Privacy Policy

Last updated: 10.06.2026

This Privacy Policy explains how K.I.A.B INVESTMENT MANAGEMENT CONSULTING LTD, a company incorporated in the Republic of Cyprus, with its registered office at 28 Oktovriou 317A, KANIKA BUSINESS CENTER BLOCK B, Floor 1, Office 101, Limassol (“Company,” “we,” “us,” or “our”), collects, uses, stores, shares, and protects personal data when you use our mobile application, website, content, features, subscriptions, in-app purchases, and related services (collectively, the “Service”).

We process personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the laws of the Republic of Cyprus.

By using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

For the purposes of GDPR, K.I.A.B INVESTMENT MANAGEMENT CONSULTING LTD is the data controller of the personal data processed in connection with the Service, unless stated otherwise.

Contact details:

K.I.A.B INVESTMENT MANAGEMENT CONSULTING LTD
Registered address: 28 Oktovriou 317A, KANIKA BUSINESS CENTER BLOCK B, Floor 1, Office 101, Limassol, Cyprus
Support email: support@kiab-imc.com

2. What the Service Does

The Service is a mobile application designed to help users play specific sound frequencies, tones, sound patterns, and/or vibration-like audio signals that may assist in cleaning a device speaker from water, dust, debris, or other particles.

The Service is primarily designed to play sound through your device speaker.

Unless a specific feature clearly states otherwise and you grant the relevant device permission, the Service does not need access to your microphone, camera, photos, contacts, precise location, or files.

The Service does not perform a certified technical diagnosis of your device and does not determine whether your speaker is physically damaged.

3. Personal Data We Collect

Depending on how you use the Service, we may collect and process the following categories of personal data.

3.1 Data You Provide to Us

You may provide personal data directly to us when you contact support, submit a request, communicate with us, or use certain features of the Service.

This may include:

• name, if provided;
• email address;
• support request details;
• device issue description;
• screenshots, files, or attachments you choose to send;
• correspondence history;
• any other information you voluntarily provide.

3.2 Data Collected Automatically

When you use the Service, we may automatically collect technical and usage data, including:

• device type, model, manufacturer, and operating system;
• app version;
• language settings;
• country or region;
• IP address;
• device identifiers, advertising identifiers, analytics identifiers, or similar identifiers where permitted;
• session timestamps and duration;
• screens viewed and app interactions;
• selected features and settings;
• crash reports, diagnostic data, and performance data;
• subscription status, purchase events, trial status, and related app events, where applicable.

3.3 Speaker Cleaning Usage Data

To operate, analyze, and improve the Service, we may process non-sensitive app usage data related to speaker cleaning features, such as:

• selected cleaning mode;
• selected frequency or sound pattern;
• session duration;
• whether a cleaning session was started, completed, or interrupted;
• app settings and preferences;
• premium feature usage;
• sound test interactions.

We do not use this data to provide a certified technical diagnosis of your device, speaker, or hardware condition.

3.4 Payment and Subscription Data

If you make purchases or subscribe to paid features, payment is usually processed by the relevant app store or payment provider, such as Apple.

We do not collect or store your full payment card details.

We may receive limited purchase-related information, including:

• product or subscription purchased;
• subscription status;
• trial status;
• renewal status;
• cancellation status;
• transaction identifiers;
• purchase date;
• country or region of purchase;
• refund status, where available;
• app store receipt or subscription validation data.

3.5 Support Communications

If you contact us for support, we may process:

• your email address;
• the content of your message;
• technical information relevant to your request;
• screenshots or attachments you choose to provide;
• correspondence history;
• information needed to investigate billing, subscription, refund, or technical issues.

We use this information to respond to your request, troubleshoot issues, provide assistance, and improve customer support.

3.6 Cookies and Similar Technologies

Our website and some parts of the Service may use cookies, SDKs, pixels, local storage, or similar technologies to operate the Service, analyze usage, prevent fraud, improve performance, remember preferences, and, where applicable, measure advertising effectiveness.

You can control cookies through your browser settings. Mobile tracking permissions may be controlled through your device settings.

4. Device Permissions

The Service may request certain device permissions only where needed for specific functionality.

Depending on the app version and platform, permissions may include:

• audio playback functionality;
• notifications, if you enable reminders or service messages;
• app tracking permission, if advertising or attribution tracking is used and consent is required;
• other permissions clearly explained before use.

