Privacy Policy

This notice describes how Choof, a mobile application published under the MRK SOFTWARE name, processes the personal data of its users, in accordance with Regulation (EU) 2016/679 (GDPR).

1. Data controller

The data controller is Mirko Bellabarba, an independent mobile application developer trading as MRK SOFTWARE (not operating as a VAT-registered business). For any request concerning personal data, write to mrk.devapps@gmail.com, which is also the channel for exercising the rights described in section 12.

2. No account, no registration

Choof does not require you to create an account and involves no form of registration or sign-in. We do not collect your name, surname, phone number, contact list or any credentials. Preferences and content you save (for example favourite journeys) remain stored locally on your device.

3. Categories of data collected and purposes

• Usage analytics (screens viewed, interaction events, session duration, number of launches, app version, device model, operating system, approximate geographic area at country/region level), via Google Analytics for Firebase, to understand in aggregate form how the app is used and to improve it. Collection is enabled only after the combined consent for usage and diagnostic data.
• Diagnostic and stability data (crash reports, stack traces, device state at the time of the error, and pseudonymous technical identifiers), via Firebase Crashlytics, to identify and fix defects. Collection is enabled only after the combined consent for usage and diagnostic data.
• Precise geographic location (GPS coordinates), with your permission, to show you the nearest station on the map and to automatically suggest your habitual route (e.g. home → work) in the commute features. This data is processed exclusively on your device and is never transmitted to our servers or to third parties.
• Installation technical identifier: a random code generated on the device, not linked to your identity or to the hardware, which the app sends to our servers together with the operating system (iOS or Android) and the app version the first time it uses our online services. It is used to issue the installation the technical credentials (tokens) to access our APIs and to protect them from abuse.
• Push token, when you grant the operating system's notification permission and the app registers to receive notifications; needed to deliver the alert to your device. If you activate a subscription, we also process data about tracked trains (train number, departure/ arrival stations, days and time windows for any saved habitual routes) on our servers.
• Search and journey data (for example departure and arrival stations, date and time, passenger count, filters, trains and requested itineraries), sent to our backend services and, where necessary, railway data providers to return results, timetables and service information. This data is not linked to a user account.
• Functional technical data strictly necessary to run the service, including locally stored preferences and cache data.
• Server-side technical logsgenerated by our infrastructure when the app calls our services: date and time of the request, endpoint called and its outcome. Our application does not log the user's IP address or other personal information in its own logs. The IP address is used only transiently, in memory and for no longer than one hour, to limit how many new installations can register and to prevent abuse, and is never stored. Traffic to our servers passes through Cloudflare's network, which processes the IP address for security purposes such as DDoS mitigation and abuse prevention, under its own privacy notice.
• IP address visible to our map providers (OpenStreetMap Foundation and CARTO) when the app loads map tiles, under their respective privacy notices.

4. Legal bases for processing

• Consent(Art. 6(1)(a) GDPR) for usage and diagnostic data collected through Firebase Analytics and Crashlytics, through one optional combined choice, and for personalised advertising if introduced in the future. Consent may be withdrawn at any time from Profile, with no effect on your use of the app's core features.
• Performance of the service (Art. 6(1)(b) GDPR) for the technical data indispensable to running the application.
• Legitimate interest (Art. 6(1)(f) GDPR) for infrastructure security, system logs, abuse prevention and fault diagnosis.
• Legal obligation (Art. 6(1)(c) GDPR) where retention or disclosure of data is required by applicable law.

5. Processors

Data may be processed by the following providers, acting as processors (or, in the case of the app stores, as independent controllers) under appropriate agreements:

We do not sell or otherwise transfer personal data to third parties for purposes other than those stated here.

6. Advertising and tracking

At present Choof does not display advertisingand does not carry out any form of advertising tracking. If advertising is introduced in the future (for example through Google AdMob), this notice will be updated accordingly and your consent will be requested (via a message compliant with the IAB Europe Transparency and Consent Framework and, on iOS, Apple's App Tracking Transparency permission) before any personalised ad is shown.

7. Processing involving artificial intelligence

Choof may include two distinct types of AI-based features:

• On-device suggestions(for example the "Choof AI" features): processing happens entirely locally on the user's phone, with no reliance on a remote server. No data leaves the device to generate these suggestions.
• Processing via artificial intelligence services executed exclusively server-side through OpenRouter, used to interpret and summarise public content, such as official announcements about rail traffic, strikes and engineering works published by ViaggiaTreno (Trenitalia). This processing does not involve any personal data of users: no data about you is sent to the model, processing does not take place on your device, and content you save in the app is never used to train or query artificial intelligence systems.

