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Privacy Policy — 3pLevel & 3pLevel Pro

Last updated: 2 November 2026
Effective date: 2 November 2026

This Privacy Policy explains how your information is handled when you use the 3pLevel and 3pLevel Pro applications for iPhone and iPad (together, the "Apps"). It applies to both equally.

The short version: these Apps ask your device for nothing and send nothing anywhere. They request no permissions at all, they have no network features, we run no servers, and we collect nothing about you. The sections below explain this in the detail that data protection law requires.

1. Who we are (Data Controller)

The Apps are published by:

Stooj srl
Via Alfredo Panzini 71, 09045 Quartu Sant'Elena (CA), Italy
VAT no. (P.IVA): 03932870920, REA CA-350185
Share capital: €10,000.00, of which €2,500.00 paid up
Contact for privacy matters: privacy@stooj.co

Stooj srl is the "data controller" for the limited purposes described in this policy. Because the Apps do not send your personal data to us, in practice we hold no personal data about you. We are established in Italy, and this policy is governed by the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Italian data protection law (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Stooj srl has not appointed a Data Protection Officer and is not required to: we carry out no large-scale monitoring of individuals and process no special categories of personal data. Privacy questions go to the address above.

2. Our privacy principles

  • No data collection by us. We operate no backend servers and no accounts. Nothing you do in the Apps is sent to Stooj.
  • No tracking. We do not use analytics SDKs, advertising identifiers, cross-app tracking, fingerprinting, or third-party trackers of any kind.
  • On-device, and nowhere else. Everything the Apps work with, your settings and any picture or model file you choose, stays on your device. The Apps have no network features at all.
  • No permissions requested. The Apps do not ask for location, camera, microphone, contacts, or photo-library access. There is nothing for you to grant or revoke.
  • No selling or sharing. We do not sell, rent, or share your data with anyone, because we do not have it.

3. What the Apps process, and where it goes

3.1 Sensor readings and no location

The Apps are inclinometers. They read your device's accelerometer and gyroscope through iOS's motion framework to show the roll and pitch of your vehicle. Those readings are used live on screen and are not recorded, not stored, and not transmitted anywhere.

The Apps have no location feature. They do not use GPS, they do not show a map, and they never ask for location access. Whatever your device knows about where it is, these Apps do not read it.

3.2 What the Apps store on your device

The Apps keep your settings (such as calibration, alert angles, colours and the vehicle view you chose) in the app's own storage on your device. None of it identifies you and none of it leaves the device.

You can also give the Apps two kinds of file, and only by choosing them yourself:

  • A picture, for example a photo of your vehicle, through iOS's own photo picker. The picker runs outside the App: it hands over only the single image you selected, and the Apps have no access to the rest of your photo library.
  • A 3D model file, through iOS's own document picker, which likewise gives the App only the file you picked.

Both are copied into the app's storage on your device and stay there. Neither is uploaded, analysed, or seen by Stooj. Deleting the App removes them.

3.3 Purchases and the App Store

You obtain the Apps through the Apple App Store. Apple processes your download, payment, and account information as an independent controller under Apple's privacy policy. Stooj never receives your payment details, your card, or your App Store account identity. At most, we may see aggregated, anonymised sales and App Analytics reports from Apple that cannot identify you, and only if you have allowed Apple to share analytics.

The Apps are paid downloads. They contain no in-app purchases of any kind, and they contain no purchase or subscription code.

3.4 When you contact support

If you email our support address (currently support@3pmaster.com) or submit an issue or idea through the in-app link to our support portal, the message and any contact details you choose to provide are handled through Atlassian Jira, which we use to receive, track, and respond to support requests and feedback. Atlassian acts as our data processor under a data processing agreement and processes this information on our behalf, solely so that we can reply to you and improve the Apps. We do not use support details for marketing. This is the one situation in which information reaches Stooj, and only because you chose to contact us.

When you use the in-app Send Feedback link, your mail app opens with a short technical block already filled in (your device model, your iOS version, and the app's name, version and build number) so that we can troubleshoot. It contains no location data and nothing that identifies you. You can see it before you send, and you are free to delete it.

Who receives information, and who does not. Apart from you, only three parties are ever involved:

  • Apple, as an independent controller, for your App Store download. Nothing else about your use of the Apps reaches Apple, because the Apps have no network features. Governed by Apple's own privacy policy.
  • Atlassian, as our data processor, and only for support messages you choose to send us.
  • Stooj srl, the content of those support messages, and nothing else.

No other company, advertiser, analytics provider, or data broker receives anything from the Apps, because the Apps send nothing to them.

4. What we do not collect

Other than information you voluntarily send us when you contact support, the Apps do not collect or transmit to Stooj:

  • your name, email, phone number, or contacts;
  • your account credentials;
  • your precise or approximate location;
  • your settings, or any picture or model file you chose;
  • your payment details or App Store account identity;
  • your photo library, or any image in it other than one you hand to the App yourself;
  • device identifiers, advertising IDs, or usage analytics;
  • crash logs tied to you (any diagnostics you choose to send go to Apple, not to us, and only if you opt in at the iOS level).