The Service is primarily designed to play sounds through your device speaker. It does not normally need access to your microphone, camera, photos, contacts, or precise location.

If a future version of the Service introduces features requiring additional permissions, we will request them through the relevant operating system prompt and explain their purpose.

5. No Audio Recording

The Service is designed to play sounds through your device speaker.

Unless clearly stated in a specific feature and authorized by you through a device permission prompt, the Service does not:

• record audio;
• listen to your surroundings;
• access your microphone;
• analyze conversations;
• store voice recordings;
• transmit microphone data to us or third parties.

6. Purposes and Legal Bases for Processing

We process personal data for the following purposes and legal bases.

6.1 To Provide the Service

We process personal data to operate the app, provide speaker cleaning features, manage access to free and premium features, verify purchases, remember settings, and deliver requested functionality.

Legal basis: performance of a contract.

6.2 To Manage Purchases and Subscriptions

We process purchase and subscription data to verify access, manage premium features, validate receipts, prevent fraud, and respond to billing-related support requests.

Legal basis: performance of a contract, legitimate interests, and legal obligation where applicable.

6.3 To Provide Customer Support

We process personal data to respond to support requests, troubleshoot issues, investigate errors, assist with subscriptions or refunds, and provide customer service.

Legal basis: performance of a contract and legitimate interests.

6.4 To Improve and Maintain the Service

We process technical, diagnostic, and usage data to monitor performance, fix bugs, improve cleaning modes, test functionality, develop new features, and understand how users interact with the Service.

Legal basis: legitimate interests.

6.5 To Ensure Security and Prevent Fraud

We process data to detect, prevent, and investigate fraud, abuse, unauthorized access, payment misuse, security incidents, and violations of our Terms.

Legal basis: legitimate interests and legal obligation.

6.6 To Send Service Communications

We may send service-related messages, including technical notices, security alerts, subscription notices, support replies, policy updates, and administrative communications.

Legal basis: performance of a contract, legal obligation, and legitimate interests.

6.7 Marketing, Analytics, and Attribution

Where permitted, we may use analytics and attribution tools to understand app performance, measure marketing campaigns, improve user acquisition, and evaluate advertising effectiveness.

Where legally required, we will rely on your consent for advertising identifiers, tracking, push notifications, or similar activities.

Legal basis: consent or legitimate interests, depending on the context and applicable law.

6.8 To Comply with Legal Obligations

We may process and retain certain data to comply with accounting, tax, legal, regulatory, dispute resolution, consumer protection, and law enforcement obligations.

Legal basis: legal obligation.

7. Third-Party Service Providers

We may share personal data with trusted third-party service providers who help us operate, analyze, secure, monetize, support, or improve the Service.

These may include providers of:

• cloud hosting and infrastructure;
• analytics;
• crash reporting;
• attribution and marketing measurement;
• customer support tools;
• subscription and purchase management;
• payment and app store services;
• fraud prevention;
• email and communication services;
• advertising networks, where applicable.

Depending on the actual app configuration, such providers may include:

• Apple App Store / Apple services;
• Google Firebase;
• Google Analytics;
• RevenueCat;
• Adjust;
• AppsFlyer;
• Amplitude;
• Meta / Facebook SDK;
• email and customer support providers.

This list must be updated to reflect the actual SDKs, service providers, and tools used in the Service.

We require service providers to process personal data only for appropriate purposes and to implement reasonable technical and organizational security measures.

8. Advertising and Tracking

The Service may use advertising, analytics, or attribution technologies.

These technologies may process device identifiers, advertising identifiers, IP address, app events, purchase events, and similar data.

Where required by law or platform rules, we will ask for your consent before tracking you across apps or websites owned by other companies.

You can manage tracking preferences through your device settings, including:

• iOS: Settings → Privacy & Security → Tracking;
• iOS: Settings → Privacy & Security → Apple Advertising;
• Android: Google Settings → Ads or Privacy settings, depending on your device.

Opting out of personalized advertising does not necessarily remove all ads. You may still see contextual or non-personalized ads.

9. Push Notifications

If the Service offers push notifications, we may send notifications only where permitted by your device settings or consent.

You can disable push notifications at any time in your device settings.

