Privacy Policy

1. Introduction and Company Information

CountDelight ("we," "our," or "us") is a product of Sanctuary Moon Ltd, an Irish registered company committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect information when you use our mobile application ("App").

Company Details:

Product Name: CountDelight
Parent Company: Sanctuary Moon Ltd
Registered in: Ireland
Registered Address: Ireland
Email: hello@countdelight.com
Data Protection Contact: hello@countdelight.com

As an Irish company, we comply with the General Data Protection Regulation (GDPR), Irish Data Protection Act 2018, and all applicable EU data protection legislation.

2. Our Privacy-First Philosophy

2.1 What Makes Us Different

Unlike most apps, CountDelight is designed so that:

• No Server Storage: We don't store your countdown data on our servers
• No Access to Your Content: We cannot see your countdown titles, dates, descriptions, notes, or any personal information you enter
• Local-First Architecture: Your data lives on your device and optionally in YOUR iCloud account
• Minimal Data Collection: We only collect what's necessary for the app to function and improve

3. Information We Collect

3.1 Information We DO NOT Collect

To be crystal clear, we do NOT collect, store, or have access to:

• Your countdown titles, dates, or descriptions
• Your custom tags, categories, or notes
• Any personal events or moments you track
• Photos or attachments you add to countdowns
• Your calendar events or personal data
• Your iCloud data (it's stored in YOUR iCloud account, not ours)

3.2 Information We DO Collect

A. Anonymous Usage Analytics

CountDelight collects anonymous usage analytics to help us understand which features are used and improve the app. The data is captured as discrete event names with no free-text content — never countdown titles, task names, journal content, search queries, or AI prompts. It includes:

• Feature Usage: Which features are used and how often (e.g., "user created a countdown," not "user created 'Birthday Party' countdown")
• Navigation Patterns: Which screens you visit within the app
• Session Data: How long you spend in the app

Analytics are split across two layers:

• On-Device Analytics: A complete local record is stored entirely on your device in a local database. This layer is never transmitted, is automatically deleted after 90 days, and you can disable or wipe it at any time in Settings.
• Anonymous Remote Telemetry (PostHog): A subset of feature-usage events and screen views is sent to PostHog, our analytics provider, so we can see aggregate usage patterns. Each install is identified only by a random UUID generated on your device — not your Apple ID, name, email, or any device identifier. Performance metrics and error reports are not forwarded. This layer is on by default and you can turn it off at any time in Settings → Privacy.

B. Purchase Information

• Transaction Records: Your one-time Pro upgrade purchase (processed entirely by Apple)
• Purchase Status: Whether you have purchased CountDelight Pro
• Note: We don't receive or store your payment details — Apple handles all payments

3.3 Data Collection Summary Table

Data Type	Purpose	Where It Goes
Your Countdown Content	We don't collect this	N/A — Not collected
On-Device Analytics	Understand feature usage	Stays on your device only
Purchase Data	Enable Pro features	Apple (via StoreKit)

4. How We Use Information

4.1 Legitimate Purposes Only

We use collected information solely to:

• Provide App Functionality: Enable countdown creation, notifications, and sync features
• Improve the App: Identify and fix bugs, optimize performance, develop new features
• Understand Usage: Learn which features are popular to prioritize development
• Support You: Help troubleshoot issues when you contact support
• Ensure Security: Detect and prevent fraud, abuse, or security issues
• Legal Compliance: Comply with applicable laws and regulations

4.2 What We DON'T Do With Your Data

• ❌ Sell your data to anyone
• ❌ Rent or trade your information
• ❌ Show advertising of any kind
• ❌ Share your personal data with third parties for their marketing
• ❌ Train AI models on your countdown content

5. Data Storage and iCloud

5.1 Where Your Data Lives

Local Storage (Always)

Your countdown data is stored locally on your device. This data includes:

• All your countdowns, tags, and categories
• App preferences and settings
• This data remains on your device and is not sent to us

iCloud Storage (Optional - Your Choice)

If you enable iCloud sync:

• Your countdown data is stored in YOUR personal iCloud account
• Data syncs across your Apple devices signed into the same iCloud account
• We do not have access to your iCloud data
• Apple's iCloud Terms and Privacy Policy apply
• Requires sufficient iCloud storage space
• You can disable sync anytime in Settings

5.2 Data Security

We implement industry-standard security measures:

• Encryption: Data transmitted over networks is encrypted
• Secure APIs: All communications use secure protocols
• Access Controls: Limited access to systems on a need-to-know basis
• Regular Updates: Security patches and updates

Important: No security system is perfect. You're responsible for keeping your device secure with a passcode/biometric lock and maintaining your iCloud account security.

6. Third-Party Services

6.1 Apple Services

CountDelight integrates with Apple's ecosystem. These integrations use Apple's infrastructure and are governed by Apple's privacy practices:

• iCloud (CloudKit): Optional data sync to YOUR personal iCloud account (Pro feature)
• Apple Calendar (EventKit): Optional two-way calendar integration — CountDelight can read events from and write events to your Apple Calendar. This requires your explicit permission and can be revoked at any time in iOS Settings
• Notifications: Countdown alerts and reminders, delivered through Apple's notification system
• Live Activities (ActivityKit): Optional real-time countdown display on your lock screen and Dynamic Island
• Siri & App Intents: Voice commands and Shortcuts automation
• StoreKit: One-time Pro purchase (processed entirely by Apple)
• WidgetKit: Home screen and lock screen widgets
• Foundation Models (On-Device AI): All AI features currently included with CountDelight Pro run entirely on your device using Apple's on-device models. No data is sent to any server — not even Apple's. Requires a supported device; gracefully unavailable on older hardware. If we ever introduce optional cloud-powered AI features, they will be offered as a separate, opt-in product with their own pricing and a separate data-handling disclosure

Apple's Privacy Policy applies to these integrations: Apple Privacy

6.2 Third-Party Disclaimer

We carefully select third-party services, but we are not responsible for their privacy practices. Third-party services may change their practices without notice to us.

