SunnyOrbit Privacy Policy

1. Who we are

SunnyOrbit is a trading name of Moiasun LLC, a limited liability company organised under the laws of the State of Delaware, USA. SunnyOrbit is a small independent studio that makes mobile apps. Our first app is Pooled.

Moiasun LLC is the controller of the personal data described in this policy. That means we decide how and why it is used.

• Postal address: 16192 Coastal Highway, Lewes, DE 19958, United States
• Email: support@sunnyorbitapps.com (our single contact address for everything, including privacy)

We have not appointed a data protection officer. Please send any privacy question to the email address above.

In this policy, "we", "us" and "our" mean Moiasun LLC, trading as SunnyOrbit.

2. What this policy covers

This policy covers two things:

• the website at sunnyorbitapps.com, including the Pooled pages on it; and
• any email you send us, whatever it is about.

Each of our apps has its own privacy policy that explains the data handled inside that app:

• Pooled: Pooled Privacy Policy

For data inside an app, that app's policy governs. If it and this policy say different things about that app, the app's policy is the one that applies.

3. This website

We collect nothing through the website itself. sunnyorbitapps.com has no sign-up, no account and no form that sends data to us directly. (The contact form only opens your own email app with a message ready to send.) It does not set cookies. It does not use local storage, session storage, tracking pixels, analytics or advertising tools. The one small script on the site handles things like the menu and animations. It stores nothing on your device and sends nothing anywhere. Our fonts are hosted on our own site, so loading a page does not contact Google Fonts or any other font service. Our Cookie Policy has more detail.

Our host logs IP addresses. The site is hosted by GitHub Pages, a service of GitHub, Inc. When you visit, GitHub logs your IP address for security purposes. GitHub handles those logs under its own GitHub General Privacy Statement. We do not receive, see or use those logs.

Links to other sites. The site links to other services, such as Google Play. If you follow one of those links, the other service's privacy policy applies to what happens there.

4. Emails you send us

If you email support@sunnyorbitapps.com, including through the contact form or a link on this site that opens your email app, we receive:

• your email address and the name shown on your email;
• what you write, plus anything you attach, such as screenshots; and
• the technical details that come with any email, such as the date and time it was sent.

We use this to read and answer your message, fix problems you report, handle privacy requests, and keep a record of what we agreed with you. We do not add you to a mailing list and we do not send marketing email.

Please do not send us more than we need. For example, don't send passwords, full bank details or ID documents. If we need to confirm who you are, we will tell you what we need.

Our email is handled by [TO FILL: email provider, e.g. Google Workspace / Zoho], which stores our mailbox on our behalf.

You do not have to email us, and nothing on the website needs you to. If you want a reply, though, we need your email address to send it.

5. Our apps

Each app's own policy describes what that app does with your data. Here is a short summary for Pooled. The Pooled Privacy Policy is the full and binding version.

• Pooled works without an account. Without an account, nothing leaves your phone, and your records are encrypted on the device.
• Pooled has no ads, analytics, crash reporting or tracking tools. The only company it contacts is Google (Firebase), and it does so only once you create an account.
• If you create an account, your data is synced to Google Firebase. It is encrypted in transit and at rest, but it is not end-to-end encrypted.

6. Why we may use your data (legal bases)

Data protection law in the EU, the UK and some other places requires us to state a legal basis for each use of personal data. Ours are:

• Answering your emails and helping with problems you report: our legitimate interest in replying to people who contact us and in improving our apps. If your email is about an app account, answering it also helps us provide the service you signed up for.
• Handling privacy requests, and keeping records that show we handled them: legal obligation.
• Keeping emails that may be needed to set up, bring or defend a legal claim: legitimate interest.
• Consent: we do not currently rely on consent for anything this policy covers. If we ever do, we will say so at the time. You will be able to withdraw your consent whenever you like, without affecting anything we did before.

We make no automated decisions about you and we do not profile you. We do not use your personal data to train AI models.

7. Who we share it with

We do not sell personal data. We do not share it for advertising, and we do not give it to data brokers.

We share personal data only in these cases:

• Service providers (processors) that store or handle data on our behalf and only on our instructions. For the matters this policy covers, that is our email provider, [TO FILL: email provider]. (GitHub hosts the website, but as explained above, it keeps its own security logs and we do not send it any data.)
• Legal requests. We may disclose data if the law requires it, for example because of a valid court order. We may also disclose it where we need to in order to protect someone's safety or to establish or defend a legal claim. Unless the law forbids it, we will tell you first.
• A change of ownership. If Moiasun LLC or one of its apps is ever sold or merged, personal data may pass to the new owner. The new owner would have to keep the promises in this policy. We would tell you before that happened.

8. International transfers

Moiasun LLC is a US company. The people who run SunnyOrbit may read and answer your email from outside the United States, including from Bangladesh. Our email provider may store the mailbox in the United States or elsewhere. GitHub keeps its logs in the United States.

If you are in the EU, the UK or Switzerland, this means your personal data will be handled in countries whose data protection laws differ from yours. We handle it as this policy describes wherever it is. Where our email provider receives data from the EU, the UK or Switzerland, we rely on one of two safeguards. If the provider takes part in the EU-US Data Privacy Framework (and, for UK data, its UK Extension), we rely on that. Otherwise, we rely on the Standard Contractual Clauses in the provider's data processing terms. Email us if you would like more information about these safeguards.

