Privacy Policy

Effective date: October 26, 2026

Last updated: October 26, 2026

This Privacy Policy describes the policies and procedures of Keran Labs (“We”, “Us”, or “Our”) on the collection, use, and disclosure of Your information when You use the Manager PA mobile application (the “Application” or “Service”). Manager PA is an application provided and operated by Jarosław Paweł Jarosz, an individual developer operating under the project/brand name Keran Labs. It explains Your privacy rights under applicable data protection regulations, including the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and the California Online Privacy Protection Act (CalOPPA).

Keran Labs is an independent software project founded and maintained by an individual software developer based in Poland. By accessing or using the Service, You acknowledge that You have read and understand this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

• Account: A unique account created for You to access Our Service or parts of Our Service.
• Application: Refers to Manager PA, the software application provided by Keran Labs.
• Company / Data Controller / Service Provider: Refers to Keran Labs (operated as an individual enterprise in Poland). For the purposes of the GDPR, Keran Labs is the Data Controller of Your account credentials and app diagnostic telemetry, and acts as a Data Processor regarding the employee notes and records stored by You.
• Device: Any device capable of accessing the Service, including smartphones, tablets, or computers.
• Personal Data (Personal Information): Any information that relates to an identified or identifiable natural individual.
• Service: Refers to the Manager PA application.
• Third-Party Services: External tools, SDKs, APIs, and platforms integrated with the Service, including Google Analytics, Google AdMob, Google Gemini, Google Play In-App Payments, and Apple App Store In-App Purchases.
• Usage Data: Data collected automatically, either generated by using the Service or from the Service infrastructure itself (e.g., diagnostic logs, session durations, device identifiers).
• You / User: The individual accessing or using the Service, typically a team leader, manager, or professional acting on behalf of themselves or their organization.

Collecting and Using Your Personal Information

Types of Data Collected

1. Personal Data Provided Directly by You

While using Our Service, We may collect:

• Account credentials (e.g., email address, display name, user ID).
• Billing status and receipt identifiers related to In-App Subscriptions (handled securely via Apple App Store or Google Play Store).
• Customer support communications and submitted feedback.

2. Workplace, Team, and Employee Records (User Content)

Manager PA is built to organize teams, structure direct reports, take notes, attach files, record skills, goals, tasks, events, and track mood/evaluations.

• Employee & Team Profiles: Names, roles, organization hierarchies, skills, motivations, performance ratings, and work preferences.
• Uploaded Attachments: Images, documents, or files that You grant permission to access from Your Device’s photo library or file storage.
• Controller vs. Processor Responsibility: You (the manager/employer) act as the primary Data Controller for any personal information regarding third parties (such as direct reports or team members) that You enter into the Service. You warrant that You have a lawful basis (e.g., employment contract necessity, internal legitimate interest, or consent) to log this workplace information.

3. Usage Data & Diagnostics (Google Analytics)

Usage Data is collected automatically when using the Application via services such as Google Analytics. This may include:

• Device properties: device model, operating system version, unique device identifiers (e.g., IDFA, Android Advertising ID).
• Performance telemetry: app launch times, screen views, feature interactions, crash logs, and network connection status.
• Network data: truncated IP addresses used for geolocation metrics (country/city level).

Advertising (Google AdMob)

The free tier of the Service may display third-party advertisements served by Google AdMob. To serve contextual or personalized ads, AdMob may collect and process device identifiers, advertising IDs, IP addresses, and diagnostic information.

• Personalized Ads: Depending on Your device settings and regional requirements (such as the GDPR consent prompt in the European Economic Area), ads may be tailored based on Your interests.
• Opt-Out Options: You may opt out of interest-based advertising at any time through Your Device operating system settings:
  • iOS: Navigate to Settings > Privacy & Security > Tracking and disable tracking permissions.
  • Android: Navigate to Settings > Privacy > Ads and enable “Delete advertising ID” or toggle personalized ads off.
• For more details on Google’s advertising practices, consult the Google Advertising Privacy Policy.

In-App Purchases and Subscriptions

Manager PA offers premium tiers and auto-renewing subscriptions (such as advanced features and AI integration). We do not collect, process, or store Your payment card details directly. All financial transactions are managed entirely by:

• Apple App Store In-App Purchases: Governed by Apple’s Privacy Policy and StoreKit protocols.
• Google Play In-App Payments: Governed by Google Play’s Terms of Service and Billing APIs.

The Application receives only cryptographic receipt validation tokens and entitlement status confirming whether Your Account holds an active Premium license.

Artificial Intelligence Processing (Google Gemini)

Manager PA integrates Generative AI functionalities powered by the Google Gemini API to deliver managerial insights, feedback phrasing, and team guidance.

• Anonymization and Minimization: Before any user-entered notes or evaluations are transmitted to the Google Gemini API, personal identifiers (such as employee real names and specific personal identifiers) are removed, masked, or replaced with pseudonyms on the device/client-side whenever feasible.
• No Public Foundation Training: Data transmitted through enterprise Google Gemini API integrations is not used to train or refine public foundation models without explicit authorization, in accordance with Google’s API Data Governance terms.
• Advisory Nature Disclaimer: AI-generated suggestions, summaries, and recommendations are strictly intended as informational aids. They do not constitute legal, HR, or psychological advice. Final discretion and responsibility for all workplace interactions, evaluations, and employment actions remain solely with You.

