1. Introduction
Cosmic Brokkoli UAB (“Cosmic Brokkoli”, “we”, “us”, “our”) is the developer of Orbital Studio (the “App”), an Android application that lets users design, edit and preview watch faces for Wear OS devices.
This Privacy Policy explains how the App handles information. The short answer is that it does not: Orbital Studio does not collect, transmit or store personal data. Everything you create with it stays on your device.
The App has no user accounts, no server backend and no online synchronisation. It is designed to work entirely offline, apart from the standard functions of the Android and Wear OS operating systems, which are provided by Google and are outside our control.
This Policy is published in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Lithuanian Law on Legal Protection of Personal Data, and the Google Play Developer Program Policies, including the User Data policy and the Data safety declaration requirements.
It applies exclusively to the Orbital Studio Android application. Other Cosmic Brokkoli products and our website are covered by their own notices.
By using the App you acknowledge this Privacy Policy. If you do not agree with it, please do not use the App.
2. Data Controller
Although no personal data is processed through the App, the entity responsible for the App and for this Privacy Policy is:
Cosmic Brokkoli UAB
J. Savickio g. 4-7, LT-01108 Vilnius
Lithuania
Email: privacy@cosmicbrokkoli.com
Website: https://cosmicbrokkoli.com
Developer of record on Google Play: Cosmic Brokkoli UAB.
Because the App performs no processing of personal data, the appointment of a Data Protection Officer under Art. 37 GDPR is not required. All privacy enquiries can be sent to the email address above.
3. Information We Do Not Collect
Orbital Studio does not collect, request, generate, transmit, sell or store any personal data. There is no Cosmic Brokkoli server, endpoint or telemetry channel to which the App could send information.
Specifically, the App does not include and does not use:
accounts, login, registration or authentication of any kind
names, email addresses, phone numbers or postal addresses
user profiles or user-related records
passwords or credentials
any database, whether on a device we control or on a server
cloud storage, backend services or online synchronisation
upload of your files to our systems, or download of content from our systems
analytics SDKs of any kind (Firebase Analytics, Google Analytics or equivalents)
crash or performance reporting SDKs (Crashlytics or equivalents)
advertising, ad networks, ad SDKs or sponsored content
the Android Advertising ID (AAID) or any other advertising identifier
tracking, cross-app tracking, cross-device tracking or fingerprinting
cookies, web beacons or similar technologies
persistent hardware identifiers (IMEI, MAC address, serial number)
location data, whether precise or approximate
contacts, calendar, call logs, SMS or messages
microphone or camera capture sent anywhere off the device
health, fitness or biometric data
push notifications or messaging services
social login (Google, Facebook, Apple or others)
external APIs or third-party web services
profiling or automated decision-making within the meaning of Art. 22 GDPR
Because we hold no personal data, we cannot identify you, we cannot contact you, and we cannot link any use of the App to you.
4. Local Storage
Everything you produce with Orbital Studio - watch face projects, layouts, styles, colours, complication configuration, imported images and preview assets - is stored exclusively in the local storage of your device, either inside the private application directory of the App or in a location that you explicitly choose.
This data never leaves your device through the App. We have no access to it: it is not readable by us, not mirrored to any server, and not shared with any third party.
You remain in full control of it at all times:
you can edit or delete individual projects inside the App
you can remove all locally stored App data from Android Settings, by clearing the storage of the App
you can delete everything permanently by uninstalling the App
Uninstalling the App removes its local data from the device, with the exception of files that you deliberately exported to shared storage or to another location outside the App. Those files remain yours to manage.
Transfer to your watch. When you install or preview a watch face on a paired Wear OS device, the transfer takes place locally between your phone and your watch through the Android and Wear OS system components provided by Google. Cosmic Brokkoli is not part of that exchange and receives nothing from it.
Device backup. If you have enabled Android Auto Backup or a Google account backup on your device, the Android operating system may include App data in your own Google backup. This is a function of Android and of your Google account settings, not of Orbital Studio: we neither request it nor receive access to it. Such backups are governed by the Google Privacy Policy and can be disabled in your device settings.
5. Permissions
Android permissions are requested only when a feature needs them, only at the moment that feature is used, and only for local processing on your device. Declining a permission may disable the related feature, but never prevents you from using the rest of the App.
The permissions the App may request, and the sole purpose of each, are the following:
| Permission | Why the App may request it |
|---|
| Photos and media (READ_MEDIA_IMAGES on Android 13+, READ_EXTERNAL_STORAGE on older versions) | Import images from your device to use them as backgrounds or elements of a watch face. Images are read locally and are never uploaded. |
| Files chosen by you (Android photo picker and Storage Access Framework) | Open and save watch face project files in a folder you select. The App accesses only the files you pick, for as long as needed. |
| Write to storage (WRITE_EXTERNAL_STORAGE, Android 10 and earlier only) | Save exported watch face files to a location of your choice on the device. |
| Bluetooth and paired device access (BLUETOOTH_CONNECT and Wear OS system components) | Detect your paired Wear OS watch and install or preview a watch face on it. The exchange is local, between your phone and your watch. |
| Notifications (POST_NOTIFICATIONS, Android 13+) | Show local status messages generated on the device, such as an export or installation that has completed. These are not push notifications: no message is sent from any server. |
| Internet (INTERNET) | Declared where the Android and Wear OS system components and Google Play distribution require it. Orbital Studio does not contact any Cosmic Brokkoli server and does not upload your content. |
6. Third Party Services
Orbital Studio does not use any third-party service, SDK or library to collect personal data.
