Privacy Policy

Effective date: 1 September 2026

This Privacy Policy explains how Dragos Pora, trading as pacifictones ("APS", "we", "us", or "our"), processes personal data in connection with the Android Provisioning Studio desktop application, the APS website, licence activation, purchases, downloads, and support.

APS is designed as a local-first business application. Device information, provisioning profiles, deployment history, screenshots, reports, files, and diagnostic logs remain on the customer's computer unless the customer deliberately exports or sends them. APS does not require an APS account and does not automatically upload connected-device content to us.

1. Controller and contact

The controller responsible for the processing described in this Privacy Policy is:

Dragos Pora, trading as pacifictones Email: hello@pacifictones.com

Full legal provider and address information is available in the Impressum:

https://aps.pacifictones.com/impressum

2. Scope

This Privacy Policy applies to:

  • the APS website and download pages;
  • the APS desktop application;
  • licence purchase, activation, validation, and deactivation;
  • product support and security reports; and
  • information voluntarily provided to us.

Third-party websites, Android, device manufacturers, applications installed on connected devices, and services configured by customers through APS are governed by their respective privacy terms.

3. Data processed locally by APS

APS processes information locally on the computer on which it is installed so that customers can inspect, configure, and provision Android devices.

Depending on the features used, this may include:

  • Android device identifiers and system information;
  • application information;
  • provisioning profiles and configuration settings;
  • Wi-Fi, VPN, proxy, certificate, and kiosk configuration;
  • deployment targets, results, history, and logs;
  • screenshots and reports;
  • files imported into or exported from APS;
  • Logcat and other diagnostic information; and
  • local application preferences.

This information is stored locally on the customer's computer or in locations selected by the customer.

APS does not automatically transmit this information to us or to Lemon Squeezy.

The customer controls locally stored information and is responsible for its lawful processing, access, security, backup, retention, and deletion.

4. Information APS does not automatically collect

APS does not automatically collect or upload:

  • connected-device serial numbers or hardware identifiers;
  • installed application inventories;
  • provisioning profiles or commands executed by the customer;
  • screenshots, files, reports, deployment history, Logcat, or diagnostic content;
  • usage analytics or behavioural telemetry;
  • advertising identifiers;
  • precise location data; or
  • credentials stored in profiles or on connected devices.

APS does not use advertising SDKs and does not sell personal data.

5. Purchases and Lemon Squeezy

APS licences are sold through Lemon Squeezy, which acts as merchant of record.

When a customer uses the Lemon Squeezy checkout, Lemon Squeezy may process information such as name, email address, billing and payment information, country, tax information, order information, and fraud-prevention signals.

Payment card information is entered directly into checkout services provided by Lemon Squeezy and its payment partners. APS does not receive or store complete payment card numbers.

Lemon Squeezy may provide APS with information necessary to deliver and administer a licence, such as purchaser contact information, order and product identifiers, licence status, activation information, and transaction status.

Lemon Squeezy processes personal data under its own privacy policy:

https://www.lemonsqueezy.com/privacy

We use purchase and licence information to deliver and administer licences, prevent fraud and licence abuse, provide support, handle refunds or chargebacks, maintain business records, and comply with legal obligations.

6. Licence activation

Initial activation of a paid APS licence requires an internet connection.

APS may transmit the minimum information necessary to verify and register the licence, including:

  • the licence key;
  • a randomly generated installation or instance identifier;
  • an installation name used for licence administration;
  • APS version and operating-system family;
  • product or licence variant; and
  • normal connection information such as IP address, date, and time.

Activation may be processed through APS infrastructure and Lemon Squeezy's licence service.

After successful activation, APS is designed to operate without a continuous internet connection. Where internet access is available, APS may occasionally verify licence status.

APS does not transmit identifiers, application inventories, profiles, screenshots, logs, files, or other content from connected Android devices as part of licence activation.

7. Updates, downloads, and website technical data

APS may check whether a newer version is available. Such a request may contain the installed APS version, operating-system family, application channel, and normal network information.

When the APS website, downloads, or APS-operated endpoints are accessed, the infrastructure used to provide them may process technical information necessary to deliver and secure the service.

This may include:

  • IP address;
  • request date and time;
  • requested URL or file;
  • browser and operating-system information;
  • referrer information where supplied;
  • response status and transferred data volume; and
  • security and error information.

This information is processed only as necessary to provide and secure the website, downloads, activation infrastructure, diagnose failures, prevent abuse, and establish or defend legal claims.

Technical logs are retained only for as long as reasonably necessary for these purposes, unless longer retention is required for a security incident, legal claim, or legal obligation.

8. Cookies and tracking

The base APS website does not use advertising cookies, behavioural tracking, or optional analytics cookies.

Cookies or local storage may be used where strictly necessary to provide a function requested by the visitor, maintain security, or initiate checkout.

Lemon Squeezy may use cookies or similar technologies when its checkout is used, subject to its own policies.

If APS later introduces non-essential analytics, advertising, marketing tracking, or similar technologies, this Privacy Policy and the applicable consent mechanism will be updated where required.

