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Privacy Policy
Effective date: June 30, 2025
Last updated: June 30, 2025
This Privacy Policy applies to the Bewhale Mobile application (the “Application”) developed and operated by QURELUX GmbH (hereafter referred to as “we,” “us,” or “Service Provider”), made available as a free, offline mobile application. This Policy is intended to inform users of our practices regarding the collection, use, and disclosure of information when using the Application.
Your privacy is of utmost importance to us. This Privacy Policy is designed to be compliant with applicable privacy regulations in both the European Union (EU General Data Protection Regulation - GDPR) and the United States (California Consumer Privacy Act - CCPA/CPRA).
1. Data Collection and Use
A. Types of Data Collected
We may collect the following categories of data from users of the Application:
Automatically Collected Information
When you use the Application, certain technical information may be collected automatically, including:
Your mobile device’s IP address
Your operating system version
The pages or features of the Application you interact with
Timestamps of use (e.g., when you launched or closed the app)
Session duration and in-app behavior
We do not collect or store precise geolocation data or access your GPS.
User-Provided Information
Some features of the Application may ask you to optionally provide personal data, including but not limited to:
Email address (for feedback or export features)
App usage data (e.g., predictions, tasks completed)
All such information is stored locally on your device only and is never sent to our servers unless explicitly stated and consented.
2. Purpose of Data Processing
We process personal data for the following purposes:
To operate the core functionality of the Application
To analyze anonymized usage statistics to improve performance and usability
To contact you only if explicitly permitted (e.g., via support email)
To allow data export or deletion at your request
To comply with legal obligations, protect user safety, or enforce terms of use
3. Legal Basis (GDPR Compliance)
Under Article 6 of the GDPR, we process your data only when one of the following applies:
Consent (Art. 6(1)(a)): when you provide email or other data voluntarily
Contractual necessity (Art. 6(1)(b)): to provide you with the requested service
Legitimate interests (Art. 6(1)(f)): for app security, analytics, and offline performance
Legal obligation (Art. 6(1)(c)): to comply with law enforcement or regulatory requirements
4. Third-Party Data Sharing
We do not sell your personal data. Data sharing is strictly limited:
We may transmit aggregated, anonymized data to external services to improve the Application (e.g., crash reporting).
We may disclose information:
If required by law, subpoena, or governmental request
To protect our legal rights or investigate misuse
To trusted third-party providers strictly for functional purposes (under NDA or equivalent safeguards)
5. Data Retention and Deletion
User-provided data remains on your device and is retained only as long as the app remains installed.
Upon uninstalling the Application, all stored data is deleted.
If you wish to delete your data while retaining the app, please contact us at vl.krasnobaev@qurelux.at and we will provide step-by-step instructions or send a purge script if applicable.
6. Children’s Privacy (COPPA & GDPR-K)
The Application is not directed to or intended for children under the age of 13 (U.S.) or 16 (EU). We do not knowingly collect or solicit personal data from children.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at vl.krasnobaev@qurelux.at. We will take prompt steps to delete such information.
7. Security
We take reasonable and appropriate security measures to protect your personal data, including:
Local device encryption (iOS sandboxing and secure CoreData implementation)
No cloud storage or server transmission
Protection against unauthorized access or data leakage
While we strive to use commercially acceptable means to protect your information, no method of storage is 100% secure.
8. Your Rights (GDPR + CCPA)
Depending on your location, you may have the following rights:
For EU/EEA Users (GDPR):
Right to access your data
Right to rectification or correction
Right to erasure (“Right to be forgotten”)
Right to data portability
Right to restrict or object to processing
Right to lodge a complaint with your local Data Protection Authority
For California Residents (CCPA/CPRA):
Right to know what personal data we collect and use
Right to request deletion of your personal data
Right to opt-out of data selling (not applicable as we don’t sell data)
Right to non-discrimination for exercising your privacy rights
To exercise any of these rights, please contact us at vl.krasnobaev@qurelux.at.
9. Opt-Out and App Uninstallation
You can opt-out of all data collection by uninstalling the Application at any time. The standard uninstall process for your device (iOS) is sufficient.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted in the app and/or on this page. If material changes occur, we will provide a prominent notice.
Continued use of the Application after any modifications implies acceptance of the revised policy.
