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Privacy Notice

Last updated: Nov 5, 2025

1. Introduction

This Privacy Notice (“Notice”) describes how RomanSoft OÜ (“Company,” “we,” or “us”) collects, uses, and processes your personal data when you access mobile applications (“Application”) Anydream for iOS. 

By using the Platform, you acknowledge and agree to the practices described in this Notice. If you do not agree to this Notice, you must discontinue using the Platform.

This Notice applies to all personal data collected through your use of the Platform, whether collected directly from you, through automated means, or from third parties authorized to share your information with us.

2. Important Information and Who We Are

Purpose of this Privacy Notice

This Privacy Notice aims to provide you with information on how Anydream collects, processes, and protects your personal data. It explains the types of data we collect, how we use it, your rights concerning your data, and how you can contact us if you have any questions or concerns.

Controller

Anydream is operated by RomanSoft OÜ.

Name of Controller

Name: RomanSoft OÜ

Registration number: 17053868

Registered address: Harju maakond, Tallinn, Lasnamäe linnaosa, Tuulemäe tn 5, 11411

Email[email protected] – for general inquiries
[email protected] – for privacy inquiries

 

3. The Data We Collect About You

We collect various types of personal data through our mobile application. The information we collect depends on how you interact with the Platform and the permissions you grant us.

Personal Data You Provide Directly:

– Identity Data: Name, email address.

– Device Tokens: Device token, account token, push notification token. 

– Support Tickets Data: Data you provide when contacting our support team or submitting a support ticket.

– Subscription Data: Information related to your subscriptions, including status, type, and duration.

Automatically Collected Data:

– Device Information: Device ID, operating system, device type, model, language, and other related technical data.

– Analytics Data: Anonymous data collected through third-party analytics services (such as Firebase, Appsflyer, Crashlytics, Apple Analytics, Google Analytics).

– Advertising Identifiers: Provided by your device if you have granted permission (e.g., Apple IDFA or Google Advertising ID).

– Push Notification Token: Used for sending personalized notifications and updates.

– IP Addresses: Collected for technical, security, and analytics purposes.

– Web Request Headers: Collected to ensure the proper functioning of the Platform.

– Favorites and Preferences: Information related to your saved favorites, personalized settings, and anonymized usage preferences.

– Content Viewing History: Anonymized data about content you have viewed or saved on the Platform.

Data Collected Through Third-Party Services:

We use several analytics and tracking tools to improve our services, understand user interactions, and optimize our content. These include:

– Firebase: User engagement tracking, analytics, crash reporting data. Privacy Policy: Firebase Privacy Policy

– Appsflyer: Mobile attribution and marketing analytics data. Privacy Policy: Appsflyer Privacy Policy.

– Crashlytics: Application performance monitoring and crash reporting data. Privacy Policy: Crashlytics Privacy Policy.

– Apple Analytics: Application performance and user engagement analytics data. Privacy Policy: Apple Privacy Policy.

– Google Analytics: Application analytics for visitor interaction analysis data. Privacy Policy: Google Privacy Policy.

– Google reCAPTCHA: IP-address and data on user interaction with Application. Privacy Policy: Google Privacy Policy.

– Meta Pixel: Application analytics for visitor interaction analysis data. Privacy Policy: Meta Privacy Policy.

– IPinfo: geolocation based on your IP-address. Privacy Policy: Privacy Policy.

Also we receive Payment Data from third party payment processors, such as Apple Pay: Payment details provided when making purchases/payment for subscriptions through the Application (such as transaction ID, payment method, but not full credit card details, which are handled by third-party payment processors). 

We would like to put your attention to the fact that we never collect following types of data:

– Passwords: We do not collect or store your passwords. Authentication and login are handled through secure third-party systems.

– Search History: We do not store explicit search histories linked to individual users. Data is anonymized and used for analytics purposes only.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

– Where it is necessary to perform the contract we are about to enter into or have entered into with you (such as providing access to the Anydream, managing your subscriptions, and delivering purchased content).

– Where you have provided your consent for us to use your personal data for specific purposes (such as marketing communications).

– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

– Where we need to comply with a legal obligation (such as data retention requirements, responding to lawful requests by public authorities, and fulfilling regulatory obligations).

Purposes for Which We Will Use Your Personal Data

To process your personal data, we rely on the following lawful bases:

  • performance of the contract – for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Service) with you;
  • legitimate interest – for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
  • legal obligation – for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;
  • consent – for additional specific purposes.

If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.

When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.

We have set out below a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. Where appropriate, we have also identified what our legitimate interests are.

