Privacy Policy — Wish4soul

1. Introduction

This Privacy Policy explains how Bridgeway, s.r.o. ("we", "us", "the operator") handles data in connection with the Wish4soul mobile application (the "App").

The App is designed to work offline and does not require account creation or login. The App does not collect or store your name, e-mail address, postal address, or any other directly identifying personal data on our own servers, because we do not operate any servers that store this information — all your data within the App (e.g. settings, saved content, progress) stays locally on your device and is never transmitted to us.

The only data collection that occurs is through third-party services integrated into the App for analytics and advertising purposes, as described below.

2. Data Controller

For the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"), we are the data controller only in respect of the limited processing described in Section 3. For data processed by Google (Google Analytics, Google Ads), Google LLC generally acts as an independent controller or as our processor, depending on the specific service and settings — see Section 5.

3. What Data Is Processed

3.1 Data stored only on your device (never sent to us)

Any content you create or configure inside the App (preferences, saved items, progress, etc.) is stored locally on your device only. We have no access to it, cannot see it, and it is not transmitted anywhere by us.

3.2 Data collected by third-party services

We use the following third-party services inside the App:

• Google Analytics for Firebase / Google Analytics (GA4) — used to understand how the App is used (e.g. screens viewed, app opens, session length, crashes, general device/OS type, approximate location derived from IP address, and app instance/advertising identifiers).
• Google Ads (AdMob) — used to display advertisements, which may be personalized based on the advertising identifier (e.g. Google Advertising ID / AAID), device information, and approximate location.

Depending on your device and consent choices, this can include:

• Device identifiers (e.g. Advertising ID)
• IP address (used to derive approximate location, then typically truncated/anonymized by Google)
• Device model, operating system, language, and app version
• App usage and interaction events
• Crash and performance diagnostics

We do not collect or have access to your name, e-mail address, physical address, phone number, or any account credentials, since the App has no account or login system.

4. Legal Basis for Processing

Since analytics and advertising identifiers are not "strictly necessary" processing, under GDPR and the ePrivacy Directive we rely on:

• Your consent (Art. 6(1)(a) GDPR) — collected via an in-app consent prompt shown on first launch (e.g. through Google's User Messaging Platform), before any non-essential Analytics or Ads identifiers are activated. You can withdraw this consent at any time in the App's settings or your device's ad settings.

If you do not consent, non-essential analytics and ad personalization are disabled or limited to non-personalized advertising, consistent with your choice.

5. Third-Party Processors / Recipients

Google LLC (including its European entity, Google Ireland Limited) processes this data under its own privacy policy and may transfer data to the United States or other countries. Google self-certifies compliance with applicable EU-US data transfer frameworks and/or relies on Standard Contractual Clauses (SCCs) for such transfers.

We do not sell your data, and we do not share it with any party other than the Google services listed above for the purposes stated.

6. Data Retention

• Data stored locally on your device remains until you uninstall the App or clear its data/cache.
• Data processed by Google Analytics is generally retained according to Google's default retention settings (commonly 2–14 months) before automatic deletion or aggregation.
• Advertising identifiers used by Google Ads are retained per Google's own policies and can be reset or deleted by you at any time via your device's ad settings ("Reset Advertising ID" / "Delete Advertising ID").

7. Your Rights Under GDPR

If you are located in the European Economic Area (or another jurisdiction with similar rights), you have the right to:

• Access — request confirmation of what data is processed about you.
• Rectification — request correction of inaccurate data.
• Erasure — request deletion of data (note: data stored only on your device is already fully within your control and can be erased by uninstalling the App).
• Restriction of processing — in certain circumstances.
• Object — to processing based on legitimate interests or for direct marketing/advertising purposes.
• Data portability — receive data you provided in a structured, machine-readable format, where applicable.
• Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
• Lodge a complaint with the Slovak Office for Personal Data Protection, Hraničná 12, 820 07 Bratislava, dataprotection.gov.sk (or your own national Data Protection Authority).

To exercise any of these rights regarding data we control, contact us at gdpr@bridgeway.sk. For data processed directly by Google, you can also manage or delete it via your Google Account privacy settings and your device's ad settings.

8. Children's Privacy

The App is not directed at children under the age of 13 (or the higher age of consent applicable in your country), and we do not knowingly collect data from children. If the App is listed under Google Play Families Policies, advertising is restricted to non-personalized ads and Google Analytics/Ads are configured accordingly to comply with those policies and applicable children's privacy laws (e.g. COPPA where relevant).

9. Security

While the App does not transmit personal data to our own servers, we take reasonable measures to ensure any data handled by integrated third-party SDKs is transmitted securely (e.g. via HTTPS/TLS), and rely on Google's own security safeguards for Analytics and Ads data.

10. Changes to This Policy

We may update this Privacy Policy from time to time, for example to reflect changes in the App's functionality or in applicable law. The "Last updated" date at the top of this page will be revised accordingly. Material changes will be highlighted where required by law.

11. Contact

Questions, requests, or complaints about this Privacy Policy or your data can be sent to: