Noko & Nela mobile app – Privacy Policy (GDPR)
Service: “Noko & Nela” mobile application (iOS/Android) and the related website
Data Controller: lcc.hu Kft. (registered office: 2040 Budaörs, Ostor utca 9.; tax number: 11712293-2-13; EU VAT No.: HU11712293; company register No.: 13-09-233626)
Contact: legal-support@nokoandnela.com
Territorial scope: EU Member States
Languages: Hungarian and English; in case of inconsistency, the Hungarian version prevails.
1. What does this notice cover?
This notice explains how we process personal data in the Noko & Nela mobile app and on the related website. Children are not expected to provide personal data on their own; the app is used with a parent/guardian present.
2. At‑a‑glance summary
- No accounts, no subscriptions, no ads.
- By default: the app collects usage analytics (Google Analytics 4 / Firebase) for aggregate measurement and quality improvement; no advertising profiling.
- Email contacts: support and complaints are handled via email. The app may pre‑fill certain technical details into the email body to speed up troubleshooting; you may delete or edit these details before sending.
3. Categories of data and purposes
Contact data (email contents, optional name): when you contact us by email. Purpose: customer support, complaint handling, establishing/defending legal claims. Legal basis: GDPR Art. 6(1)(b) (performance/support) and 6(1)(f) (legitimate interests). Retention: typically 12 months; longer where needed for legal claims.
Device technical details within support emails (e.g., platform, OS version, app version): the app may pre‑insert these in the mailto template; you are not required to send them and you may remove them. Purpose: troubleshooting. Legal basis: legitimate interests (GDPR Art. 6(1)(f)). Retention: aligned with contact emails.
Usage data / analytics (GA4/Firebase): events, screen views, session counts, app version. We do not collect precise location, contacts, or use advertising identifiers for profiling. Purpose: understand usage patterns, improve quality, identify errors. Legal basis: legitimate interests (GDPR Art. 6(1)(f)), with a balancing test; no cross‑service tracking and no advertising use. Retention: 2 months (default) or 14 months (depending on configuration); after that, non‑aggregated data is deleted.
Note: We do not target or knowingly collect children’s personal data. If we learn a child’s personal data reached us without parental authorization, we will delete it.
4. Children’s protection
- The Service is used with a parent/guardian present.
- If the app is distributed under Apple’s Kids Category, any third‑party analytics must comply with the category’s rules and be used for measurement only; use of advertising identifiers or ad‑targeting is not permitted.
5. Third parties and disclosures
- Platform providers: Apple/Google ecosystems for app distribution.
- Analytics (legitimate interests; active): Google Analytics 4 / Firebase (Google Ireland Limited). Event and user‑data retention is 2 or 14 months; non‑aggregated data is deleted thereafter. Google’s EU Data Boundary solutions and SCCs may apply to any transfers outside the EEA.
6. International transfers
Analytics processing occurs primarily within the EU. If data is transferred outside the EEA, such transfers rely on the EU Standard Contractual Clauses (SCCs) and/or Google’s EU Data Boundary mechanisms.
7. Legal basis and settings (analytics)
Analytics runs under our legitimate interests (GDPR Art. 6(1)(f)). Right to object: you may object to analytics by emailing us; we will assess your request and, where technically reasonable, limit or disable collection associated with you. Objections do not affect processing carried out lawfully before your request.
8. Your rights
You have the right to access, rectify, erase (“right to be forgotten”), restrict processing, object (where processing is based on legitimate interests), and data portability (where applicable).
How to exercise: email legal-support@nokoandnela.com and we’ll respond within 30 days.
9. Complaints and supervisory authority
If you believe your personal data is processed unlawfully, you may lodge a complaint with your local supervisory authority, or with the Hungarian authority:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
1055 Budapest, Falk Miksa utca 9–11.
Phone: +36 (1) 391‑1400
Email: ugyfelszolgalat@naih.hu
Web: naih.hu
10. Security
We apply reasonable technical and organizational measures (app‑level access controls, encryption in transit, limited logging). We do not use automated decision‑making or profiling.
11. Retention and deletion
- Support correspondence: typically 12 months.
- Analytics: 2 or 14 months depending on GA4 settings; thereafter non‑aggregated data is automatically deleted.
- Data needed for legal claims: retained until the limitation period expires.
12. Website cookies
On the website we use only strictly necessary cookies. If we later use any non‑essential (e.g., analytics) cookies, we will seek prior consent and publish a detailed cookie notice.
13. Processors
Processors acting on our behalf (only if and insofar as we use them): – Google Ireland Limited – Google Analytics 4 / Firebase (analytics; based on legitimate interests)
– Apple Distribution International Ltd. / Google LLC – platform and store services (app distribution)
14. Contact and requests
For privacy requests and to exercise your rights: legal-support@nokoandnela.com.
15. Changes
We may update this notice from time to time. Changes take effect on the date of publication, and the Effective Date at the end of this document will be updated.
Effective as of October 31, 2025.