PRIVACY POLICY – NAMORA Last updated: 3 March 2026 1. CONTROLLER Controller: Jens Allmer Hochschule Ruhr West, University of Applied Sciences Institute for Measurement Engineering and Sensor Technology Medical Informatics and Bioinformatics Duisburger Str. 100 Building 02, floor 1, room 118 45479 Mülheim an der Ruhr Germany Email: info@allinapps.de No Data Protection Officer (DPO) has been appointed. 2. SCOPE This Privacy Policy applies to the Namora Progressive Web App (PWA) and the related web services used to provide account management, name search and exploration, synchronization across devices, and community-driven name intelligence features. 3. CATEGORIES OF PERSONAL DATA Depending on how Namora is used, the following categories of personal data may be processed: Account and profile data: - Email address (used for authentication) - Optional first name, additional given names, last name, nickname - Birth year, gender identity, base locale - Profile settings and search preferences Name exploration data: - Names collected by the user ("babied" names) - Names excluded by the user, including optional exclusion reasons - Search history and interaction events (e.g. dictionary searches, card dealing) - Tool-specific settings such as letter preferences and filters Crowd-sourced name data: - Names searched for but not found in the dictionary (contributed anonymously to improve the database) - Names entered in user profiles or exclusion lists that are not in the dictionary - This data is collected to identify missing names for future dictionary enrichment - No AI or automated profiling is applied to this data without explicit user consent Technical data: - Necessary server-side logs required to operate the service - Daily request quota counters - Local device storage used for offline functionality 4. PURPOSES AND LEGAL BASES Personal data are processed for the following purposes and legal bases: - Provision of the Namora service, including account management, name search, and synchronization Legal basis: Art. 6(1)(b) GDPR (performance of a contract) - Improvement of the name database through crowd-sourced contributions Legal basis: Art. 6(1)(f) GDPR (legitimate interest in improving service quality) - Security, abuse prevention, fair usage enforcement, and service integrity Legal basis: Art. 6(1)(f) GDPR - Compliance with legal obligations Legal basis: Art. 6(1)(c) GDPR 5. LOCAL STORAGE AND SYNCHRONIZATION User preferences, search settings, and name selections are synchronized with the server to enable cross-device use and persistence. 6. DATA SHARING AND PROCESSORS Personal data are shared only to the extent necessary to operate the service, with the following processors: - Supabase (authentication and database hosting, EU region) No personal data are sold. 7. INTERNATIONAL DATA TRANSFERS Where service providers process data outside the European Economic Area, appropriate safeguards such as Standard Contractual Clauses (SCCs) are used in accordance with GDPR requirements. 8. DATA RETENTION AND DELETION Users may delete their account at any time. - Upon deletion, personal data are removed without undue delay. - Crowd-sourced name contributions (anonymous aggregated data) may be retained for dictionary improvement purposes, as they do not constitute personal data once anonymized. 9. CHILDREN Namora is designed to help parents and families select baby names. Where minors use the service, this should occur with parental or legal guardian consent where required by applicable law. 10. USER RIGHTS Users have the right to: - Access their personal data - Rectification of inaccurate data - Erasure of personal data - Restriction of processing - Data portability - Lodge a complaint with a supervisory authority Requests may be sent to: info@allinapps.de 11. SECURITY Appropriate technical and organizational measures are implemented to protect personal data. However, no method of transmission or storage is completely secure. 12. CHANGES TO THIS POLICY This Privacy Policy may be updated from time to time. The date at the top of the document indicates the most recent version.