PRIVACY POLICY – ALL IN ONE APPLICATION
1. WHO WE ARE
SL 1637 CONSULT AGENCY LTD, a private company limited by shares, incorporated and registered in the Republic of Cyprus under company registration number HE 435853, with its registered and principal place of business at 110 Gladstonos Street, House of Spartas, 3032 Limassol, Cyprus (hereinafter referred to as the “Company”, “we”, “us” or “our”), acts as the data controller and is responsible for the processing of personal data disclosed by you when you make use of our services through the application “All in One” (the “Application”).
We may operate through offices or affiliated entities located in Cyprus. References to the “Company”, “we” or “us” in this Privacy Policy mean the legal entity responsible for determining the purposes and means of processing your Personal Data in connection with the Application.
This Privacy Policy applies to the “All in One” mobile application (the “Application”), which is owned and operated by the Company. The Application was technically developed by David Lekveishvili (the “Service Provider”), acting as a data processor on behalf of the Company, unless otherwise stated. The Application is provided free of charge and on an “AS IS” basis.
The Company respects your privacy and is committed to protecting your Personal Data, in compliance with Regulation (EU) 2016/679 (the “GDPR”) and applicable Cyprus data protection laws.
2. INFORMATION COLLECTION AND USE
The Application collects information when you download, access, and use it. This information may include:
- Your device’s Internet Protocol (IP) address;
- Application usage data, including pages viewed, time and date of access, and time spent within the Application;
- Device and technical information, including mobile device type, operating system, and version.
Such data is processed to ensure the functionality, security, and improvement of the Application, as well as for analytics and performance monitoring.
3. LOCATION DATA
The Application does not collect precise (real-time) location data of your mobile device.
However, the Application may collect approximate location data, derived from your IP address or device settings, for the following purposes:
- Geolocation Services: to provide localized or personalized content and functionality;
- Analytics and Improvements: to analyse aggregated usage patterns and improve the performance and functionality of the Application;
- Third-Party Services: anonymised and aggregated location data may be shared with external service providers solely for optimisation and analytics purposes.
You may disable location permissions at any time through your device settings.
4. PERSONAL DATA PROVIDED BY YOU
For an enhanced user experience, the Service Provider may request that you provide certain Personal Data, including but not limited to:
- Username;
- Telephone number;
- User identification number (User ID).
Such Personal Data is processed on the legal basis of performance of a contract and/or your consent, and is retained only for as long as necessary for the purposes set out in this Privacy Policy.
5. THIRD-PARTY ACCESS AND DISCLOSURES
Only aggregated and anonymised data is periodically transmitted to third-party services to assist in improving the Application.
The Application uses third-party services that maintain their own privacy policies, including but not limited to:
The Company encourages you to review the privacy policies of these third-party providers.
The Service Provider may disclose Personal Data:
- where required by law or regulatory obligation;
- where disclosure is necessary to protect legal rights, user safety, or to investigate fraud or security incidents;
- to trusted service providers acting under contractual confidentiality and data protection obligations, and solely for the purposes instructed by the Company.
6. LEGAL BASIS FOR PROCESSING
Personal Data is processed on one or more of the following legal bases:
- Your consent;
- Performance of a contract;
- Compliance with legal obligations;
- Legitimate interests of the Company, provided such interests are not overridden by your fundamental rights and freedoms.
7. DATA RETENTION
The Service Provider retains Personal Data only for as long as you use the Application and for a reasonable period thereafter, unless a longer retention period is required or permitted by law.
You may request deletion of your Personal Data at any time by contacting info@sl1637.com. Requests will be handled without undue delay and in accordance with applicable law.
8. YOUR RIGHTS
Subject to applicable law, you have the right to:
- Access your Personal Data;
- Request rectification or erasure;
- Restrict or object to processing;
- Data portability;
- Withdraw consent at any time;
- Lodge a complaint with the Cyprus Office of the Commissioner for Personal Data Protection.
9. OPT-OUT RIGHTS
You may stop all information collection by the Application by uninstalling it using the standard uninstall procedures available on your device or application marketplace.
10. CHILDREN’S PRIVACY
The Application is not intended for use by individuals under the age of 16.
The Company and the Service Provider do not knowingly collect, use, or process Personal Data of children under the age of 16. No part of the Application is directed at or designed to attract children, and the Company does not permit registration or use of the Application by minors.
If the Company or the Service Provider becomes aware that Personal Data of a child under the age of 16 has been collected without valid parental consent, such Personal Data will be deleted without undue delay, in accordance with applicable data protection laws.
If you are a parent or legal guardian and believe that a child under the age of 16 has provided Personal Data through the Application, please contact us immediately at david.lekveishvili.work@gmail.com so that appropriate action can be taken.
11. SECURITY
The Service Provider implements appropriate technical and organizational measures to safeguard Personal Data against unauthorized access, alteration, disclosure, or destruction. We may share your personal data with our trusted third-party service providers, who, on our behalf, operate, maintain, and/or support our Application.
12. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be updated from time to time. Material changes will be communicated through the Application or by other appropriate means. Continued use of the Application constitutes acceptance of the updated Privacy Policy.
13. EFFECTIVE DATE
This Privacy Policy is effective as of 26 January 2026.
14. YOUR CONSENT
By using the Application, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your Personal Data as described herein, unless another legal basis applies.
15. CONTACT US
If you have any questions regarding this Privacy Policy or data protection practices, please contact:
info@sl1637.com
To enable us to process your request, please contact us using the registered email address you disclosed and registered with us. We may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorized access requests and comply with our security obligations.
If you have any questions or want more details about how we use your data, you may contact us at the above contact details, and we will be happy to provide you with further details.
If, following your request to us, we are unable to provide you with a satisfactory answer, then you may complain with the local data protection supervisory authority. The data protection supervisory authority in Cyprus is: the Commissioner for Data Protection P.O. Box 23378, 1682 Nicosia, Cyprus- www.dataprotection.gov.cy
We would however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner, so please contact us in the first instance.