Privacy Policy

Effective Date: December 3, 2025

Last Updated: December 3, 2025

This Privacy Policy applies to all mobile applications ("Apps") developed and published by Hamza Oucha ("we," "us," or "our"). We are committed to protecting your privacy and being transparent about our data practices.

1. Our Privacy-First Approach

Our Apps are designed with a "Local First" philosophy. This means:

• Your data stays on your device - We do not store your personal data on our servers
• You control your data - All content and settings remain under your control
• Minimal data collection - We only collect data necessary for app functionality

2. Information We Do NOT Collect

Unless explicitly stated otherwise for a specific app, we do not collect:

• Personal identifiers (name, email address, phone number)
• Physical addresses or precise geolocation data
• Browsing history or search history
• User-generated content (notes, photos, documents)
• Device identifiers for advertising purposes
• Biometric data

3. Data Collection by App Type

3.1 Apps That Collect No Personal Data

Some of our Apps function entirely offline and collect no personal information whatsoever. For these apps:

• All data is stored locally on your device
• No analytics or tracking is performed
• No internet connection is required

3.2 Apps with Optional Cloud Sync

Some Apps may offer optional iCloud sync to back up your data across your personal devices. When you enable iCloud sync:

• Data is synced through Apple's iCloud service (governed by Apple's Privacy Policy)
• We do not have access to your iCloud data
• You can disable sync at any time in the app settings

3.3 Apps with Subscriptions or In-App Purchases

Some Apps may offer premium features through subscriptions or one-time purchases. For these transactions, we use third-party services to manage subscriptions and validate purchases:

3.3.1 RevenueCat (Subscription Management)

We use RevenueCat Inc. to manage in-app subscriptions and purchases. RevenueCat collects and processes:

• Purchase history data - Information about your subscription status and purchases
• Anonymous user identifier - A randomly generated ID to manage your subscription across devices
• Device information - Basic device data for subscription validation
• Transaction data - Receipt validation to prevent fraud

Important Notes:

• RevenueCat does NOT receive your payment information (credit card, billing address)
• All payment processing is handled securely by Apple through the App Store
• The user identifier cannot be used to personally identify you
• RevenueCat acts as a data processor on our behalf

RevenueCat Contact:
RevenueCat, Inc.
1032 E Brandon Blvd #3003
Brandon, FL 33511, United States
Email: support@revenuecat.com
Privacy Policy: https://www.revenuecat.com/privacy/

3.3.2 Superwall (Paywall Presentation)

We use Superwall to display subscription offers and manage paywall experiences. Superwall collects:

• Purchase events - When you view or interact with subscription offers
• Anonymous analytics - How users interact with paywalls (to improve the experience)
• Device information - Basic device data for paywall optimization

Important Notes:

• Superwall does NOT collect personally identifiable information
• Superwall does NOT track users across apps for advertising
• All data collected is used solely for app functionality and analytics
• Superwall acts as a data processor on our behalf

Superwall Contact:
Superwall (Nest 22, Inc.)
Email: support@superwall.com
Privacy Policy: https://superwall.com/legal/privacy-policy

3.3.3 Apple StoreKit (Payment Processing)

All purchases are processed through Apple's App Store using StoreKit:

• Apple handles all payment information securely
• We never receive your credit card or billing information
• Transaction processing is governed by Apple's Privacy Policy

3.3.4 Data Processing Summary for Purchases

When you make a purchase or subscribe:

1. Apple processes your payment - Your payment information stays with Apple
2. RevenueCat validates the receipt - Ensures the purchase is legitimate
3. Superwall tracks the conversion - Helps us optimize the subscription experience
4. Your app unlocks features - Based on validated entitlements

At no point do we receive personally identifiable payment information. All services use anonymous identifiers and encrypted connections.

3.4 Apps That Collect Anonymous Usage Data (Future)

Some future Apps may collect anonymous analytics to improve performance and fix bugs. When this applies:

• Data is anonymized and aggregated - it cannot be used to identify you
• Examples include: app crash reports, feature usage statistics, performance metrics
• You can opt-out of analytics in the app settings or your device's privacy settings
• We may use Apple's built-in analytics framework, which is governed by Apple's privacy policies

3.5 Apps That Require Account Creation (Future)

If a future App requires account creation, we will:

• Clearly disclose what information is required (e.g., email address)
• Explain why the information is needed
• Provide options to delete your account and associated data
• Update this policy with specific details about that app's data practices

4. Third-Party Services Summary

Our Apps may integrate with the following third-party services:

We do NOT use:

• Third-party advertising networks
• Social media tracking SDKs (Facebook, TikTok, etc.)
• Third-party analytics beyond Apple's built-in tools
• Data brokers or selling services

5. How We Use Information

Any data collected through third-party services is used solely for:

