EXEcutor32 Privacy Policy

This Privacy Policy explains what personal data is processed when you use the EXEcutor32 app for iPhone and iPad (the "App"), the website executor32.com (the "Website") and our support. In this Policy, a "Sandbox" is one of the separate PC-style environments that the App creates on your device; a "Linked Folder" is a folder outside the App's own storage that you give the App access to; and a "Plan" is a paid EXEcutor32 Pro subscription sold through the App Store. Your use of the App is governed by Apple's Licensed Application End User License Agreement (https://www.apple.com/legal/internet-services/itunes/dev/stdeula/) and our Terms of Use (https://executor32.com/terms). This Policy is written in English. If we provide a translation, it is for convenience; if the English text and a translation differ, the version more favourable to you applies.

1. Who is responsible

1.1. The controller is Leonid Gorbarenko, the developer and seller of EXEcutor32 on the App Store ("we", "us"). Contact for all privacy questions and requests: executor32.app@gmail.com.

1.2. Which laws apply. Our processing is subject to the Law of Georgia on Personal Data Protection. The App is not offered on the App Store in the European Union, the European Economic Area, the United Kingdom or Switzerland. Where the EU General Data Protection Regulation (GDPR), the UK GDPR, the Swiss Federal Act on Data Protection or another data protection law nevertheless applies to our processing of your data, for example when you visit the Website, you also have the rights that law gives you. We give the rights in section 13 to all users, wherever they live.

1.3. Data protection officer and representatives. We have not appointed a data protection officer. Because we do not offer the App in the European Union or the United Kingdom, we have not appointed a representative there. Please send all privacy questions and requests to executor32.app@gmail.com.

2. Summary

• The App works without an account.
• Most of what the App stores stays on your device and never reaches us (section 4).
• App analytics is off unless you turn it on (section 5).
• On the Website, analytics runs only after you accept it in the cookie banner (section 9).
• We do not sell personal data, do not show ads, and do not track you across other companies' apps or websites.

3. What we process, why, and on what legal basis

These legal bases are provided for by the Law of Georgia on Personal Data Protection and, where it applies, by the GDPR (Art. 6(1)(a) consent, Art. 6(1)(b) contract, Art. 6(1)(f) legitimate interests). Apple, not we, processes purchases (section 7). Where we rely on legitimate interests, you can object (section 13).

4. Data that stays on your device

The following is stored only on your device. The App does not send it to us:

• the programs, files, saves, Sandboxes and settings you add, including the system registry of each Sandbox;
• the Linked Folders and files you choose (the App keeps the system access bookmarks for them);
• browser data: open tabs and page snapshots, history, favourites, site icons, your search-engine choice, and the cookies and website data kept by the browser. Settings → Browser → "Clear History and Website Data" deletes them;
• your downloads and the download list;
• controls layouts;
• permissions you chose to remember for a program;
• whether you have an active Plan (a cached status used when the App Store cannot be reached);
• your analytics choices;
• a list of recent games, shared with the EXEcutor32 home-screen widget on the same device.

If you turn on MetricKit (in Settings → Analytics), the App saves Apple's performance and diagnostic reports on your device. They can include launch and responsiveness metrics, CPU, memory, battery and network performance, crashes, hangs and stack traces. The App keeps up to about 5 MB of them. If you turn on Local diagnostics, the App saves a limited event log on your device, up to about 1 MB. The App does not upload either of them to us or to anyone else. Turning an option off deletes what it saved.

When you start a download in the built-in browser, the App asks for permission to show notifications. If you allow it and a download finishes while the App is in the background, the App shows a local notification with the file name. The notification is created on your device and is not sent to us.

You can delete all of this data by deleting the App. Linked Folders outside the App are not deleted.

5. Optional app analytics (Google Analytics for Firebase)

5.1. Off by default. On first launch the App asks for your choice. All options start switched off, and you can continue without analytics. The App sends usage data to Google only if you turn on "Firebase Analytics", there or later in Settings → Analytics.

5.2. The App's own events contain only:

• that the App started, with the app version, build and bundle identifier;
• that a program launch was requested, started, failed or ended, with how it was started (for example from the home screen or a widget), whether a shortcut was used, the number of control presets, the screen resolution setting, the size of the program file, the exit reason and the session length;
• controls-menu actions, with the screen, the action, the type and number of controls, and whether a gamepad is connected;
• changes to the frame-rate limit setting (old and new value);
• multiplayer room actions and states, with the connection mode and the number of players;
• if MetricKit is also on, the number of MetricKit reports received.

