01 At a glance
The short version above covers how we operate. The sections below explain the details in full, in the order you're most likely to care about them.
02 Who we are
This Privacy Policy is issued by [LEGAL ENTITY NAME] ("we," "us," or "our"), the developer and publisher of the mobile applications listed on our website (together, the "Apps") and the website at [WEBSITE URL] (the "Website").
For the purpose of applicable data protection laws, [LEGAL ENTITY NAME] acts as the data controller of any personal data processed under this policy.
Our contact address is [POSTAL ADDRESS] and our privacy contact email is [PRIVACY EMAIL].
03 Scope of this policy
This policy applies to:
- The use of our iOS Apps, including all features, in-app purchases, and supporting services.
- The Website and any subdomains operated by us.
- Any communications between you and us, such as support emails.
This policy does not apply to third-party services, websites, or applications that may be linked to from our Apps or Website. When you interact with those services, their own privacy policies apply.
04 Information we collect
We collect only what is necessary to operate and improve the Apps. In practice, this falls into a small number of categories.
Information you provide directly
When you use our Apps, you may enter content such as expense records, word lists, notes, tags, settings, and preferences. We refer to this as "App Content." App Content is stored locally on your device, and — if you choose to enable iCloud sync — in your own iCloud account.
Information you send us
If you contact us by email or through the contact form on our Website, we will receive your email address and any information you choose to include in your message. We use this only to respond to you.
Purchase information
If an App offers paid features or in-app purchases, those transactions are handled entirely by Apple through the App Store. We receive only anonymous, aggregated sales data from Apple. We do not receive your credit card number, billing address, or full Apple ID.
Diagnostic information (optional)
If you have opted in to sharing diagnostic data with Apple on your device, Apple may share crash reports and performance metrics with us through its standard developer tools. These reports do not contain personally identifying information, and we use them solely to find and fix bugs.
Website analytics (if applicable)
The Website may use a privacy-respecting analytics tool to measure aggregate visitor numbers. If used, this tool does not set tracking cookies, does not collect personally identifying information, and does not share data with advertisers. The specific tool in use (if any) is listed in the Third-party services section.
05 Information we do not collect
To make things clear, here is what we do not collect:
- We do not collect your name, address, or phone number unless you voluntarily include it in a message to us.
- We do not track your location.
- We do not access your contacts, calendars, photos, microphone, or camera unless a specific feature requires it, and only after you grant permission on your device.
- We do not build advertising profiles, and we do not share any data with advertisers.
- We do not use third-party analytics SDKs (such as Facebook SDK, Google Analytics for apps, or similar) inside our Apps.
06 How we use information
Where we do process information, we use it only for the purposes described below:
- To provide the Apps. Your App Content is processed on your device so the Apps can function — for example, to display your expenses, sort your word lists, or generate your statistics.
- To sync across your devices. If you enable iCloud sync, your App Content is stored in your iCloud account so it is available on your other Apple devices. This happens through Apple's CloudKit service; we do not have access to the content.
- To respond to you. When you contact us, we use your email address and message to answer your question.
- To fix bugs and improve the Apps. Aggregated crash reports and diagnostic data help us identify and resolve issues.
- To comply with the law. We may process information where we are required to do so by applicable law, including to respond to lawful requests from public authorities.
Under data protection laws such as the EU General Data Protection Regulation (GDPR) and the UK GDPR, our legal bases for processing personal data are: (a) the performance of our contract with you (providing the Apps you have chosen to use), (b) our legitimate interests in maintaining, securing, and improving the Apps, and (c) your consent, where required (for example, for optional features).
07 iCloud & on-device storage
By default, all of your App Content is stored locally on your device. If you enable iCloud sync in the Apps, your App Content is also stored in your iCloud account using Apple's CloudKit service.
When using iCloud sync:
- Your data is stored in your own iCloud container, under your Apple ID.
- Data is transmitted and stored according to Apple's security and privacy standards, including encryption in transit and at rest.
- We do not have access to your iCloud content. We can read only anonymous, aggregate statistics provided to us by Apple (for example, the total number of active users).
You can turn iCloud sync off in your device's iCloud settings at any time, and delete iCloud data by managing storage for the App in your Apple ID settings.
08 Third-party services
We rely on a small number of third-party services to operate. Each of them has its own privacy policy, which you should review separately.
- Apple Inc. — for App Store distribution, in-app purchases, iCloud storage, and developer diagnostic reports. See apple.com/legal/privacy.
- [HOSTING PROVIDER] — for serving the Website.
- [EMAIL PROVIDER] — for receiving support email at our contact address.
- [ANALYTICS PROVIDER, IF ANY] — for privacy-respecting aggregate visitor counts on the Website.
We do not use any third-party service inside our Apps for behavioural advertising, marketing profiling, or cross-site tracking.
10 Data retention
We retain personal information only for as long as needed for the purposes described in this policy:
- App Content is retained on your device (and in your iCloud account if enabled) for as long as you keep it there. You can delete it from within the App or by uninstalling the App.
- Support emails are retained for as long as needed to respond to your enquiry, and for a reasonable period afterwards for record-keeping and quality purposes — typically [NUMBER] months.
- Aggregate and anonymous data may be retained indefinitely, because it cannot be used to identify you.
11 Security
We take reasonable technical and organisational measures to protect information against loss, misuse, and unauthorised access. These include using HTTPS for all Website traffic, storing App Content within Apple's secure iOS sandbox, and relying on Apple's iCloud infrastructure for synced data.
No system is perfectly secure, however, and we cannot guarantee absolute security. If we become aware of a security incident that affects your personal information, we will notify you and the relevant authorities where required by law.
12 Children's privacy
Our Apps are not directed at children under the age of [13 / 16, depending on jurisdiction]. We do not knowingly collect personal information from children in this age group. If you believe that a child has provided us with personal information, please contact us using the details below so we can take appropriate action.
13 Your rights
Depending on where you live, you may have specific rights with respect to your personal information. These may include:
- The right to access the personal information we hold about you.
- The right to correct inaccurate or incomplete information.
- The right to request deletion of your personal information.
- The right to restrict or object to our processing of your personal information.
- The right to data portability — receiving your information in a machine-readable format.
- The right to withdraw consent where we rely on consent to process your information.
- The right to lodge a complaint with a data protection authority.
Because most App Content stays on your device, you can exercise most of these rights directly in the App — by editing or deleting your own content, or by uninstalling the App. For any information we hold centrally, such as support correspondence, please contact us at [PRIVACY EMAIL] and we will respond within the timeframes required by applicable law (typically within 30 days).
California residents
If you are a resident of California, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information we collect about you, the right to request deletion, and the right to opt out of the "sale" or "sharing" of personal information. We do not sell or share personal information as those terms are defined under California law.
14 International users
Our Apps and Website are operated from [COUNTRY]. If you use the Apps from outside [COUNTRY], you understand that your information may be transferred to, stored in, and processed in [COUNTRY], as well as in the countries where our third-party service providers operate.
Where personal information is transferred outside of the European Economic Area, the United Kingdom, or other regions with data protection laws, we rely on appropriate legal mechanisms — such as Apple's own data protection framework or Standard Contractual Clauses — to protect your information.
15 Changes to this policy
We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. If the changes are material, we will provide additional notice — for example, through an in-App announcement or a note on our Website — before the changes take effect.
Your continued use of the Apps or Website after changes take effect constitutes your acceptance of the updated policy.
16 Contact
If you have any questions about this Privacy Policy or about how your personal information is handled, please get in touch. We read every message, and we aim to reply within a few working days.