• Providing and improving our Apps - Ensuring features work as intended
• Subscription management - Verifying your purchase status to unlock premium features
• Fraud prevention - Validating purchases to prevent unauthorized access
• Customer support - Responding to your questions and troubleshooting issues
• App optimization - Understanding which features are used and improving user experience
• Legal compliance - Complying with applicable laws and responding to legal requests

We do NOT:

• Sell your data to third parties
• Use your data for advertising or marketing purposes
• Share your data with third parties except as described in this policy
• Track you across other apps or websites

6. Data Storage and Security

• Local storage: Most app data is stored only on your device using iOS secure storage mechanisms
• iCloud storage: If you enable sync, data is encrypted and stored in your personal iCloud account
• Third-party servers: RevenueCat and Superwall store purchase-related data on secure servers (AWS) in the United States
• Our servers: We do not maintain user databases or store personal information on our own servers
• Encryption: All data transmitted to third-party services is encrypted using industry-standard TLS/SSL protocols
• Security measures: We and our service providers follow industry best practices to protect data

7. Data Retention

• Local data: Remains on your device until you delete the app or manually clear the data
• iCloud data: Stored in your iCloud account according to your iCloud storage settings
• RevenueCat data: Purchase history and subscription status are retained as long as you have an active subscription, then for accounting purposes as required by law
• Superwall data: Anonymous analytics data is retained for app optimization purposes
• Support communications: Emails sent to our support address may be retained for customer service purposes

8. Your Rights and Choices

You have the following rights regarding your data:

8.1 Right to Access

You can access your data at any time within the app. Since we don't store your personal data on our servers, most information is already in your possession on your device. To access purchase data stored by RevenueCat, contact us at privacy@hamzaoucha.com.

8.2 Right to Deletion

To delete your data:

• Delete the app from your device - this removes all local data
• Disable iCloud sync (if enabled) - go to iOS Settings > [Your Name] > iCloud > [App Name] and toggle off
• Delete iCloud data - go to iOS Settings > [Your Name] > iCloud > Manage Storage > [App Name] > Delete Data
• Request deletion of RevenueCat data - contact us at privacy@hamzaoucha.com and we will request deletion from RevenueCat
• Cancel subscriptions - go to iOS Settings > [Your Name] > Subscriptions and cancel

Note: Some purchase records may need to be retained for legal and accounting purposes even after deletion requests.

8.3 Right to Opt-Out

• Analytics: Disable in iOS Settings > Privacy > Analytics & Improvements
• iCloud Sync: Disable in the app's settings menu
• Personalized paywalls: Contact us to request exclusion from paywall optimization experiments

8.4 Right to Portability

Since your app data is stored locally on your device or in your personal iCloud account, you already have full control and portability of your data. For purchase history stored by RevenueCat, contact us at privacy@hamzaoucha.com to request a copy.

9. Children's Privacy

Our Apps are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us immediately at privacy@hamzaoucha.com and we will delete it promptly.

10. International Data Transfers

Our third-party service providers (RevenueCat and Superwall) store data on servers located in the United States. By using our Apps, you consent to the transfer of your purchase-related data to the United States.

Both RevenueCat and Superwall have implemented appropriate safeguards for international data transfers, including:

• Standard Contractual Clauses (SCCs) for EU data transfers
• GDPR-compliant Data Processing Agreements
• SOC 2 Type II security certifications

If you use iCloud sync, your data may be transferred to Apple's data centers according to Apple's Privacy Policy.

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know: What personal information we collect (see Section 3)
• Right to delete: Request deletion of your personal information (see Section 8.2)
• Right to opt-out of sale: We do not sell personal information
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights

To exercise these rights, contact us at privacy@hamzaoucha.com.

12. European Union/EEA Privacy Rights (GDPR)

If you are located in the European Union or European Economic Area, you have additional rights under the General Data Protection Regulation (GDPR):

• Right to access: Request a copy of your personal data
• Right to rectification: Correct inaccurate personal data
• Right to erasure: Request deletion of your personal data
• Right to restrict processing: Limit how we use your personal data
• Right to data portability: Receive your data in a machine-readable format
• Right to object: Object to certain types of data processing
• Right to withdraw consent: Withdraw consent at any time where processing is based on consent
• Right to lodge a complaint: File a complaint with your local data protection authority

Legal Basis for Processing:

• Contract performance: Processing subscription data to provide premium features you purchased
• Legitimate interests: Fraud prevention, app optimization, and customer support
• Consent: Optional features like analytics (can be withdrawn in settings)

To exercise these rights, contact us at privacy@hamzaoucha.com.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, third-party services, or for legal, operational, or regulatory reasons. When we make changes:

• We will update the "Last Updated" date at the top of this policy
• For material changes, we may notify you through the App or via email (if we have your email)
• Continued use of the App after changes constitutes acceptance of the updated policy

We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: