Privacy Policy

Effective Date: August 15, 2026

Last Updated: August 15, 2026

1. Introduction

Welcome to GesCom. Gescom ("we," "our," or "us") is committed to protecting your privacy and ensuring transparency in how we handle your personal information. This Privacy Policy explains how we collect, use, store, share, and protect information when you use the GesCom mobile application (the "App") on Android devices.

By downloading, installing, accessing, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with any part of this Privacy Policy, please do not use the App.

This Privacy Policy applies to all users globally and has been designed to comply with applicable data protection laws and regulations worldwide, including but not limited to the General Data Protection Regulation (GDPR) in the European Economic Area, the California Consumer Privacy Act (CCPA) in California, the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Privacy Act 1988 in Australia, the Personal Data Protection Act in Singapore, the Lei Geral de Proteção de Dados (LGPD) in Brazil, and other applicable privacy legislation.

2. Information We Collect

2.1 Photos and Media

The GesCom App collects and accesses photos and media files stored on your Android device. This includes:

• Images and photographs stored in your device's gallery or photo library
• Media files including pictures, videos, and other visual content
• Metadata associated with photos and media files, such as file names, file sizes, creation dates, and modification dates
• EXIF data that may be embedded in photos, which can include camera settings, timestamps, and potentially location information if your camera app has recorded it

2.2 Device Information

When you use the App, we may automatically collect certain information about your device, including:

• Device model and manufacturer
• Operating system version (Android version)
• Unique device identifiers
• Mobile network information
• Device settings and preferences
• Screen resolution and display specifications
• Language settings

2.3 Usage Information

We may collect information about how you interact with the App, including:

• App features and functions you use
• Actions you take within the App
• Frequency and duration of your activities on the App
• Error reports and performance data
• Crash logs and diagnostic information

2.4 Information We Do Not Collect

We want to be clear about what we do not collect:

• We do not collect your name, email address, or contact information unless you voluntarily provide it to us
• We do not track your precise geolocation through GPS or network-based location services
• We do not access your contacts, call logs, or SMS messages
• We do not collect financial or payment information
• We do not use third-party analytics, advertising, or tracking services

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Primary App Functionality

• To provide, operate, and maintain the core features and functionality of the GesCom App
• To process and display photos and media files as requested by you
• To enable you to organize, manage, view, edit, or share your photos and media within the App
• To perform operations on photos and media as directed by you

3.2 App Improvement and Development

• To understand how users interact with the App and identify areas for improvement
• To develop new features and functionality
• To optimize App performance and user experience
• To conduct testing and quality assurance

3.3 Technical Support and Maintenance

• To diagnose and fix technical problems
• To respond to your support requests and communications
• To monitor and analyze App stability and performance
• To prevent, detect, and address technical issues, bugs, and errors

3.4 Security and Fraud Prevention

• To protect the security and integrity of the App
• To detect, prevent, and respond to fraud, abuse, security incidents, or other malicious or illegal activities
• To enforce our Terms of Service and other policies

3.5 Legal Compliance

• To comply with applicable laws, regulations, legal processes, or enforceable governmental requests
• To protect the rights, property, or safety of Gescom, our users, or the public

4. Legal Basis for Processing (GDPR and International Compliance)

For users in the European Economic Area, United Kingdom, Switzerland, and other jurisdictions with similar requirements, we process your personal data based on the following legal grounds:

4.1 Contractual Necessity

Processing is necessary for the performance of our agreement with you to provide the App and its features. When you choose to use GesCom, we need to access photos and media to deliver the functionality you expect.

4.2 Legitimate Interests

We have legitimate interests in:

• Improving and optimizing the App
• Ensuring the security and stability of our services
• Understanding how users interact with the App
• Preventing fraud and abuse

We have assessed that these interests are not overridden by your rights and freedoms.

4.3 Consent

Where required by law, we obtain your explicit consent before processing certain types of personal data, particularly access to photos and media files on your device. You may withdraw your consent at any time through your device settings or by uninstalling the App.

4.4 Legal Obligation

In some cases, we may need to process your data to comply with legal obligations, such as responding to lawful requests from courts or regulatory authorities.

5. How We Share Your Information

5.1 No Third-Party Services

GesCom does not integrate with, utilize, or share your information with any third-party services, analytics platforms, advertising networks, or external service providers. Your photos, media, and other information remain on your device and within the App.

5.2 No Sale of Personal Information

We do not sell, rent, trade, or otherwise transfer your personal information to third parties for monetary or other valuable consideration. This includes photos, media files, device information, and usage data.

