Privacy Policy

01 Introduction

This Privacy Policy applies equally to Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets (collectively, the "Guesthouse Mobile Applications" or the "Applications"), developed and provided by eMviasoft Ltd ("we", "us", or "our"). It explains how information is collected, used, stored, shared, and protected when you use any of the applicable Applications. No one Application is the primary application for purposes of this Privacy Policy; unless a provision expressly states otherwise, every provision applies to each of the three Applications.

Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets form an integrated mobile application suite. Each Application is a separate mobile application, but the applicable Applications may access and use a common local database stored on the same user device in order to provide integrated functionality. Information entered or generated in one Application may therefore be available to another of the applicable Applications installed on that same device where necessary for that functionality. The shared database remains local to the device and is not uploaded to eMviasoft Ltd servers merely because it is shared among the applicable Applications.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and other applicable data protection laws.

02 Privacy-First Design — Local Storage Only

The applicable Applications are designed with privacy as a core principle. Each Application operates primarily using local storage on the user's device:

• All property, reservation, guest, account, and operational data you enter is stored locally on your device using an encrypted SQLite database.
• Your property, reservation, guest, account, and operational data is not transmitted to our servers or third-party servers. Limited analytics data described in Section 5.1 may be transmitted automatically to Google Firebase Analytics.
• We do not have access to the content of your locally stored property, reservation, guest, account, or operational data.
• Where the applicable Applications use the shared Guesthouse local database described below, uninstalling Guesthouse Butler alone may not delete shared data while another Guesthouse application remains installed and continues to use that database.

This means that eMviasoft Ltd does not collect, store, or process the content of your personal property-management data on its servers. The limited analytics data described below is separate from the operational content you create in the applicable Applications.

03 Information You Provide and Store Locally

Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets are designed to store operational information created or entered by the user locally on the user's device. The Applications may use a common local database on the same device in order to provide integrated functionality between the Applications.

Operational information stored in the common local database is not transmitted to, stored on, or accessible through eMviasoft Ltd servers. eMviasoft Ltd does not have access to the content of the user's local Guesthouse database.

Information stored in the common local database may be accessed locally by Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets installed on the same device where necessary for their functionality. This local access between the Applications does not constitute transmission of operational information to eMviasoft Ltd servers.

Users remain responsible for the information they enter into the Applications and for complying with applicable data protection requirements where that information relates to third parties.

03A Optional Recipe Downloads — Guesthouse Breakfast

Guesthouse Breakfast may, at the user's discretion, download selected popular recipes from around the world for use within the Application. This functionality downloads recipe content to the user's device. It does not upload the user's operational information, locally stored Guesthouse database, or user-created content to eMviasoft Ltd servers.

Downloaded recipe content is stored locally on the user's device for use within Guesthouse Breakfast. The recipe download functionality does not provide a mechanism for users to upload, synchronize, back up, or otherwise store their own recipes or other locally created operational data on eMviasoft Ltd servers.

04 Device Permissions

The applicable Application requires the following permissions on your device:

4.1 Notifications

The applicable Application requests permission to send local notifications to remind you about upcoming reservations, cleaning schedules, and stock alerts. These notifications are generated locally on your device and are not sent through our servers. You can disable notifications at any time in your device settings.

4.2 Photo Library / Camera Access

If you choose to add photos to property listings, the applicable Application requires access to your photo library or camera. Photos are stored locally on your device and are never uploaded to our servers.

4.3 Local Storage and Shared Guesthouse Database

The applicable Application stores its data locally on your device. Guesthouse Butler is part of the Guesthouse application family, which currently includes Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets. These applications may use the same local database on the device in order to provide integrated functionality and consistent data across the Guesthouse applications.

Information entered or generated in one of these Guesthouse applications may therefore be available to another Guesthouse application installed on the same device where this is necessary for its functionality. This local sharing does not, by itself, transmit your property, guest, reservation, breakfast, asset, inventory, expense, or other operational data to eMviasoft Ltd servers or to a remote cloud database.

Each Guesthouse application is a separate application and requires its own separate subscription for premium access. Sharing the local database does not provide or transfer a subscription, licence, or premium access from one Guesthouse application to another.

05 Data Transmission and Third Parties

We do not transmit your property, reservation, guest, account, or operational data over the internet. The applicable Application does not include cloud synchronization, online backup, or any feature that uploads such content to remote servers. The applicable Application does, however, use Firebase Analytics for the limited analytics purposes described below.

Network communication may occur for the following limited purposes:

• Subscription payment processing through the official app store (Apple App Store or Google Play Store), which is governed by their respective privacy policies.
• Analytics processing through Google Firebase Analytics, as described in Section 5.1.
• Optional download of recipe content in Guesthouse Breakfast, initiated by the user.

