Privacy Policy

Last updated: 14 June 2026

This Privacy Policy explains how Venturer Network s.r.o. ("Venturer", "we", "us", or "our") collects, uses, shares, and protects information when you use the Venturer Guide mobile application (the "App"). Venturer Guide is a self-guided city tour app with audio narration.

We are the data controller responsible for your personal data.

Controller details

We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and applicable Slovak data protection law.

1. Scope

This Policy applies to the Venturer Guide App, currently distributed via Google Play for Android devices. When the App becomes available on additional platforms (such as Apple's App Store), this Policy will be updated to reflect any platform-specific practices.

The App does not require you to create an account or provide your name, email address, or other contact details. However, this does not mean we collect no personal data. Even without an account, a persistent identifier tied to your device allows us to recognise your device across sessions and build a usage profile associated with it. Under the GDPR, this device-linked information is still personal data, and this Policy explains how we handle it.

2. Information we collect

We only collect information where we have a reason to do so. Because the App has no sign-up, we do not collect your name, email, or contact details. The data we do collect falls into the categories below.

a) Location data

The App accesses your device's GPS location while the App is open and in use, in order to provide its core functionality — showing you nearby points of interest, your position on the map, and location-based guide content. We do not collect your location in the background or while the App is closed.

We also derive a coarser, stored form of your location: we reverse-geocode your position into an approximate city or area and save this (for example, the city you are currently in, or whether you are near a city you previously visited). We use this derived location, together with your usage data, to show relevant content and to send you relevant push notifications (see section (d) below).

You control location access through your device's location permission and can disable it at any time in your device settings. If you disable it, location-dependent features will not work and we will not collect or derive location data.

b) Device, identifier, and usage data

When you use the App, certain technical and usage information is collected automatically, including:

  • Device information — device model, operating system and version, language and region settings, mobile network information;
  • Identifiers — device identifiers (such as your Android device ID) and an installation identifier used by our analytics and bug-reporting tools to recognise your device across sessions. This identifier is shown to you as a Support ID on the App's home screen, so you can reference it if you ever contact us about your data (see section 7);
  • Usage information — the features and content you interact with, screens viewed, audio played, places saved, tours started, taps and other in-app actions, search and filter activity, session frequency and duration, and crash and performance data;
  • Approximate location derived from your IP address.

c) Analytics and profiling

We use analytics tools to understand how the App is used, to improve it, and to group users into audience segments for the notifications described below. We build a pseudonymous, device-level profile that records, for example, how many audio guides you have played, places you have saved, and tours you have started, your subscription status, and your approximate location.

We analyse this usage to create audience segments — for example, users who started but did not finish a tour, or who have not opened the App for a number of days. This is a form of profiling, used to decide which notifications and content are relevant to you. It does not produce legal effects concerning you or similarly significantly affect you.

We use the following providers:

  • Mixpanel (Mixpanel, Inc.) — product analytics. Your Mixpanel data is processed on Mixpanel's EU-hosted infrastructure.
  • Google Analytics for Firebase / GA4 (Google Ireland Limited / Google LLC) — used to build audience segments for push-notification targeting.

Session recording. We use Mixpanel's mobile Session Replay feature, which captures the screens of the App as they appear to you while you use it, similar to a screen recording. By default, this technology masks anything you type. We have configured it to show place and tour content — place names, descriptions, and photos of locations and points of interest, all sourced from our own app content rather than from you — so we can understand how that content is used. Text you type, such as in the search field, remains masked and is never visible in recordings, and the App does not include any feature for uploading or viewing personal photos. Session recordings are linked to the same device-level identifier used for our other analytics, so a recording can be associated with the device profile described in section (b), though not with your name or contact details. We currently record sessions for all users of the App; recordings are stored by Mixpanel for up to 30 days, after which they are no longer available. Access to session recordings is restricted to authorised personnel at Venturer who need it to improve the App.