Purpose/ActivityType of DataLawful Basis for Processing
To register you as a new userIdentity Data, Device TokensPerformance of a contract with you
To provide and manage our services and PlatformIdentity Data, Device Tokens, Analytics Data, IP Addresses, Web Request Headers, Payment Data, Essential cookiesPerformance of a contract with you; Legitimate interest (improvement and maintenance of Platform functionality)
To process your purchases, subscriptions, and transactionsPayment Data, Subscription DataPerformance of a contract with you
To provide customer support and resolve issuesIdentity Data, Support Tickets Data, Device InformationPerformance of a contract with you; Legitimate interest (user satisfaction)
To personalize your user experienceFavorites and Preferences, Push Tokens, Device Information, Content viewing story, Analytics DataLegitimate interest (enhancing user experience)
To provide targeted advertising and promotionsAdvertising Identifiers, Analytics DataLegitimate interest (marketing and revenue generation)
To collect feedback and conduct researchIdentity Data, Support Tickets Data, Favorites and PreferencesLegitimate interest (improving our Platform)
To improve our Platform, products, services, and marketing strategiesAnalytics Data, Device InformationLegitimate interest (enhancement of Platform)
To comply with legal and regulatory obligationsAll applicable data categoriesCompliance with a legal obligation
To detect, prevent, and respond to fraud, abuse, or security issuesAll applicable data categoriesLegitimate interest (protecting the Platform and its users)
To display relevant advertisements based on your interests, enhance your user experience in our application, to improve AnydreamAnalytical, advertising, functional cookiesConsent

 

5. Disclosures of Your Personal Data

We do not sell or trade your personal data. However, we may share your personal data with third parties for the purposes described in this Notice.

Sharing with Service Providers

We use the following trusted third-party service providers to share with them and process your personal data by them on our behalf:

– Firebase (Google LLC): Analytics, crash reporting, authentication services.

– Privacy Policy: Firebase Privacy Policy

– Appsflyer: Mobile attribution and marketing analytics.

– Privacy Policy: Appsflyer Privacy Policy

– Crashlytics (Google LLC): Application performance monitoring and crash reporting.

– Privacy Policy: Crashlytics Privacy Policy

– Apple Analytics: Application performance and user engagement analytics.

– Privacy Policy: Apple Privacy Policy

– Google Analytics: Analytics for visitor interaction analysis.

– Privacy Policy: Google Privacy Policy

– IPinfo: receiving geolocation data based on your IP-address. 

– Privacy Policy: Privacy Policy. 

– SendPulse: email automation platform. 

– Privacy Policy: Privacy Policy.

– CloudFlare: cloud services. 

– Privacy Policy: Privacy Policy.

– Facebook: analytics and advertisement.

– Privacy Policy: Privacy Policy.

Sharing for Legal Reasons

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (such as court orders or subpoenas). This includes sharing data to:

• Comply with applicable laws, regulations, and legal processes.

• Enforce our user agreement and other agreements, including investigation of potential violations.

• Protect the rights, property, or safety of Anydream, its users, or others.

Third-Party Links

Our Platform may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.

6. International Transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. This may include transferring your data to third parties that operate in countries outside the European Economic Area (EEA), the United States, or other jurisdictions with differing data protection standards.

Data Transfers Outside of the EEA

If you are located within the EEA, your personal data may be transferred to third-party service providers in countries outside the EEA. Where we transfer your personal data to a third party in a country that is not subject to an adequacy decision by the European Commission, we implement appropriate safeguards to ensure your personal data remains protected in accordance with this Privacy Notice.

These safeguards may include Standard Contractual Clauses (SCCs) in order to ensure that the third party is bound by contractual obligations to protect your data to the same standard as required within the EEA.

7. Data Security

We are committed to ensuring the security of your personal data. We use appropriate technical and organizational measures to protect your data from unauthorized access, alteration, disclosure, or destruction.

Security Measures Implemented

– Encryption: We use encryption technologies (such as SSL/TLS) to protect your data during transmission between your device and our servers.

– Access Control: Only authorized employees, contractors, and agents who need to know personal data to operate, develop, or improve our services are given access to your data.

– Data Minimization: We limit the collection of personal data to what is necessary for the purposes described in this Privacy Notice.

– Regular Security Assessments: We conduct periodic security reviews and tests to ensure our infrastructure and systems are secure and functioning correctly.

– Anonymization & Pseudonymization: Where possible, we anonymize or pseudonymize personal data to reduce the risk to your privacy.

– Backup & Recovery: We maintain data backups and disaster recovery plans to protect against data loss.

