Privacy Policy

Last updated: 30 June 2026

Blue Tail Labs d.o.o. ("we", "us", "our") operates the CouponExchange mobile application (the "App"). This policy explains what personal data we collect, why we collect it, and your rights under the General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 2018–2023.

1. Data controller

Blue Tail Labs d.o.o.
Email: info@bluetaildevelopment.com

2. What we collect and why

Device install ID — a randomly generated UUID created on first launch and stored on your device. We use this to create an anonymous account so you can upload vouchers and earn trade credit without registering. Legal basis: performance of contract (Art. 6(1)(b) GDPR).
Session token — a short-lived token stored on your device that authenticates your requests to our server. Legal basis: performance of contract.
Voucher barcode data — the barcode content of Dunnes Stores vouchers you scan and submit. We store this to make your voucher available for another user to claim. Legal basis: performance of contract.
Trade credit ledger — a record of credits earned (upload) and spent (claim), linked to your anonymous account. Legal basis: performance of contract.
Timestamps — when your account was created, when vouchers were uploaded or claimed. Used for fraud detection and system integrity. Legal basis: legitimate interests (Art. 6(1)(f) GDPR).

We do not collect your name, email address, phone number, location, or payment information unless you explicitly choose to link an Apple account in a future version of the App. We do not run third-party analytics or advertising SDKs.

3. How long we keep your data

Your data is kept for as long as your account is active. When you delete your account, all associated data (install ID, session tokens, uploaded vouchers, credit ledger) is permanently deleted within 30 days. We do not retain any data beyond that period unless required by Irish law.

4. Who we share your data with

We do not sell, rent, or share your personal data with third parties except:

our hosting and database infrastructure provider, who process data on our behalf under a data processing agreement; and
when required by law or a court order.

5. Data transfers outside the EEA

We aim to host all data within the European Economic Area. If any transfer outside the EEA is necessary, we will rely on the European Commission's standard contractual clauses or another lawful transfer mechanism.

6. Your rights

Under GDPR you have the right to:

Access — request a copy of the data we hold about you.
Rectification — ask us to correct inaccurate data.
Erasure — ask us to delete your data. You can also do this directly in the App via Settings → Delete account.
Restriction — ask us to pause processing while a dispute is resolved.
Portability — request your data in a structured, machine-readable format.
Object — object to processing based on legitimate interests.

To exercise any of these rights, email us at info@bluetaildevelopment.com. We will respond within 30 days. You also have the right to lodge a complaint with the Data Protection Commission of Ireland.

7. Account deletion

You can delete your account at any time from within the App (Settings → Delete account) or by submitting a request at https://couponexchange-api-production.up.railway.app/account/delete. Deletion is permanent and takes effect within 30 days.

8. Security

We use industry-standard measures including encrypted connections (HTTPS/TLS), hashed session tokens, and access controls. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

9. Children

The App is not directed at children under 13. We do not knowingly collect data from anyone under 13. If you believe a child has provided us with personal data, contact us and we will delete it promptly.

10. Changes to this policy

We may update this policy from time to time. Material changes will be notified via the App. Continued use after the effective date constitutes acceptance of the updated policy.

11. Contact

Questions or concerns: info@bluetaildevelopment.com