NETBLOCK PRIVACY POLICY

Last updated: January 16, 2026

NetBlock (the “App”, “NetBlock”, “we”, “us” or “our”) is a parental-control and device supervision application developed and operated by Kinga Stefania Rudnicka in collaboration with LGL Skylink Technologies (together: the “Data Controllers”). This Privacy Policy describes how the Data Controllers collect, use, store, disclose and protect personal data processed in connection with NetBlock and the services provided through the App (the “Services”).

This Privacy Policy is part of NetBlock’s Terms of Service and applies to parents who install and manage the App and to the children and other users of devices supervised through the App (collectively, “Users”). By using NetBlock, you accept the practices described in this Privacy Policy.

SUMMARY

What we do: NetBlock allows parents to supervise devices they own or lawfully control to monitor app usage, enforce app and website blocks, and receive device location and blocking notifications.
Who is responsible: Data Controllers: Kinga Stefania Rudnicka & LGL Skylink Technologies.
Core data we process from supervised devices: app usage time; installed apps list; app block events; website block events; GPS location; device metadata (model, OS); system notifications generated by NetBlock; device identifiers (Android ID / FCM token / instance ID).
Parent data we collect: parent email for account management and support.
We do NOT collect: contacts, messages (SMS or chat content), photos, videos, raw audio recordings, clipboard contents, social media messages, full browsing history or search queries.

A. DATA CONTROLLERS, CONTACTS, AND DPO

Data controllers: Kinga Stefania Rudnicka and LGL Skylink Technologies. They jointly determine the purposes and means of processing the personal data described in this Policy.
Contact: +855 96 739 8820
Email: privacy@netblock.app

B. SCOPE & APPLICABILITY

This Policy applies to the personal data processed in connection with: (i) parent account registration and management; (ii) the supervision and monitoring of devices registered by a parent (the “Monitored Devices”); and (iii) data processed to provide customer support, billing, notifications and secure storage. The App is intended for use by parents who install and configure the App on devices they lawfully control. Data collection from a child’s device occurs only after the parent gives explicit consent and completes the mandatory in-app consent flow.

C. WE COMPLY WITH CHILDREN’S PRIVACY LAW

NetBlock is a parental control tool and not a child-directed consumer service. Where a child under the applicable age threshold is involved, NetBlock will only collect personal data from the child’s device after verifiable parental consent is obtained. Parents are responsible for ensuring they have the lawful authority to supervise the target device.

D. CATEGORIES OF DATA WE PROCESS

D.1 Data collected from Monitored (child) devices

App usage time: collected to present usage reports to the parent and enforce usage rules.
Installed apps list: collected to allow parents to view and block installed applications.
App block events: log of when NetBlock blocked an app (timestamp, app identifier).
Website block events: log of attempted blocked websites (domain only; parent-facing summary).
GPS location: device location reported to parent when enabled for location tracking.
Device metadata: device model, OS version, and minimal environment info to support compatibility and troubleshooting.
System notifications generated by NetBlock: internal notifications such as “app blocked” used for parent alerts.
Device identifiers: Android device ID, app instance ID, or FCM token (used for device linking, push notifications and to uniquely identify devices for parent linking and to ensure correct notification routing).
Aggregate usage metrics: (such as total daily screen time or app category summaries) generated from the data listed above.

D.2 Data collected from Parents / Account Owners

Parent email address: mandatory for account creation, authentication, password reset, billing communications, and customer support correspondence.
Billing information: where applicable, only necessary billing metadata. Payment card details are processed by our payment provider (ABA PayWay) and are not stored on our servers.

D.3 Data we do NOT collect

NetBlock does NOT collect, process or store the following from Monitored Devices or parent accounts:
- Contacts.
- SMS / other messaging content (SMS, MMS, in-app messages).
- Photos or videos.
- Audio recordings (raw microphone recordings).
- Clipboard contents.
- Social media messages.
- General browsing history URLs (we may record domain or categorized data for blocking purposes only, and only when the parent enables web monitoring where available).
- Full device usage telemetry. We only collect per-app usage durations required for parental reports.
- Any other personal data not explicitly listed above.