Before sending, the App removes file names, folder paths, launch arguments, names you typed (Sandbox, layout and room names), program version information, error texts and its own internal identifiers.

5.3. Data the Firebase SDK collects itself once analytics is on: an app-instance identifier, device model, OS version, app version, language, and automatic events such as first open, session start and engagement time. The SDK may also collect Apple's identifier for vendor (IDFV) and record which App screens you view. Google derives an approximate location (country, region and city) from your IP address and then discards the IP address. The App does not use location services. The App does not use Apple's advertising identifier (IDFA) and does not ask for permission to track you.

5.4. No advertising. The data is not used for advertising. The App sets Google's advertising consent signals (ad_storage, ad_user_data, ad_personalization) to "denied".

5.5. Legal basis and withdrawal. The legal basis is your consent (and, where they apply, the rules on storing and reading data on your device). Your consent also covers the transfer of this data to Google in the USA (section 11). You can withdraw consent at any time in Settings → Analytics ("Disable all analytics" or the "Firebase Analytics" switch). The App then stops collection and resets the analytics data and identifier on the device. Withdrawal does not affect processing before it. Data already sent stays with Google until the retention period ends (section 12), unless you ask us to delete it earlier.

5.6. Recipient. Google acts as our processor under Google's data processing terms for Google Analytics, which cover Google Analytics for Firebase. See section 11 for international transfers.

6. Crash reports shared through Apple

If you have turned on sharing with app developers in iOS Settings (Privacy & Security → Analytics & Improvements → Share With App Developers), Apple may give us crash and diagnostic reports through App Store Connect. Apple collects them under its own privacy policy. We use what we receive only to fix problems, on the basis of our legitimate interest in keeping the App working. You can turn this sharing off in iOS Settings at any time.

7. Purchases

Apple sells Plans and processes payments under Apple's own privacy policy. We receive no payment details. Apple gives us sales and subscription reports; they do not include your name, email address or payment details. The App uses StoreKit on your device to check your Plan (product, purchase and expiry dates, renewal status and transaction identifiers). It does not send this to us.

8. Multiplayer, the browser and programs you run

8.1. We do not run multiplayer servers and do not receive multiplayer data.

• Nearby play (Multipeer Connectivity, over Wi-Fi and Bluetooth): only nearby devices that run EXEcutor32 and are looking for rooms can see your room. They see a name made from your device name and a random 6-character code that stays the same on your device. Players in the room see the name of the program you host and receive the game's network traffic. The connection is encrypted.
• Game Center: you play only with people you invite (a Game Center invitation or, on iOS 26 or later, a party code or link that you share). Through Apple, they receive your Game Center name and player identifier, and they receive the game's network traffic. Game Center is run by Apple under Apple's privacy policy.

8.2. The built-in browser and programs. Websites you open, the search engine you choose, and online services that programs you run contact receive your IP address and whatever they collect, under their own privacy policies. We do not receive this data. When a program asks to open a web address outside the App, the App asks you first.

9. The Website (executor32.com)

9.1. Hosting and server logs. The Website is run on servers of a hosting provider that acts as our processor. When you visit it, your browser sends your IP address and technical request data, and the web server records them in its logs. Legal basis: legitimate interests (security and operation of the Website). Retention: section 12.

9.2. Cookie banner and choices. On your first visit, a banner asks whether you accept analytics cookies. Your choice is saved in your browser's local storage, so the banner does not appear again. You can change it at any time with the "Cookie settings" link at the bottom of each page. If you decline or withdraw, the Website deletes the Google Analytics cookies and the Firebase data stored in your browser that it can reach; if analytics was running, the page reloads without it.

9.3. Analytics (only with your consent). If you accept, the Website loads Google Analytics 4 (through Firebase) from Google's servers. It records page views; clicks on links and buttons (the element, its text up to 50 characters, the link address and the page). Google Analytics sets cookies (such as _ga and cookies whose names begin with _ga_) and browser storage, and receives your IP address and browser information; Google derives an approximate location (country, region and city) from the IP address. We use these statistics only to understand how the Website is used; we do not build profiles of visitors. Before you accept, no analytics code is loaded. Legal basis: your consent.

9.4. Storage that needs no consent. The Website stores your language choice and your cookie choice in your browser's local storage. They are not sent to us. They are strictly necessary to provide what you asked for.