Despite our efforts to maintain a high level of security, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we strive to protect your data as effectively as possible.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Retention Periods

Type of Data

Retention Period

Account Information (Name, Email, Device Tokens)Retained as long as your account remains active. If your account is deleted, we will retain your personal data for a period of up to 5 years to comply with legal obligations and for legitimate business purposes.
Advertising Identifiers, Analytics DataRetained for up to 2 years for improving our services and understanding user preferences. Aggregated data that does not identify a specific individual may be retained indefinitely.
Support TicketsRetained for 5 years to assist with customer inquiries and maintain accurate records of user interactions.
Subscription and Payment DataRetained for the duration of the subscription period and up to 7 years thereafter to comply with tax and legal obligations.
IP Addresses and Web Request HeadersRetained for up to 1 year for security and troubleshooting purposes.
CookiesRetention period varies based on the type of cookie (session or persistent). Persistent cookies are typically retained for up to 2 years unless deleted by the user.

 

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you choose to delete your account, we will delete or anonymize your personal data unless we are required by law to retain certain information or have a legitimate business interest to do so (such as resolving disputes or enforcing our agreements as mentioned herein).

9. Accessing and Correcting Your Personal Data

We are committed to providing you with control over your personal data. You have the right to access, update, and delete your personal data at any time.

Your Rights

Depending on your jurisdiction, you may have the following rights:

1. Right of Access: You can request a copy of your personal data that we hold.

2. Right to Rectification: You can request correction of any inaccurate or incomplete personal data.

3. Right to Erasure: You can request the deletion of your personal data, subject to certain exceptions (e.g., ongoing legitimate business needs or legal requirements).

4. Right to Restrict Processing: You can request that we suspend the processing of your personal data in certain scenarios.

5. Right to Data Portability: You can request the transfer of your personal data to you or a third party in a structured, commonly used, and machine-readable format.

6. Right to Object: You can object to the processing of your personal data for specific purposes, such as direct marketing.

7. Right to Withdraw Consent: Where we rely on your consent to process your data, you can withdraw it at any time.

How to Exercise Your Rights

You can exercise your rights by contacting us at:

Email: [email protected]

We will respond to your request within one month of receiving it. In some cases, it may take us longer if your request is particularly complex or if you have made multiple requests. In such a case, we will notify you and keep you updated on the progress.

Identity Verification

To protect your privacy and ensure security, we may need to request specific information from you to confirm your identity before we process your request. This is a security measure to ensure that personal data is not disclosed to any unauthorized person.

10. Withdrawing Your Consent

If you have provided your consent for the processing of your personal data, you have the right to withdraw your consent at any time. However, please note that withdrawing your consent will not affect the legality of any processing conducted prior to your withdrawal.

How to Withdraw Your Consent

You can withdraw your consent by contacting us at:

Email: [email protected]

Upon receipt of your request, we will stop processing your personal data for the specific purpose(s) you initially agreed to, unless we have another legal basis for continuing the processing (such as legal obligations or legitimate business interests).

Please note that withdrawing your consent may result in limited functionality of certain features of the Anydream application or may prevent you from accessing specific services altogether.

11. Other Jurisdictions

Regardless of your location, we will process your personal data in accordance with applicable data protection laws and will respect any rights you may have under those laws.

Submitting Requests

Please contact us via:

Email: [email protected]

We will respond to your request as required by applicable law.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your activity on our mobile application. Cookies are small text files that are placed on your device to collect information about your interactions with our services.

Types of Cookies We Use

1. Essential Cookies: Necessary for the operation of our services. These cookies do not collect personal data and cannot be disabled.

2. Analytical Cookies: Used to collect information about how you use our services, allowing us to improve user experience and optimize our Platform. These include tools such as:

– Google Analytics (Privacy Policy)

– Facebook Analytics (Privacy Policy)

– Appsflyer (Privacy Policy)

3. Advertising Cookies: Used to display relevant advertisements based on your interests. These cookies are only placed if you provide explicit consent.

4. Functional Cookies: Remember your preferences and enhance your user experience on our application.

Managing Cookies

You can control or disable cookies through your browser settings. However, disabling essential cookies may affect the functionality of our services.

13. Changes to This Privacy Notice

We keep our Privacy Notice under regular review. You are encouraged to review this Notice periodically to stay informed of our practices. Continued use of the Platform following the posting of updates constitutes your acceptance of the changes.

If there are material changes to the Privacy Notice or Anydream that affect your data privacy rights, we will notify you by displaying information on the Application and, if necessary, ask for your consent.