Effective Date: 24 September 2024

At EMQM Limited, we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use this app. By using this app, you agree to the terms outlined in this Privacy Policy. If you do not agree with these terms, please refrain from using this app.

1. Who We Are 

Understeer is developed and maintained by EMQM Limited, based in England, United Kingdom. We act as the Data Controller in relation to the processing of personal data under the UK General Data Protection Regulation (UK GDPR).

2. Information We Collect

The app collects minimal information. Specifically, the app automatically creates a user account associated with your device’s unique identifier (UUID) to manage subscriptions and restore purchases. No personal data such as name, email address, or location is collected.

Data we collect:

•UUID (Unique User ID): This identifier is linked to your device and used to manage your Pro plan subscription and restore purchases.

We do not collect any other personal information.

3. How We Use Your Information

The limited information we collect is used for the following purposes:

•Subscription Management: The UUID is used to verify whether a user has subscribed to the Pro plan and to restore purchases if the  app is reinstalled.

•Purchase Restoration: In the event of deletion and reinstallation of the app, the UUID allows for the restoration of previous in-app purchases or subscriptions.

4. Legal Basis for Processing

We rely on the following legal basis to process your personal data under the UK GDPR:

•Performance of a Contract: We process your UUID to provide you with access to your Pro plan subscription, including purchase restoration services.

•Legitimate Interests: We process your UUID to ensure the correct functioning of the app and to restore in-app purchases, which is necessary to provide you with a consistent user experience.

5. Sharing Your Information

We do not share your personal data with third parties, except in the following circumstances:

•Service Providers: We may share limited information with third-party service providers who assist us with the functioning of the app, such as Apple for processing purchases or subscriptions. These service providers are contractually bound to safeguard your information.

•Legal Obligations: We may disclose your data if required by law or if we believe that such action is necessary to comply with legal obligations or protect our rights, safety, or property.

6. Data Retention

We retain your UUID for as long as it is necessary to provide the app’s services and manage your Pro plan subscription.

7. Security of Your Information

We implement appropriate technical and organisational measures to safeguard your data from unauthorised access, loss, or disclosure. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Data Protection Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

•Access: You have the right to request a copy of the data we hold about you.

•Rectification: You can request that we correct any inaccurate or incomplete information.

•Erasure: You have the right to request the deletion of your personal data, where applicable.

•Restriction of Processing: You can request that we restrict the processing of your data in certain circumstances.

•Objection to Processing: You have the right to object to our processing of your data in certain situations.

•Data Portability: You may request that your data be transferred to another service provider.

To exercise any of these rights, please contact us at [email protected].

9. International Data Transfers

As a company based in the United Kingdom, your data is processed in the UK. If we ever need to transfer your data outside of the UK or the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your data in accordance with UK GDPR.

10. Children’s Privacy

The app is not intended for use by individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will take steps to delete it.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted within the app, and the “Effective Date” at the top of the policy will be updated. Continued use of the app after any changes signifies your acceptance of the updated terms.

12. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us at:

[email protected]