This policy describes how BAUGEY MATHEO, trading as DEVOLIM, processes personal data in connection with the Air Quality mobile application and the website https://airquality.devolim.fr. It is drawn up in accordance with Regulation (EU) 2016/679 of 27 April 2016 (the "GDPR") and French Act No. 78-17 of 6 January 1978 as amended.
In short. The app works without an account: no email, no password, no login identifier. Your cities, settings and history stay on your device — we have no access to them. Your sensitivity profile is kept on your device too; it is never disclosed to advertising networks, and is shared only with audience measurement, which is subject to your consent (§ 4 and § 10). Your location is never sent as-is: it is rounded to the data model's grid before any network request. The free version shows advertising, subject to your consent within the European Economic Area. Payments are handled entirely by Apple or Google: we see neither your identity nor your payment details.
1. Data controller
BAUGEY MATHEO (DEVOLIM)
248 rue de Bègles, 33800 Bordeaux, France
SIREN: 948 000 757
Email: contact.airquality@devolim.fr
Given the nature and scale of the processing, the appointment of a data protection officer is not required under Article 37 GDPR. Any request concerning personal data may be sent to the address above.
2. Design principles
The app was built around data minimisation and data protection by design (Articles 5 and 25 GDPR):
- no account: no sign-up, no authentication, no login identifier, no hosted profile;
- no content server: your cities, history and settings never leave your device;
- location degraded before transmission: coordinates are rounded before any network request (section 5);
- no sale of data, under any circumstances.
3. Data kept on your device
The following information is stored in a database internal to the app and in the system preferences. It is neither transmitted nor hosted by the publisher:
- your cities: name, country and coordinates of the cities you follow, and your home city;
- your history: the air quality readings you have consulted (48 hours in the free version, twelve months with a subscription);
- your alerts: chosen thresholds, city concerned, activation state;
- your settings: language, units, index scale, theme, sensitivity profile (section 4);
- technical usage markers: onboarding completion, counters used for free-tier limits, last known location used to frame the map.
Depending on your phone's settings, this data may be included in your device's native backup (iCloud or Android backup). Such backups are operated by Apple or Google, outside the publisher's control. Uninstalling the app deletes all of this data from the device.
4. Sensitivity profile — health-related data
The app lets you optionally indicate a sensitivity profile (for example "asthma or respiratory condition", "cardiovascular condition", "pregnancy", "young child", "older person", "outdoor sport"). This only adjusts the threshold at which you are alerted; it does not change the readings displayed.
Such information may reveal health-related data, a special category of personal data under Article 9 GDPR. It is entered voluntarily by you, on the basis of your explicit consent (Article 9(2)(a)). It is kept on your device and is sent neither to a content server nor to an advertising network: it is never used to target an ad. When you change this profile, and only then, the list of ticked sensitivities is included in one audience measurement event (§ 10), which is subject to your consent: without consent, no event is sent at all. You can change this profile, or return to "no particular sensitivity", at any time in the app settings.
5. Location
With your permission, the app uses your device's location to show air quality where you are. Permission is requested at the end of the onboarding flow, after a screen explaining what it is for, and never on first launch. It is optional: the app remains fully usable by selecting a city manually.
Your exact coordinates never leave the device. Before any network request, your position is rounded to the data model's grid — in the order of eleven kilometres in Europe and forty-five kilometres elsewhere. The service queried therefore only receives a grid point covering a wide area, never your address. This rounding is also what allows the cache to be shared between users in the same area.
The name of the municipality matching your position is obtained through reverse geocoding, performed by the Apple or Google location services built into the operating system. In France, matching a position to a municipality may also rely on a public administrative-boundaries service. No movement history is built: only the last known position is stored locally, to avoid querying the system on every launch.
You may withdraw location permission at any time in your phone's settings.
6. Relay servers
To query data sources, the app does not contact providers directly but calls stateless relay functions (Firebase Cloud Functions) hosted in the europe-west1 (Belgium) region. These functions receive only rounded coordinates and return the corresponding readings; they cache results per geographic area, for all users, and retain no user identifier, no profile and no content data.
As with any online service, the hosting infrastructure (Google Cloud) generates technical logs that may include the IP address of the request, its timestamp and the response code. These logs, inherent to the operation and security of the service, are kept for a limited period by the infrastructure provider and are not used for profiling.
7. Advertising and consent
The free version is funded by advertising served by Google AdMob (Google Ireland Limited). The formats used are: an opening interstitial (frequency-capped), banners, an in-screen rectangle and a native placement in the ranking. A Premium subscription removes all advertising.
