.
• iCloud: turn iCloud off for Atomic Tab, or delete its iCloud data, in iOS Settings → [your name] → iCloud.
• Game Center: sign in or out in iOS Settings → Game Center.
• No ads: buying Atomic Tab Pro removes ads.

11. Young people

The App is a study tool for students and adults. It is intended for people aged 14 and over, the age at which a person can consent to online services on their own under Italian law (Art. 2-quinquies of the Italian Privacy Code). Where the law of your country sets a higher age, that age applies. If you are younger, please use the App only with the involvement of a parent or guardian, who can give or refuse consent to ads and analytics on your behalf. We do not knowingly collect personal data from children. If you believe a child has contacted us, write to us and we will delete the correspondence.

12. Security

The App keeps your data in iOS’s sandboxed storage, which iOS encrypts when your device is locked with a passcode. Purchase status is stored in the iOS Keychain. Your iCloud copy is protected by Apple’s iCloud security. Because the App does not send your training data to us, it cannot be exposed through a breach of our systems. You protect it best by using a device passcode and keeping iOS up to date. If a personal-data breach affecting data we control occurs, we will notify the supervisory authority and you where the GDPR requires it.

13. This website

This website is hosted on Google Firebase Hosting. It uses no cookies, no analytics and no advertising. To deliver the pages and protect them from abuse, Google’s servers necessarily process your IP address and standard request information (browser type, time and page requested) in short-lived technical logs, as our processor. The legal basis is our legitimate interest in running a secure website (Art. 6(1)(f)).

14. Information for US residents

We do not sell personal information for money. Ads in the App are personalised only if you allow tracking in Apple’s prompt (and consent where Google’s form is shown); if you do, Google may use your advertising identifier for cross-context behavioural advertising, which some state laws call “sharing”. You can opt out at any time by turning off tracking for Atomic Tab in iOS Settings → Privacy & Security → Tracking. Where Google’s privacy message offers a US-state opt-out and you use it, the App asks only for non-personalised ads. Where state law gives you rights to know, delete or correct personal information, or to appeal a decision, you can exercise them by writing to us. We will not discriminate against you for doing so.

15. Changes to this policy

We may update this policy when the App or the law changes. We will change the “Last updated” date above. For significant changes, for example a new way of processing data, we will also tell you in the App before the change takes effect and, where required, ask for your consent again.

16. Contact

Federica Benacquista
Via del Lido 106
04100 Latina (LT), Italy
Email: support@copycut.it