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Privacy Policy

Family Assets · Last Updated: 09 July 2026

1. Introduction

Welcome to the Family Assets mobile application ("Family Assets" or the "Application"). This Privacy Policy explains how COM SY 54 - VASIL ZASHEV AND ASSOCIATES Ltd. (the "Company", "we", "our", or "us") collects, uses, processes, stores, and protects information in connection with your use of the Application. The Company is incorporated and operates under the laws of the Republic of Bulgaria. Family Assets has been designed in accordance with the principles of Privacy by Design and Data Minimisation. The Application processes only the minimum amount of information necessary to provide its intended functionality. This Privacy Policy has been prepared in accordance with the following:

  • Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”);
  • Google Play Developer Program Policies;
  • Google Play User Data Policy;
  • Apple App Store Review Guidelines;
  • Apple Developer Program License Agreement;
  • Other applicable privacy and consumer protection laws.

2. Data Controller

COM SY 54 - VASIL ZASHEV AND ASSOCIATES Ltd. Republic of Bulgaria Website: https://www.comsyworld.com Email: mobile@comsyworld.com

3. Scope

This Privacy Policy applies solely to the Family Assets mobile application on Android and iOS. It does not extend to Google Play, the Apple App Store, Google Play Billing, Apple In-App Purchases, or any operating system services, each of which is governed by its own respective policy.

4. Information We Collect

The Application does not require an online account and does not collect or store on our servers your name, email address, telephone number, postal address, payment card information, precise location, contacts, photos, videos, microphone recordings, or any user-created records of family assets or personal property. Certain limited technical data (such as IP address or device identifiers) may pass through Google's and Apple's own infrastructure when the Application communicates with Google Play Billing, Apple In-App Purchases, or Google Analytics for Firebase. This technical data is processed directly by Google or Apple under their respective privacy policies; the Company does not receive, view, or store it.

5. Local Registration

Family Assets includes a local registration mechanism that is stored exclusively on the user's device. This mechanism may consist of a locally created profile and, where applicable, locally stored credentials used only to secure access to the Application on that device. It is not linked to any online account, does not create a user identifier recognisable by the Company, and no registration information is transmitted to, or stored on, Company servers.

6. Local Data Storage

All records of family assets, personal property, and related information created within the Application are stored locally on the user's device. The Company has no ability to access, read, modify, or recover such records. If the operating system's standard backup feature is enabled on the user's device (such as iCloud Backup on iOS or Google Drive backup on Android), locally stored Application data may be included in that backup as part of the general device backup process. Such backups are created, stored, and controlled entirely by Apple or Google in accordance with their own policies; the Company has no access to, and cannot retrieve or restore, data from these backups.

7. Analytics (Google Analytics for Firebase)

The Application uses Google Analytics for Firebase to collect anonymous and aggregated usage statistics, including application version, operating system version, device model, language, country/region, screens viewed, session duration, interaction events, and application performance metrics. This information is used exclusively to improve performance, identify software defects, understand feature usage, and enhance the overall user experience. We do not use analytics for user profiling, targeted advertising, or the sale of user information. Analytics data is processed by Google under its own privacy policy, available at https://policies.google.com/privacy. The legal basis for this processing under the GDPR is the Company's legitimate interest in ensuring the stability, security, and continuous improvement of the Application.

8. Subscriptions and Payments

Users may use Family Assets free of charge during an initial 7-day trial period. Once this trial period ends, an active subscription is required to continue using the Application. Current subscription plans and pricing are available within the Application and in our Terms of Use. All payments are processed exclusively through Google Play Billing and Apple In-App Purchases. The Company never receives or stores payment card information. Subscriptions renew automatically at the end of each subscription period unless cancelled at least 24 hours before the renewal date. Users can review, manage, or cancel their subscription at any time directly through their Google Play account settings (Android) or their Apple ID account settings (iOS). The Company does not process cancellations or renewals directly, as these are handled entirely by Google Play Billing and Apple In- App Purchases.

9. Data Sharing

We do not sell or rent user information. User-created records are never shared with third parties. Limited technical analytics data may be processed by Google Analytics for Firebase. Payment information is processed solely by Google or Apple, as applicable. As Google and Apple may process data outside the European Economic Area, any such international transfer is carried out under the safeguards implemented by Google and Apple, including the European Commission's Standard Contractual Clauses, as described in their respective privacy policies.

10. Security

We implement appropriate technical and organisational measures to protect the Application and its services. Users remain responsible for safeguarding their own devices and any locally stored data.

11. Data Retention

User-created data remains on the user's device until deleted by the user or removed through uninstallation of the Application. Analytics data is retained in accordance with the retention settings of Google Analytics for Firebase.

12. Children's Privacy

The Application is intended for personal and family use by adults and is not directed to children under the applicable minimum age.

13. Your Rights

Where applicable, users may exercise their privacy rights under the GDPR. As we do not store user-created records on our servers, most data can be deleted directly from the user's device. To the extent the Company processes any personal data (for example, in response to a query sent to our contact email), users may exercise the following rights by contacting us at mobile@comsyworld.com:

  • Right of access to personal data held about you;
  • Right to rectification of inaccurate or incomplete data;
  • Right to erasure (“right to be forgotten”);
  • Right to restriction of processing;
  • Right to data portability;
  • Right to object to processing based on legitimate interest. The Company has not appointed a Data Protection Officer, as this is not required given the limited scope and nature of the personal data processed. If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (Комисия за защита на личните данни, “CPDP”), or with the supervisory authority of your own EU member state.

14. Changes to this Policy

We may update this Privacy Policy from time to time. Any changes become effective upon publication of the updated version within the Application.

15. Contact

COM SY 54 - VASIL ZASHEV AND ASSOCIATES Ltd. Republic of Bulgaria Website: https://www.comsyworld.com Email: mobile@comsyworld.com