In the European Economic Area, the United Kingdom and Switzerland, ads are preceded by a request for your consent, through Google's messaging platform compliant with the IAB Europe Transparency and Consent Framework (TCF). That message lets you accept or refuse:
- personalised advertising, based on advertising identifiers and usage data;
- and, where applicable, the associated measurement purposes.
If you refuse, the app remains fully usable: ads are then non-personalised, chosen on the basis of content and context, without advertising profiling. Data that Google and its partners may process for these purposes includes the device advertising identifier (IDFA on iOS, Android advertising ID), device type, operating system version, language, an approximate location derived from the IP address, and interactions with ads. Details of this processing, the list of partners and their purposes are available in the consent message itself and in Google's advertising privacy information.
You may change your choices at any time: by resetting or deleting your device's advertising identifier (iOS: Settings → Privacy & Security → Tracking; Android: Settings → Google → Ads), by uninstalling and reinstalling the app, or by writing to contact.airquality@devolim.fr. You can also manage Google ad personalisation at myadcenter.google.com.
Your sensitivity profile (section 4), your alerts and your history are never shared with advertising networks, and no targeting is carried out on the basis of health-related data.
8. App Tracking Transparency (iOS)
On iOS, where required, a tracking authorisation request (App Tracking Transparency) is presented after European consent has been collected. Refusing has no impact on functionality: it only prevents access to the device advertising identifier and therefore ad personalisation. This choice can be changed at any time in Settings → Privacy & Security → Tracking.
9. Subscriptions and in-app purchases
Air Quality Premium is offered as an auto-renewing subscription (monthly or yearly) or as a one-off lifetime purchase. All transactions are handled by the distribution platform: the App Store (Apple Inc.) or Google Play (Google LLC).
The publisher receives neither your identity, nor your address, nor your payment details. Purchase validation and subscription status are handled by RevenueCat, Inc. (United States), a specialist provider interfacing with both stores. RevenueCat processes an anonymous installation identifier, the receipt information supplied by the store (plan, renewal date, status, free-trial eligibility) and technical device data, solely to unlock paid features and prevent fraud. See RevenueCat's policy, Apple's policy and Google's policy. Contractual terms are set out in our subscription terms.
10. Audience measurement
The app uses Firebase Analytics (Google) to measure audience in aggregate form and understand feature usage: app opening, screen views, adding a city, displaying the subscription screen, purchases, changes to the sensitivity profile. The data processed includes an app instance identifier, device model, system version, language and approximate country. Neither your cities nor your readings appear in these events, and no data is sold.
The sensitivity-profile event carries the list of ticked sensitivities (§ 4). That data falls under Article 9 GDPR: it is attached to no advertising identifier, is never disclosed to advertising networks and is used for no targeting whatsoever. Since audience measurement depends on your consent, declining is enough for none of these events to be sent.
11. Crash reports
To detect and fix defects, the app sends crash reports through Firebase Crashlytics (Google): technical stack trace, device model, system and app version. No contact details are included. This collection is disabled in development builds.
12. Remote configuration
Firebase Remote Config allows certain operating parameters to be adjusted remotely (ad frequency, free-tier limits, maintenance messages, minimum required version). This service transmits technical device and version information; it collects no content.
13. Application security
Firebase App Check, relying on App Attest / DeviceCheck (iOS) and Play Integrity (Android), attests that calls to our relay servers come from a genuine installation of the app. This mechanism protects the service against abuse and quota exhaustion; it collects no content and does not identify the user.
14. Notifications
Air quality alerts are produced entirely on your device: a background task periodically retrieves readings for the cities you follow and compares them with your thresholds. The app uses no push notifications: no server knows the content of your alerts, and no notification token is collected or transmitted.
Notification permission is requested when you create your first alert, never at launch. Each alert can be disabled or deleted individually, and permission can be withdrawn at any time in your phone's settings.
15. Home screen widgets
Widgets display the latest known reading for the relevant city. The information required (city name, index, reading time) passes through a local shared storage area between the app and the extension, on your device only. No data is transmitted to a third party for this purpose.
16. Map
The map screen displays base maps supplied by Mapbox, Inc. Loading tiles necessarily involves transmitting to Mapbox the area displayed and the zoom level, together with usual connection data (IP address, device type). See Mapbox's privacy policy. The pollution layer overlaid on the map is produced by our own relay servers (section 6).
17. Website
This website is static and entirely self-contained: it sets no cookies, uses no analytics tool, contains no advertising pixel and makes no request to any third-party service — the web fonts themselves are served from this domain. Visiting it therefore involves no transmission of data beyond the hosting provider, whose technical connection logs are kept for a limited period. When you write to us, your email address and the content of your message are processed solely in order to reply.