9. Support and communications

If you contact APS, we may process information you voluntarily provide, such as your name, business contact information, organisation, licence or order reference, message content, and attachments.

Support material may contain device information, screenshots, logs, usernames, file paths, network information, or other personal or confidential information.

Customers should inspect and redact support material before sending it and provide only information necessary to resolve the issue.

APS does not automatically upload support material.

Support correspondence is retained only for as long as reasonably necessary to resolve the request, administer the business relationship, comply with legal obligations, or establish or defend legal claims.

Where the General Data Protection Regulation (GDPR) applies, personal data may be processed on the following legal bases:

  • Article 6(1)(b) GDPR — contract or pre-contractual steps: to sell, deliver, activate, administer, and support APS licences;
  • Article 6(1)(c) GDPR — legal obligations: where processing is required by tax, accounting, or other applicable law;
  • Article 6(1)(f) GDPR — legitimate interests: to operate and secure APS infrastructure, prevent abuse, diagnose failures, respond to business communications, and establish or defend legal claims; and
  • Article 6(1)(a) GDPR — consent: where optional processing legally requires consent.

Where processing is based on legitimate interests, those interests consist of operating and protecting APS and its infrastructure, preventing misuse, providing support, and protecting legal rights.

Information required to purchase or activate a licence is necessary to perform the licence agreement. Without it, APS may be unable to deliver or activate the licence.

Support information is voluntary, although insufficient information may prevent us from resolving a request.

11. Recipients

We disclose personal data only where necessary.

Recipients may include:

  • Lemon Squeezy and services involved in payment, tax, fraud prevention, checkout, and licence administration;
  • hosting, content-delivery, activation, and infrastructure providers;
  • email and support service providers;
  • professional advisers such as accountants, tax advisers, legal advisers, auditors, or insurers where necessary; and
  • courts, regulators, law-enforcement authorities, or other public authorities where disclosure is legally required.

APS does not disclose locally stored Android device information because APS does not receive that information unless the customer deliberately sends it.

12. International transfers

Some service providers may process personal data outside the European Economic Area.

Where GDPR requires safeguards for such transfers, we rely on an applicable adequacy decision, the European Commission's Standard Contractual Clauses, or another legally recognised transfer mechanism.

Third-party providers may provide additional information about their international transfers in their own privacy documentation.

13. Retention

Personal data is retained only for as long as reasonably necessary for the purpose for which it was processed or as required by applicable law.

In particular:

  • licence and activation information may be retained while necessary to administer the licence and afterwards where necessary for fraud prevention, transfers, refunds, disputes, or legal claims;
  • transaction, invoice, tax, and accounting information is retained for legally required periods;
  • technical logs are retained according to the criteria described in Section 7;
  • support correspondence is retained according to the criteria described in Section 9; and
  • information relevant to a dispute, security incident, or legal claim may be retained until the matter and applicable legal retention or limitation periods have ended.

Information stored locally by APS remains under the customer's control and is retained until the customer deletes it or removes it using APS or operating-system tools.

14. Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, loss, or disclosure.

Measures may include encrypted network connections, access controls, secrets management, protected licence records, software updates, provider access controls, and data minimisation.

Customers remain responsible for securing their computers, APS Workspace, exported information, licence keys, backups, connected devices, and credentials or certificates used in provisioning.

Security concerns may be reported to:

hello@pacifictones.com

15. Customer responsibility for device data

APS is a tool operated under the customer's control.

The customer determines which devices are connected, what information is inspected, which actions are executed, and which information is exported or retained.

The customer is responsible for ensuring that it has the necessary authority and legal basis to inspect, configure, manage, or process information from connected devices.

Customers are also responsible for appropriate access controls, notices, retention, deletion, and other data-protection requirements applicable to their use of APS.

Because APS does not automatically transmit connected-device data to us, the local use of APS does not by itself make us the customer's processor for that locally stored data.

If a future APS cloud service processes device data on behalf of customers, the applicable privacy and contractual documentation will be updated before that service is offered.

16. Your data protection rights

Subject to applicable law, you may have rights to:

  • request access to personal data concerning you;
  • request correction of inaccurate data;
  • request deletion or restriction of processing;
  • object to processing based on legitimate interests;
  • receive certain personal data in a portable format; and
  • withdraw consent at any time where processing is based on consent, without affecting processing that occurred before withdrawal.

Requests may be sent to:

hello@pacifictones.com

We may request information reasonably necessary to verify the requester's identity and locate the relevant information.

You also have the right to lodge a complaint with a competent data protection supervisory authority.

17. Automated decision-making and marketing

APS does not use personal data to make automated decisions producing legal or similarly significant effects about individuals.

Licence or fraud-prevention systems may automatically flag a transaction or activation. Customers may contact us where human review is appropriate.

APS does not currently operate a marketing newsletter and does not use personal data for behavioural advertising.

18. Changes to this Privacy Policy

We may update this Privacy Policy when APS features, providers, processing activities, or legal requirements change.

The current version and effective date will be published at:

https://aps.pacifictones.com/privacy