This Privacy Policy describes how PE OLEKSANDR FIRSOV, registered in Ukraine (“Company”, “we”, “our”, or “us”), collects, uses, and protects your information when you use Verba (the “App”) on iOS or Android devices.

We comply with:

The EU General Data Protection Regulation (GDPR)
The California Consumer Privacy Act (CCPA), as amended by CPRA
The California Online Privacy Protection Act (CalOPPA)

The data controller responsible for your personal data is:

PE OLEKSANDR FIRSOV Kyiv, Ukraine Veresneva Street, 4 Email: admin@verbamobile.com

2. Information We Collect

2.1 Information You Provide

We collect:

Full name
Email address
Information you provide when contacting support

2.2 Camera and Microphone Access

Camera

We request access to your device camera to:

Take pictures of documents or other items you choose to capture for the translation service. Captured images are processed securely and used solely for the purpose of providing the translation service. Images are not stored or shared with third parties.

Camera access is used only when you actively use related features and only after granting permission.

We do not access the camera in the background.

Microphone

We request access to your device microphone to:

Translate your voice input, using our speech recognition technology. Recorded audio is processed securely and used solely for the purpose of providing the translation service. Audio data is not stored or shared with third parties.

Microphone access is only active during feature use and with your explicit consent.

2.3 Automatically Collected Information

When you use the App, we automatically collect:

Device type and operating system
IP address
App version
Usage statistics
Crash reports
Interaction data

This information may be linked to your account.

3. Technologies and Third-Party Services

We use the following services:

3.1 Firebase Firestore

We use Google Firestore (Firebase) provided by Google Ireland Limited to store user data securely in the cloud.

Purpose:

Store account data
Maintain app functionality
Ensure secure data storage

Data may be processed on Google servers, including outside the EU. Where required, transfers rely on Standard Contractual Clauses (SCCs).

Google Privacy Policy: https://policies.google.com/privacy

3.2 Google Analytics for Firebase

We use Google Analytics for Firebase to analyze app usage and improve performance.

This service collects:

Device identifiers
Usage data
App interactions

You may opt out via:

Device-level advertising settings
Resetting your device advertising ID

3.3 Future Advertising

We plan to integrate advertising networks in the future.

When ads are enabled:

We will update this Privacy Policy.
You will be informed via app update.
We will provide required consent mechanisms (especially for EU users).

We currently do NOT display ads.

If you are located in the EEA, we process your data under:

Consent (camera, microphone, analytics where required)
Contractual necessity (to provide app services)
Legitimate interest (improving security and functionality)
Legal obligation (where applicable)

You may withdraw consent at any time.

5. How We Use Your Data

We use personal data to:

Create and manage user accounts
Provide core app functionality
Store user data securely
Improve performance and features
Respond to support requests
Maintain security and prevent fraud
Comply with legal obligations

We do NOT:

Sell personal information
Share data for cross-context behavioral advertising (currently)
Offer subscriptions

6. Data Retention

We retain personal data:

While your account remains active
Until you request deletion
As required by applicable laws

To request deletion, contact: [admin@verbamobile.com]

7. Your Rights

You have the right to:

Access your personal data
Rectify inaccurate data
Erase your data
Restrict processing
Data portability
Object to processing
Withdraw consent
File a complaint with a supervisory authority in Germany or your country of residence

Relevant supervisory authority (Germany): Sächsischer Datenschutz- und Transparenzbeauftragter

7.2 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

Know what personal data we collect
Access specific pieces of data
Request deletion
Correct inaccurate data
Limit use of sensitive personal information
Opt-out of sale/sharing (we do not sell data)
Non-discrimination for exercising your rights

To exercise your rights, contact: [admin@verbamobile.com]

We may verify your identity before processing requests.

7.3 CalOPPA Disclosure

In compliance with CalOPPA:

This Privacy Policy is accessible within the App.
We will notify users of material changes.
We do not currently respond to “Do Not Track” signals.

8. International Data Transfers

As our legal entity is located in Germany, your data may be processed in:

Germany
Other EU countries
The United States (via Google services)

Transfers outside the EU are protected via:

Standard Contractual Clauses (SCCs)
Additional security safeguards

9. Data Security

We implement appropriate technical and organizational measures, including:

Encrypted connections (HTTPS/TLS)
Secure Firebase infrastructure
Access controls
Limited internal access

No method of transmission is 100% secure.

10. Children’s Privacy

The App is not directed to children under 13 (or 16 in the EEA where applicable).

We do not knowingly collect data from children.

If you believe a child has provided data, contact us for removal.

11. Changes to This Policy

We may update this Privacy Policy.

If changes are material, we will notify users via:

In-app notice
App Store / Play Store update
Updated "Last Updated" date

12. Contact Information

PE OLEKSANDR FIRSOV Registered in Ukraine. Kyiv, Ukraine Veresneva Street, 4 Email: [admin@verbamobile.com] Website: https://verbamobile.com

1. Controller Information (GDPR)