Privacy Policy

1. Introduction

At Penguin Studio (hereinafter “Penguin Studio”, “we” or the “Controller”) we respect your privacy and are committed to protecting your personal data. This Privacy Policy (the “Policy”) explains what data we collect, how we use it, who we share it with and what your rights are as a User of the DrinksApp application (the “App”).

This Policy applies to the use of the App in all its versions and platforms. By using the App, the User accepts the practices described in this document.

2. Data Controller

• Legal name: Penguin Studio
• Business address: Medellín, Colombia
• Contact email: contact@abeber.co
• Website: https://abeber.co

3. Data We Collect

We collect the following categories of information:

3.1. Data provided directly by the User

The App is designed to work without requiring registration or identifiable personal data. If the User chooses to contact us by email, we may receive their email address and the content of their message.

3.2. Data collected automatically

When the User uses the App, we may automatically collect:

• Device data: model, operating system and version, device language and region, unique device identifiers (IDFA on iOS, AAID on Android).
• Usage data: interactions with the App, screens visited, game modes used, frequency and duration of use, access dates and times.
• Technical data: IP address (anonymized when technically possible), diagnostic data, error and performance logs.
• Purchase data: history of purchases and subscriptions made through the Stores (we do not receive credit card or payment method information).

3.3. Advertising data

If the User uses the free version of the App, our advertising partners may collect device advertising identifiers and ad interaction data. The User can limit ad tracking from their device settings (Settings > Privacy on iOS, or Settings > Google > Ads on Android).

4. Purposes of Processing

We use the collected data for the following purposes:

• Provide, maintain and improve the operation of the App.
• Process and manage purchases and subscriptions through the Stores.
• Display personalized or contextual advertising in the free version.
• Analyze use of the App to optimize its content and performance.
• Detect, prevent and address technical issues, fraud and abuse.
• Comply with legal obligations and respond to requests from competent authorities.
• Notify the User about changes to the App or to these policies.
• Provide support to the User when requested.

5. Legal Basis for Processing (EU/EEA and UK Users)

For Users subject to the European Union General Data Protection Regulation (GDPR) or equivalent regulations, the legal bases justifying processing are:

• Performance of a contract: to provide the App and manage its features, in accordance with the Terms and Conditions.
• Legitimate interest: to improve the App, prevent fraud and protect security.
• Consent: for the use of non-essential cookies, personalized advertising and push notifications (where applicable). The User may withdraw consent at any time.
• Compliance with legal obligations: where processing is necessary to comply with the law.

6. Cookies and Tracking Technologies

The App and our website may use cookies, advertising identifiers and similar technologies to:

• Remember the User's preferences (language, settings).
• Measure the performance and use of the App.
• Personalize the advertising shown (free version).

The User can manage cookies and trackers from their browser or device settings. Refusing certain cookies may limit available functionality.

7. Sharing Data with Third Parties

We do not sell or rent the User's personal data. We may share information with the following third parties, exclusively for the purposes described:

• Apple Inc. and Google LLC: as operators of the Stores through which the App is distributed and payments are processed.
• Analytics providers: such as Google Analytics for Firebase or equivalent services, to understand use of the App.
• Advertising providers: such as Google AdMob or other ad networks, to display ads in the free version.
• Infrastructure providers: hosting, cloud storage and technical monitoring services.
• Competent authorities: when legally required by court order, law or applicable regulation.

All third parties with whom we share information are contractually required to process the data in accordance with this Policy and applicable laws.

8. International Data Transfers

Data may be transferred to and stored on servers located outside the User's country of residence, including the United States and other countries where our technology providers operate. In such cases, we ensure that transfers are carried out under adequate legal mechanisms, such as the Standard Contractual Clauses approved by the European Commission, or equivalent.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy or to comply with legal obligations. Usage and diagnostic data are generally kept for a maximum of 24 months, unless a longer retention period is legally required. After that period, data is deleted or irreversibly anonymized.

10. Security

We implement reasonable technical and organizational measures to protect the User's data against unauthorized access, loss, alteration or destruction. However, no system is 100% secure and we cannot guarantee absolute security. The User is responsible for maintaining the security of their device and their account on the relevant Store.

11. User Rights

In accordance with applicable law, the User has the following rights regarding their personal data:

• Access: obtain confirmation as to whether we process their data and access it.
• Rectification: request correction of inaccurate or incomplete data.
• Erasure (“right to be forgotten”): request deletion of their data when it is no longer necessary.
• Restriction: request restriction of processing in certain cases.
• Portability: receive their data in a structured, commonly used format, or request its transmission to another controller.
• Objection: object to processing based on legitimate interest or for direct marketing purposes.
• Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of prior processing.
• Not to be subject to automated decisions: that produce legal effects or significantly affect them.
• Lodge complaints: with the competent supervisory authority (Agencia Española de Protección de Datos, CNIL in France, Garante in Italy, BfDI in Germany, ANPD in Brazil, Superintendencia de Industria y Comercio in Colombia, etc.).

To exercise any of these rights, the User may contact us at contact@abeber.co. We will respond to the request within the applicable legal deadlines (generally 30 days).

12. Minors

The App is not directed to persons under 18 (or the applicable age of majority). We do not knowingly collect personal data from minors. If a parent or guardian becomes aware that a minor has provided us with personal data, they should contact us so we can delete it immediately.

13. Provisions Applicable to Residents of Brazil (LGPD)

Users residing in Brazil are protected by the General Data Protection Law (Law No. 13,709/2018, “LGPD”) and have the same rights described in section 11, as well as the other rights provided for in that law. The competent authority is the Autoridade Nacional de Proteção de Dados (ANPD).

14. Provisions Applicable to Residents of Colombia (Habeas Data)

Users residing in Colombia are protected by Law 1581 of 2012 (General Personal Data Protection Regime) and related regulations. The User has the right to know, update, rectify and delete their personal data, as well as to revoke the authorization granted. The competent authority is the Superintendencia de Industria y Comercio (SIC).