11. Contact Us
For any questions or concerns regarding this Privacy Policy, or to make a request regarding your personal data, please contact:
QURELUX GmbH
Attn: Data Protection Officer
Email: vl.krasnobaev@qurelux.at
Effective date: June 30, 2025
Last updated: June 30, 2025
This Privacy Policy applies to the Bewhale Mobile application (the “Application”) developed and operated by QURELUX GmbH (hereafter referred to as “we,” “us,” or “Service Provider”), made available as a free, offline mobile application. This Policy is intended to inform users of our practices regarding the collection, use, and disclosure of information when using the Application.
Your privacy is of utmost importance to us. This Privacy Policy is designed to be compliant with applicable privacy regulations in both the European Union (EU General Data Protection Regulation - GDPR) and the United States (California Consumer Privacy Act - CCPA/CPRA).
1. Data Collection and Use
A. Types of Data Collected
We may collect the following categories of data from users of the Application:
Automatically Collected Information
When you use the Application, certain technical information may be collected automatically, including:
Your mobile device’s IP address
Your operating system version
The pages or features of the Application you interact with
Timestamps of use (e.g., when you launched or closed the app)
Session duration and in-app behavior
We do not collect or store precise geolocation data or access your GPS.
User-Provided Information
Some features of the Application may ask you to optionally provide personal data, including but not limited to:
Email address (for feedback or export features)
App usage data (e.g., predictions, tasks completed)
All such information is stored locally on your device only and is never sent to our servers unless explicitly stated and consented.
2. Purpose of Data Processing
We process personal data for the following purposes:
To operate the core functionality of the Application
To analyze anonymized usage statistics to improve performance and usability
To contact you only if explicitly permitted (e.g., via support email)
To allow data export or deletion at your request
To comply with legal obligations, protect user safety, or enforce terms of use
3. Legal Basis (GDPR Compliance)
Under Article 6 of the GDPR, we process your data only when one of the following applies:
Consent (Art. 6(1)(a)): when you provide email or other data voluntarily
Contractual necessity (Art. 6(1)(b)): to provide you with the requested service
Legitimate interests (Art. 6(1)(f)): for app security, analytics, and offline performance
Legal obligation (Art. 6(1)(c)): to comply with law enforcement or regulatory requirements
4. Third-Party Data Sharing
We do not sell your personal data. Data sharing is strictly limited:
We may transmit aggregated, anonymized data to external services to improve the Application (e.g., crash reporting).
We may disclose information:
If required by law, subpoena, or governmental request
To protect our legal rights or investigate misuse
To trusted third-party providers strictly for functional purposes (under NDA or equivalent safeguards)
5. Data Retention and Deletion
User-provided data remains on your device and is retained only as long as the app remains installed.
Upon uninstalling the Application, all stored data is deleted.
If you wish to delete your data while retaining the app, please contact us at vl.krasnobaev@qurelux.at and we will provide step-by-step instructions or send a purge script if applicable.
6. Children’s Privacy (COPPA & GDPR-K)
The Application is not directed to or intended for children under the age of 13 (U.S.) or 16 (EU). We do not knowingly collect or solicit personal data from children.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at vl.krasnobaev@qurelux.at. We will take prompt steps to delete such information.
7. Security
We take reasonable and appropriate security measures to protect your personal data, including:
Local device encryption (iOS sandboxing and secure CoreData implementation)
No cloud storage or server transmission
Protection against unauthorized access or data leakage
While we strive to use commercially acceptable means to protect your information, no method of storage is 100% secure.
8. Your Rights (GDPR + CCPA)
Depending on your location, you may have the following rights:
For EU/EEA Users (GDPR):
Right to access your data
Right to rectification or correction
Right to erasure (“Right to be forgotten”)
Right to data portability
Right to restrict or object to processing
Right to lodge a complaint with your local Data Protection Authority
For California Residents (CCPA/CPRA):
Right to know what personal data we collect and use
Right to request deletion of your personal data
Right to opt-out of data selling (not applicable as we don’t sell data)
Right to non-discrimination for exercising your privacy rights
To exercise any of these rights, please contact us at vl.krasnobaev@qurelux.at.
9. Opt-Out and App Uninstallation
You can opt-out of all data collection by uninstalling the Application at any time. The standard uninstall process for your device (iOS) is sufficient.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted in the app and/or on this page. If material changes occur, we will provide a prominent notice.
Continued use of the Application after any modifications implies acceptance of the revised policy.
11. Contact Us
For any questions or concerns regarding this Privacy Policy, or to make a request regarding your personal data, please contact:
QURELUX GmbH
Attn: Data Protection Officer
Email: vl.krasnobaev@qurelux.at