Privacy and Policy

Updated: 25 May 2023
This Privacy Policy (hereinafter, the Policy) governs the processing of personal data of our apps’ users (hereinafter referred to as the Services). The list of our apps that this Policy applies to:
  • - Dog Translator & Trainer App
  • - Decibel Meter — Sound Level dB
  • - Find Lost Device - Air Tracker
  • - Offerheap: Smart IT Recruitment

We attach great importance to the protection of your personal data, so take a moment to find out more about our Privacy Policy and contact us if you have any questions.

1. Terms and Definitions

1.1. For the purposes hereof, the following terms and definitions are used:
We (ITIncubator) - Itincubator, UAB.
You (User) - any individual that is using functional features of the Services and has reached the age of full legal capacity in accordance with the legislation of the country of their citizenship.
Services - “Dog Translator & Trainer App”, “Decibel Meter — Sound Level dB” app, “Find Lost Device - Air Tracker” app, “Offerheap: Smart IT Recruitment” app.

2. Scope

2.1. This Policy shall govern any interaction between ITIncubator and users related to personal data when using the Services.
2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services. Thus, if you integrate any third-party applications with our Services, we will not be able to control how such applications process your personal data.
2.3. Please do not use the Services if you do not agree with the provisions and scope hereof.

3. Who determines the purposes and means of personal data collection?

3.1. The purposes and means of how your personal data is collected in these Services are determined by the following legal entity:
Itincubator, UAB
J. Savickio g. 4-7, LT-01108 Vilnius, Lithuania
email (general questions):
email (personal data questions):

4. Personal data

4.1. Personal data is any information that could enable direct or indirect identification of a person (e.g., their name, passport details, online identifier, etc.).
4.2. In accordance herewith, personal data may be collected both directly and indirectly.
(1) Personal data are collected directly when you provide them voluntarily (e.g. when registering in the Services).
(2) Indirect collection of personal data may occur automatically when accessing the Services, including through cookies.
4.3. We collect the required minimum of your personal data for the purposes hereof:
(1) geolocation;
(2) analytical data: browser type, user device type and model, operating system, its version and language, WI-FI status, timestamp and zone, carrier, IP address, user clicks, history of interaction with Services;
(3) payment information: list of transactions, the details of payment means;
(4) technical information: IDFA, Android ID, Google Advertiser ID, user ID, information about the ads shown, advertising interaction history.

5. Data Processing, Storage and Protection

5.1. “Processing” is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
5.2. We will process your personal data only for the following purposes and on the following legal grounds:

Data typeProcessing purposesLegal basisRetention period
GeolocationWe process your geolocation so that you can take advantage of the basic features of our Services.Performance of a contract.24 months.
Analytical dataWe process your analytical data so that we can continuously improve our Services.Legal interest to improve our services.24 months.
Payment informationWe process your payment information so that you can use the paid features of our Services and subscribe to them.Performance of a contract.10 years.
Technical informationWe process your technical information in order to display personalized ads.Your consent.24 months.

5.3. Subject to data anonymisation, your personal data may be used by ITIncubator for any other purposes.
5.4. We do not not use automated decision-making tools (including profiling) in personal data processing. Automated decision-making tools primarily include those systems that process your personal data without human intervention to make decisions that may have potential legal consequences for you.
5.5.Your personal data will be stored on the servers of our counterparties that we are using for operating our Services.
5.6. Your personal data will be stored on the servers of our Partners services of which we are using to host our Services and operate them.
5.7. Employees of ITIncubator shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Services shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties.
5.8. If your personal data is transferred to any third party, the storage time will be determined in accordance with the privacy policy of such a third party. We will do our best to inform them about the deletion of your personal data if necessary.
5.9. Any personal data collected and processed hereunder shall be properly protected unless:
(1) you consent to their disclosure;
(2) such personal data are anonymised;
(3) such personal data are subject to disclosure under the applicable law.
5.10. We will do our best to keep your personal data protected. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.

6. Transfer and Disclosure

6.1. The following third parties may have access to your personal data as we’ve authorized them to process your personal data on our behalf:
(1) Google Inc. (Ireland)
Address: Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Google Privacy policy
Google may have access to the personal data which you provide to us, because we use their service for hosting and analytics;

(2) Apple Inc. (USA)
Address: One Apple Park Way, Cupertino, CA 95014
Apple Privacy policy
Apple may have access to the personal data which you provide to us, because we use their services for hosting, analytics and payments;

(3) AppsFlyer (USA)
Address: 100 1st St 25th floor, San Francisco, CA 94105
AppsFlyer Privacy Policy
AppsFlyer may have access to the personal data which you provide to us, because we use their services for analytics.

6.2. Nevertheless to ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganization of ITIncubator should it be necessary.
6.3. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of ITIncubator and third parties or for other substantial public interest purposes.

7. Children's Personal Data

7.1. To the extent to which it is not prohibited by the applicable law, we do not authorize the use of our Services by individuals who have not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.

8. User Rights

8.1. The rights of users related to the collection and processing of personal data shall be determined in accordance with the applicable law.
8.2. Your rights with respect to the collection and processing of personal data may be determined in accordance with applicable data protection law. In accordance with applicable data protection law you may access, change and/or make additions to, delete, restrict processing and migration of, object to or withdraw your consent to the processing of your personal data as well as opt-in/opt-out and lodge a complaint to the supervisory authority.
8.3. To exercise any of your rights above and any other rights guaranteed to you by applicable law and if you have any related questions, write to: For issues related to your personal data please contact:
8.4. ITIncubator reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.

9. Final Provisions

9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.
9.2. The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby cancelled.
9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
9.5. This policy has been drawn up in Russian and English. In the event of any textual discrepancy, the Russian version prevails.