This Privacy Policy explains, in accordance with Articles 12 and 13 of the General Data Protection Regulation (GDPR), how the Android app Portable Alarm System (package ID com.mnhksdev.portablealarm) processes personal data.
1. Controller
H.K.Solution GmbH
Westerdeicher Str. 11
26553 Dornum / Nessmersiel
Germany
Email: mnhksdevelopment@gmail.com
2. Provision of this website by IONOS
This Privacy Policy is hosted on webspace provided by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. IONOS processes the necessary data as our processor under an agreement pursuant to Article 28 GDPR.
When the page is accessed, the processing includes in particular the referrer, requested page or file, browser type and version, operating system, device type, access time and the IP address technically required for the connection. According to IONOS, the IP address is anonymised immediately after transmission and is subsequently processed only in anonymised form to determine the approximate access location.
IONOS WebAnalytics is enabled by default with web hosting. The analysis uses log files or a tracking pixel, does not use cookies and is carried out exclusively for statistical analysis and technical optimisation. The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are the secure and stable provision of the page, error analysis, prevention of misuse and needs-based optimisation.
According to IONOS, visitor data is stored for eight weeks. IONOS does not disclose this data to third parties or transfer it to countries outside the European Union. More information is available in the IONOS notices on data processing by web hosting and WebAnalytics.
3. Overview and local processing by default
The controller does not receive or store alarm, sensor, microphone or camera data on its own servers. The alarm functions operate locally on your device. Alarm photos and event history are not sent to the controller, Unity or Google Play. This app version does not provide email or cloud delivery of alarm photos.
Data leaves the device only in connection with Unity Ads if you expressly allow advertising, and through Google Play Billing to check and process the optional Pro purchase. Sections 6 and 7 provide details.
4. Local alarm functions and data
| Function | Data processed | Purpose and retention |
|---|---|---|
| Sensor monitoring | Motion, rotation, light, proximity, magnet and charging-state values | Detecting an alarm event. Processed temporarily in memory; not transmitted. |
| Sound detection | Short microphone measurements | Detecting the configured sound threshold. No audio recording is stored or transmitted. |
| Camera motion | Reduced camera frames for scene-change detection | Only when enabled. Temporarily processed; no video recording or transmission. |
| Alarm photo | A single image upon an alarm | Only when enabled. Encrypted with a device-bound key in private app storage. Deleted when the event is manually removed, on the next app start or use after seven days have elapsed, or when the app is uninstalled. |
| Event history | Time, alarm reason and reference to an optional photo | Limited to 30 entries. Entries older than seven days are removed on the next app start or use; manual deletion is available at any time. |
| Settings and PIN | Configuration, voluntary text input, content URI of a selected alarm sound and salted PIN verifier | Providing selected functions. Sensitive text is encrypted; the PIN is not stored in plain text. |
| Advertising and purchase state | Advertising choice, time of the last interstitial ad and locally cached Pro state | Stored locally until changed, app data is reset or the app is uninstalled. |
The legal basis for local app functions requested by the user is Article 6(1)(b) GDPR. Locally storing technically necessary settings is also permitted under Section 25(2)(2) TDDDG. If your use of camera or microphone functions might capture other people, you must ensure that your use is lawful. The app must not be used for unlawful or covert surveillance.
5. Android permissions
- Camera: camera motion, alarm photos and flashlight, only when the relevant function is enabled.
- Microphone: sound detection only; audio is not recorded or stored.
- Notifications: the visible Android foreground-service notification while the alarm is armed.
- Vibration: enabled alarm or confirmation vibration.
Permissions are requested only when you activate a related function. You may revoke them at any time in Android settings. The corresponding feature will then no longer be available. Granting an Android permission does not constitute consent to advertising.
6. Unity Ads
The free version may display banner and occasional interstitial ads supplied by Unity Ads. Ads are not shown during an active alarm, arming or countdown flow. The Unity Ads SDK is activated only after you make an advertising choice.
Your choices
- Continue without consent: Unity Ads is not activated and no advertising data is sent to Unity. The free core functionality remains available.
- Allow contextual advertising: ads are not selected using a personal interest profile. Unity nevertheless processes technical data for ad delivery, measurement, security and fraud prevention.
- Allow personalised advertising: Unity and participating advertising partners may use technical data and ad interactions to create or use interest and usage profiles and tailor ads accordingly.
Data, purposes and recipients
According to Unity, the SDK may collect and share the following in particular with Unity companies, technical service providers, advertisers, attribution, advertising and bidding partners: IP address and approximate region derived from it, Google advertising ID, Unity and partner identifiers, installation-specific identifiers, device, operating-system, app and network information, session and usage times, diagnostic information, ad requests, impressions, clicks and other interactions within an ad, as well as purchase history. App usage times may be processed if the relevant optimisation features are enabled in the Unity dashboard.
Processing is carried out to deliver contextual or personalised ads, measure reach and performance, provide analytics, limit ad frequency, provide the advertising function, prevent fraud, maintain security and comply with legal obligations. Alarm and sensor values, microphone content, camera frames, alarm photos, event history, PIN and alarm text are not sent to Unity.
Unity identifies Unity Technologies S.F., 116 New Montgomery Street, Suite 200, San Francisco, CA 94105, USA, as responsible for its own processing. Its European contact is Unity Technologies ApS, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark; privacy contact: DPO@unity3d.com.
Legal bases, withdrawal and retention
The legal basis for our activation of Unity Ads is your consent under Article 6(1)(a) GDPR. Storing information on your device and accessing device information is based on consent under Section 25(1) TDDDG. The advertising choice is voluntary. Refusal must not block the free core functionality.
