This Privacy Policy describes how Pavel Ivanov, in the process of incorporating the company BCrypto (the "Controller"), processes the personal data of users of the Q-Audion application (the "Application") during its Beta Test phase, in compliance with the GDPR and Italian Legislative Decree 196/2003 as amended by Decree 101/2018.
1. Data controller
Pavel Ivanov, a natural person, Italian tax code VNVPVL76C22L219M, domiciled at Corso Orbassano 216, 10137 Torino (TO), Italia, reachable at bcrypto@gmail.com. Upon incorporation of BCrypto, the controller role will transfer to the incoming company. Given the current scale of processing, no DPO has been appointed under Art. 37 GDPR.
2. Categories of data, purposes and legal basis
| Category | Examples | Purpose | Legal basis |
|---|---|---|---|
| Account identifiers | User ID, display name, profile picture (end-to-end encrypted) | Account creation and management | Contract |
| Phone number | If provided, stored only as a SHA-256 hash with pepper, never in plaintext. When the User starts the address-book import, the address-book numbers are hashed on the device with SHA-256 and a server-provided pepper (or, if the pepper is unavailable, with plain SHA-256) and only the hashes are sent to match already-registered users; names and plaintext numbers never leave the device and the server does not retain address-book hashes beyond the matching | Discovery of contacts already on Q-Audion | Consent / Contract |
| Communication content | Messages, audio/video calls, attachments | Service delivery | Contract |
| Technical metadata | Sender/recipient, timestamps, delivery status, call type, connection IP | Routing, security | Contract / Legitimate interest |
| Presence data | Online/offline status, last seen | Presence feature | Contract |
| Push notification tokens | Android: Firebase Cloud Messaging (Google). iOS: Apple Push Notification service and PushKit (Apple) | Notification and incoming-call delivery | Contract |
| Diagnostic data | Android: Firebase Crashlytics (Google): crashes, OS/device version. iOS: no third-party service; crash and error reports are produced by in-house components and sent only if the User enables diagnostics in Settings > Privacy | Bug detection | Legitimate interest / Consent (iOS) |
| Email address | Only for accounts registered "with extension and email" (no phone number): account verification and recovery | Account management | Contract |
| Accessory identifier | Only if the User pairs the optional Q-Audion earbuds: accessory identifier associated with the account | Hardware-backed key custody | Contract |
| Abuse reports | Chosen category and identifiers of the reported contact, message or group, transmitted in encrypted form; reviewed within 24 hours | User safety, moderation | Legitimate interest |
| Usage telemetry and operational diagnostics | Only if the User enables "Encrypted operational diagnostics" ("Diagnostica operativa cifrata") in Settings > Privacy (off by default): anonymised usage events (app start, login outcome, call start/end, group events — only the event type and a few technical fields, filtered of identifiers, e-mail and phone numbers) sent over TLS to the Controller's servers, and encrypted operational diagnostics (call-pipeline metrics, WARN-level and above logs) readable only server-side; in addition, only if the User separately enables "Real-time diagnostic logs" (also off by default), redacted application logs (tags, sizes, truncated fingerprints — never keys, tokens or message content) sent over TLS to the Controller's diagnostics backend while the app is in use | Bug detection, Service improvement | Consent |
| Optional VPN tunnel | Only if enabled by the User: connection metadata to the Controller's relay nodes (IP address, connection timestamps, traffic volume), processed transiently; no browsing content | Traffic routing, abuse prevention | Contract / Legitimate interest |
| Voluntary reports | Bug reports, beta feedback | Service improvement | Consent |
| Device integrity | Android: Google Play Integrity / Keystore. iOS: no third-party service | Fraud and tampering prevention | Legitimate interest |
Messages, calls and attachments are protected by end-to-end encryption: the Controller cannot access their plaintext content.
3. Processing methods and security measures
Processing uses IT tools with logic tied to the purposes above. Measures in place: end-to-end encryption of content; cryptographic hashing of phone numbers; encryption in transit (TLS); app and device integrity checks; minimisation of data access.
4. Recipients and data processors
- Server and hosting infrastructure providers for signalling, sync and call-connectivity relay;
- Google Ireland Limited, for Firebase Cloud Messaging, Firebase Crashlytics and Play Integrity (Android app);
- Apple Inc. / Apple Distribution International Ltd., for the Apple Push Notification service and PushKit (iOS app), as an independent controller for notification transit;
- the SMS provider delivering the phone-number verification code, which transiently processes the number in plaintext;
- network infrastructure providers (STUN/TURN relay), which transiently process IP addresses and routing metadata without access to encrypted content.
If the User enables the optional Google Assistant integration for voice-initiated calls or messages, the voice component is processed by Google under its own privacy policy, as an independent controller for that part. The Controller only receives the name and/or number resolved by Google Assistant, used transiently.
If the User enables the optional VPN tunnel, based on WireGuard, the device's traffic is routed through the Controller's relay nodes. The nodes transiently process the connection metadata needed for routing and abuse prevention (IP address, connection timestamps, per-node aggregate traffic volume) and neither inspect nor log browsing content. The device's public IP address is not persistently recorded by the VPN service; the central server keeps the peer registration (client WireGuard public key, node, internal tunnel address) for 24 hours from creation, with automatic removal on expiry, and a register of session tokens (token identifier, user, issue and expiry times, without IP address) for audit purposes, automatically deleted within 24 hours of each token's expiry. Deleting the account immediately removes the User's VPN entitlement, peer registration and tokens, together with the contact fingerprints (hashes) linked to the account.
If the User uses Q-Audion through Android Auto or on a Wear OS smartwatch, those surfaces only render data already present on the phone (contacts, conversations, call state) through Google's Car App Library and Wearable Data Layer on the User's own devices; the Controller collects no additional data through them. Google processes the projection and data-layer transport as an independent controller under its own privacy policy.
Data is not disclosed to third parties for marketing or commercial profiling.
5. Transfers outside the EU
Some processors (notably Google) may process data outside the European Economic Area, based on an adequacy decision (including, where applicable, the EU-U.S. Data Privacy Framework) or the European Commission's Standard Contractual Clauses.
6. Retention period
Account data is kept for the duration of use and deleted, typically within 30 days, after account deletion or the end of the Beta Test. Technical communication metadata is kept for the minimum time necessary, generally no more than 90 days. Diagnostic data follows the provider's terms (Crashlytics), generally no more than 90 days. Anonymised usage events and encrypted operational diagnostics, collected only with the User's consent, are kept for the time strictly necessary for diagnostics: usage events in a fixed-capacity store where the oldest entries are overwritten, encrypted diagnostics in daily files accessible only to the Controller. Metadata of the optional VPN tunnel is processed transiently, except as stated in section 4.
7. Data subject rights
Users have the right to access, rectify, erase, restrict and object to processing, to data portability, and to withdraw consent at any time, by writing to bcrypto@gmail.com. Users may also lodge a complaint with the Italian Data Protection Authority (Garante).
8. Minors
The Application, during Beta Test, is not intended for persons under 18. The Controller does not knowingly collect data from minors and will delete it if it becomes aware of any.
9. Nature of data provision
Providing the data required to create an account is necessary to use the Application. Phone number, push notifications and participation in bug reporting are optional.
10. Automated decision-making
The Controller does not carry out processing based solely on automated decision-making or profiling under Art. 22 GDPR.
11. Changes
The Controller may update this Policy, notifying Users via the Application or by publishing the updated version with its date.
12. Contact
For questions or to exercise your rights: bcrypto@gmail.com.