E. PURPOSES AND LEGAL BASIS FOR PROCESSING

We process data only to provide the Services and for limited, compatible purposes:
- Provisioning and operation of the Services (account management, device linking, app blocking, website blocking).
- Delivering notifications and alerts to parents (FCM).
- Billing and payment processing (via ABA PayWay).
- Security, fraud prevention and abuse detection.
- Customer support and troubleshooting (Zendesk).
- Compliance with legal obligations.
We do not use data for advertising, profiling for ads, or sell personal data to third parties.

F. THIRD-PARTY SERVICE PROVIDERS (SUBPROCESSORS)

Primary subprocessors:
Microsoft Azure - hosting and storage (data residency: see below).
Firebase Cloud Messaging (FCM) - push notifications only; no analytics enabled.
Zendesk - customer support ticketing.
ABA PayWay - payment gateway and transaction processing.
We do not use analytics or crash reporting SDKs such as Firebase Analytics, Firebase Crashlytics, Sentry, or similar.

G. DATA RETENTION, DELETION, AND ACCOUNT TERMINATION

Retention period: We retain parent account data and Monitored Device records only as long as the parent’s account is active and necessary to provide the Service. Historical logs are retained for 12 months for operational needs and fraud prevention.
On account deletion: When the parent deletes their account via Account → Delete Account & Data, we permanently delete all associated Monitored Device data, logs, location history, and parent account data from active systems and scheduled backups within a maximum of 90 days (or provide your actual backup deletion timeframe). Deletion is irreversible.
Legal hold: Where legally required, we may retain certain data for longer to comply with legal obligations or to defend legal claims; in such cases we will notify the parent if required by law.

H. DATA SUBJECT RIGHTS

Parents / data controllers and data subjects have rights including, subject to verification, the right to: access, correct, port, restrict processing, object to processing, and request erasure of personal data. To exercise rights, contact: privacy@netblock.app. We will respond to verifiable requests in accordance with applicable law and within the timelines required by the relevant legal framework.

I. SECURITY

We implement administrative, technical and physical safeguards to protect personal data, including:
- Encryption in transit (TLS) and encryption at rest for stored data.
- Role-based access control and logging for internal access.
- Regular security testing and vulnerability management.
- Limited access to support staff and subprocessors on a need-to-know basis.
In case of a security breach affecting personal data, we will notify affected parties and regulators as required by applicable law.

J. INTERNATIONAL DATA TRANSFERS

NetBlock may use cloud infrastructure or service providers that store or process data outside the user’s country. When personal data is transferred internationally, we apply appropriate safeguards, which may include the use of European Union Standard Contractual Clauses (SCCs), data-processing agreements, and other legally recognized mechanisms. Where applicable, we also implement additional technical and organizational measures to protect the data during transfer and processing.

K. ACCESSIBILITY, DEVICE ADMIN & VPN DECLARATIONS

K.1 Accessibility Service & Data Usage

Netblock uses the Android Accessibility Service to provide parental control and child safety features. This service operates in the background to enforce parental controls in real time, such as blocking restricted apps, applying schedules, and tracking usage duration while the device is in use. By tapping "Agree" (in NetBlock mobile application), you explicitly consent to NetBlock accessing, collecting, using, and handling the following data:

   1. App Activity Data

• Inventory of Installed and Active Applications

• What: App name, package name, and status (whether an app is installed, opened, closed, blocked, or currently running in the foreground).

• Purpose: To populate the list of apps in the Parent Dashboard, allowing the guardian to view the device inventory and choose which specific apps to permanently block, schedule, or monitor.

• App Launch Attempts

• What: Detection of the exact moment a child attempts to open an app.

• Purpose: To instantly trigger the "Blocked" screen for restricted apps and to notify the parent or guardian of the attempt.

• Foreground App and Website Identification

• What: Identification of the app name or website domain currently visible on screen (NetBlock does not read page content or typed text).

• Purpose: To apply real-time parental restrictions and ensure safety while browsing.

• App Usage Data and Duration

• What: Tracking the duration of active app usage.