5.3 Limited Disclosure Scenarios

While we do not share information with third parties in the normal course of business, we may disclose information in the following limited circumstances:

• Legal Requirements: When required by law, regulation, legal process, or enforceable governmental request, we may disclose information to law enforcement, regulatory authorities, courts, or other governmental entities
• Protection of Rights: To protect the rights, property, or safety of Gescom, our users, or the public, including enforcing our Terms of Service or investigating potential violations
• Business Transfers: In connection with any merger, sale of company assets, financing, acquisition, or dissolution of all or a portion of our business, your information may be transferred to the successor entity, subject to this Privacy Policy
• With Your Consent: We may share information with third parties when you have given us explicit permission to do so

6. Data Storage and Security

6.1 Local Storage

The GesCom App is designed to store and process your photos and media locally on your Android device. We do not maintain remote servers or cloud storage for your personal photos and media files accessed through the App.

6.2 Security Measures

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data transmission where applicable
• Secure coding practices and regular security assessments
• Access controls to limit who can access information within our organization
• Regular monitoring for security vulnerabilities
• Incident response procedures for potential security breaches

6.3 Limitations of Security

While we strive to protect your information, no method of electronic storage or transmission over the internet is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the security of your device, including using strong passwords, keeping your operating system updated, and protecting your device from unauthorized access.

6.4 Device Security

Because the App stores and processes information locally on your device, the security of your data depends significantly on:

• Your device's physical security (screen locks, biometric authentication)
• The security of your Android operating system and keeping it updated
• Other apps installed on your device and their permissions
• Your network security when using the App

We recommend enabling device encryption, using strong authentication methods, and keeping your device's operating system and security patches current.

7. Data Retention

7.1 Retention Principles

We retain your information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7.2 Photos and Media

Photos and media files accessed by the App remain under your control on your device. The App does not create permanent copies of your media on external servers. Any temporary files created by the App for processing purposes are deleted when no longer needed or when you close the App.

7.3 Device and Usage Information

Device information and usage data collected for App functionality, performance monitoring, and improvement purposes are retained only as long as necessary for these purposes, typically no longer than 24 months, unless required for legal or security purposes.

7.4 Legal Obligations

We may retain certain information for longer periods when required by law, regulation, legal process, or to protect our legal rights, resolve disputes, or enforce our agreements.

7.5 Deletion

When you uninstall the GesCom App from your device, all App-specific data stored locally is removed according to standard Android app deletion procedures. Your original photos and media files in your device's storage remain unchanged.

8. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information:

8.1 Access and Portability

You have the right to:

• Request access to the personal information we hold about you
• Receive a copy of your personal information in a structured, commonly used, and machine-readable format
• Request that we transmit your information to another service provider where technically feasible

8.2 Correction and Update

You have the right to:

• Request correction of inaccurate or incomplete personal information
• Update your information through the App settings where available

8.3 Deletion and Erasure

You have the right to:

• Request deletion of your personal information in certain circumstances
• Request the "right to be forgotten" where applicable under GDPR and similar laws
• Erase App data by uninstalling the application from your device

8.4 Restriction and Objection

You have the right to:

• Object to our processing of your personal information in certain circumstances
• Request restriction of processing your personal information
• Opt out of certain types of data collection or processing

8.5 Withdrawal of Consent

Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

8.6 Managing Permissions

You can control the App's access to photos and media through your Android device settings:

• Go to Settings > Apps > GesCom > Permissions
• Toggle permissions on or off as desired
• Note that disabling certain permissions may limit or prevent the App from functioning properly

8.7 Exercising Your Rights

To exercise any of these rights, please contact us at ahmad3.10bsse@gmail.com. We will respond to your request within the timeframe required by applicable law, typically within 30 days. We may need to verify your identity before processing your request.

8.8 No Discrimination

We will not discriminate against you for exercising any of your privacy rights, including by denying services, charging different prices, or providing a different level of service quality.

9. Children's Privacy

9.1 Age Restrictions

The GesCom App is not intended for use by children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be 14, 15, or 16 in certain countries). We do not knowingly collect personal information from children under these ages.

9.2 Parental Consent

If you are between 13 (or the applicable age in your jurisdiction) and 18 years old, you should review this Privacy Policy with your parent or legal guardian and ensure they consent to your use of the App.

9.3 Notice to Parents and Guardians

If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us at ahmad3.10bsse@gmail.com. If we become aware that we have collected personal information from a child under the applicable age without proper parental consent, we will take steps to delete that information from our systems.

9.4 Age Verification

We do not actively verify the age of our users. It is the responsibility of parents and guardians to monitor their children's use of mobile applications and ensure compliance with age restrictions.

10. International Data Transfers

10.1 Global Operations

As GesCom operates globally, your information may be processed in countries other than where you reside. These countries may have data protection laws that are different from the laws of your country.