10. Support by email

10.1. Our support works by email only: executor32.app@gmail.com. The Website has no contact form.

10.2. If you email us, we receive your email address, your name if your email shows it, the message, and anything you attach or include, such as a description of your device or a screenshot.

10.3. We use this data only to reply to you and to fix problems. See section 3 for the legal bases, section 11.4 for the storage of support emails by Google in the USA, and section 12 for how long we keep it.

11. Who receives data, and international transfers

11.1. Recipients.

11.2. Data reaching us. We process the data that you send us (for example by email) under the law of Georgia. The European Commission has not adopted an adequacy decision for Georgia. Where the GDPR applies to our processing, it applies to us directly, and we protect your data as it requires.

11.3. Transfers from us to other countries. Some recipients process data outside Georgia. Our hosting provider runs the Website on servers in the Netherlands, a country that Georgian law recognises as providing an adequate level of data protection. Where a recipient is in a country that Georgian law does not recognise as providing an adequate level of data protection, we transfer data only on a basis that Georgian law permits:

• App and Website analytics (Google): your consent (sections 5.5 and 9.3).
• Support emails (Gmail): your consent, as explained in section 11.4.

Where the GDPR applies, transfers to Google LLC in the USA rely on Google LLC's certification under the EU-U.S. Data Privacy Framework and, for analytics, also on the Standard Contractual Clauses in Google's data processing terms. You can ask us which safeguards apply and for a copy of them.

11.4. Support emails and the USA. Our support mailbox is a Gmail account, so Google stores the messages you send to executor32.app@gmail.com in the USA and other countries where it operates. The USA is not on Georgia's list of countries with an adequate level of data protection. By writing to this address after reading this section, you consent to your message being stored by Google in this way. Please include only the personal data that your request needs. You can withdraw your consent at any time by asking us to delete your messages; we then delete them from the mailbox, and we may no longer be able to help with that request.

11.5. We do not sell or rent personal data, and we do not share it with anyone else unless the law requires us to.

12. How long we keep data

After the retention period, data is deleted or anonymised. We may keep data longer only where the law requires it or where it is needed to establish, exercise or defend legal claims.

13. Your rights

You have the right to:

• access your personal data and get a copy;
• have it corrected;
• have it deleted;
• restrict (block) its processing;
• receive it in a portable format;
• object to processing based on legitimate interests;
• not be subject to a decision based solely on automated processing (section 14);
• withdraw your consent at any time, without affecting processing before the withdrawal.

These rights follow from the Law of Georgia on Personal Data Protection and, where they apply, the GDPR, the UK GDPR and other laws. The exact scope of a right can depend on the law that applies to you.

How to use them. Email executor32.app@gmail.com. It is free. We answer without undue delay and within the time limit set by the law that applies to your request. We may ask for information to confirm that the request comes from you. The App has no accounts, and analytics data has no name attached, so we may not be able to find your analytics data. Withdrawing consent in the App (section 5.5) stops collection and resets the analytics identifier on your device.

Complaints. We would appreciate the chance to resolve your concern first. You can also complain to the competent data protection authority of Georgia, or to the data protection authority of the country where you live if its data protection law applies to our processing.

14. No automated decisions

We do not make decisions about you based solely on automated processing, including profiling, that have legal or similarly significant effects.

15. Children

The App and the Website are intended for adults (18+). We do not knowingly collect data from children. If you believe a child has sent us personal data, contact us and we will delete it.

16. Security

We limit the data we collect, keep App data on your device where possible, use HTTPS for the Website, and rely on the security measures of our providers. No method of storage or transmission is completely secure. If a data breach affects your data and is likely to cause you significant harm, we will notify you and the competent authority as the law requires.

17. Information for US residents

US state privacy laws such as the California Consumer Privacy Act set thresholds that we do not meet. We give this information voluntarily:

• What we collect: identifiers (IP address, app-instance identifier, email address if you contact us); App usage events and Website page views (only with consent); approximate location derived from the IP address; device information (model, OS version, language). Sources and purposes: sections 3-10.
• No sale or sharing for advertising. We do not sell personal information and do not share it for cross-context behavioural advertising.
• Your requests: you can ask to know, access, correct or delete your data as described in section 13. We will not treat you differently for doing so.

18. Changes to this Policy

We will publish updates at https://executor32.com/privacy-policy and change the "Last updated" date. If a change is material, we will also tell you in the App or on the Website before it takes effect. If a change needs your consent, we will ask for it.

19. Contact

Leonid Gorbarenko, email: executor32.app@gmail.com.