5. Legal bases for processing (GDPR Article 6)

Although processing happens on your device rather than on our systems, for transparency the relevant legal bases are:

  • Performance of a contract / provision of the service (Art. 6(1)(b)): processing your settings and any file you chose, on your device, is necessary to provide the features you asked the App to perform.
  • Legitimate interests (Art. 6(1)(f)): when you contact support, handling your message and feedback to answer you and improve the Apps; on our website, hosting it and counting page views, as described in the Website section.

We do not process any special categories of personal data, and we do not carry out profiling or automated decision-making.

You are not obliged to provide anything. The Apps request no permissions, so there is nothing you are asked to grant. Choosing a picture or a model file is entirely optional and the Apps work fully without either. Contacting support is equally voluntary.

6. International data transfers

Except for support correspondence (below) and our website (see the Website section), Stooj does not transfer your personal data anywhere, because we do not receive it.

Where you contact support, the information you send may be processed by Atlassian (Jira) on infrastructure that can be located outside the European Economic Area. Such transfers are covered by the safeguards in Atlassian's data processing terms, including the EU Standard Contractual Clauses. A copy of those Clauses is published with Atlassian's data processing addendum, which applies automatically to our use of their service; you may also request a copy from us at privacy@stooj.co.

7. Data retention

  • On your device: your settings and any file you chose remain until you replace them or delete the App.
  • With Stooj: we retain no personal data about you from ordinary use of the Apps. Support correspondence (emails to privacy@stooj.co or support@3pmaster.com, and issues/ideas submitted through the support portal) reaches us as ordinary email and support tickets. We keep it for as long as it remains useful for handling your request and for context on recurring issues, and we do not delete it on a fixed schedule. You can ask us to delete your support correspondence at any time by writing to privacy@stooj.co, and we will do so unless we still need it to establish or defend a legal claim.

8. Your rights

Under the GDPR you have the rights to access, rectify, erase, restrict, and port your personal data, and to object to processing. Because everything the Apps work with lives on your own device, you can exercise most of these rights directly and immediately: change or remove your settings and any file you chose from within the App, or delete the App to remove all of it.

If you believe Stooj holds any personal data about you, or you have any question about this policy, contact privacy@stooj.co and we will respond within one month (extendable by two further months for complex requests, with notice).

You also have the right to lodge a complaint with your local data protection authority. In Italy this is the Garante per la protezione dei dati personali (www.garanteprivacy.it). You may alternatively contact the supervisory authority in your own EU/EEA country of residence.

9. Children

The Apps are vehicle instruments intended for a general adult audience and are not directed to children. We do not knowingly collect personal data from children. In Italy the age of consent for information society services under Article 8 GDPR is 14; in any case, because the Apps collect no personal data for Stooj, no such data is gathered from users of any age.

10. California residents (CCPA/CPRA)

If you are a California resident, we want to be clear: Stooj does not collect, receive, sell, or share your personal information. We have not sold or shared personal information in the preceding 12 months, and we do not use or disclose sensitive personal information beyond the on-device purposes described above. Because we hold no personal information about you, there is nothing for us to disclose, delete, correct, or limit in response to a request, and we never discriminate against anyone for exercising their privacy rights. Everything associated with the Apps resides on your own device, under your control.

11. Website

Our website (3plevel.com) does not use cookies, advertising, embedded Google services, or third-party trackers, and it stores nothing on your device.

To count page views and see how quickly pages load, we use Cloudflare Web Analytics, and only for visitors outside the European Union. If you visit from the EU, the analytics script is not loaded at all. For other visitors, a small script loaded from Cloudflare sends Cloudflare the address of the page you are viewing, the page that linked to it, your browser and operating system type, your country, and the page's loading times. It uses no cookies or other storage on your device and does not identify you. We see only totals. Cloudflare keeps the detailed data for about a week and the totals for up to six months.

Cloudflare also hosts the site, for every visitor. Like any web host, it receives your IP address when your browser asks for a page, and uses it only to deliver the site and keep it secure. For hosting and analytics alike, Cloudflare acts as our data processor, and our legal basis is our legitimate interest in running the site and knowing which pages are read and which load slowly (Art. 6(1)(f) GDPR). Cloudflare may process this data in the United States, under its certification to the EU-U.S. Data Privacy Framework, with the EU Standard Contractual Clauses as a fallback.

12. Security

Because everything stays on your device, its security is protected by Apple's device-level encryption and by the passcode or biometric protection you set on your device. We recommend keeping your device software up to date.

13. Changes to this policy

We may update this policy to reflect changes to the Apps or to legal requirements. When we do, we will change the "Last updated" date above and, for material changes, note it within the Apps or on our website. Continued use of the Apps after an update means you accept the revised policy.

14. Contact

Questions about privacy or this policy:

Stooj srl, privacy@stooj.co

Copyright 2026 Stooj srl. All Rights Reserved.

P.IVA 03932870920