10. International Data Transfers

We are based in Cyprus, but some of our service providers may process personal data outside the European Economic Area.

Where personal data is transferred outside the EEA, we rely on appropriate safeguards required by applicable law, such as:

• adequacy decisions by the European Commission;
• Standard Contractual Clauses;
• contractual, technical, and organizational safeguards;
• other lawful transfer mechanisms available under GDPR.

11. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy.

Retention periods depend on the type of data and purpose of processing, including:

• support communications: for as long as necessary to resolve requests and maintain support history;
• purchase and transaction records: for the period required for accounting, tax, legal, consumer protection, and dispute purposes;
• analytics and usage data: for a limited period necessary to analyze and improve the Service;
• crash and diagnostic data: for as long as needed to investigate and fix technical issues;
• security and fraud prevention data: for as long as necessary to protect the Service and enforce our rights.

We may retain certain data longer where required by law or necessary for legal claims, fraud prevention, accounting, tax, audit, compliance, or dispute resolution purposes.

When personal data is no longer needed, we will delete, anonymize, or securely retain it only where legally permitted.

12. Data Security

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

13. Your GDPR Rights

If GDPR applies to you, you may have the following rights:

• Right of access — to request a copy of your personal data;
• Right to rectification — to correct inaccurate or incomplete data;
• Right to erasure — to request deletion of your personal data;
• Right to restriction — to request limited processing of your data;
• Right to data portability — to receive your data in a structured, commonly used, machine-readable format;
• Right to object — to object to processing based on legitimate interests or direct marketing;
• Right to withdraw consent — where processing is based on consent;
• Right to lodge a complaint — with a data protection supervisory authority.

To exercise your rights, contact us at support@kiab-imc.com.

We may need to verify your identity before responding to your request. We will respond within the time required by applicable law.

Some rights may be limited where we have legal obligations, security reasons, fraud prevention needs, or legitimate grounds to retain certain information.

14. Complaints to the Supervisory Authority

If you are located in the European Union, you have the right to lodge a complaint with your local data protection authority.

15. Children’s Privacy

The Service is not intended for children under 13.

We do not knowingly collect personal data from children where this would be prohibited by applicable law.

If you believe that a child has provided us with personal data without appropriate consent, please contact us at support@kiab-imc.com, and we will take appropriate steps to delete such data.

If the Service is made available to users under 18, they should use it only with the consent and supervision of a parent or legal guardian.

16. Sensitive Data

The Service is not designed to collect sensitive personal data.

You should not provide sensitive personal data, such as health data, biometric data, government identification numbers, financial account details, precise location data, or information about racial or ethnic origin, political opinions, religious beliefs, trade union membership, or sexual orientation.

If you voluntarily provide sensitive data in a support request, we will process it only as necessary to respond to your request and will delete or anonymize it where appropriate, unless retention is legally required.

17. Device and Speaker Information

The Service may process technical information about your device, app version, operating system, and app usage to provide and improve speaker cleaning functionality.

The Service does not perform a certified technical diagnosis of your device and does not determine whether your speaker is physically damaged.

Any information shown in the app about speaker cleaning, sound quality, cleaning progress, or cleaning results is for general utility purposes only and should not be treated as professional repair advice.

18. California and Other Regional Privacy Rights

If you are a resident of a jurisdiction that provides additional privacy rights, you may have the right to request access, deletion, correction, portability, or opt-out of certain processing.

We do not sell personal data in the traditional sense. If any advertising or analytics activity is considered a “sale” or “sharing” under applicable law, you may have the right to opt out.

To submit a request, contact us at support@kiab-imc.com.

19. Links to Third-Party Websites

The Service may contain links to third-party websites, apps, platforms, or services.

We are not responsible for the privacy practices, content, security, or policies of third parties. You should review their privacy policies before using them.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we may notify you by posting the updated Privacy Policy in the Service, on our website, or by other appropriate means.

The updated Privacy Policy will become effective on the date stated at the top of the document.

Your continued use of the Service after the updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy.

21. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our processing of personal data, please contact us at:

K.I.A.B INVESTMENT MANAGEMENT CONSULTING LTD
Registered address: 28 Oktovriou 317A, KANIKA BUSINESS CENTER BLOCK B, Floor 1, Office 101, Limassol, Cyprus
Support email: support@kiab-imc.com