Privacy Policy

1. Introduction

This Privacy Policy describes how the Habit Bank mobile application (the "App") handles data. The App is designed to help users build habits through a gamified goal system. The App is free to download; certain features are available through an optional Pro subscription or one-time purchase. By using the App, you agree to this Privacy Policy. Section 13 separately covers cookies and analytics on the habitbank.pl marketing website.

Data Controller: Pawel Konieczny, sole proprietor, Poland. Contact: habitbank0@gmail.com.

2. Summary

• Habit data stays on your device. All habits, completions, goals, statistics, settings, and notification configurations are stored locally only.
• We do not collect personal data ourselves. Habit Bank does not operate any server or database that receives your habit information.
• Pro uses two external providers. If you interact with Pro (view the paywall, subscribe, restore purchases), limited non-identifying data is processed by Apple (the biller) and RevenueCat (entitlement verification).

3. Data Stored Locally on Your Device

The following information is stored only in the App's local database on your device and is never transmitted to Habit Bank servers:

• Habit names, schedules, point values, penalty values.
• Habit completions and historical check-in records.
• Goals (rewards), goal purchase history, and points balances.
• App settings (point symbol choice, holiday mode toggle, etc.).
• Local notification configuration for habit reminders.

Notifications are scheduled and delivered locally by your device's operating system. No notification content or metadata is transmitted to us.

4. Pro Subscriptions, Apple App Store, and RevenueCat

Pro is purchased and billed through the Apple App Store. To verify your purchase and unlock Pro features, the App uses RevenueCat, Inc., a third-party subscription management service. The following limited data is processed in connection with Pro:

4.1 Processed by Apple Inc.

• Your Apple ID, payment method, billing address, and transaction history are handled by Apple under Apple's own privacy practices. Habit Bank never receives your Apple ID, name, email address, or payment details.
• For legacy-user verification, the App reads the App Store receipt's originalApplicationVersion field locally on your device to determine whether you originally purchased the App at version 1.1.2 or earlier (entitling you to free lifetime Pro). This receipt check runs on-device against Apple's StoreKit.
• Apple's privacy policy: apple.com/legal/privacy.

4.2 Processed by RevenueCat, Inc.

RevenueCat receives and stores limited technical data needed to validate receipts with Apple and to determine your active entitlement. This includes:

• A pseudonymous, randomly-generated App User ID assigned by RevenueCat for your installation. This ID is not derived from your name, email, Apple ID, or device identifiers chosen by you.
• Subscription/purchase metadata: product identifier (monthly, yearly, or lifetime), purchase and expiration dates, store country, and current entitlement status (Pro active / not active).
• Basic device and app metadata: app version, platform (iOS), OS version, country/region. An IP address is observed by RevenueCat at the moment of an API request and is used solely for transport security and fraud prevention; the lawful basis is our legitimate interest under Article 6(1)(f) GDPR.

International data transfers. RevenueCat, Inc. is established in the United States. Personal data processed by RevenueCat is therefore transferred outside the European Economic Area. Such transfers are protected under Chapter V GDPR through the European Commission's Standard Contractual Clauses and/or RevenueCat's self-certification under the EU–U.S. Data Privacy Framework (where applicable). Apple Inc. handles its own user data under its own transfer mechanisms described in Apple's privacy policy.

RevenueCat acts as a data processor for Habit Bank under its own published terms and privacy policy. RevenueCat does not receive any of your habits, completions, goals, or other in-app content. See: revenuecat.com/privacy.

4.3 Offline Behavior

Habit Bank functions offline. Your most recent Pro entitlement state is cached locally so the App continues to recognize Pro status without a network connection.

5. App Character and Nature

6. Virtual Points Disclaimer

• Fictional Nature:
  The App's Points system exists only for tracking progress and awarding virtual goals. It is purely symbolic and cannot be exchanged for real currency.
• No Real Money Value:
  Users cannot withdraw, exchange, or redeem virtual Points for real money. No Points-related financial transactions occur within the App.
• Point Symbols as Visual Labels:
  Point symbols (e.g., PTS, XP, GEMS, ★, ✦, ◆) displayed in the App are graphical labels to enhance user experience. They are not currency, do not represent any exchange rate, and do not entitle users to real funds.
• Pro Purchases Are Separate:
  Real-money in-app purchases (Pro subscriptions or Lifetime) grant access to App features only. They do not purchase Points and are unrelated to the virtual currency system.

