This Privacy Policy explains how Softmode Labs AB ("Softmode Labs," "we," "our," or "us"), a company registered in Sweden, handles your information when you use the Cloody mobile application ("App"). Softmode Labs AB is the data controller responsible for the limited personal data processed in connection with the App.

The short version: Almost all of your data stays on your device. We don't sell your data, we don't run ads, and we don't track you across apps.

1. Information We Collect

1.1 Data Stored On Your Device (and synced via your iCloud)

The following data is stored on your iPhone and, where you have iCloud enabled, synced between your own devices through Apple's iCloud (CloudKit). It is never transmitted to our servers:

iCloud sync is managed by Apple under your Apple ID and is governed by Apple's Privacy Policy. We have no access to your iCloud data.

1.2 Data Processed by Third Parties

The following providers act as our data processors / service providers, processing data only on our instructions and not for their own purposes:

1.3 Data We Do NOT Collect

2. How We Use Information

Your on-device data is used solely to provide the App's core features:

We use anonymous, aggregated analytics data (described in §1.2) solely to understand how Cloody is used at the population level and to improve the product. Our legal basis under the GDPR is legitimate interest. You can object to this processing at any time — see §8.

3. Apple Screen Time API

Cloody's App Shield feature uses Apple's Family Controls and Screen Time frameworks. These operate entirely within Apple's privacy sandbox:

4. Notifications

Cloody sends local push notifications (bedtime reminders, wind-down prompts, morning check-ins, voice message alerts). These are generated and scheduled entirely on your device. No notification data is sent to our servers.

5. Data Retention

On-device and iCloud-synced data is retained for as long as you use the App. You can delete all on-device data at any time through Settings > Reset All Data. Uninstalling the App also removes locally stored data; iCloud-synced content is removed via your Apple ID's iCloud storage management.

Anonymous analytics events held by PostHog are retained for up to 12 months and then deleted or aggregated beyond reversal. Subscription records held by RevenueCat are retained for as long as required to manage your subscription and meet Apple's reporting and refund requirements.

6. Data Security

Your data is protected by Apple's iOS security infrastructure, including device encryption and the iOS sandbox. Since your data remains on-device, it benefits from the same security protections as all other data on your iPhone.

7. Children's Privacy

Cloody is not directed at children under 13. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use Cloody.

In EU countries where the digital-services age of consent under the GDPR is higher than 13 (Germany and the Netherlands at 16, France at 15), parental consent is required if the user is below that local threshold.

8. Your Rights

Because almost all of your data is stored on your own device, you have direct control:

For subscription-related data managed by RevenueCat, contact hi@cloodyapp.com and we will facilitate any access or deletion request.

Right to lodge a complaint. If you are in the EU, EEA, UK, or Switzerland and believe your data has been handled in violation of applicable law, you have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the Swedish Authority for Privacy Protection (IMY) — imy.se. You may also lodge a complaint with the authority in your country of residence.

9. Notice for California Residents (CCPA / CPRA)

If you reside in California, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

Residents of other U.S. states that have enacted comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana and others) have substantially similar rights. To exercise them, please contact us at hi@cloodyapp.com.

10. International Data Transfers

Softmode Labs AB is based in Sweden. Our analytics provider PostHog hosts our project's data in the European Union; no analytics transfer outside the EU/EEA takes place on our side. RevenueCat is based in the United States; subscription identifiers transferred to RevenueCat are governed by Apple's App Store agreements and RevenueCat's own contractual safeguards. iCloud data is handled by Apple under your Apple ID and may be processed in Apple's global infrastructure as described in Apple's Privacy Policy.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the App or by updating the "Last updated" date above.

12. Contact Us

For questions about this Privacy Policy or to exercise your rights:

13. Legal Disclaimer

This Privacy Policy is provided for transparency and to comply with applicable privacy laws. It does not constitute legal advice. The English version of this policy is the authoritative version; translations are provided for convenience only. To the extent permitted by applicable law, in case of any conflict between this policy and a written agreement between you and Softmode Labs AB, the written agreement prevails.