7. Your Privacy Rights and Controls

7.1 In-App Privacy Controls

You have full control over your privacy within CountDelight:

• Analytics: Opt out of usage analytics in Settings
• iCloud Sync: Enable or disable at any time
• Notifications: Control permissions in iOS Settings
• Calendar Access: Grant or revoke in iOS Settings

7.2 Data Rights by Region

For Users in the European Union (GDPR)

You have the right to:

• Access: Request information about data we collect
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data
• Portability: Receive your data in a portable format
• Restriction: Limit how we process your data
• Objection: Object to certain processing
• Complaint: Lodge complaints with supervisory authorities

For Users in California (CCPA)

You have the right to:

• Know: What personal information is collected
• Delete: Request deletion of personal information
• Opt-Out: We don't sell personal information, so nothing to opt out of
• Non-Discrimination: Equal service regardless of privacy choices

Exercising Your Rights

To exercise any of these rights, contact us at hello@countdelight.com. We'll respond within the timeframe required by law (typically 30 days).

8. Data Retention and Deletion

8.1 How Long We Keep Data

• Analytics Data: Retained for up to 14 months
• Crash Reports: Retained for up to 90 days
• Purchase Records: Retained as required by tax laws (typically 7 years)
• Your Countdown Data: We don't store it, so there's nothing to delete on our end

8.2 Deleting Your Data

Delete Countdown Data:

• Local data: Uninstall the app from your device
• iCloud data: Disable iCloud sync and delete from iCloud settings

Delete Analytics Data:

Contact hello@countdelight.com with your request. We'll delete any identifiable data we have within 30 days.

9. Children's Privacy

9.1 Age Requirements

CountDelight is intended for users 13 years and older. We do not knowingly collect personal information from children under 13.

9.2 Parental Notice

If you're a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at hello@countdelight.com. We'll delete such information promptly.

9.3 COPPA Compliance

We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect or solicit information from children under 13.

10. International Data Transfers

10.1 EU-Based Service

CountDelight is operated by Sanctuary Moon Ltd, based in Ireland within the European Union. As an EU-based company, we are subject to the GDPR, one of the world's strongest data protection regulations.

10.2 International Availability

While we are based in Ireland, CountDelight is available worldwide. Analytics and crash data from our third-party providers (Firebase, PostHog) may be processed in different countries, including the United States, where data protection laws may differ.

10.3 Data Protection Safeguards

When our third-party service providers transfer data internationally, they use appropriate safeguards including:

• Standard Contractual Clauses (SCCs) approved by the EU Commission
• Adequacy decisions where applicable
• Other legally recognized data transfer mechanisms under GDPR

10.4 Your Countdown Data

Remember: Your personal countdown data stays on your device or in your iCloud account. We don't transfer it internationally because we don't have access to it.

11. Changes to This Privacy Policy

11.1 Updates

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or app features. When we make material changes, we'll notify you by:

• Posting the updated Policy in the App
• Sending an in-app notification
• Updating the "Last Updated" date at the top

11.2 Your Acceptance

Continued use of CountDelight after changes become effective constitutes acceptance of the updated Privacy Policy. If you don't agree with changes, please stop using the App.

12. Legal Compliance and Disclosure

12.1 When We May Disclose Information

We may disclose information when required by law or to protect rights and safety:

• Legal Obligations: Court orders, subpoenas, or legal processes
• Law Enforcement: Valid government requests
• Safety: Protect rights, property, or safety of users or public
• Fraud Prevention: Detect and prevent fraud or security issues
• Business Transfers: Merger, acquisition, or sale of assets

Note: We can't disclose your countdown data because we don't have access to it.

13. Do Not Track (DNT) Signals

Currently, our App doesn't respond to Do Not Track signals because iOS doesn't provide a standardized DNT implementation. However, you can control tracking through iOS Privacy settings and by opting out of analytics in CountDelight settings.

14. Additional Rights for Specific Regions

14.1 California Residents (CCPA)

California residents may request information about disclosure of personal information to third parties for direct marketing purposes. We don't share personal information with third parties for their direct marketing purposes, so there's nothing to disclose.

14.2 UK Residents (UK GDPR)

UK residents have the same data protection rights as EU residents under UK GDPR. You can exercise your rights by contacting hello@countdelight.com.

14.3 Brazilian Residents (LGPD)

Brazilian residents have data protection rights under Lei Geral de Proteção de Dados (LGPD). Contact hello@countdelight.com to exercise these rights.

15. Contact Us About Privacy

15.1 Privacy Questions

For any privacy-related questions, concerns, or requests, contact us at:

Email: hello@countdelight.com
Support: support@countdelight.com
Website: https://countdelight.com/privacy

15.2 Data Protection Officer

As an Irish company subject to GDPR, we have a data protection contact available at:

Data Protection Contact: hello@countdelight.com
Company: Sanctuary Moon Ltd
Location: Ireland

15.3 Irish Data Protection Commission

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Irish Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland
Website: dataprotection.ie

15.4 Response Time

We strive to respond to all privacy inquiries within 30 days as required by GDPR, or sooner when possible.

16. Security Breach Notification

In the unlikely event of a data breach affecting your information, we will:

• Investigate the breach immediately
• Notify affected users within 72 hours (as required by GDPR)
• Provide details about the breach and steps taken
• Report to relevant supervisory authorities as required