Privacy Policy

1. Publisher and Data Controller

220 Planets is published by:

• Name: David Béhar Doorman
• Legal status: Entrepreneur Individuel (EI)
• Registered address: 78, Avenue des Champs-Élysées, Bureau 326, 75008 Paris, France
• SIREN: 513 110 346
• Email: contact@220planets.com

David Béhar Doorman is the data controller within the meaning of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the French Informatique et Libertés Act.

2. Scope

This Privacy Policy applies to the mobile application 220 Planets, available on the Apple App Store and Google Play Store. It describes how the application handles user data and outlines your rights under applicable data protection laws. It also covers this website, 220planets.com, and email correspondence with us (section 10). The "Privacy Policy" link inside the application opens this page in your device's web browser, outside the application.

3. Data Collection

220 Planets does not collect, store, process, or transmit any personal data. The application operates entirely on the user's device. Specifically:

• No account creation is required or offered.
• No personal information (name, email, phone number, address, or any other identifier) is collected.
• No usage data (session duration, frequency of use, interactions, navigation patterns) is collected.
• No device information (device model, operating system, unique device identifiers, IP address) is collected or transmitted.
• No location data (GPS, Wi-Fi, or cell tower-based) is collected.
• No audio data is recorded, stored, or transmitted. All sound synthesis occurs locally on the device in real time.

4. Analytics, Advertising, and Tracking

• 220 Planets does not integrate any analytics tools or SDKs (such as Google Analytics, Firebase Analytics, Crashlytics, Flurry, or similar services).
• 220 Planets does not display advertisements of any kind.
• 220 Planets does not integrate any advertising networks or SDKs.
• 220 Planets does not use the Apple Identifier for Advertisers (IDFA) or the Google Advertising ID (GAID).
• 220 Planets does not track users across apps or websites owned by other companies, as defined by Apple's App Tracking Transparency framework.

5. Third-Party Services

220 Planets does not integrate any third-party services, APIs, or SDKs that collect, process, or transmit user data. The application is entirely self-contained.

The only third-party interactions occur through the platform stores (Apple App Store and Google Play Store) at the time of purchase. These transactions are handled entirely by Apple Inc. or Google LLC under their respective privacy policies. 220 Planets has no access to payment information, Apple ID, or Google account details.

6. Data Sharing

Since no personal data is collected, no data is shared with any third party, including:

• Advertising networks
• Analytics providers
• Data brokers
• Parent companies, subsidiaries, or affiliates

7. Children's Privacy

220 Planets does not collect personal data from any user, regardless of age, including children under the age of 13 (as defined by the U.S. Children's Online Privacy Protection Act, COPPA) or under the age of 16 (as defined by the GDPR).

8. Data Security

Although 220 Planets does not collect or store personal data, the application is designed with security in mind:

• Sound is synthesized on the device in real time; the application downloads nothing and streams nothing.
• The application itself establishes no network connections; when you open this Privacy Policy from within it, the page loads in your device's web browser, outside the application (section 2).
• Anything the application stores remains within its private, system-protected storage space; nothing is written to shared directories or external storage.

9. Data Retention

220 Planets retains a single item on the user's device: the interface language selected by the user, stored as a short language code so that the application reopens in that language. This item is not personal data and does not identify the user; there is no user account or publisher server for it to reach. It remains on the device until the application is uninstalled. All other application data, including audio synthesis parameters and navigation state, exists only in volatile memory during active use and is cleared when the application closes.

10. Website and Email Contact

This website, 220planets.com, does not use cookies, analytics, or any tracking technology. It is served by Cloudflare, Inc., acting as a hosting provider, which may transiently process technical connection data (such as IP addresses) for the sole purpose of delivering and securing the site.

If you contact us by email, we process the information you provide (your email address and the content of your message) for the sole purpose of answering you. This information is not shared with anyone and is kept no longer than necessary for our correspondence.

The legal basis for this processing is our legitimate interest (Article 6(1)(f) GDPR) in delivering and securing the website and in responding to correspondence you initiate. Connection logs are kept only for the short time necessary to secure the site and are not used to identify you; where Cloudflare processes them outside the European Union, that transfer is covered by the European Commission's Standard Contractual Clauses together with Cloudflare's Data Processing Addendum. To request deletion of any correspondence we hold, email contact@220planets.com and we will erase it.

11. Your Rights Under the GDPR

As a data subject under the General Data Protection Regulation (GDPR), you are entitled to the following rights:

• Right of access (Article 15 GDPR)
• Right to rectification (Article 16 GDPR)
• Right to erasure (Article 17 GDPR)
• Right to restriction of processing (Article 18 GDPR)
• Right to data portability (Article 20 GDPR)
• Right to object (Article 21 GDPR)

The application collects no personal data, so within it there is nothing to access, rectify, erase, restrict, port, or object to. Where we do hold personal data, in the email correspondence described in section 10, these rights apply in full.

To exercise them, or for any question regarding your rights, you may contact us at contact@220planets.com.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence. In France, the competent authority is:

12. California Privacy Rights (CCPA)

Under the California Consumer Privacy Act (CCPA, as amended by the CPRA), California residents have the right to know what personal information is collected, request its correction or deletion, and opt out of its sale or sharing. The publisher is not a "business" as defined by the CCPA (it meets none of the statute's revenue or volume thresholds), and in any event 220 Planets does not collect, store, sell, or share any personal information, so these rights are inherently satisfied.

13. Other Jurisdictions

Depending on your place of residence, you may have similar rights under local data protection laws, such as the LGPD (Brazil), the APPI (Japan), the PIPA (South Korea), or the PIPL (China). Since the application does not collect any personal data, these rights are inherently satisfied in the same way. For all of these jurisdictions, the personal-information handler and data controller is David Béhar Doorman, who can be contacted at contact@220planets.com to exercise any of these rights.

14. App Store Privacy Labels

In accordance with Apple's App Store requirements, 220 Planets declares Data Not Collected: it does not collect any data from this app. Because no data is collected, none is linked to your identity and 220 Planets does not track you across apps or websites owned by other companies. The equivalent declaration applies on Google Play, whose Data safety section states that no data is collected or shared.

15. Health and Safety

220 Planets generates audio content consisting of pure sine wave frequencies. The application is calibrated for low-volume listening. Users are advised to listen at a comfortable volume to protect their hearing. Prolonged exposure to any audio content at high volume may cause hearing damage.

If you experience any discomfort, tinnitus, or hearing difficulties, discontinue use immediately and consult a healthcare professional.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable laws or our practices. Any changes will be posted on this page and reflected in the "Last updated" date shown at the top. We encourage you to review this Privacy Policy periodically.

17. Applicable Law and Jurisdiction

This Privacy Policy is governed by French law. Any dispute arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Paris, France, unless otherwise required by applicable mandatory law.

18. Contact

For any questions, concerns, or requests regarding this Privacy Policy, please contact: