Privacy Policy

Last updated: 2025-01-01

1. Introduction and Scope

This Privacy Policy governs the processing of personal data by TIDYCUSTOMS ("we", "us", "our" or the "Data Controller") in connection with the CleanStart mobile application (the "App").

This Policy applies to all users of the App and describes how we collect, use, store, and protect personal data in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation - "GDPR")
• Directive 2002/58/EC (ePrivacy Directive), as amended
• Applicable national data protection laws in EU Member States

By using the App, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

3. Legal Basis for Processing

We process personal data based on the following legal grounds under Article 6(1) GDPR:

• Article 6(1)(b) - Contract: For providing the core functionality of the habit tracking service.
• Article 6(1)(a) - Consent: For optional push notifications.

4. Categories of Personal Data Collected

4.1 Data Stored Locally on Device

The App operates entirely offline. All data is stored exclusively on your device and is never transmitted to our servers or any third parties:

• Habit names and descriptions
• Habit tracking history and statistics
• Custom habit icons and colors
• Daily cost and time estimates
• Reset events and personal notes
• Achievement badges and milestones
• App preferences (theme, currency settings)
• Scheduled notification times

4.2 No External Data Collection

The App:

• Does not collect analytics data
• Does not use crash reporting services
• Does not require internet connection
• Does not create user accounts
• Does not use cookies or tracking technologies
• Does not access location data
• Does not share any data with third parties

4.3 Device Permissions

Notification Permission (optional):

• Used solely to display local notifications on your device for:
  • Daily motivational quotes (8:00 AM)
  • Weekly progress summaries (Sunday 6:00 PM)
  • Achievement milestones
• All notifications are generated locally without any external communication.

5. Purpose of Data Collection

We process personal data stored on your device for the following purposes:

1. Service Provision: To enable core app functionality including habit tracking, progress monitoring, and achievement systems.
2. Personalization: To customize the app experience based on your preferences.
3. Local Notifications: To remind and motivate you in your habit journey (only with your consent).

6. Data Recipients and Transfers

6.1 No Third-Party Access

Since the App operates entirely offline: no data is transmitted to our servers, shared with third parties, processed by external services, or leaves your device.

6.2 No International Transfers

As all data remains on your device, there are no international data transfers under Chapter V GDPR.

7. Data Retention

All app data is retained on your device until you delete the app, clear app data through device settings, or use the in-app "Delete All Data" function. We have no access to delete or retrieve your data.

8. User Rights Under GDPR

You have the following rights under Articles 15-22 GDPR, which you can exercise directly in the app:

1. Right of Access (Article 15): View all your data directly in the app.
2. Right to Rectification (Article 16): Edit any habit or data directly in the app.
3. Right to Erasure (Article 17): Delete individual habits or all data via app settings.
4. Right to Data Portability (Article 20): Export your data in CSV or Markdown format.
5. Right to Withdraw Consent (Article 7): Disable notifications at any time through device settings.

9. Security Measures

We implement appropriate technical and organizational measures under Article 32 GDPR:

• All data is stored locally using Android's secure storage frameworks (Room Database and DataStore).
• Data is protected by your device's security measures (screen lock, encryption).
• No network communication eliminates remote attack vectors.

10. Children's Privacy

11. Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making or profiling activities as defined in Article 22 GDPR.

12. Cookies and Tracking Technologies

The App does not use cookies, tracking pixels, or any similar tracking technologies.

13. Your Choices and Controls

You have complete control over your data through Device Settings (permissions, uninstall), App Settings (export, delete), and Direct Control (edit/delete entries).

14. Data Breach Notification

Since all data is stored locally, any data breach would be limited to your device. We recommend using device security features and keeping your OS updated.

15. International Users

This Privacy Policy is drafted in compliance with EU data protection standards. Users outside the EU benefit from the same privacy protections.

16. Changes to This Privacy Policy

We may update this Privacy Policy. We will notify users of material changes through notices on the Google Play Store.

17. Complaints and Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority under Article 77 GDPR. The Polish Supervisory Authority is the Urząd Ochrony Danych Osobowych (UODO).

18. Google Play Data Safety

In accordance with Google Play Developer Program Policy, we declare:

• Data collected: None (all data stays on device).
• Data sharing: None.
• Data security: All data is stored locally with device-level protection.
• Data deletion: Users can delete all data through app settings.
• Account required: No.

19. Contact Information

20. Privacy by Design

This App has been developed with privacy by design principles, including data minimization, purpose limitation, local processing, and full user control.