Privacy Policy
This Privacy Policy explains how your personal data is collected, used, and protected when you use the redu mobile application and the redu.md website. It is provided in accordance with the Law on Personal Data Protection of the Republic of Moldova (LP195/2024, in force from August 23, 2026) and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Data Controller and Data Protection Officer
Data Controller:
- Legal name: Societate cu Raspundere Limitata "CREATIVE CRAFTS"
- IDNO: 1021600036940
- Address: Moldova, Municipiul Chișinău, Trușeni, Str. Ghidighici 34
- Email: info@redu.md
Data Protection Officer (DPO):
Our designated DPO can be contacted at dpo@redu.md for any questions or requests relating to the processing of your personal data or the exercise of your rights.
2. Information We Collect
redu is designed with privacy in mind. We collect minimal data necessary to provide the service. redu does not require an account. We do not collect your name, phone number, or precise location.
2.1 Information You Provide
You may optionally send feedback through the app, which may include a message and your device type. You may also optionally provide your email address in the feedback form if you wish to receive a reply. Submitting feedback is entirely voluntary.
2.2 Automatically Collected Information
- Device identifier (client_guid): A unique identifier generated by the app, used for analytics and API authentication. This is not linked to your personal identity.
- Technical headers (X-redu-Client): With each API request, the app sends your platform type, app version, locale, and screen density to ensure proper service delivery.
- Search queries: Your search terms may be logged server-side to improve search quality.
- Usage analytics: Anonymous data such as app opens, feature usage, and crash reports, collected via Firebase Analytics.
2.3 Data Not Collected
Your shopping lists, favorites, preferences, and search history are stored locally on your device only and are not transmitted to our servers. We do not collect personal identification data such as name, phone number, precise location, or payment information.
3. Purposes and Legal Basis for Processing
| Purpose | Data processed | Legal basis |
|---|---|---|
| Deliver the app and its features (search, compare, display prices) | Device identifier, technical headers | Legitimate interest — necessary to operate the service you requested |
| Improve search quality | Search queries (anonymized) | Legitimate interest — improve the service for all users |
| Analytics, bug fixing, and crash reporting | Usage analytics, crash reports (via Firebase Analytics) | Legitimate interest — maintain, secure, and improve the app |
| Respond to your feedback | Feedback message, optional email address | Consent — implied by your voluntary submission |
Where processing is based on legitimate interest, we have assessed that our interest does not override your fundamental rights and freedoms, given that the data collected is minimal, non-identifying, and necessary for core app functionality.
Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent, contact dpo@redu.md.
4. Data Retention
- Device identifier (client_guid): Retained while you actively use the app. Deleted upon request.
- Search queries: Retained for up to 12 months, then anonymized or deleted.
- Feedback messages: Retained for up to 24 months or until resolved, whichever comes first.
- Analytics data: Retained for up to 24 months, in accordance with Firebase Analytics retention settings.
You may request deletion of your data at any time by contacting dpo@redu.md.
5. Data Sharing and Processors
- Google LLC (Firebase Analytics): Processes anonymous usage analytics and crash reports on our behalf. Google acts as a data processor under a data processing agreement. Google's privacy policy: policies.google.com/privacy.
No other third parties receive your personal data.
6. International Data Transfers
Our application servers are located in the Republic of Moldova. However, Firebase Analytics data may be processed by Google on servers located in the United States or other countries. These transfers are governed by Google's data processing terms, which include Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an adequate level of data protection as required by LP195/2024 and the GDPR.
7. Data Storage and Security
Your shopping lists, favorites, and preferences are stored locally on your device and are not transmitted to our servers. For data that is transmitted (analytics, feedback), we use industry-standard encryption (TLS) in transit and access controls at rest. However, no method of electronic transmission or storage is 100% secure.
8. Cookies and Tracking
The redu mobile app does not use cookies. Our website (redu.md) may use essential cookies for functionality. See our Cookie Policy for details.
9. Children's Privacy
redu is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact dpo@redu.md and we will delete it promptly.
10. Your Rights
- Right of access (Art. 15): Request confirmation of whether your data is being processed and obtain a copy.
- Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17): Request deletion of your personal data when it is no longer necessary or when you withdraw consent.
- Right to restriction (Art. 18): Request that we restrict the processing of your data in certain circumstances.
- Right to data portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format.
- Right to object (Art. 21): Object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact our DPO at dpo@redu.md. We will respond within 30 calendar days. If your request is complex, we may extend this period by a further 60 days, with prior notification.
11. Right to Lodge a Complaint
- Centrul Național pentru Protecția Datelor cu Caracter Personal (CNPDCP)
- Address: str. Serghei Lazo 48, MD-2004, Chișinău, Republic of Moldova
- Website: datepersonale.md
We encourage you to contact our DPO first at dpo@redu.md so we can attempt to resolve your concern directly.
12. Automated Decision-Making
redu does not use automated decision-making or profiling that produces legal effects or similarly significant effects on you. Price comparisons and "Best Prices" calculations are deterministic algorithms applied to publicly available retailer data, not to your personal data.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. For material changes, we will make reasonable efforts to notify you through the app. Continued use of the app after changes constitutes acceptance of the revised policy.
14. Contact Us
For general inquiries: info@redu.md
For data protection inquiries: dpo@redu.md
Postal address: SRL "CREATIVE CRAFTS", Str. Ghidighici 34, Trușeni, Municipiul Chișinău, Republic of Moldova