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
Company Number: [To be added]
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

We collect anonymous analytics to understand how people use CountDelight and improve it:

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

All analytics are anonymous and cannot be linked to you personally.

B. Technical and Device Information

• Device Type: iPhone model, iPad model
• Operating System: iOS version
• App Version: Which version of CountDelight you're using
• Device Identifiers: Anonymous advertising ID (you can reset this in iOS settings)
• Language and Region: For localization purposes

C. Purchase Information

• Transaction Records: Premium feature purchases (processed entirely by Apple)
• Subscription Status: Whether you're a Premium subscriber
• Note: We don't receive or store your payment details—Apple handles all payments

D. Crash and Performance Data

• Crash Reports: Technical information when the app crashes
• Error Logs: Details about errors to help us fix bugs
• Performance Metrics: App speed and responsiveness data

3.3 Data Collection Summary Table

Data Type	Purpose	Linked to You?
Your Countdown Content	We don't collect this	N/A - Not collected
Usage Analytics	Improve app features	No - Anonymous
Device Information	Compatibility & support	No - Anonymous
Crash Reports	Fix bugs and errors	No - Anonymous
Purchase Data	Enable Premium features	Via Apple ID only

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
• ❌ Use your countdown content for advertising
• ❌ 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 Analytics Services

Firebase Analytics & Crashlytics (Google)

• Purpose: App usage analytics and crash reporting
• Data Collected: Anonymous usage patterns, device info, crash logs
• Privacy Policy: Google Firebase Privacy

PostHog

• Purpose: Product analytics and feature usage tracking
• Data Collected: Anonymous usage events, session data
• Privacy Policy: PostHog Privacy

6.2 Advertising Services

Google AdMob (Free Version Only)

• Purpose: Display ads to support free version
• Data Collected: Device identifiers, ad interactions
• Personalized Ads: Based on your iOS advertising preferences
• Control: Manage in iOS Settings → Privacy → Advertising
• Remove Ads: Upgrade to Premium for ad-free experience
• Privacy Policy: Google Privacy

6.3 Apple Services

CountDelight integrates with Apple's ecosystem:

• iCloud: Optional data sync to YOUR iCloud account
• Apple Calendar: Optional calendar integration (requires your permission)
• Apple Notifications: Countdown alerts and reminders
• Siri & Shortcuts: Voice commands and automation
• StoreKit: In-app purchases (processed by Apple)
• Widgets: Home screen and lock screen widgets

Apple's Privacy Policy applies: Apple Privacy

6.4 Third-Party Disclaimer

We carefully select third-party services, but we're not responsible for their privacy practices. We recommend reviewing their privacy policies. Third-party services may change without notice.

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
• Advertising ID: Reset or disable in iOS Privacy 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