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!time2smoke
GDPR

Privacy Policy

Version 1.1  ·  Effective April 4, 2026  ·  Data Controller: Carlos Santos  ·  Portugal, EU

Privacy by design

Your smoking history, plan data, progress, and statistics are designed to remain stored locally on your device and are not intentionally transmitted to the Developer's servers during normal app operation. The Developer seeks to limit data collection to the data needed to operate the trial period, subscription features, and related service functions.

01

Introduction and Data Controller

This Privacy Policy explains how the !time2smoke application ("the App") processes personal data in accordance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) and other applicable law.

The data controller is Carlos Santos, an individual developer based in Portugal, European Union. For privacy-related enquiries, you may contact: support@time2smoke.app.

02

Privacy by Design

!time2smoke was designed to keep most app data on the user's device. Smoking history, plan data, progress information, and statistics are intended to remain stored locally on the device and are not transmitted to the Developer as part of normal app operation.

The Developer does not receive this local app data through the ordinary operation of the App. The Developer seeks to limit remote data processing to the data necessary for trial management, subscription support, and related service functions.

03

Data Collected and Purposes

3.1 Data stored locally on your device

The following data is created and stored locally on your device through the App. This data is not transmitted to the Developer as part of normal app operation:

If you uninstall the App or clear its local data, this information may be deleted from the device, subject to any device-level backup, restore, or synchronization settings outside the Developer's control.

3.2 Data transmitted to external services

The App uses limited remote data processing to manage trial eligibility, subscription functionality, and related support functions.

a) Installation date and device identifier

The date of first installation (install_date) may be recorded in the Developer's backend services and associated with a randomly generated or pseudonymous device identifier. This information is used to calculate the 7-day trial period, support trial integrity, and help prevent the trial from restarting upon reinstallation. This identifier is not intended to directly identify you by name or email address.

Legal basis: Performance of contract (Art. 6(1)(b) GDPR), and where applicable, the Developer's legitimate interests in preventing abuse of the trial system (Art. 6(1)(f) GDPR).

b) Subscription-related data

The App uses RevenueCat to support subscription entitlement and purchase-status management. This may include subscription status information, app-user identifiers, and store purchase identifiers needed to determine whether premium access is active, in trial, cancelled, or expired. Payment card data is processed by the App Store (Apple) or Google Play (Google), not by the Developer.

Legal basis: Performance of contract (Art. 6(1)(b) GDPR).

c) Support communications

If you contact the Developer, the Developer may process the information you include in your message, such as your email address and the contents of your request, in order to respond and provide support.

Legal basis: Legitimate interests in handling user enquiries and support requests (Art. 6(1)(f) GDPR), or performance of contract where the request relates to service access or subscription support (Art. 6(1)(b) GDPR).

04

Service Providers and Data Recipients

Google LLC — Firebase / Firestore

Used to support limited backend storage related to trial eligibility and app functionality. Data is configured to be hosted in a European region, subject to Google's infrastructure and service terms. Privacy policy ↗

RevenueCat, Inc.

Used to support subscription entitlement and purchase-status management. RevenueCat may process identifiers and subscription-status information on behalf of the Developer. Privacy policy ↗

Apple Inc. / Google LLC — App stores

Handle in-store payment processing, store account billing, and subscription infrastructure under their own terms and privacy notices.

Personal data is not sold and is not shared for advertising purposes. The Developer does not use your data for third-party behavioural advertising.

05

Health-Related Information

The App relates to smoking reduction or cessation and may therefore involve information that users consider health-related. However, the Developer does not intentionally collect or receive users' smoking history, plan data, or progress records from the App's normal operation. Such information is designed to remain on the user's device.

To the extent the Developer processes only limited technical or subscription-related identifiers and not the user's local smoking-history data, the scope of health-data processing by the Developer is intended to be correspondingly limited.

06

Data Retention

Installation-date records, device identifiers, and related technical subscription-support data are retained only for as long as necessary to manage trial eligibility, subscription-related issues, fraud-prevention checks, or related disputes.

Where such data is no longer needed for those purposes, it will be deleted or anonymised within up to 90 days, unless a longer retention period is required by law or reasonably necessary to establish, exercise, or defend legal claims.

Data processed by third-party providers such as RevenueCat may be retained according to their own applicable retention practices and contractual arrangements. RevenueCat's privacy information ↗

07

Your Rights

Under the GDPR, you may have the following rights regarding the personal data processed by the Developer:

Access

Know what personal data is being processed.

Rectification

Correct inaccurate or incomplete personal data.

Erasure

Request deletion where applicable.

Restriction

Request that processing be limited in certain cases.

Portability

Receive applicable data in a structured, machine-readable format.

Objection

Object to certain processing, including some legitimate-interest processing.

These rights apply to the personal data processed by the Developer. Data stored only on your device remains under your control on that device.

To exercise any applicable rights, contact: support@time2smoke.app. The Developer aims to respond within one month, subject to the timelines permitted under applicable data protection law.

You also have the right to lodge a complaint with your local supervisory authority, or in Portugal with the CNPD (cnpd.pt).

08

Data Security

The Developer implements appropriate technical and organisational measures, proportionate to the nature of the processed data, to protect personal data against unauthorised access, accidental loss, misuse, or unlawful disclosure. These measures may include encrypted communications (such as HTTPS/TLS) and access-control restrictions for backend services.

09

International Transfers

Some service providers used by the App may process personal data outside the European Economic Area, including in the United States. Where personal data is transferred internationally, such transfers are intended to be safeguarded through mechanisms recognised under applicable data protection law, which may include Standard Contractual Clauses approved by the European Commission.

10

Tracking, Analytics, and Similar Technologies

The App does not use cookies in the traditional web-browser sense. The Developer does not use advertising SDKs or behavioural tracking technologies for third-party marketing or profiling purposes through the App.

The device identifier described in section 3 may be used only for functional purposes such as trial management, subscription support, fraud prevention, and service integrity.

11

Children

The App is intended for adults only and is not directed to children. The Developer does not knowingly collect personal data from minors.

12

Changes to This Policy

The Developer may update this Privacy Policy from time to time. If material changes are made, users will be notified through the App or by other appropriate means at least 15 days before the changes take effect, unless a shorter period is required for legal or security reasons.

The effective date shown at the top of this Policy indicates when the current version came into force.

13

Contact and Complaints

For questions about privacy or personal data processing, contact: support@time2smoke.app.

You may also contact the supervisory authority of your country of residence in the EU, or the Portuguese CNPD (cnpd.pt).