Privacy Policy

1. Introduction

Welcome to Komuniteti ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application ("App") available on iOS and Android platforms.

This Privacy Policy complies with the General Data Protection Regulation (GDPR) of the European Union and the Law on Personal Data Protection of the Republic of Albania (Law No. 9887, dated 10.03.2008, as amended).

By using the Komuniteti App, you consent to the data practices described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. Data Controller Information

Data Controller: Komuniteti
Address: Albania
Email: [email protected]
Website: https://komuniteti.al

For any questions or concerns regarding this Privacy Policy or our data practices, please contact us at the email address provided above.

3. Information We Collect

3.1 Personal Information You Provide

When you register for an account or use our services, we collect the following personal information:

3.2 Information Collected Automatically

When you use our App, we automatically collect certain information:

3.3 User-Generated Content

When you use certain features of our App, we collect:

• Reports: Title, description, visibility settings, priority level
• Media Files: Photos and videos uploaded with reports (up to 5 files per report)
• Comments: Text content posted on reports
• Poll Responses: Your answers to community polls
• Messages: Content of communications within the App

3.4 Billing Information

We collect billing-related information associated with your property:

• Payment status and history
• Outstanding amounts
• Billing periods

4. How We Use Your Information

We use the collected information for the following purposes:

4.1 Service Provision

• Create and manage your user account
• Provide property management services
• Process and display reports and activities
• Enable communication between residents and property management
• Display billing information and payment status

4.2 Communication

• Send push notifications about reports, polls, and important updates
• Respond to your inquiries and support requests
• Send service-related announcements
• Verify your identity through OTP (One-Time Password) verification

4.3 Service Improvement

• Analyze usage patterns to improve our App
• Debug technical issues and fix errors
• Develop new features and services

4.4 Legal Compliance

• Comply with legal obligations
• Respond to lawful requests from public authorities
• Protect our legal rights and interests

5. Legal Basis for Processing (GDPR)

Under the GDPR, we process your personal data based on the following legal grounds:

You may withdraw your consent at any time by adjusting your device settings or contacting us directly. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

We share your information with the following categories of service providers:

6.2 Property Management

We share relevant information with property managers and administrators for:

• Report management and resolution
• Billing and payment tracking
• Community communication

6.3 Legal Requirements

We may disclose your information when required by law, court order, or governmental regulation, or when we believe in good faith that disclosure is necessary to:

• Protect our rights, privacy, safety, or property
• Protect the safety of users or others
• Investigate fraud or security issues
• Comply with a judicial proceeding or legal process

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity.

7. International Data Transfers

Your information may be transferred to and processed in countries outside Albania and the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Binding Corporate Rules (where applicable)

For transfers to the United States, our service providers (such as Google/Firebase) participate in data protection frameworks and maintain appropriate certifications.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

After the retention period, data is securely deleted or anonymized.

9. Your Rights

9.1 GDPR Rights (EU Users)

Under the GDPR, you have the following rights:

1. Right of Access (Art. 15) - Request a copy of your personal data
2. Right to Rectification (Art. 16) - Request correction of inaccurate data
3. Right to Erasure (Art. 17) - Request deletion of your data ("right to be forgotten")
4. Right to Restriction (Art. 18) - Request limitation of processing
5. Right to Data Portability (Art. 20) - Receive your data in a structured format
6. Right to Object (Art. 21) - Object to processing based on legitimate interests
7. Right to Withdraw Consent (Art. 7) - Withdraw consent at any time
8. Right to Lodge a Complaint - File a complaint with a supervisory authority

9.2 Albanian Data Protection Rights

Under Albanian law, you have similar rights including:

• Right to information about data processing
• Right to access your personal data
• Right to request rectification or deletion
• Right to object to processing
• Right to file complaints with the Information and Data Protection Commissioner

9.3 Exercising Your Rights

To exercise your rights:

• In-App: Use the "Delete Account" feature in Settings
• Email: Contact [email protected]
• Update Profile: Edit your information directly in the App

We will respond to your request within 30 days. In complex cases, we may extend this period by an additional 60 days, with notification.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

10.1 Technical Measures

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest
• Authentication: Secure token-based authentication with refresh mechanisms
• Access Controls: Role-based access to data and systems
• Secure Storage: Use of secure, encrypted databases

10.2 Organizational Measures

• Employee training on data protection
• Regular security assessments
• Incident response procedures
• Data protection impact assessments (where required)

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to promptly addressing any security incidents.

11. Children's Privacy

Our App is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

If we discover that we have collected personal information from a child under 13, we will take steps to delete such information as soon as possible.

12. Third-Party Links and Services

Our App may contain links to third-party websites or services, including:

• Business websites listed in our directory
• External payment processors
• Social media platforms

We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Push Notifications

We use Firebase Cloud Messaging to send push notifications. You can manage notification preferences:

• iOS: Settings > Notifications > Komuniteti
• Android: Settings > Apps > Komuniteti > Notifications

Types of notifications include:

• Report updates and status changes
• New comments on your reports
• Property announcements
• Poll reminders
• Billing reminders

14. Location Services

We collect location data only when you grant permission. Location data is used for:

• Displaying nearby businesses on the map
• Geocoding addresses for reports
• Showing your property location

You can disable location services:

• iOS: Settings > Privacy > Location Services > Komuniteti
• Android: Settings > Apps > Komuniteti > Permissions > Location

15. Cookies and Similar Technologies

Our App uses local storage and similar technologies to:

• Store authentication tokens
• Save your preferences (language, dark mode, font size)
• Cache data for offline access

These are essential for the App's functionality and cannot be disabled without affecting core features.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy in the App
• Sending a push notification (if enabled)
• Updating the "Last Updated" date at the top of this document

We encourage you to review this Privacy Policy periodically. Your continued use of the App after any changes constitutes acceptance of the updated Privacy Policy.

17. Language

This Privacy Policy is available in multiple languages within the App. In case of any discrepancy between translated versions, the English version shall prevail.

Supported languages:

• Albanian (Shqip)
• English
• German (Deutsch)
• French (Français)
• Italian (Italiano)
• Russian (Русский)
• Turkish (Türkçe)
• Chinese (中文)

18. Contact Us

19. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with:

For Albanian Residents:
Information and Data Protection Commissioner
Rr. "Abdi Toptani", Nr. 5
Tirana, Albania
Website: https://www.idp.al

For EU Residents:
Your local Data Protection Authority (DPA)