Privacy Policy Tukio App

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Privacy Policy

Last updated: 16 August 2025

1. Data Controller

Synnexo Pax S.R.L. (Registration: J15/1309/2020)
Drumul Guliei no. 189i1, Samurcasi, Romania
Email: privacy.ro@tukio.eu

2. Data We Collect

2.1 Account Information

Email address (required for registration)
Name and surname (optional)
Phone number (optional)
Profile preferences and settings

2.2 Device and Usage Data

Device type, operating system, and unique identifiers
App usage patterns and feature interactions
Error logs and performance metrics
IP address and general location (country/region)

2.3 Camera and Image Data

Product Images: Photos taken for AI scanning (processed temporarily)
QR Codes: Scanned for product identification
Image Metadata: Technical information (timestamp, camera settings)

2.4 Wishlist and Preference Data

Saved products and price alerts
Shopping preferences and categories of interest
Price comparison history

3. How We Use Your Data

3.1 Service Provision

AI Product Recognition: Images processed by Google Vertex AI/Gemini
Price Comparison: Matching products across online retailers
Personalized Recommendations: Based on your scanning and wishlist history
Notifications: Price alerts and product availability updates

3.2 Service Improvement

Analyzing usage patterns to enhance AI accuracy
Debugging and fixing technical issues
Developing new features based on user behavior

3.3 Legal Compliance

Fraud prevention and security monitoring
Compliance with Romanian and EU regulations
Responding to legal requests when required

4. Data Processing Legal Basis (GDPR)

Contract Performance: Account management and core app functionality
Legitimate Interest: Service improvement and security
Consent: Marketing communications and optional features
Legal Obligation: Compliance with Romanian and EU laws

5. Data Sharing and Third Parties

5.1 AI Processing Partners

Google Cloud AI: Image processing for product recognition
- Images processed temporarily, not stored permanently
- Subject to Google's privacy policies
- Data processed within EU/EEA when possible

5.2 Price Comparison Services

Product queries sent to partner retailers' APIs
No personal data shared, only product information
Aggregated usage statistics may be shared anonymously

5.3 Service Providers

Supabase: Secure database hosting (EU-based)
Analytics Providers: Anonymized usage statistics
Email Service: For notifications and support communications

5.4 Legal Requirements

We may disclose data when required by:

Romanian law enforcement
EU regulatory authorities
Court orders or legal processes

6. Data Security

6.1 Technical Measures

End-to-end encryption for data transmission
Secure authentication and session management
Regular security audits and penetration testing
Access controls and monitoring systems

6.2 Organizational Measures

Staff training on data protection
Data minimization and retention policies
Incident response procedures
Regular privacy impact assessments

7. Data Retention

Account Data: Retained while account is active + 2 years
Product Images: Processed temporarily, deleted within 24 hours
Usage Analytics: Anonymized after 12 months
Legal Records: Retained as required by Romanian law

8. Your Rights Under GDPR

8.1 Access and Portability

Request copies of your personal data
Export data in machine-readable format
Access via app settings or email request

8.2 Correction and Deletion

Update inaccurate personal information
Delete your account and associated data
Right to be forgotten (with legal exceptions)

8.3 Processing Controls

Withdraw consent for marketing communications
Object to automated decision-making
Restrict processing in certain circumstances

8.4 How to Exercise Rights

In-App: Profile settings and privacy controls
Email: privacy.ro@tukio.eu
Response Time: Within 30 days as required by GDPR

9. Cookies and Tracking

9.1 Essential Cookies

Authentication and session management
Security and fraud prevention
Core app functionality

9.2 Analytics Cookies

Usage patterns and feature adoption
Performance monitoring and optimization
Anonymized user behavior analysis

9.3 Cookie Controls

Manage cookie preferences through:

App settings menu
Browser settings for web components
Opt-out links in email communications

10. International Data Transfers

Primary data processing within EU/EEA
Google AI services may process in US (adequacy decision)
All transfers comply with GDPR Article 44-49

11. Children's Privacy

Our service is not intended for children under 16. We do not knowingly collect data from minors without parental consent.

12. Changes to Privacy Policy

Updates posted in-app with notification
Material changes require new consent
Previous versions available upon request

13. Data Protection Officer

For privacy-related questions:

Email: privacy.ro@tukio.eu
Address: Drumul Guliei no. 189i1, Samurcasi, Romania

14. Supervisory Authority

Romanian Data Protection Authority (ANSPDCP)

Website: dataprotection.ro
Email: anspdcp@dataprotection.ro

15. Contact Us

For questions about this Privacy Policy:

Email: privacy.ro@tukio.eu
Phone: +40 756 048 838
Address: Drumul Guliei no. 189i1, Samurcasi, Romania