Legal

Privacy Policy

Effective date: April 26, 2026 · Last updated: April 26, 2026

Plain-English summary. 21 Counts keeps your lesson progress on your device. We don't run user accounts, we don't ship analytics, and we don't sell anything about you. The only personal-ish data that touches our systems is the anonymous subscriber ID our subscription provider (RevenueCat) uses to remember whether you're a Pro user — and the purchase Apple processes to bill you.

1. Who we are

This Privacy Policy describes how the publisher of the 21 Counts mobile application ("21 Counts", "we", "us") handles information when you use the App.

2. Information we collect

Stored locally on your device

Lesson progress — completed lesson IDs, exam pass status, total XP, current streak, last activity date.
App settings — your selected theme, whether you've seen the intro flow, current selected tier in the picker, and similar UI state.

This local data lives in Apple's SwiftData store on your device. It is not transmitted to us. Resetting progress in the app or deleting the App removes this data.

Subscription state (via RevenueCat)

When you make an in-app purchase or restore one, our subscription provider RevenueCat generates an anonymous user identifier and stores whether your "21 Counts Pro" entitlement is active. RevenueCat may also receive technical purchase metadata from Apple (product identifier, period, country, transaction time) to determine entitlement status. See RevenueCat's privacy policy.

Purchase processing (via Apple)

All payments are processed by Apple through the App Store. We never see your name, email, address, or payment details. Apple shares only the anonymous transaction information needed to validate your subscription. See Apple's privacy policy.

Crash and performance data

If you have iOS analytics sharing enabled at the system level, Apple may share aggregated, de-identified crash and performance data with developers. You can review or disable this in Settings → Privacy & Security → Analytics & Improvements on your iOS device.

3. What we don't collect

We do not collect your name, email, phone number, or address.
We do not maintain user accounts.
We do not include third-party advertising or ad tracking SDKs.
We do not include third-party analytics SDKs (e.g., Google Analytics, Firebase Analytics, Facebook SDK).
We do not access your contacts, photos, location, microphone, or camera.
We do not sell or rent any information about you.

4. How we use information

To run the app — local progress data is read by the App to show you which lessons are complete, your streak, XP, etc.
To unlock Pro features — your RevenueCat entitlement status determines whether Pro content is available.
To respond to support — if you email us, we use your email address only to reply to your message.

5. Data sharing

We only share data with the providers strictly required to operate the App:

Apple (App Store, StoreKit) — for app distribution and payment processing.
RevenueCat — for subscription entitlement management.

We do not share data with anyone else for marketing, analytics, or any other purpose.

6. Data retention

Local data lives on your device until you reset progress or delete the App. RevenueCat retains subscriber records for as long as needed to operate subscriptions and meet legal obligations; see their policy for details.

7. Children's privacy

The App is intended for adults (18+) and we do not knowingly collect any data from children. If you believe a child has used the App, contact us and we will help with deletion.

8. Your rights

Because we don't store identifiable personal data on our servers, most rights (access, correction, deletion) you'd exercise against a typical service apply to your local device or to Apple/RevenueCat:

Local data — reset or delete in-app, or delete the App from your device.
Subscription data — manage subscriptions in Settings → [your name] → Subscriptions on iOS, or contact Apple Support.
RevenueCat records — submit a request to RevenueCat directly via their policy page.
Anything else — email pondd.me@gmail.com.

9. International users

By using the App, you understand that the providers we rely on (Apple, RevenueCat) operate globally and may process data in countries other than your own. They follow their own commitments under regimes such as the EU GDPR and California's CCPA/CPRA.

10. Security

We rely on Apple's built-in protections (sandboxing, file encryption with device passcode) for local data. RevenueCat and Apple use TLS for communications. No system is perfectly secure, but the App processes very little data — there is intentionally not much to compromise.

11. Changes

We may update this Policy. Material changes will be reflected in the "Effective date" above. Continued use of the App after a change constitutes acceptance of the updated Policy.

12. Contact

Questions about this Privacy Policy? Email pondd.me@gmail.com.

Note: This is a starting template that reflects the App as currently built (no analytics, no accounts, only Apple and RevenueCat as data processors). If you add SDKs (analytics, ads, crash reporting beyond Apple's defaults) later, update the lists above. Have a lawyer review before launch — this is not legal advice.