Privacy Policy - Evelina Care

1. Introduction

Evelina Care ("we," "us," "our," "Company") is a healthcare service provider incorporated in Lithuania. This Privacy Policy explains our data practices and your rights when using our mobile application and services available through Google Play Store and other platforms.

Contact Information:

• Service Provider: Evelina Care
• Registration: Lithuania
• Email: kestutis@evelinacare.com

We reserve the right to suspend or terminate your access to our services immediately and without prior notice if we determine, in our sole discretion, that you have violated any terms of service or this privacy policy.

2. Children's Privacy and COPPA Compliance

2.1 Children Under 13 (COPPA Compliance)

Our app is designed as a general audience app but may be used by children under 13. We are fully compliant with the Children's Online Privacy Protection Act (COPPA).

Key Points:

• We do NOT collect any personal information from children under 13
• We do NOT collect any personal information from users of any age
• Since we collect no personal data, parental consent is not required
• Parents do not need to review or delete any personal information as none is collected

2.2 International Compliance

• GDPR (EU): We comply with GDPR requirements for children under 16
• Local Laws: We comply with applicable local laws regarding children's privacy
• Age Verification: Since we collect no personal data, age verification is not required

2.3 Parental Rights

Since we do not collect personal information from children or any users:

• There is no personal information to review
• There is no personal information to delete
• Parents can contact us at any time with questions: kestutis@evelinacare.com

3. Data We Do NOT Collect

We do not collect, store, or process:

• Names, addresses, or contact information
• Health or medical data
• Government identification numbers (Social Security numbers, etc.)
• Financial or payment information
• Personal identifiers of any kind
• User accounts or profiles
• Photos, videos, or audio recordings
• Location data (precise or approximate)
• Email addresses or phone numbers
• Biometric data
• Calendar information
• Contact lists
• Device identifiers for advertising purposes

4. Technical Data We May Collect

4.1 Anonymous Technical Information

We may collect limited, non-personal technical data including:

• Anonymous usage statistics (app crashes, feature usage)
• General geographic region (country/city level only)
• Device type (mobile/tablet, operating system version)
• App version information
• Anonymized error logs for bug fixing

4.2 Cookies and Local Storage

• Essential data storage only for app functionality
• No tracking cookies or analytics cookies
• No third-party tracking services
• Users can clear app data without affecting core functionality

Important: All technical data collected is anonymous and cannot be used to identify individual users.

5. How We Use Technical Data

Anonymous technical data is used solely for:

• Maintaining app functionality and performance
• Improving user experience
• System security and stability monitoring
• Bug fixes and app improvements
• General usage analytics (aggregated and anonymous only)

6. Data Sharing and Third Parties

6.1 No Personal Data Sharing

Since we collect no personal data:

• We have no personal data to share with third parties
• We do not sell, rent, or trade any user information
• We do not share data with advertising networks
• We do not share data with analytics providers

6.2 Technical Service Providers

• We may use technical service providers for app hosting and infrastructure
• These providers have access only to anonymous technical data
• All providers are bound by strict data processing agreements
• No personal information is ever shared

6.3 Legal Compliance

• We may provide anonymous technical logs if legally required
• No personal data can be disclosed as none is collected
• We will notify users of any legal requests when legally permitted

7. International Data Transfers

• No personal data transfers occur as none is collected
• Anonymous technical data may be processed by service providers
• All technical processing occurs within EU/EEA or adequate jurisdictions

8. Data Security

8.1 Technical Safeguards

• Encrypted connections (HTTPS/TLS)
• Secure infrastructure with regular updates
• Access controls for technical systems
• Regular security audits

8.2 No Personal Data at Risk

Since we collect no personal data, there is no personal information at risk of breach or unauthorized access.