10.2 Local Processing

Because the App processes photos and media locally on your device without transferring them to remote servers, most of your personal information remains within your geographic location on your device.

10.3 Safeguards for International Transfers

When information is transferred internationally, we implement appropriate safeguards to ensure your information receives adequate protection, including:

• Standard contractual clauses approved by relevant authorities
• Adequacy decisions recognizing equivalent data protection standards
• Other lawful transfer mechanisms as approved by applicable data protection authorities

10.4 EEA and UK Users

For users in the European Economic Area and United Kingdom, any international transfers of personal data will be conducted in accordance with Chapter V of the GDPR and UK data protection law, ensuring appropriate safeguards are in place.

11. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information:

11.1 Right to Know

You have the right to request that we disclose:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information is collected
• Our business or commercial purpose for collecting or selling personal information
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we have collected about you

11.2 Right to Delete

You have the right to request deletion of your personal information that we have collected from you, subject to certain exceptions.

11.3 Right to Opt-Out

We do not sell your personal information as defined by the CCPA. You have the right to opt out of the sale of your personal information, but since we do not engage in such sales, this right does not currently apply.

11.4 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA privacy rights.

11.5 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

11.6 Right to Limit Use of Sensitive Personal Information

If we collect sensitive personal information, you have the right to limit its use and disclosure to only what is necessary to perform the services or provide the goods reasonably expected by an average consumer.

11.7 Authorized Agents

You may designate an authorized agent to make requests on your behalf. We may require verification of both your identity and the agent's authorization.

11.8 Shine the Light Law

California's "Shine the Light" law permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes.

11.9 Exercising California Rights

To exercise your California privacy rights, contact us at ahmad3.10bsse@gmail.com. We will respond within 45 days of receiving your request, with a possible extension of up to 90 days when reasonably necessary.

12. Other Jurisdiction-Specific Rights

12.1 Brazil (LGPD)

For users in Brazil, the Lei Geral de Proteção de Dados provides additional rights including:

• Confirmation of the existence of processing
• Access to data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or excessive data
• Portability of data to another service provider
• Deletion of personal data processed with consent
• Information about public and private entities with which data is shared
• Information about the possibility of denying consent and consequences
• Revocation of consent

12.2 Canada (PIPEDA)

For users in Canada, you have rights under the Personal Information Protection and Electronic Documents Act including the right to access your personal information, challenge its accuracy, and withdraw consent.

12.3 Australia (Privacy Act)

For users in Australia, the Privacy Act 1988 and Australian Privacy Principles provide you with rights to access and correct your personal information, and to make complaints about privacy breaches.

12.4 Other Jurisdictions

Users in other jurisdictions may have additional rights under local privacy laws. Please contact us at ahmad3.10bsse@gmail.com to inquire about rights specific to your location.

13. Changes to This Privacy Policy

13.1 Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational, legal, or regulatory reasons. When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy.

13.2 Material Changes

If we make material changes that significantly affect your privacy rights or how we handle your personal information, we will provide additional notice through one or more of the following methods:

• Displaying a prominent notice within the App
• Sending an email notification if we have your email address
• Posting a notice on our communication channels
• Requiring you to accept the updated Privacy Policy before continuing to use the App

13.3 Your Continued Use

Your continued use of the App after the effective date of any changes to this Privacy Policy constitutes your acceptance of such changes. If you do not agree to the updated Privacy Policy, you must stop using the App and uninstall it from your device.

13.4 Review Obligation

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information and to understand your privacy rights.

14. Data Breach Notification

14.1 Security Incidents

In the event of a data breach or security incident that affects your personal information, we will take immediate steps to investigate, contain, and mitigate the breach.

14.2 User Notification

If a data breach is likely to result in a risk to your rights and freedoms, we will notify you without undue delay, and where feasible, within 72 hours of becoming aware of the breach, in compliance with applicable law. Our notification will include:

• The nature of the breach and categories of data affected
• The likely consequences of the breach
• Measures we have taken or propose to take to address the breach
• Recommendations for steps you can take to protect yourself
• Contact information for further inquiries

14.3 Regulatory Notification

We will also notify relevant supervisory authorities and regulators as required by applicable data protection laws.

15. Third-Party Links and Services

15.1 No Third-Party Integration

The GesCom App does not integrate with third-party services, analytics platforms, advertising networks, or external service providers at this time.

15.2 Future Integrations

Should we integrate third-party services in the future, we will update this Privacy Policy accordingly and notify you of such changes. Any third-party services would have their own privacy policies, and we would encourage you to review them.

15.3 User-Initiated Sharing

If the App provides functionality that allows you to share content with third-party applications or services (such as social media platforms or messaging apps), your use of such features and the information you share will be governed by the privacy policies of those third-party services.

