Unplug OS Privacy Policy

Your Privacy Matters

This Privacy Policy describes how Unplug OS ("we", "us", or "our") collects, uses, and protects your information when you use our mobile application. Unplug OS is made by Nicole Kelner LLC DBA Mindful Tech Studio, the maker of Free Time. We are committed to protecting your privacy and being transparent about our data practices.

1. Information We Collect

1.1 Account Information

When you create an account using Apple Sign In, we may collect:

• Email address (either your real email or Apple's private relay email)
• Name (if you choose to provide it through Apple Sign In - this is optional and stored as a display name)
• Unique user identifier for your account
• Account creation and last login dates
• Authentication tokens (securely stored and encrypted)

1.2 Usage and Analytics Data

To help you understand your digital habits and improve the App, we collect:

• Blocking mode session activity (when blocking is active and for how long)
• Temporary access session durations and completion rates
• Number of times you attempt to open blocked apps
• Usage patterns by time of day
• Puzzle completion statistics and preferences
• Streaks and achievement milestones

1.3 App Configuration Data

• Your app blocking preferences and configurations
• Blocking schedules and time restrictions
• Notification preferences and puzzle type selections
• Names of saved places you create (e.g., "Home")

1.4 Technical Data

• Device identifier (for data validation purposes only)
• iOS version (for compatibility purposes)
• App crashes and error reports (to improve stability)

1.5 Location Data (Processed On-Device Only)

Unplug OS can optionally use your location to detect when you arrive at a saved place (such as home) and automatically start blocking mode. If you grant location permission:

• Location is used with "While Using the App" permission only
• The coordinates of your saved places are stored locally on your device only and are never transmitted to our servers
• We do not track, record, or upload your location history
• You can revoke location permission at any time in iOS Settings, and the App will continue to work without location-based features

1.6 QR Code Data

Unplug OS lets you use QR codes as physical triggers for blocking mode. We do not collect or store any data from QR code scans. All QR functionality is processed entirely on your device. No scan history or QR code contents are transmitted to our servers. The camera is used only to scan QR codes; no photos or video are captured, stored, or transmitted.

2. Information We Do NOT Collect

We are committed to minimal data collection. We do NOT collect:

• Phone numbers or physical mailing addresses
• Your location coordinates on our servers (location processing happens entirely on your device)
• Real-time location tracking or location history
• Government-issued identifiers (Social Security numbers, driver's license numbers)
• Content of your messages, emails, or other communications
• Photos, videos, or other media files (the camera is used only for QR scanning, on-device)
• Browsing history or website content
• Contact lists or social media data
• Biometric data (Face ID, Touch ID are processed locally by iOS only)
• Advertising identifiers (IDFA) — Unplug OS contains no advertising or ad tracking SDKs

3. Third-Party Services We Use

3.1 Firebase by Google

• Authentication: Secure user sign-in and account management
• Firestore Database: Secure cloud storage for your account information (user ID, email, display name, and account creation date)
• App Check: Device validation and security protection
• Crashlytics: Crash and error reporting to improve stability

3.2 Mixpanel

• Usage Analytics: Anonymous tracking of app usage and feature interactions
• Performance Metrics: App stability and error tracking
• Technical Data: Device model, operating system version, and approximate geographic location (city and region derived from IP address for analytics purposes)
• Anonymous Identification: Unique anonymous identifiers for tracking usage patterns
• QR Trigger Events: Anonymized event counts of blocking mode activations (no QR contents or location data)
• No Personal Data: Only Firebase user IDs or anonymous device identifiers - we never share names, emails, or precise personal information with Mixpanel

All data sent to Mixpanel is anonymized and used solely to improve app performance and user experience.

3.3 RevenueCat (Subscription Management)

• Subscription Management: Handles in-app purchases and subscription status verification
• Payment Processing: Processes payments through Apple's App Store (RevenueCat does not store credit card information)
• Purchase History: Tracks subscription status, purchase receipts, and entitlements
• User Identification: Receives your anonymous user ID (Firebase UID) to link purchases to your account
• Data NOT Received: RevenueCat does NOT receive your email, name, or payment details (payments are handled by Apple)

RevenueCat is subject to its own privacy policy. All payment information is processed securely through Apple's payment systems.

3.4 Technical Information Collected by Analytics Services

Our analytics providers (Mixpanel, Firebase) may automatically collect:

• Device model and operating system version
• App version and performance metrics
• Approximate geographic location (city and region derived from IP address)
• Network carrier and connection type

This technical data is used solely to understand app performance, fix bugs, and improve user experience. We do not collect precise GPS coordinates or track your real-time location.