You can change or fully withdraw your choice at any time under Settings → Ads & privacy. After full withdrawal, no further ads are requested from Unity. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Your choice is stored locally so it can be respected on later app starts.
Unity states that it retains personal data for as long as necessary for the relevant purposes, the service relationship and legal, tax, security or legal-defence requirements. More information, the current list of advertising partners and access or deletion options are available in Unity's Game Player and App User Privacy Policy and its Unity Ads SDK data disclosures.
7. Google Play Billing and the optional Pro purchase
When the app starts or resumes, it connects to Google Play Billing. It checks product availability and price and whether there is an existing, pending, cancelled or completed Pro purchase. This is necessary to restore an existing Pro entitlement and avoid showing ads to Pro users. A purchase is optional.
Google may process Google Account, device, app, network, purchase and transaction data. The app receives the product identifier, product and price information and, where available, purchase time, purchase state, acknowledgement state, order identifier and purchase token. The purchase token is sent to Google Play only to acknowledge the purchase. The app does not receive complete payment data such as card or bank details. Locally, the app stores only whether Pro status has been recognised.
The legal basis for purchasing, acknowledging and restoring Pro entitlement is Article 6(1)(b) GDPR. To the extent product and status checks take place before a purchase, the legal basis is Article 6(1)(f) GDPR; our legitimate interests are presenting correct price and product information, reliably recognising existing entitlements and avoiding ads being shown incorrectly. The local Pro state is necessary for the explicitly requested purchase and licence function under Section 25(2)(2) TDDDG.
Google Play is provided in the European Economic Area by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Commerce Limited may be involved in purchase and payment processing. Google’s Privacy Policy and the Google Play Terms for the EEA also apply.
8. Recipients and international transfers
Alarm, sensor, microphone, camera and photo data are not disclosed. When this website is accessed, IONOS receives the data described in Section 2. Depending on your use and choices, recipients of technical advertising and purchase data may include Unity, Google, their affiliated companies and processors, and the advertising, attribution and bidding partners used by Unity.
Unity and Google may process data in the United States and other countries outside the European Economic Area. According to the providers, such transfers rely, depending on the recipient, on a European Commission adequacy decision, including the EU–US Data Privacy Framework, or on the European Commission’s Standard Contractual Clauses and supplementary measures where required. Information and ways to request copies of the safeguards are available in the provider notices linked above and in Google’s information on international data transfers.
9. Retention, deletion, backups and security
- Temporary sensor, microphone and camera data is not stored after the relevant evaluation.
- Event history contains no more than 30 entries. Entries and linked photos older than seven days are deleted on the next app start or use.
- You can delete events and photos in the app at any time. Android removes local data when app data is cleared or the app is uninstalled.
- Settings, advertising choice, last-ad time and local Pro state remain until changed, app data is reset or the app is uninstalled.
- Alarm photos are encrypted with AES-GCM and a device-bound key in private app storage. PINs are stored only as a salted verifier derived using PBKDF2.
- Alarm photos, event history and settings are excluded from Android cloud backups and device transfers. Photos are not placed in the public gallery.
The retention period in Section 2 applies to website visitor data held by IONOS. Data held by Unity and Google is subject to the retention criteria described in Sections 6 to 8.
10. Contact and privacy requests
If you contact us by email, we process your sender address, message content, time and technical email metadata to respond. The legal basis is Article 6(1)(b) GDPR for contract-related requests, Article 6(1)(c) GDPR when meeting statutory data-protection duties, and otherwise Article 6(1)(f) GDPR; our legitimate interest is handling and documenting requests.
Messages are deleted when the request has been finally resolved and no statutory retention, evidence or limitation period requires continued storage. Google Ireland Limited may process technical communications data in providing the email service; the Google notices cited above apply.
11. Profiling and automated decisions
For personalised advertising, Unity and advertising partners may create or use usage and interest profiles. Contextual advertising is not selected using a personal interest profile. The controller does not itself make decisions based solely on automated processing that produce legal effects or similarly significantly affect you within the meaning of Article 22 GDPR.
12. Voluntary provision, consequences and minors
Camera, microphone and notification permissions and alarm photos are optional; without the relevant permission or activation, only the corresponding feature is unavailable. Advertising consent and the Pro purchase are optional. If advertising consent is refused, the free core functionality remains available without Unity Ads.
The app is not specifically directed at children under 16. If it is offered directly to a person under 16, consent-based advertising may be enabled only with consent or authorisation from the holder of parental responsibility. Without such authorisation, Unity Ads must not be activated.
13. Your rights
Where the legal requirements are met, you have the right of access, rectification, erasure, restriction of processing, data portability and objection. You can withdraw consent at any time for the future. You also have the right to lodge a complaint with a data protection supervisory authority under Article 77 GDPR.
Data that remains solely on your device cannot be viewed or corrected by the controller. You can remove it in the app or by clearing app data. For data held by Unity or Google, you may also contact the relevant provider directly; Unity also offers privacy controls through the privacy icon within an ad.
For requests to us, use the contact details in Section 1. The supervisory authority at the controller’s registered office is the State Commissioner for Data Protection of Lower Saxony, PO Box 221, 30002 Hanover, Germany, email: poststelle@lfd.niedersachsen.de. Complaints may be submitted using the authority’s online service. You may also contact any other supervisory authority competent under Article 77 GDPR.
14. Changes to this Privacy Policy
We will update this policy if features, services used or legal requirements change. The current version will be made available at the privacy-policy URL provided for the app.