Privacy Policy for TGM Tour

Effective Date: 08.07.2025

1. Introduction

Firefly Media SRL ("we," "us," or "our") operates the TGM Tour mobile application (the "App"). This Privacy Policy explains how we handle information when you use our audio tour guide application.

2. Our Privacy Commitment

TGM Tour is designed with privacy in mind. We do not collect, store, track, or share any personal information from our users. This policy explains what this means for you.

3. Information We Do NOT Collect

We want to be clear about what we don't do:

• No Personal Information: We do not collect names, email addresses, phone numbers, or any other personal identifiers

• No Location Tracking: We do not track, store, or share your location data

• No Usage Analytics: We do not collect data about how you use the app

• No Device Information: We do not collect information about your device, operating system, or technical specifications

• No Behavioral Data: We do not track your listening habits, preferences, or tour selections

• No Third-Party Tracking: We do not use any third-party analytics, advertising, or tracking services

4. How the App Works

TGM Tour operates entirely on your device:

• Audio tour content is downloaded directly to your device

• All app functionality runs locally on your phone or tablet

• No data is transmitted to our servers during normal app usage

• Your tour history and preferences (if any) are stored only on your device

5. Permissions We May Request

The app may request certain permissions to function properly:

• Storage Access: To download and store audio tour files on your device

• Network Access: Only to download tour content when you choose to do so

• Audio Playback: To play tour audio content

These permissions are used solely for app functionality and no data is collected or transmitted through these permissions.

6. Data Security

Since we don't collect any data, there is no personal information at risk. All tour content and any app preferences are stored locally on your device and are subject to your device's security measures.

7. Third-Party Services

TGM Tour does not integrate with any third-party services that collect user data. We do not use:

• Analytics services

• Advertising networks

• Social media integrations

• Cloud storage services for user data

8. Children's Privacy

Our app is safe for users of all ages. Since we don't collect any personal information, there are no special privacy concerns for children under 13 or any other age group.

9. International Users

This privacy policy applies to all users regardless of location. Since we don't collect any personal data, there are no data transfer or localization concerns.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted in the app and will be effective immediately upon posting. We encourage you to review this policy periodically.

11. Contact Information

If you have any questions about this Privacy Policy or the TGM Tour app, please contact us via the app.

12. Legal Compliance

This policy is designed to comply with applicable privacy laws including:

• European Union General Data Protection Regulation (GDPR)

• California Consumer Privacy Act (CCPA)

• Other applicable local privacy regulations

Since we don't collect personal data, most privacy law requirements are not applicable to our app.

13. Your Rights

Because we don't collect any personal information:

• There is no personal data to access, modify, or delete

• There are no data processing activities to opt out of

• There is no personal information to port to other services

14. Conclusion

TGM Tour is committed to providing an excellent audio tour experience while respecting your privacy completely. By not collecting any personal information, we ensure that your privacy is protected by design.

This Privacy Policy is effective as of the date listed above and applies to all users of the TGM Tour application.