• Purpose: To enforce daily screen time limits and apply schedules such as bedtime or study hours, and to generate usage reports for the parent.

   2. Privacy & Safety

• Exclusive Access: Data is only shared with the linked parent/guardian account.

• No Data Sales: We do not sell or share data with third parties for advertising.

• Encrypted Transmission: All data is sent via secure, encrypted connections.

• Exclusions: NetBlock does not collect or record messages, keystrokes, passwords, photos, camera data, or contacts.

   By tapping ‘Agree’, (in NetBlock mobile application) you grant NetBlock permission to use the Android Accessibility Service for the purposes described above. You can withdraw this consent at any time in the Android System Settings.

K.2 Usage Access (PACKAGE_USAGE_STATS)

Used: YES. Required to obtain per-app usage time and to present accurate app usage reports to the parent.

K.3 Device Admin / Device Owner

Used: Device Admin. Required to help prevent unauthorized uninstall of the supervision components and to perform limited security actions when explicitly configured by the parent. Device Admin is not used to remotely wipe devices except when a parent expressly triggers a permitted security action and only to the extent disclosed.

K.4 Display Over Other Apps

Used: YES. To display blocking screens when a restricted app or website is opened.

K.5 VPN

Used: NO. NetBlock does not implement a local or full VPN, does not inspect web content via VPN, and does not rely on VPN for domain blocking. Blocking is implemented via Accessibility and Device Admin mechanisms and as disclosed in the App.

L. PAYMENTS & BILLING

Payments are processed via ABA PayWay. NetBlock does not store raw card numbers on our systems. Payment processors’ own privacy notices and terms apply to payment card handling - parents are directed to payment provider pages during the checkout flow.

M. CUSTOMER SUPPORT & LOGS

Customer support requests are handled via Zendesk. Parents may voluntarily provide additional diagnostic or device information during support interactions; this will only be used to troubleshoot and resolve the issue. Support logs are retained as necessary for case management and then deleted according to our retention schedule.

N. NO ADS / NO THIRD-PARTY ADVERTISING

NetBlock contains no third-party advertising SDKs, does not use collected user data for advertising, and does not sell personal data.

O. SUBPROCESSOR / DETAILED TECHNICAL APP NOTES (APPENDIX)

Microsoft Azure: hosting, storage, database services.
Firebase Cloud Messaging (FCM): push notifications; no analytics enabled.
Zendesk Inc.: support ticketing.
ABA PayWay: payment gateway.

Technical notes: NetBlock records per-app usage durations using Android UsageStats API (PACKAGE_USAGE_STATS). NetBlock uses the Accessibility API for blocking events and to display blocking UI; Accessibility data is not recorded beyond structured block events required for logs and parent notifications. Device identifiers such as Android ID or instance IDs are recorded only to uniquely identify and maintain linkage between parent account and Monitored Device and to route push notifications reliably.

P. DATA PROCESSOR ROLE CLARIFICATION

LGL Skylink Technologies and Kinga Stefania Rudnicka (collectively referred to as “NetBlock”, “we”, or “us”) act as the data controllers for information collected from the parent account.

For Monitored Device data, the parent (account owner) is the data controller, as they decide what information is collected and for what purpose (parental supervision). In this context, NetBlock acts as a data processor, processing Monitored Device data solely on behalf of, and according to the instructions of, the parent account owner.

Q. DATA SUBJECT REQUESTS & HOW TO CONTACT US

To exercise rights (access, correction, deletion, portability, restriction or objection) or to submit privacy inquiries, contact: privacy@netblock.app. Provide sufficient information to verify your identity and the request target (account email, device identifiers, etc.). Verified requests will be handled in accordance with applicable law.

R. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes in our practices, legal requirements or product features. The “Last updated” date at the top will be revised. We will provide notice of significant changes via the App or by email to the parent account contact where required.

S. GOVERNING LAW & DISPUTE RESOLUTION

This Policy shall be governed by the laws of the Kingdom of Cambodia, without regard to conflicts of law principles.

Effective Date: November 24, 2025

Last Updated: January 16, 2026