18. Legal bases
| Processing | Legal basis (GDPR) |
|---|---|
| Displaying air quality, followed cities, local history | Performance of the contract — Art. 6(1)(b) |
| Use of location (optional) | Consent — Art. 6(1)(a), via the system permission |
| Sensitivity profile (health data) | Explicit consent — Art. 6(1)(a) and 9(2)(a) |
| Alerts and notifications | Consent — Art. 6(1)(a) |
| Personalised advertising | Consent — Art. 6(1)(a) |
| Non-personalised advertising (absent consent) | Legitimate interest in funding the free service — Art. 6(1)(f) |
| Subscriptions and purchase validation | Performance of the contract — Art. 6(1)(b) |
| Audience measurement | Consent — Art. 6(1)(a), and Art. 9(2)(a) for the sensitivity profile (§ 4) |
| Crash reports | Legitimate interest in stabilising the service — Art. 6(1)(f) |
| App security, remote configuration, technical logs | Legitimate interest in security and proper operation — Art. 6(1)(f) |
| Replying to emails | Legitimate interest in handling enquiries — Art. 6(1)(f) |
19. Recipients
| Recipient | Role |
|---|---|
| Google Ireland Limited / Google LLC | Firebase (relay functions, Analytics, Crashlytics, Remote Config, App Check), AdMob advertising, Google Play distribution and billing |
| Apple Inc. | iOS distribution, App Store billing, system location services |
| RevenueCat, Inc. | Subscription management and validation |
| Mapbox, Inc. | Base map tiles |
| Google's advertising partners | Ad delivery and measurement, within the limits of your consent |
The providers of atmospheric and weather data do not appear in this table: they are queried by our relay servers, never by your device, and receive no data about you. No data is sold, rented or transferred for purposes other than those described in this policy.
20. Transfers outside the European Union
The app's relay functions are hosted in the European Union (Belgium). Some recipients (Google, Apple, RevenueCat, Mapbox) may nevertheless process technical data in the United States. Such transfers are covered by the adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework and, additionally, by the standard contractual clauses adopted by the European Commission.
21. Retention periods
- Local data (cities, history, alerts, settings, sensitivity profile): kept while the app is installed; free history is limited to a rolling 48 hours, Premium history to twelve months.
- Relay server cache: a few minutes to a few hours depending on the data, with no link to a user.
- Infrastructure technical logs: a limited period set by the hosting provider, for security purposes.
- Audience measurement: retained by Google according to project settings (14 months by default).
- Crash reports: retained by Google, in the order of 90 days.
- Subscription status: retained by RevenueCat and the relevant store for the duration of the contractual relationship, then in line with accounting and evidential obligations.
- Emails received: three years from the last exchange.
22. Your rights
Under Articles 15 to 22 GDPR, you have the right of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out beforehand.
Exercising your rights directly. Since most of your data is on your device, you remain in control without going through us: delete a city or an alert, or change your sensitivity profile, in the app; withdraw location or notification permission in your phone's settings; reset your advertising identifier; and, for complete and permanent erasure, uninstall the app — all local data is then deleted. Subscribers can also export their history as CSV from the settings, under "My data".
For any other request, write to contact.airquality@devolim.fr. We will reply within one month of receiving the request, which may be extended by two months where the request is complex, in accordance with Article 12(3) GDPR. We may ask for details enabling us to identify the processing concerned; as there is no account, we hold nothing that identifies you in advance.
23. Lodging a complaint
If, after contacting us, you believe your rights have not been respected, you may lodge a complaint with the French data protection authority or with the supervisory authority of your country of residence:
CNIL — 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
www.cnil.fr
24. Security
Exchanges between the app and our relay servers are encrypted (HTTPS/TLS) and protected by App Check. Access keys to data providers are held server-side and never appear in the distributed app. Your local data benefits from the operating system's protection mechanisms, including device encryption where enabled. As no measure can guarantee absolute security, we undertake to notify any data breach in accordance with Articles 33 and 34 GDPR.
25. Minors
The app is not intended for children under thirteen and does not knowingly collect data relating to them. It is not designed as a child-directed app within the meaning of the distribution platforms' rules. If you hold parental responsibility and believe a child has provided us with data, please write to us and we will carry out the necessary deletions.
26. Changes
This policy may change as the app or the applicable regulations evolve. The date of the latest update appears at the top of this page; any substantial change will be brought to your attention in the app or with the next update. The version in force is the one published on this page.
27. Language
This English version is provided for convenience. In the event of any discrepancy, the French version shall prevail.