In particular, the App does not integrate:
Firebase, in any of its products
Google Analytics or Google Analytics for Firebase
Firebase Crashlytics or any other crash reporting service
Google AdMob or any other advertising or monetisation network
attribution, install-referrer or mobile-measurement SDKs
social network SDKs or social login providers
remote configuration, feature-flag or A/B testing services
third-party performance monitoring or session recording
third-party cloud storage or content delivery services
Third-party components that are included in the App, such as open-source user interface and graphics libraries, run entirely offline on your device and transmit no data.
Two platform relationships must be named explicitly, because they are not controlled by us:
Google Play. Distribution, installation, updates and, where applicable, billing are handled by Google. Google processes the related data as an independent controller under the Google Privacy Policy. From the Google Play Console we receive only aggregated and anonymised statistics - for example install counts, ratings, country, device and Android version breakdowns, and platform-level stability clusters - which do not allow us to identify individual users.
Android and Wear OS. Pairing your watch, installing a watch face on it and rendering it are performed by operating system components provided by Google, under Google policies and your device settings.
We are not responsible for the data practices of Google or of your device manufacturer. You can review the Google Privacy Policy at https://policies.google.com/privacy.
We do not sell, rent, licence, trade or otherwise disclose personal data to third parties, and we could not do so, because we hold none.
7. Children’s Privacy
Orbital Studio is a design tool intended for a general audience. It is not directed to children and it is not published in the Google Play Families programme.
Because the App collects no personal data at all, it collects no personal data from children either. This is true regardless of the age of the user.
We do not knowingly collect information from anyone, including children under 13, or under the higher age threshold set by national law in several EU and EEA states pursuant to Art. 8 GDPR, which may be up to 16.
The App contains no advertising, no tracking, no in-app data collection and no user-generated content shared with other users.
Parents and guardians who have questions about the App may write to privacy@cosmicbrokkoli.com.
8. Security
Because no data is transmitted to us or stored on our infrastructure, the classic risks of a personal data breach on our side - server intrusion, database exfiltration, credential theft - do not apply to Orbital Studio.
The content you store locally is protected by the security model of your own device:
the Android application sandbox, which prevents other applications from reading the private files of the App
device encryption, enabled by default on current Android versions
your screen lock: PIN, password, pattern or biometrics
On our side, we apply secure development practices, review the third-party dependencies we include, keep the App free of network calls to our own systems, and sign every release with our developer key so that Google Play can verify its authenticity.
We recommend that you keep your screen lock enabled, keep Android and the App up to date, and install the App only from Google Play or another official channel.
No method of electronic storage is completely secure. If your device is lost, stolen, rooted or otherwise compromised, data stored locally may become accessible to others. We cannot recover, restore or remotely delete data that never left your device.
9. Your Rights under the GDPR
The GDPR grants you the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection (Art. 21) and withdrawal of consent (Art. 7).
With respect to Orbital Studio, these rights have no data to be exercised upon: we hold no personal data about you, so there is nothing for us to disclose, correct, export, restrict or delete.
You keep direct and immediate control over the content on your device. Deleting a project inside the App, clearing the App storage or uninstalling the App is the practical equivalent of erasure, performed by you, instantly.
You are not subject to automated decision-making or profiling under Art. 22 GDPR.
No international data transfer takes place, because no data is transferred at all. Consequently, no adequacy decision or Standard Contractual Clauses are required.
If you contact us by email, we will process your email address and the content of your message for the sole purpose of answering you, on the basis of Art. 6(1)(f) GDPR, our legitimate interest in responding to enquiries. We delete such correspondence once it is no longer needed for that purpose.
You have the right to lodge a complaint with a supervisory authority. In Lithuania this is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI), L. Sapiegos g. 17, LT-10312 Vilnius, ada@ada.lt. You may also complain to the authority of your country of residence or place of work.
10. Data Safety Declaration on Google Play
For transparency, our Data safety declaration in the Google Play Console mirrors this Policy:
no data is collected by the App
no data is shared with third parties
no data types are transferred off the device by the App
the question of encryption in transit does not arise, because nothing is in transit
no account or data deletion request mechanism is needed on our side, since no data reaches us; the data on your device is deleted by you at any time
If a future version of the App ever changes this, we will update both this Privacy Policy and the Data safety declaration before that version is released.
11. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to the App, to our practices, or to legal and store requirements.
When we do, we will revise the “Last updated” date at the top of this page and publish the new version at this same address.
Material changes, and in particular any change that would introduce the collection of data, will be announced inside the App and in the release notes on Google Play. Where the law requires it, we will ask for your consent before such a change takes effect.
Continued use of the App after an updated Policy has been published constitutes acknowledgement of that update.
12. Contact Information
For any question, request or complaint concerning this Privacy Policy or the App:
Cosmic Brokkoli UAB
J. Savickio g. 4-7, LT-01108 Vilnius
Lithuania
Privacy enquiries: privacy@cosmicbrokkoli.com
Website: https://cosmicbrokkoli.com
Application: Orbital Studio, watch face designer for Wear OS.
We answer privacy enquiries without undue delay and in any case within one month, in accordance with Art. 12(3) GDPR.