9. Your Rights

9.1 Limited Rights Application

Since we collect no personal data:

• No access rights needed (no personal data stored)
• No correction rights applicable
• No deletion rights necessary
• No portability rights relevant

9.2 Technical Data Control

• Cookie control through browser settings
• Opt-out from any optional technical data collection
• Service discontinuation at any time

10. Advertising and Marketing

10.1 No Personalized Advertising

• We do not serve personalized advertisements
• We do not collect data for advertising purposes
• We do not share data with advertising networks
• Any advertisements (if present) are not targeted based on personal information

10.2 Third-Party Advertising

If our app contains advertisements:

• Ads are served by third-party providers
• We do not control third-party advertising practices
• Third-party advertisers may collect their own data according to their privacy policies
• Users should review third-party privacy policies independently

11. App Permissions

11.1 Required Permissions

Our app may request the following permissions for functionality:

• Internet Access: To provide online features and updates
• Network State: To check connectivity for online features

11.2 No Sensitive Permissions

We do not request access to:

• Camera or microphone
• Location services
• Contact lists
• Photo galleries
• SMS or phone functions
• Calendar or other personal data

11.3 Permission Management

• Users can review and modify app permissions in device settings
• Denying permissions may limit app functionality but will not affect core features

12. Service Termination and Access Blocking

12.1 Immediate Termination Rights

• You violate any terms of service
• You attempt to compromise system security
• You engage in prohibited activities
• We determine, in our sole discretion, that continued access poses risks
• You misuse our services in any way

12.2 No Data Impact

Since no personal data is collected:

• No personal data deletion required upon termination
• No data retention concerns
• No impact on personal information

13. Third-Party Services and Links

13.1 External Links

• Our app may contain links to third-party websites or services
• We are not responsible for third-party privacy practices
• Users should review third-party privacy policies independently
• Third-party services may collect personal information according to their own policies

13.2 Integrated Services

• We may integrate with third-party services for functionality
• Integration does not involve sharing personal data (as we collect none)
• Third-party services may collect their own data directly from users

14. Compliance Framework

14.1 Legal Compliance

We comply with:

• Children's Online Privacy Protection Act (COPPA) - United States
• General Data Protection Regulation (GDPR) - European Union
• Lithuanian data protection laws
• International privacy standards and best practices

14.2 Google Play Store Requirements

This privacy policy meets all Google Play Store requirements including:

• Comprehensive disclosure of data practices
• Clear information about children's privacy
• Transparency about third-party data sharing
• Contact information for privacy inquiries

15. Contact Information and Data Protection Authority

15.1 Privacy Inquiries

For all privacy questions, contact:

• Email: kestutis@evelinacare.com
• Response Time: We will respond to privacy inquiries within 30 days

15.2 Supervisory Authority

For privacy concerns in the EU, you may contact:

• Authority: State Data Protection Inspectorate (Lithuania)
• Address: A. Juozapavičiaus str. 6, LT-09310 Vilnius
• Phone: +370 5 279 1445
• Email: ada@ada.lt

15.3 Additional Contacts

For users in other jurisdictions, contact your local data protection authority or privacy commissioner.

16. Policy Updates and Changes

16.1 Change Notification

• Website and app posting of policy updates
• Significant changes will be prominently displayed
• Continued use constitutes acceptance of changes
• We recommend reviewing this policy periodically

16.2 Material Changes

• Significant policy changes will be prominently displayed in the app
• Users may discontinue service if they disagree with changes
• We will provide advance notice of material changes when possible

16.3 Version Control

• This policy supersedes all previous versions
• Previous versions are available upon request
• Effective date indicates when current version took effect

17. Governing Law and Jurisdiction

This Privacy Policy is governed by:

• Primary Jurisdiction: Lithuanian law
• Data Protection Framework: EU GDPR
• Additional Regulations: Local regulations as applicable
• Dispute Resolution: Lithuanian courts have jurisdiction for legal disputes

18. Additional Information

18.1 Language

• This policy is provided in English
• Translations may be available but English version controls
• Contact us if you need clarification in other languages

18.2 Accessibility

• We are committed to making this policy accessible to all users
• Contact us if you need this policy in an alternative format
• We will provide reasonable accommodations for accessibility needs