5.1 Firebase Analytics

The applicable Application uses Google Firebase Analytics to understand how the applicable Application is used and to improve its functionality, reliability, and user experience. Firebase Analytics may automatically collect the following limited data categories:

• Identifiers — Device ID (Firebase App Instance ID). Purpose: Analytics. Linked to the user: No.
• Usage Data — Product Interaction. Purpose: Analytics.

The Firebase App Instance ID is a randomly generated app-installation identifier used for analytics. It is not your hardware serial number, advertising identifier, name, email address, or account identifier, and eMviasoft Ltd does not use it to identify you personally.

Product Interaction data may include information about screens viewed, features used, in-app actions, session activity, and similar interactions with the applicable Application. It does not include the content of your property records, reservation records, guest details, photos, expenses, passwords, or other operational data stored locally on your device.

We use this analytics data only to measure product usage, diagnose usability issues, improve features, and maintain the applicable Application. We do not use it for advertising, personalised advertising, marketing profiles, or the sale of personal data.

Firebase Analytics is provided by Google. Google may process analytics data in accordance with its own privacy terms and applicable data-protection safeguards.

Each Guesthouse Mobile Application is licensed and subscribed to separately. A subscription purchased for Guesthouse Butler does not unlock Guesthouse Breakfast or Guesthouse Assets, and the same principle applies to subscriptions purchased for either of those applications. Each application may offer the same subscription periods and prices, but each purchase applies only to the application for which it was made.

06 Subscription and Payment Information

Subscription purchases are processed exclusively through the Apple App Store or Google Play Store. We do not collect or store payment card details. The app stores receive and process all payment information according to their own privacy policies:

• Apple App Store: www.apple.com/legal/privacy
• Google Play Store: policies.google.com/privacy

Free-trial status for the applicable Application is stored locally on your device only and is not transmitted to us or any third party.

We may receive limited subscription status information from the app stores (e.g., active/inactive subscription) to verify your access to premium features.

07 Legal Basis for Processing (GDPR)

To the extent that any processing of personal data occurs, the legal basis is:

• Performance of a contract — to provide the applicable Application and its features to you (Article 6(1)(b) GDPR).
• Legitimate interest — to maintain and improve the applicable Application, prevent fraud, and ensure security (Article 6(1)(f) GDPR).
• Consent — for any optional features you explicitly enable (Article 6(1)(a) GDPR).
• Legal obligation — to comply with applicable laws (Article 6(1)(c) GDPR).

08 Your Rights Under GDPR

Since your data is stored locally on your device, you have full and direct control over it at all times. Additionally, under GDPR you have the following rights:

• Right of access — request a copy of any personal data we may hold about you.
• Right to rectification — correct inaccurate or incomplete data.
• Right to erasure ("right to be forgotten") — request deletion of your data; you can do this directly by uninstalling the applicable Application or clearing app data. Where the common local database is used by more than one Guesthouse Mobile Application, uninstalling a single application may not delete the shared database or data still required by another installed Guesthouse Mobile Application. To remove all shared local data, the user may need to remove all Guesthouse Mobile Applications and/or clear the shared application data using device controls, where supported.
• Right to restrict processing — limit how your data is processed.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interest.
• Right to withdraw consent — at any time, where processing is based on consent.
• Right to lodge a complaint — with the Bulgarian Commission for Personal Data Protection (CPDP) or your local supervisory authority.

To exercise any of these rights, contact us at info@guesthousebutler.com.

09 Children's Privacy

The applicable Application is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal information, please contact us immediately and we will take steps to delete it.

10 Data Security

We take reasonable technical and organizational measures to protect data within the applicable Application:

• Passwords are stored as cryptographic hashes (never in plain text).
• The local database is protected by your device's operating system security.
• We recommend using device-level security (PIN, biometrics, encryption).

However, no method of electronic storage is 100% secure. You are responsible for protecting your device and login credentials.

11 Data Retention

Operational data is retained locally on your device while it remains in the local Guesthouse database. Because Guesthouse Butler, Guesthouse Breakfast and Guesthouse Assets may use the same local database, uninstalling one Application alone may not delete shared data if another Application remains installed. To delete locally stored data, use available in-app or device-level data deletion controls, or remove the Applications and their shared local data as supported by your operating system.

Firebase Analytics data is retained in accordance with the retention settings configured for the Firebase project and Google's applicable retention practices. Because analytics identifiers are not linked by us to your identity, we may not be able to associate an analytics record with a particular individual based solely on a privacy request.

12 International Data Transfers

No international transfer of your locally stored property, reservation, guest, account, or operational data occurs as part of the applicable Application's core functionality. Limited Firebase Analytics data and data processed by Apple, Google, or other app-store service providers may be transferred and processed in other countries under their respective privacy frameworks and safeguards.

13 Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the applicable Application. We encourage you to review this policy periodically.

14 Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Company: eMviasoft Ltd
• Address: 2A Frederic Joliot-Curie blvd. 1113 Sofia, Bulgaria
• Support Email: info@guesthousebutler.com
• Privacy Email: info@guesthousebutler.com
• VAT/Company Number: BG207392577