Third-Party Service Providers

We work with trusted third-party service providers who assist Us in operating the Application:

Provider	Purpose	Privacy Information
Google Analytics	App performance, usage trends, and diagnostics	Google Privacy Policy
Google AdMob	In-app ad delivery and measurement	AdMob Policy
Google Gemini API	AI-driven management suggestions and insight generation	Google Gemini API Terms
Google Play / Apple StoreKit	Payment processing and subscription entitlement verification	Store platform billing systems

Legal Bases for Processing under GDPR (EEA/UK Users)

If You are located in the European Economic Area (EEA), the UK, or Switzerland, Our legal bases for processing Your personal data under the General Data Protection Regulation (GDPR) include:

• Performance of a Contract (Art. 6(1)(b) GDPR): Providing core application functionality, syncing workspace data, and activating Premium in-app purchases.
• Legitimate Interests (Art. 6(1)(f) GDPR): Improving app stability, monitoring aggregate performance with Google Analytics, and preventing fraudulent activity.
• Consent (Art. 6(1)(a) GDPR): Delivering personalized advertising through Google AdMob and accessing optional device permissions (such as photo library attachments). You may withdraw consent at any time.
• Legal Obligation (Art. 6(1)(c) GDPR): Retaining tax and billing records where mandatory under Polish and EU regulations.

Your GDPR Rights

Under Chapter III of the GDPR, You have the right to:

• Access the personal data We hold about You.
• Rectify any inaccurate or incomplete personal data.
• Erase (“Right to be Forgotten”) Your personal data.
• Restrict or Object to the processing of Your personal data.
• Data Portability: Request a structured, machine-readable copy of Your data.
• Lodge a Complaint: File an inquiry with Your local Data Protection Authority (in Poland: Urząd Ochrony Danych Osobowych – UODO).

Account Management and Account Deletion

Both Apple and Google policies, as well as global privacy laws, guarantee Your right to manage and erase Your account and associated records:

• Web Account Management: You can review and manage Your account details online at https://keranlabs.com.
• Permanent Account Deletion: You can permanently delete Your Account, team setups, employee logs, notes, and profile data by visiting Our dedicated portal: https://keranlabs.com/delete-account/ or by using the in-app “Delete Account” option within Application Settings.

Upon receiving a validated deletion request, all personal data linked to Your Account will be removed from Our production databases within thirty (30) days, except where retention is strictly required to comply with statutory legal or tax obligations.

Notice to California Residents (CCPA & CPRA)

This section applies exclusively to California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA/CPRA):

• Categories of Personal Information Collected: Identifiers (email, IP address, device ID), commercial information (subscription status), internet/network activity (analytics logs), and user-uploaded workplace records.
• Sale or Sharing of Personal Information: We do not sell Your Personal Information for monetary compensation. However, the use of third-party advertising cookies or device SDKs (such as Google AdMob) may be classified as “sharing” for cross-context behavioral advertising under California law.
• Your California Rights:
  • Right to Know: Request disclosure of the categories and specific pieces of Personal Information collected.
  • Right to Delete: Request erasure of Your collected Personal Information.
  • Right to Correct: Request correction of inaccurate Personal Information.
  • Right to Opt-Out of Sharing: You may opt out of cross-context behavioral advertising by adjusting Your device tracking settings or submitting a request via Our deletion/management link.
  • Right to Non-Discrimination: We will not discriminate against You for exercising any CCPA/CPRA rights.

California Online Privacy Protection Act (CalOPPA) Disclosures

• Do Not Track (DNT) Signals: Our Application does not currently alter its behavior in response to automated web browser “Do Not Track” signals because no uniform industry standard exists. However, mobile platform ad-tracking preferences are respected.
• In-App Privacy Access: Users can access this Privacy Policy directly from the Application Settings screen and through the public app store product pages.

Data Retention

We retain Your Personal Data only for as long as is necessary to fulfill the operational purposes set forth in this policy, maintain Your active Account, or satisfy statutory accounting standards. When data is no longer necessary, it is securely expunged or anonymized.

International Data Transfers

Your information may be processed on servers and cloud storage infrastructure located outside of Your home country or territory. If data is transferred from within the European Economic Area to servers in non-EEA jurisdictions (such as the United States for Google Analytics or Gemini processing), We ensure that adequate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission.

Children’s Privacy

Manager PA is a business and organizational productivity tool intended strictly for adults and professionals. We do not knowingly collect personal information from individuals under the age of 16. If We learn that a minor has submitted personal details, We will promptly take steps to delete that data.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of material changes by posting the updated Privacy Policy at this location and updating the “Last updated” date. We advise You to check this page periodically for updates.

Contact Us

If You have questions, requests, or concerns regarding this Privacy Policy, You can contact Us:

Developer: Jarosław Paweł Jarosz
Brand / Project: Keran Labs
Email: [email protected]
Website: https://keranlabs.com
Jurisdiction: Poland, European Union