We rely on our legitimate interest in understanding how the App is used, diagnosing problems, and improving the product as the legal basis for this processing (see section 3). We do not use session recordings or analytics data for advertising, and we do not sell this data. You can object to this processing at any time — see Your rights in section 7.

d) Push notifications

We use Firebase Cloud Messaging (Google) to send you push notifications — for example about new tours and cities, features, updates, or a reminder to continue a tour you left unfinished. To do this, a unique push-notification token is associated with your device. Using the audience segments described in section (c), some of these notifications are targeted to users for whom they are relevant. You can turn push notifications off at any time in your device settings, which stops this processing.

e) Feedback and bug reports

The App includes an in-app feedback and bug-reporting feature provided by Shake (Shake Technologies). When you submit feedback, we collect the message you write, any screenshots or attachments you choose to add, a device identifier, and technical diagnostic information (such as device and app details and logs) so we can reproduce and fix problems. This information is collected only when you choose to submit feedback.

f) Subscription and purchase data

The App offers paid subscriptions on a monthly or yearly basis. Subscription management and payment processing for the App use RevenueCat (RevenueCat, Inc.) and Google Play Billing. RevenueCat manages subscription state, validates purchases, and syncs entitlements. It identifies your device using an anonymous App User ID and does not receive your name, email address, or payment card details. All payment transactions are processed by Google Play Billing. We do not collect, receive, or store your payment card details — Google processes your payment in accordance with its own privacy policy.

In connection with your subscription, we store and process:

  • Your subscription status (active, expired, cancelled), plan type, billing cycle, start and end dates, and subscription value;
  • A device or order identifier and purchase token provided by Google Play, which lets us verify and manage your entitlement.

We use this information to provide and manage your subscription and to comply with our legal and accounting obligations.

g) Affiliate links

The App may include affiliate links to third-party services such as GetYourGuide. When you tap such a link, you are taken to the third party's own website or app, with a unique affiliate identifier that allows the partner to attribute the referral to us. We do not share your personal data directly with these partners. Once you leave the App, the third party's own privacy policy and terms govern your interaction with them. We may receive aggregated, non-identifying reporting (such as the number of referrals or commissions earned).

3. How we use your information and our legal bases

Under the GDPR, we rely on the following legal bases:

Purpose Legal basis (GDPR Art. 6)
Providing the App's core features, including location-based guide content Performance of a contract / our legitimate interest in providing the service you requested
Providing and managing paid subscriptions and processing transactions via Google Play Performance of a contract
Complying with accounting, tax, and other legal obligations Compliance with a legal obligation
Analytics, profiling, and session recording to understand and improve the App and build audience segments Our legitimate interest in understanding usage, fixing problems, and improving the App
Sending push notifications, including targeted notifications Our legitimate interest in keeping you informed about relevant content and features, balanced against your right to object (see section 7) and your ability to disable notifications in device settings
Handling feedback and bug reports you submit Our legitimate interest in diagnosing and fixing problems
Operating affiliate links and measuring referrals Our legitimate interest in funding and improving the App
Keeping the App safe and secure, and preventing fraud and abuse Our legitimate interest

Where we rely on legitimate interests — including for analytics, profiling, session recording, and notification targeting — you have the right to object at any time, free of charge, as described in section 7. Where we rely on consent for other purposes, you may withdraw it at any time; this does not affect the lawfulness of processing carried out before withdrawal.

4. How we share your information

We do not sell your personal data. We share information only as described below:

  • Service providers (processors). We share data with the providers that help us operate the App:

    • Google — Firebase / Google Analytics (analytics and audience building) and Firebase Cloud Messaging (push notifications);
    • RevenueCat (RevenueCat, Inc.) — subscription management, purchase validation, and entitlement syncing. RevenueCat processes an anonymous App User ID and purchase receipt data on our behalf. Data is stored on AWS infrastructure in the United States;
    • Google Play Billing — processes your subscription payment and provides us with subscription status and order/purchase identifiers (see section 2(f)). Google acts as the merchant of record for your purchase and processes your payment details under its own privacy policy — we never receive your card details;
    • Mixpanel — product analytics and session recording (EU-hosted);
    • Shake — in-app feedback and bug reporting.

    These providers process data on our behalf under appropriate data processing agreements.

  • Affiliate partners. Tapping an affiliate link directs you to a third party (such as GetYourGuide) under their own privacy policy.
  • Legal and protection. We may disclose information where necessary to comply with applicable law, a court order, or a lawful request from a public authority, or to protect our rights, safety, or property, or those of others.
  • Business transfers. If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and of any choices you may have.

5. International data transfers

Where personal data is transferred outside the European Economic Area (EEA), we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses and/or the EU–U.S. Data Privacy Framework, to ensure your data receives an adequate level of protection.

  • Mixpanel — your analytics data is stored on Mixpanel's EU-hosted infrastructure. Mixpanel, Inc. is a US-based company and may access data under the safeguards above.
  • Google (Firebase, Google Analytics, Cloud Messaging, Google Play) — may process data on global infrastructure, including in the United States.
  • Shake — may process feedback and diagnostic data outside the EEA.
  • RevenueCat — processes subscription and purchase data on AWS infrastructure in the United States under Standard Contractual Clauses and their Data Processing Addendum.

6. Data retention

We keep personal data only for as long as necessary for the purposes described in this Policy:

  • Session recordings are retained by Mixpanel for up to 30 days from when they are captured, after which they are automatically no longer available.
  • Other analytics and profiling data is retained according to the retention settings of our analytics providers and is then deleted or anonymised.
  • Feedback and bug reports are retained for as long as needed to investigate and resolve the issue.
  • Subscription and transaction records are retained for the duration of your subscription and for as long as required afterwards to meet our legal, tax, and accounting obligations.
  • Push-notification tokens are deleted when you uninstall the App or disable notifications in your device settings; while installed with notifications enabled, the token is retained to allow delivery.

When data is no longer needed, we delete or anonymise it.

7. Your rights

Subject to the conditions in the GDPR (Articles 15–22), you have the right to:

  • Access the personal data we hold about you;
  • Rectify inaccurate or incomplete data;
  • Erase your data ("right to be forgotten");
  • Restrict processing of your data;
  • Data portability — receive your data in a structured, commonly used, machine-readable format;
  • Object to processing based on our legitimate interests, including profiling;
  • Withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us at milanventurer@gmail.com. You also have the right to lodge a complaint with a supervisory authority. In Slovakia, this is:

Úrad na ochranu osobných údajov Slovenskej republiky
Hraničná 12, 820 07 Bratislava 27, Slovakia
www.dataprotection.gov.sk

Because the App does not require an account, we have no way to connect your name or email address to the data we hold — it is linked only to a device identifier. To act on a request, please include the Support ID shown at the bottom of the App's home screen in your message to us. Without it, we may be unable to locate or delete your data, since nothing else ties your message to a specific device profile.

8. Cookies and similar technologies

The App does not use browser cookies in the traditional sense, but the analytics, messaging, and bug-reporting SDKs described above use device identifiers and similar technologies to recognise your device and collect usage information. You can manage this through your device settings and by exercising the rights described in section 7.

9. Children

The App is not directed to children. You must be at least 16 years old to use the App. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child under 16 has provided us with personal data, please contact us at milanventurer@gmail.com and we will delete it.

10. Security

We apply appropriate technical and organisational measures to protect personal data against loss, misuse, and unauthorised access, disclosure, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where the changes are significant, provide a more prominent notice within the App. We encourage you to review this Policy periodically.

12. Contact us

If you have any questions about this Privacy Policy or how we handle your data, contact us at:

Venturer Network s.r.o.
Budovateľská 5, 821 08 Bratislava, Slovakia
Email: milanventurer@gmail.com