The experimental passenger train-problem reporting features are currently disabled and are neither available nor visible in the user interface. They collect no data at this stage.

8. Push notifications

Choofoffers optional push notifications, for example to alert you about a specific train or habitual route. Only after you grant the operating system's notification permission and the app registers to receive notifications, the technical information needed to deliver the notification is stored on our servers: the installation technical identifier described in section 3, the notification token issued by the Expo Push Notification service (which in turn relies on Firebase Cloud Messaging on Android and the Apple Push Notification service on iOS) and what you are following (for example train number, departure/ arrival stations and, for habitual routes, days and time windows). No data identifying you personally is associated with it. When you delete your last subscription in the app, the token and no-longer needed subscription data are deleted immediately; the installation identifier follows the retention period set out in section 11. If you revoke permission in the operating system settings, the app performs this deletion the next time it starts or returns to the foreground and detects the revocation. Tokens found to be unreachable are disabled and automatically deleted after seven days.

9. In-app purchases

Choof may offer in-app purchases, handled entirely by the Apple App Store and Google Play Store under their respective terms. We neither receive nor process any credit card or other payment instrument data: the app stores only tell us that a purchase was completed, in aggregate or pseudonymised form.

10. Place of processing and transfers outside the EU

Our servers and their database are hosted on Oracle Cloud Infrastructure in the Milan region, Italy. Other data is processed on the systems of the providers listed in section 5. Some of them, in particular Google LLC, Apple Inc. and Cloudflare, Inc., may process data outside the European Economic Area, typically in the United States.

Such transfers take place under the safeguards set out in Chapter V of the GDPR, specifically: the EU-US Data Privacy Framework adequacy decision for providers certified under it, and the Standard Contractual Clauses approved by the European Commission in the remaining cases, together with supplementary measures where necessary.

11. Retention periods

• Usage analytics (Google Analytics for Firebase): retained for a maximum of 14 months, then automatically deleted.
• Crash reports (Crashlytics): retained for a maximum of 90 days.
• System logs: retained for a maximum of 30 days, unless needed to investigate abuse or a security incident.
• Installation technical identifier: retained while you use the app and deleted automatically after 12 months without any access to our services.
• Notification tokens: retained while push registration remains active. Tracked-train data is retained while the related subscription remains active. Deleting the last subscription removes data that is no longer needed immediately. If operating-system permission is revoked, deletion occurs at the next app start or foreground return; a token found to be unreachable is deleted within seven days after it is disabled.
• GPS location: not retained, processed only locally on the device at the time of use.
• Local preferences: remain on the device and are removed by uninstalling the application.

12. Your rights

As a data subject you may exercise, at any time and free of charge, the rights granted by Articles 15-22 GDPR: access, rectification, erasure, restriction of processing, portability, objection to processing and withdrawal of consent. Requests should be sent to mrk.devapps@gmail.com and will be answered within one month.

You also have the right to lodge a complaint with the competent supervisory authority — in Italy the Garante per la protezione dei dati personali — or with the authority of the Member State in which you reside.

13. Data deletion

Since there are no user accounts, local preferences are deleted by uninstalling the application. An uninstall cannot itself make an immediate call to our server: a token that is no longer reachable is disabled and deleted by the automatic procedure within seven days after deactivation, while the installation technical identifier is deleted automatically after 12 months without any access to our services. To request earlier deletion of any data held on our systems, write to mrk.devapps@gmail.com stating the platform you used; requests are handled within 30 days. For data held by third-party providers you can also act directly through their own controls.

14. Children

Choof is intended for a general audience and is not directed at children under 14 in Italy, the age of digital consent under Italian law, nor at children below any lower age required by the law applicable in their country. We do not knowingly collect data from children below that age. If a parent or guardian believes this has happened, they can report it to mrk.devapps@gmail.com and the data will be promptly deleted.

15. Security

We apply appropriate technical and organisational measures to protect data against unauthorised access, loss, alteration or disclosure: encrypted traffic in transit (HTTPS/TLS), system access restricted to the controller and authenticated, and application secrets held in dedicated protected stores.

16. Changes to this notice

This notice may be updated over time, for instance when features or providers change. The last-updated date is shown at the top of the page; material changes will be signalled inside the application and, where required, fresh consent will be collected.

Note: this document is prepared to meet the requirements of Google Play Console and Apple App Store Connect. The declarations made in Play Console's Data Safety form and in the App Store privacy labels must match what is described here. Review by a qualified legal advisor is recommended before publication.