9. How long we keep it

• Support emails: we delete an email thread within 12 months of the last message in it. There are two exceptions, set out in the next two points.
• Records of privacy requests: if you ask to see, correct or delete your data, we keep a short record of the request and of what we did for 3 years after we close it. The record says who asked, what was asked, when, and what we did. It lets us show we handled the request properly.
• Legal claims: if an email is needed for an actual or likely legal claim, we keep it until the matter is finished.
• Website logs: GitHub decides how long it keeps its own logs. We hold no website data.

You can ask us to delete an email conversation sooner. We will do so unless one of the exceptions above applies.

10. Security

The website is served over HTTPS, so pages travel to you encrypted. Only the people who run SunnyOrbit can read the support mailbox. We keep the data we hold to a minimum, which also limits what could be exposed.

No system is perfectly secure, and we will not claim otherwise. If a security incident affects your personal data, we will tell you, and any regulator, as the law requires.

11. Your rights

Wherever you live, you can ask us to:

• tell you whether we hold personal data about you, and give you a copy (access);
• correct anything that is wrong (rectification);
• delete it (erasure);
• limit how we use it while a question is being sorted out (restriction);
• give it to you, or to someone else, in a common machine-readable format (portability);
• stop using it, where we rely on legitimate interests (objection); and
• withdraw any consent you have given, without affecting what we did before.

How to ask. Email support@sunnyorbitapps.com, if possible from the email address the request is about. Before we act on a request, we check that it really comes from you. Usually we do this by replying to that address. If we need more, we ask only for what is necessary to confirm who you are. Someone else can make a request for you if they show us that you have authorised them.

How long it takes. Requests are free. We reply within one month. If a request is complex, we may extend this by up to two further months, and we will tell you why within the first month. Where a US state law sets its own deadline, we reply within 45 days and extend by up to another 45 days only where that law allows. If we cannot do what you ask, for example because the law requires us to keep something, we will explain why.

We will not treat you differently for using any of these rights.

For data inside an app, you can often do this yourself in the app. The app's own policy explains how.

12. Complaints

If you are unhappy with how we have handled your data, please tell us first at support@sunnyorbitapps.com. We will try to put it right.

If you are in the EU/EEA, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State where you live, work, or where you believe an infringement occurred (see the list of EU authorities).

If you are in the UK, you can complain to us first at support@sunnyorbitapps.com. We will acknowledge your complaint within 30 days and respond without undue delay. You can also complain to the Information Commissioner's Office.

Wherever you live, you can contact your local data protection authority.

13. United States notices

No sale, no targeted advertising. We do not sell personal data, including sensitive data. We do not share it for cross-context behavioural advertising, and we do not use it for targeted advertising or profiling. That holds for every meaning of "sell" and "share" in California law and in the other US state privacy laws.

California and Delaware. This section gives the disclosures required by the California Online Privacy Protection Act (CalOPPA) and the Delaware Online Privacy and Protection Act. The personal information we collect, what we use it for and who receives it are listed in sections 3, 4 and 7. You can review and ask us to change your information as described in section 11. We explain how we tell you about changes in section 17. The effective date is at the top of this page. California and Delaware residents have the same rights as everyone else under section 11.

Do Not Track. Some browsers send a "Do Not Track" (DNT) or Global Privacy Control signal. We do not track you across other websites or apps over time, and we do not let third parties do so through our website or apps. So there is nothing for these signals to switch off, and we treat every visitor as if the signal were on. No third party collects personal information about your online activities over time and across different websites when you use our website or apps.

14. Other countries

Everyone gets the rights in section 11, wherever they live. Some countries also give you a regulator you can go to:

• Brazil: you have the rights given by the LGPD, and you can petition the national data protection authority (ANPD). Our channel for LGPD requests is support@sunnyorbitapps.com.
• Canada: you can complain to the Office of the Privacy Commissioner of Canada.
• India, Bangladesh and elsewhere: you can contact your national data protection authority. We will add the specific information your local law requires as those laws come into force.

15. Children

Our website and apps are not directed at children. You must be 18 or older to use our apps. We do not knowingly collect personal information from anyone under 18.

If we learn that we hold personal data about someone under 18 because they used our website or apps, we delete it. If they have an app account, we close it. If you believe a child has given us personal data, whether you are a parent, a guardian or anyone else, please email support@sunnyorbitapps.com and we will act on it.

16. EU and UK representative

EU representative. Under Article 27 of the GDPR, we have appointed [TO FILL: EU representative name and address, or remove this section if the owner decides not to appoint one or excludes the EU from distribution] as our representative in the European Union. You may contact them, in addition to or instead of us, on any matter relating to the processing of your personal data.

UK representative. Under Article 27 of the UK GDPR, we have appointed [TO FILL: UK representative name and address, or remove this paragraph if not appointed] as our representative in the United Kingdom.

17. Changes to this policy

If we change this policy, we will post the new version on this page and update the date at the top. If a change materially affects how we use information you have already given us, we will tell you before it takes effect. We will do that in the app concerned, or by email if we have your address. Earlier versions are available on request.

18. Contact

For questions about this policy or your personal data, email support@sunnyorbitapps.com, or write to Moiasun LLC, 16192 Coastal Highway, Lewes, DE 19958, United States.

We wrote this policy to describe what we actually do. If anything here is unclear, please email us and we will explain.