Privacy Policy — Flatty

Effective date: June 17, 2025  ·  Last updated: June 17, 2025

1. Introduction

Kadilo Inc. ("we", "us", or "our") operates the Flatty mobile application (the "App") — a rental apartment aggregator available in Belarus and Poland. This Privacy Policy explains what personal data we collect, how we use it, and what rights you have regarding your data.

By using the App, you agree to the collection and use of information as described in this policy.

2. Data Controller

For all privacy-related requests, please contact us at the email address above.

3. What Data We Collect and Why

3.1 Data collected automatically

When you use the App, we automatically collect the following data:

Data	Purpose	Legal basis
IP address	Security, fraud prevention	Legitimate interest
Device name, OS version, app version	Bug diagnostics, compatibility	Legitimate interest
App usage data (screens visited, session duration)	Product improvement	Legitimate interest
Crash logs and error reports	Bug fixing	Legitimate interest
Advertising ID (GAID on Android, IDFA on iOS)	Showing relevant ads (non-premium users only)	Consent
Push notification token	Delivering notifications about new listings	Consent

3.2 Data you provide voluntarily

Data	Purpose	Legal basis
Saved searches and filters	Restoring your preferences	Contract performance
Favourite listings	Providing the favourites feature	Contract performance
Notes on listings	Providing the notes feature	Contract performance
Approximate location	Displaying listings on the map	Consent

4. Third-Party Services

We use the following third-party services that may collect data as described in their own privacy policies:

Service	Purpose	Privacy Policy
Google Play Services	Core Android functionality	policies.google.com/privacy
Google AdMob	Displaying ads (non-premium users)	policies.google.com/privacy
Firebase Cloud Messaging	Push notifications	firebase.google.com/support/privacy
Google Maps SDK	Displaying listings on the map	policies.google.com/privacy

We do not integrate Facebook, Appodeal, or any other advertising networks beyond those listed above.

5. Advertising and Consent (GDPR / EEA Users)

If you are located in the European Economic Area (EEA), including Poland, we will ask for your consent before showing personalised ads via Google AdMob.

• If you grant consent, AdMob may use your Advertising ID to show ads relevant to your interests.
• If you decline consent, you will still see ads, but they will not be personalised.
• You can withdraw or change your consent at any time through the App's privacy settings or by contacting us at flattyby@gmail.com.

Google AdMob processes ad-related data under its own terms. Data may be transferred to Google servers in the United States under Standard Contractual Clauses approved by the European Commission.

6. App Tracking Transparency (iOS)

On iOS 14 and later, we request permission to access your device's Advertising Identifier (IDFA) through Apple's App Tracking Transparency (ATT) framework. This identifier is used solely for delivering relevant ads via Google AdMob.

• If you allow tracking, personalised ads may be shown.
• If you decline, non-personalised ads will be shown instead.

You can change this permission at any time in iPhone Settings → Privacy & Security → Tracking → Flatty.

7. International Data Transfers

We use services provided by Google LLC, which is based in the United States. When data is transferred outside the EEA, Google relies on Standard Contractual Clauses (SCCs) as the legal mechanism to ensure adequate data protection. For more information, see Google's data transfer FAQ.

8. Data Retention

We retain automatically collected technical data (logs, crash reports) for no longer than 12 months. Data stored locally on your device (favourites, filters, notes) remains until you delete the App or clear its data. We do not operate user accounts, so there is no account deletion process.

9. Children's Privacy

The App is not directed to children under the age of 13. We do not knowingly collect personal data from children. If you believe your child has provided us with personal data, please contact us at flattyby@gmail.com and we will delete it promptly.

10. Your Rights (EEA / GDPR)

If you are located in the EEA, you have the following rights under the General Data Protection Regulation (GDPR):

• Right of access — you can request a copy of the personal data we hold about you.
• Right to rectification — you can ask us to correct inaccurate data.
• Right to erasure ("right to be forgotten") — you can request deletion of your personal data.
• Right to restriction — you can ask us to restrict how we process your data.
• Right to data portability — you can request your data in a structured, machine-readable format.
• Right to object — you can object to processing based on legitimate interest.
• Right to withdraw consent — where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at flattyby@gmail.com. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority. In Poland, this is:

11. Security

We use commercially reasonable technical and organisational measures to protect your data. However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

12. Cookies

The App itself does not use cookies. However, third-party SDKs embedded in the App (such as Google AdMob) may use local storage or similar technologies for ad measurement and frequency capping.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of the App after changes are posted constitutes acceptance of the updated policy.

14. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us: