Data Protection Notice
This notice supplements the Privacy Policy, which describes Tefteri's data handling in detail. The GDPR applies where relevant to EEA users, and the UK GDPR applies where relevant to UK users. Swiss data-protection law applies where relevant to Swiss users; it does not use the same legal-basis framework as the GDPR. This notice is information about processing and your rights, not a request for consent or a certification of compliance.
1. Controller and Contact
Pavlos Stathopoulos, Athens, Greece operates Tefteri as an individual and is the controller responsible for personal data processed to operate the App and its online services. For privacy questions and rights requests, emailprivacy@pavlossta.com. For general support, email support@pavlossta.com.
2. Local Use and Information Processed
You can use Tefteri without an account. Notebook content stays on your device unless you connect Google for cloud synchronization through Firestore. Sign-out stops authenticated sync but does not erase the notebook or remove its account binding. Local use does not mean there is no online activity: aggregate statistics, crash reporting, and update checks can operate without sign-in.
- Notebook and sync data: categories, notes, optional details/contact text, dates, reminder settings, ownership identifiers, update times, deletion markers, and operation receipts. Notebook content is supplied by you.
- Account data: Google/Firebase identifiers, email, basic profile information supplied by Google, and authentication session information when you choose to connect. Necessary account data is required for cloud sync, but not local notebook use.
- Local settings: appearance, language, statistics choice, notebook binding, notification state, and legal-document version records. These settings are not synchronized as notebook entries; a version record is not proof of GDPR consent.
- Statistics and diagnostics: aggregate operation counters, app version, and separate technical data processed by Crashlytics, Remote Config, and delivery infrastructure, as described below and in the Privacy Policy.
- Correspondence and chosen sharing: information you send in support/rights requests or the optional Google Forms feedback form, or choose to export, share, or save to a calendar. Independent copies are handled by their recipients under their own practices.
Tefteri is a general-purpose notebook, not a healthcare service. We do not request health information or other special-category personal data. Entering, synchronizing, or sending us sensitive personal data about yourself or others is prohibited, including special-category data and criminal-conviction/offence data. See the Privacy Policy for examples. The App does not inspect or automatically classify notes. If you believe you have uploaded sensitive information, delete the relevant content and contactprivacy@pavlossta.com for assistance. Ordinary notebook entry, Google connection, acceptance of the Terms, and notification permission do not provide explicit consent for special-category processing.
3. Purposes and GDPR Legal Bases
- Contract — Article 6(1)(b): authenticate your account, provide the cloud notebook and synchronization you request, and handle related service support.
- Legitimate interests — Article 6(1)(f): measure aggregate feature use and reliability to improve the App, without individual journeys or notebook profiling. You can object through Statistics in Profile; we honor this by stopping new submissions. Where applicable device-access law requires consent, collection must remain disabled until valid consent is obtained.
- Consent — Article 6(1)(a): voluntary upload of the pending diagnostic batch in builds offering one-time report approval. Future batches need a new choice. Local capture and other SDK processing require separate assessment.
- Legitimate interests — Article 6(1)(f): protect accounts and infrastructure, prevent misuse, diagnose failures, maintain reliability, provide update information, answer general inquiries, and defend legal claims. These interests must be assessed against your rights, using limited technical data and content filtering. You can object where this basis applies.
- Legal obligation — Article 6(1)(c): fulfill applicable data-protection duties and respond to valid legal requirements.
Processing that requires consent needs a separate, valid choice before it begins; changing a document or continuing to use the App does not supply that consent. You may withdraw consent where processing relies on it, without affecting the lawfulness of processing before withdrawal. We do not make solely automated decisions producing legal or similarly significant effects about you or profile your notebook content.
4. Statistics and Separate Technical Services
In app versions implementing aggregate statistics, Statistics (Στατιστικά) is enabled by default and can be disabled in Profile without losing notebook features. Explicit opt-outs are preserved. The choice is local to each device. In Android builds implementing the current statistics notice, no measurement is submitted until onboarding is complete and the notice has been acknowledged. The welcome screen shows “Στέλνονται συνολικά στατιστικά χρήσης. Απενεργοποίηση στις Ρυθμίσεις.” Existing users see a one-time notice before collection. Dismissing that notice leaves statistics paused; acknowledgement preserves any saved opt-out and is not consent for processing that legally requires consent. Submissions toadmin.pavlossta.com contain only protocol version 3, a fixed counter name and app version, covering creation, editing, deletion and conversion of entries; synchronization outcomes and fixed failure categories; reminder scheduling and reconciliation; notification permission choices; sign-in, sign-out, export, device reset and account deletion outcomes; and caught root-interface errors. The server stores daily totals, not an individual event history for these submissions. Totals count operations/reports, not unique people or incidents.
The payload contains no persistent analytics identifier, account identifier, notebook content, screen path, engagement duration, country, device profile, or raw error detail. Infrastructure still receives connection information, including IP addresses, so the collection process is not described as entirely anonymous. Disabling statistics stops new submissions; an in-flight request may finish. There is no durable analytics queue. Existing totals remain and contain no account attribution. We do not correlate them with account records, sync activity, crash reports or identifiable request logs. Older installed app versions may still send individual events with a persistent random identifier; their Profile control can disable that measurement. We do not use Firebase Analytics for it.
The statistics switch does not disable Crashlytics, Remote Config, authentication, or synchronization. In Android builds implementing one-time report approval, automatic crash-report uploads are disabled. The SDK can capture and store technical reports locally before approval. After reopening the App, you may be asked to send the pending batch through Google Firebase. “Αποστολή” approves only that batch; “Όχι” deletes it, and dismissing sends and deletes nothing. Future batches require a new choice. Reports can include error traces, device/operating-system information and installation/session identifiers; they are separate from aggregate statistics. Custom handled reports remove raw messages and use allowlisted diagnostic values; automatic SDK reports have their own technical content. The statistics switch does not control this upload choice. Older distributed builds may still upload reports automatically. The new startup upload gate requires a new Android build and cannot be delivered solely through a JavaScript update. Remote Config processes installation identifiers, country/language codes, time zone, version details, and technical requests for update/configuration checks. Providers receive network information when accessed. The Privacy Policy explains these separate services and their data handling. We do not request your contact list, precise device location, or biometric identifiers.
5. Recipients and International Transfers
Recipients include Google/Firebase for Authentication, Firestore, Crashlytics, and Remote Config; Vercel and hosted PostgreSQL infrastructure for our analytics service; Expo update-delivery infrastructure; ImprovMX for email forwarding, Google Gmail for receiving support correspondence, and Google Forms for optional feedback; recipients/calendar providers you choose; and authorities or legal advisers where necessary. Firebase generally processes service data on our behalf under applicable data-processing terms; Google also has its own role and privacy terms for your Google account. We do not sell personal data or share it with advertisers or data brokers.
Some providers process data outside Greece or the EEA, including in the United States. A European database does not ensure all processing stays in Europe. Transfers must be covered by an applicable adequacy decision or appropriate safeguards, such as Standard Contractual Clauses and supplementary measures where required. Google's published arrangements include the EU–US Data Privacy Framework for eligible entities and applicable contractual safeguards; seeFirebase's privacy and security information. Applicable UK and Swiss transfer requirements must also be met where relevant. Contact us for the provider/location information and applicable safeguards, including how to obtain a copy with confidential details redacted where necessary.
6. Retention and Deletion
- Local notebook: remains until you delete it or clear the applicable notebook/app data. Sign-out alone does not erase it.
- Cloud notebook: active content remains while the account exists unless deleted sooner. Successful sync removes deleted entry content; minimal deletion markers and receipts may remain until account deletion to prevent recreation by older devices.
- Analytics: daily totals and historical raw Tefteri events are scheduled for removal from the live database after 12 calendar months with daily cleanup. Allow up to one cleanup interval; failed jobs require investigation and removal of overdue records. Provider backups have separate lifecycles.
- Firebase diagnostics and identifiers: Google documents 90-day retention for Crashlytics traces and associated identifiers before removal begins, and removal of deleted authentication information within 180 days. Installation identifiers and security logs have separate lifecycles. See the Privacy Policy for details and provider disclosures.
- Correspondence: correspondence and feedback remain as needed to handle the request and related follow-up. Necessary rights-request, notice, or dispute records may remain for compliance or claims, restricted to that purpose. No fixed mailbox or feedback expiry period is currently specified; deletion can be requested subject to applicable exceptions.
Account deletion requires verification and removes account notebook records and sync metadata from live Firestore, deletes the Firebase account, and clears that notebook on the current device where records are readable and ownership is known. Unreadable recovery data with unknown ownership may remain; clear Android app storage to remove remaining installation data. Failures may need retry or assistance. It does not delete your Google account. Use the Account Deletion instructionsor email us if you cannot use the App.
Other devices may retain local copies until cleared; exports and saved calendar events are independent copies. Analytics and crash records are not automatically linked to your account for deletion. We assess separately identifiable records when handling a request without collecting extra identifiers merely to reidentify unrelated telemetry. We do not maintain custom cloud-notebook backups. Provider-managed recovery copies and necessary legal records can expire later than live account data. Retained copies must not be used as an active notebook or restored without reapplying deletions.
7. Your Rights and Requests
Subject to the applicable conditions, you can request access, correction, erasure, restriction, and portability, withdraw consent where applicable, and object to processing based on legitimate interests. Rights are not absolute; we explain any applicable exception and your options. Profile's JSON export is a convenient copy of the current device notebook, including pending changes, not a substitute for requesting other personal data we hold.
Email privacy@pavlossta.com, whether or not you have an account. Using your account email where available can help us locate your records. We may request proportionate identity-verification information if reasonably necessary. GDPR requests are normally free. We respond without undue delay and within one month of receipt. If complexity or the number of requests warrants a permitted extension, we explain it within the first month; it can be up to two additional months.
You can complain to the Hellenic Data Protection Authorityor another competent authority, including in your place of habitual residence, work, or the alleged infringement. UK users can contact theInformation Commissioner's Office (ICO). Swiss users can report potential violations to theFederal Data Protection and Information Commissioner (FDPIC)under its applicable procedure. Applicable judicial remedies remain available.
8. Security and Risk Assessment
Safeguards include encrypted connections, authenticated ownership checks in Firestore rules, owner-scoped sync, and limited diagnostic metadata. Firebase-managed encryption at rest concerns hosted data; device notebook data uses app-local storage. Tefteri does not provide end-to-end encryption for cloud content or a separate notebook-encryption guarantee. Authorized cloud service operation can involve access to server-side data. No storage or transmission method is completely secure.
Protect your device and Google account, review lock-screen notification settings, and handle exports carefully. The need for a data-protection impact assessment depends on processing risks and applicable law. This notice does not claim that a formal DPIA has been completed; listing safeguards is not a substitute for a required assessment.