1. Data Controller
The Data Controller responsible for your personal data is:
Itty Bitty Byte LLC
210 Old Graham Hill Rd
Santa Cruz, CA 95060-1427
United States
Email: privacy@led1-wallet.com
Phone: +1 (831) 291-4837
For all privacy-related inquiries, please contact us at the email address above. We will respond within 30 days of receiving your request.
2. Information We Collect
2.1 Information You Provide Directly
- Contact Information: Full name, email address, phone number, and company name when you submit our contact form, request a quote, or communicate with us.
- Project Details: Descriptions of your project requirements, budget preferences, and technical specifications you share through forms or correspondence.
- Communication Records: Emails, messages, and other communications exchanged between you and our team.
2.2 Information Collected Automatically
- Device Information: Browser type and version, operating system, device type, screen resolution.
- Usage Data: Pages visited, time spent on pages, click patterns, referring URLs, and navigation paths.
- Network Data: IP address, approximate geographic location (city/region level), Internet Service Provider.
- Cookie Data: Information collected through cookies and similar technologies as described in our Cookie Policy.
2.3 Information We Do Not Collect
We do not collect sensitive personal data including racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, or biometric data unless explicitly provided by you for project-specific purposes with your express consent.
3. Legal Bases for Processing (GDPR)
We process your personal data under the following legal bases as defined by the General Data Protection Regulation (GDPR):
| Processing Activity |
Legal Basis |
| Responding to contact form submissions and quote requests |
Performance of a contract / Pre-contractual measures (Art. 6(1)(b)) |
| Sending project updates and communications |
Legitimate interest (Art. 6(1)(f)) |
| Processing payments and invoices |
Performance of a contract (Art. 6(1)(b)) |
| Website analytics and performance monitoring |
Consent (Art. 6(1)(a)) |
| Marketing communications and newsletters |
Consent (Art. 6(1)(a)) |
| Legal compliance and dispute resolution |
Legal obligation (Art. 6(1)(c)) / Legitimate interest (Art. 6(1)(f)) |
4. Purpose of Processing
We use your personal data for the following purposes:
- Service Delivery: To respond to your inquiries, provide quotes, and deliver our Android app development services.
- Communication: To send project updates, respond to support requests, and maintain ongoing business relationships.
- Website Improvement: To analyze site usage, improve user experience, and optimize our content and services.
- Legal Compliance: To comply with applicable laws, regulations, and legal processes.
- Security: To detect, prevent, and respond to fraud, security incidents, and technical issues.
- Marketing: To send promotional materials about our services — only with your explicit consent, which you may withdraw at any time.
5. Data Retention
We retain personal data only as long as necessary for the stated purposes or as required by law. Specific retention periods are as follows:
| Data Category |
Retention Period |
| Contact form submissions |
24 months from last communication, unless a contract is established |
| Client project data |
Duration of contract + 5 years for legal compliance |
| Communication records (emails, messages) |
3 years from date of last communication |
| Invoices and financial records |
7 years as required by U.S. tax law |
| Website analytics data |
26 months (anonymized after 14 months) |
| Marketing consent records |
Duration of consent + 3 years |
| Cookie data |
As specified in our Cookie Policy |
Data is retained only as long as necessary for stated purposes or required by law. Upon expiration of the relevant retention period, data is securely deleted or anonymized.
6. International Data Transfers
Your data is primarily stored and processed in the United States. If we transfer personal data outside the United States to countries that have not been deemed to provide an adequate level of data protection, we implement the following safeguards:
- Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses as the primary mechanism for cross-border data transfers to ensure your data receives equivalent protection.
- Data Processing Agreements: All third-party processors are bound by data processing agreements that include appropriate safeguards.
- Adequacy Decisions: Where applicable, we rely on adequacy decisions by the European Commission.
For EU/EEA residents, you may request a copy of the applicable Standard Contractual Clauses by contacting us at privacy@led1-wallet.com.
7. Third-Party Sharing
We do not sell personal data. We do not share data for advertising purposes.
We may share your data with the following categories of third parties, solely for the purposes described in this Policy:
- Service Providers: Hosting providers, email services, analytics platforms, and CRM systems that assist in operating our business.
- Professional Advisors: Lawyers, accountants, and auditors where necessary for legal compliance or business operations.
- Legal Authorities: When required by law, regulation, legal process, or governmental request.
All third-party processors are bound by contractual obligations to process data only as instructed and to maintain appropriate security measures.
8. Your Rights Under GDPR
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under the GDPR:
- Right of Access (Art. 15): You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data.
- Right to Rectification (Art. 16): You have the right to request correction of inaccurate personal data and to complete incomplete data.
- Right to Erasure / Right to Be Forgotten (Art. 17): You have the right to request deletion of your personal data when it is no longer necessary for the purposes for which it was collected.
- Right to Restriction of Processing (Art. 18): You have the right to request restriction of processing in certain circumstances, such as when you contest the accuracy of the data.
- Right to Data Portability (Art. 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
- Right to Object (Art. 21): You have the right to object to processing based on legitimate interests or for direct marketing purposes at any time.
- Right to Withdraw Consent (Art. 7(3)): Where processing is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Lodge a Complaint (Art. 77): You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of alleged infringement.
To exercise any of these rights, please contact us at privacy@led1-wallet.com. We will respond to your request within 30 days.
9. Your Rights Under CCPA
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):
- Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you.
- Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
- Right to Opt-Out: You have the right to opt-out of the sale of your personal information. We do not sell personal data.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
- Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
- Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information.
To submit a CCPA request, please contact us at privacy@led1-wallet.com or call +1 (831) 291-4837. We may need to verify your identity before processing your request.
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption of data in transit (TLS/SSL) and at rest (AES-256)
- Regular security assessments and vulnerability testing
- Access controls and role-based permissions
- Employee training on data protection and security best practices
- Incident response procedures and breach notification protocols
- Secure data backup and disaster recovery systems
Disclaimer: While we strive to protect your personal data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, but we commit to promptly notifying affected individuals and relevant authorities in the event of a data breach as required by applicable law.
11. Children's Privacy
Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal information, please contact us immediately and we will take steps to delete such information.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting a notice on our website and updating the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Itty Bitty Byte LLC
Attn: Data Protection Officer
210 Old Graham Hill Rd
Santa Cruz, CA 95060-1427
United States
Email: privacy@led1-wallet.com
Phone: +1 (831) 291-4837