Privacy Policy
Last updated: August 4, 20261. General Information
PDF Reader - Minimal is a minimalist Android app for viewing PDF files on your device. This policy explains, in plain language, what information the app handles, who is responsible for it and what rights you have.
2. Data Controller
The data controller is:
Cayetano López
Email: minimarizumx@gmail.com
Spain, European Union
We do not have a data protection officer (DPO), as we are not required to appoint one under Article 37 GDPR.
This policy is governed by the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and, in Spain, by Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD).
3. Information We Collect
1. Your PDF files (never seen by us). PDF files are opened and rendered exclusively on your device. We cannot see, read, upload or store the content of your documents. The app only keeps a local history of recently opened files, stored on your device.
2. Advertising data (Google AdMob). The app shows ads served by Google AdMob. When ads are shown, Google may process personal data such as: device identifiers (including the Android Advertising ID), IP address and approximate location, technical and diagnostic data, and data about your interactions with ads. Google is the data controller for this data; we only receive aggregated, anonymized reports.
3. Payments. You can pay to remove ads through Google Play. Payments are processed entirely by Google Play, which may process your payment and billing data. We do not see or store your payment information.
4. Purpose of Processing
Your data is processed for the following purposes:
- Core app function: processing your data exclusively on your device so the app works (nothing leaves your device).
- Advertising: showing ads and measuring their performance.
- Payments: processing purchases (remove ads) through Google Play.
- Fraud prevention: protecting the advertising ecosystem.
5. Legal Basis
Advertising: personal data for advertising is processed by Google, which is the data controller for AdMob ads, based on your consent (Article 6(1)(a) GDPR). In the EU/EEA, the UK and Switzerland, consent is requested before personalized ads are shown, through the consent dialog provided by Google’s User Messaging Platform (UMP) integrated in the app. If you do not give consent, personalized ads will not be shown. You can change or withdraw your consent at any time through the consent options in the app or Google’s ad personalization settings (adssettings.google.com); this does not affect the lawfulness of processing carried out before withdrawal.
Core app function: the app processes data locally on your device, which is necessary for the performance of the contract with you (Article 6(1)(b) GDPR).
Payments: purchases are processed by Google Play under its own terms and privacy policy.
6. Data Sharing and International Transfers
We do not sell personal data. We only share data with the providers strictly necessary for the app to work:
- Google (AdMob): receives the ad-related data described in section 3. Google may transfer this data to the United States. Google is certified under the EU-U.S. Data Privacy Framework, recognized by the European Commission through an adequacy decision, and additional safeguards (standard contractual clauses) apply. Google Privacy Policy
- Google Play: processes your payments and purchase data on its own behalf.
7. Data Retention
Data on your device: the data stored by the app on your device (usage statistics, recently opened files, recordings, settings) remains on your device until you clear the app’s data or uninstall it.
Advertising data: Google determines the retention periods of ad-related data in accordance with its data retention policy. Google Data Retention Policy
Payment data: Google Play retains payment data for the periods required by law.
8. Children
Our apps are rated PEGI 3, but they are not specifically directed at children.
In the European Union, data processing for advertising requires consent. Below the age of consent — 14 years in Spain and up to 16 in other EU member states — consent must be given or authorized by the holder of parental responsibility (Article 8 GDPR and, in Spain, Article 7 LOPDGDD). The consent dialog provided by Google applies these age rules automatically.
Our apps do not collect or transmit children’s personal data to us: all data handled by the app stays on the device. Google, as the controller of advertising data, applies its own safeguards for minors.
9. Your Rights
Under the GDPR you have the right to access, rectify or erase your personal data, to restrict or object to its processing, to data portability, and to withdraw your consent at any time.
Because our apps store data only on your own device and never send it to us, you can exercise these rights directly: clear the app’s data or uninstall it from the Android settings.
For advertising data, processed by Google as its controller, use Google’s controls (reset your Advertising ID in Android settings, manage consent in the app, or adssettings.google.com).
You also have the right to lodge a complaint with a supervisory authority: in Spain, the Spanish Data Protection Agency (AEPD), or the authority of your country of residence.
10. Automated Decision-Making and Profiling
Advertising platforms such as Google AdMob use automated processes to decide which ads to show you, based on the data described in section 3. This means your user profile may be used to select ads relevant to you (profiling). You can disable this at any time by withdrawing your consent or managing your ad personalization settings (adssettings.google.com).
We do not carry out automated decisions that produce legal effects or significantly affect you.
11. Changes to This Policy
We will update this policy when necessary — for example, if we change how data is processed or add new features. We recommend reviewing it periodically. If a change requires your consent, we will ask for it.
12. Contact Us
For any question about this policy, your data or your rights, contact us at: minimarizumx@gmail.com