7. Data Security

• Locally stored habit data is protected by your device's built-in security. We recommend enabling passcode, biometric, or full-disk encryption features on your device.
• Communication with RevenueCat and Apple occurs over TLS-encrypted connections initiated by the App.
• We do not operate any server that holds your data, so a Habit Bank server breach is not a possible vector. Risk is limited to the providers listed in Section 4 and their respective security practices.

8. Children's Privacy

• The age rating that applies in your region is the one displayed on the Apple App Store listing for Habit Bank.
• In-app purchases and subscriptions must be initiated only by users of an age sufficient to enter into a binding purchase under applicable law, or with verifiable parental consent. Apple's App Store age restrictions and Family Sharing / Ask to Buy controls apply to all purchases.
• EU/EEA — GDPR Article 8: where any processing of a child's personal data by our processors (e.g., RevenueCat) is based on consent, that consent must be given or authorised by the holder of parental responsibility for users below the age threshold set by their EU member state (16 by default; 13–15 in some member states, including Poland which sets it at 16).
• Habit Bank does not knowingly collect personal data from children outside the limited subscription metadata described in Section 4. Habit data remains on the device and is not transmitted to us. If you believe a child has made an unauthorized purchase, please contact Apple for refund assistance and contact us at the address below.

9. Third-Party Services

• Apple App Store / StoreKit — payment processing, receipt verification, and Pro billing.
• RevenueCat, Inc. — subscription entitlement management, as described in Section 4.
• No advertising, analytics, crash-reporting, or marketing SDKs are integrated into the App. The App does not track you across other apps or websites.

10. Your Rights

• Delete local data: Uninstalling the App removes all locally stored data from your device.
• Cancel subscription: Subscriptions are managed in your Apple ID settings (Settings → [your name] → Subscriptions on iOS). After cancellation, locally stored habits, completions, and goals are preserved on your device.
• Access or erase Pro data held by RevenueCat: To request access to, correction of, or deletion of the limited subscription metadata RevenueCat processes about your installation, contact us at the email below. We will work with RevenueCat to honor verified requests in accordance with applicable law.

11. Legal Basis for Processing (EU/EEA Users)

For users in the European Union or European Economic Area, where any data processing falls within the scope of the GDPR:

• Habit data (local-only): Not processed by Habit Bank as a controller; data remains on your device.
• Pro subscription data (Apple, RevenueCat): Processed for the performance of the contract (Article 6(1)(b) GDPR) for Pro features, and for our legitimate interest (Article 6(1)(f)) in fraud prevention and accurate entitlement enforcement.
• You have the rights to access, rectification, erasure, restriction of processing, data portability (where applicable), and to lodge a complaint with your local supervisory authority.

12. Data Retention

• Local habit data is retained on your device until you delete it within the App or uninstall the App.
• Subscription metadata at RevenueCat is retained for as long as it is required to operate Pro entitlements and to meet legal and tax obligations of Apple and RevenueCat.

13. Website Cookies and Analytics (habitbank.pl)

Sections 2–12 of this Privacy Policy describe how the mobile App handles data. This section covers the separate habitbank.pl marketing website on which this Privacy Policy is published.

• Necessary cookies: The website sets a small cookie to remember your cookie-consent choice. No tracking occurs through this cookie.
• Analytics (opt-in): The website uses Google Analytics to understand aggregate visitor behaviour (pages viewed, country, device type). Google Analytics is loaded only after you explicitly opt in via the cookie banner; if you decline, no Google Analytics tag, cookie, or request is created. Google Analytics is provided by Google LLC (USA) and may transfer data outside the EEA under the EU–U.S. Data Privacy Framework. The lawful basis is your consent under Article 6(1)(a) GDPR; you can withdraw consent at any time by clearing the website cookie or selecting "Reject" in the cookie banner.
• No tracking outside the website. The website does not embed advertising pixels, social-network trackers, or cross-site identifiers.
• See Google's privacy policy at policies.google.com/privacy for details on its processing.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be reflected on this page with a new effective date and, where the change is material, also announced within the App.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, our practices, or your rights, please contact us at:

Data Controller: Pawel Konieczny, sole proprietor, Poland
Email: habitbank0@gmail.com