16. Cookies and Tracking Technologies

16.1 Limited Use

As a mobile application that operates locally on your device without web-based components, GesCom has limited use of cookies and similar tracking technologies.

16.2 Local Storage

The App may use local storage technologies on your device to store preferences, settings, and cache data to improve App performance and user experience. This information is stored locally and is not transmitted to external servers.

16.3 Analytics and Tracking

We do not currently use third-party analytics services, tracking cookies, advertising identifiers, or similar technologies to monitor your behavior across different apps or websites.

17. Do Not Track Signals

Some web browsers and devices transmit "Do Not Track" (DNT) signals. Because there is no industry or legal standard for recognizing or honoring DNT signals in the mobile app context, and because our App does not track users across third-party websites or services, we do not currently respond to DNT signals from browsers or devices.

18. Automated Decision-Making and Profiling

We do not use your personal information for automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. Any processing of your information is done to provide App functionality that you directly control and initiate.

19. Data Protection Officer and Representatives

19.1 Contact for Privacy Matters

For all privacy-related inquiries, questions about this Privacy Policy, or to exercise your privacy rights, please contact us at:

Email: ahmad3.10bsse@gmail.com
Company: Gescom
Application: GesCom

19.2 Response Time

We endeavor to respond to all privacy-related inquiries within 30 days, or within the timeframe required by applicable law in your jurisdiction.

19.3 EU Representative

If required under GDPR, we will appoint an EU representative and update this Privacy Policy with their contact information.

20. Complaints and Supervisory Authority

20.1 Right to Lodge a Complaint

If you believe we have not handled your personal information in accordance with applicable law or this Privacy Policy, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

20.2 EEA and UK Users

Users in the European Economic Area and United Kingdom have the right to lodge a complaint with:

• Your local data protection authority
• The supervisory authority in the country where you work
• The supervisory authority in the country where an alleged infringement of data protection law occurred

20.3 Contact Before Complaint

We encourage you to contact us first at ahmad3.10bsse@gmail.com so we can attempt to resolve your concerns directly before you approach a supervisory authority.

21. Business Transfers

If Gescom is involved in a merger, acquisition, asset sale, bankruptcy, reorganization, or similar transaction, your personal information may be transferred or acquired by a third party as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy. We will take reasonable steps to ensure the acquiring party honors the commitments we have made in this Privacy Policy.

22. Accessibility

We are committed to ensuring this Privacy Policy is accessible to all users. If you have difficulty accessing or understanding any part of this Privacy Policy due to a disability or language barrier, please contact us at ahmad3.10bsse@gmail.com, and we will work to provide the information in an alternative format that meets your needs.

23. Data Minimization and Purpose Limitation

We are committed to the principles of data minimization and purpose limitation. We collect only the minimum amount of personal information necessary to provide the App's functionality and use it only for the purposes disclosed in this Privacy Policy. We do not use your information for purposes beyond what is reasonably expected based on our relationship with you and the nature of the App.

24. Accuracy and Data Quality

We take reasonable steps to ensure that the personal information we process is accurate, complete, and up to date. Since photos and media remain on your device under your control, you are primarily responsible for the accuracy of that content. If you believe any information we hold about you is inaccurate, please contact us so we can correct it.

25. Transparency and Accountability

We are committed to transparency in our data practices and accountability for compliance with applicable privacy laws. This Privacy Policy is part of our commitment to transparency. We maintain internal policies, procedures, and controls to ensure ongoing compliance with privacy obligations and to demonstrate accountability to users and regulators.

26. Special Categories of Personal Information

We do not intentionally collect special categories of personal information (also known as sensitive personal information) such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, or data concerning sex life or sexual orientation. However, photos and media you choose to access through the App may contain such information if you have included it in those files. We process such information only as necessary to provide the App's functionality and in accordance with applicable law.

27. No Selling or Sharing for Cross-Context Behavioral Advertising

We do not sell your personal information to third parties. We do not share your personal information with third parties for cross-context behavioral advertising purposes. We do not use your information to create profiles about you for advertising purposes or to serve you targeted advertisements.

28. Privacy by Design and Default

We implement privacy by design and by default principles in the development and operation of the GesCom App. This means:

• Privacy considerations are integrated into the App's design from the earliest stages
• The default settings provide the highest level of privacy protection
• Users are given clear choices and control over their information
• Technical and organizational measures are implemented to protect privacy
• Data processing is transparent and accountable

29. Retention and Deletion Procedures

29.1 Systematic Deletion

We have implemented procedures to systematically delete or anonymize personal information when it is no longer needed for the purposes for which it was collected.

29.2 User-Initiated Deletion

You