3.5 Website Analytics (Not Used in Mobile App)

Note: Our website (findfreetime.com) uses Google Analytics for website traffic analysis only. This analytics service is not used in the mobile app and only applies to website visitors who accept cookies through our cookie consent banner. Mobile app analytics are handled exclusively by Mixpanel as described above.

Firebase, Mixpanel, and RevenueCat services are subject to their respective privacy policies. All data is encrypted in transit and at rest.

4. No Advertising or Tracking

Unplug OS does not contain advertising, advertising SDKs, or ad attribution tools. We do not access your device's advertising identifier (IDFA), and we do not track your activity across other companies' apps or websites. Because of this, Unplug OS does not show Apple's App Tracking Transparency prompt.

5. How We Store Your Data

5.1 Local Storage

Most data is stored locally on your device using iOS's secure storage systems. This includes preferences, usage statistics, blocking configurations, and the coordinates of your saved places.

5.2 Cloud Storage

Account information is securely stored in Firebase Firestore, including account email and authentication information.

5.3 Encryption and Security

• iOS Keychain for secure token storage
• Encrypted storage for sensitive data such as Screen Time tokens
• All data encrypted in transit and at rest

6. How We Use Your Data

We use your data solely to provide and improve the App's functionality:

• Enable blocking mode and temporary access session features
• Provide usage insights and progress tracking
• Maintain preferences across app launches
• Show your session status via Live Activities and the Dynamic Island (rendered on your device by iOS)
• Improve app stability and performance

7. Data Sharing and Third Parties

We do not sell, trade, or share your personal data with third parties for marketing purposes. Your data is only shared with:

• Firebase/Google: As our secure database and authentication provider
• Apple's Screen Time framework: Required for blocking functionality

We do not use advertising networks or data brokers.

8. Your Rights and Controls

• Data Access: View your usage analytics within the App
• Data Deletion: Delete all local data by uninstalling the App
• Account Deletion: Delete your account through the App's settings
• Location Control: Enable or disable location access in iOS Settings
• Screen Time Control: Revoke permissions in iOS Settings

9. Data Retention

• Account data (Firebase): Retained until you delete your account
• Usage analytics (Mixpanel): Automatically purged after 365 days
• Crash reports (Crashlytics): Retained for 90 days
• Local app data: Retained on your device until app uninstall
• Subscription data (RevenueCat): Retained per RevenueCat's retention policy; purchase receipts retained as required by tax and accounting law

10. Children's Privacy

Unplug OS is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. In certain EU/EEA member states, the minimum age for digital consent may be lower (but not below 13). If we learn that we have collected data from a child below the applicable age without verified parental consent, we will delete that data promptly. If you believe a child has provided us with personal data, please contact us at support@findfreetime.com.

11. For European Users (GDPR)

If you are located in the European Economic Area (EEA), UK, or Switzerland, you have additional rights under GDPR including:

• Right to access your personal data
• Right to erasure ("right to be forgotten")
• Right to data portability
• Right to object to processing

To exercise these rights, contact us through the App's support feature.

Legal Basis for Processing (GDPR Article 6)

We process your personal data under the following legal bases:

• Contract Performance (Art. 6(1)(b)): Account creation, authentication, subscription management, and core app functionality (app blocking, temporary access sessions, puzzles). These are necessary to provide the service you signed up for.
• Consent (Art. 6(1)(a)): Usage analytics (Mixpanel). You can withdraw consent at any time through the App's analytics settings, and the app will continue to function normally.
• Legitimate Interest (Art. 6(1)(f)): Crash reporting (Firebase Crashlytics) to maintain app stability and security. We have balanced this against your privacy rights and determined the minimal, anonymized nature of crash data justifies this basis.

International Data Transfers

Your data may be transferred to and processed in the United States by our service providers:

• Firebase/Google (USA) — Protected under Google's Data Processing Terms and Standard Contractual Clauses (SCCs)
• Mixpanel (USA) — Protected under Mixpanel's Data Processing Addendum and Standard Contractual Clauses
• RevenueCat (USA) — Protected under RevenueCat's Data Processing Agreement and Standard Contractual Clauses

These transfers are safeguarded by EU Standard Contractual Clauses (SCCs) as approved by the European Commission, and where applicable, the EU-US Data Privacy Framework.

Withdrawing Consent

Where we process your data based on consent, you can withdraw consent at any time through the App's analytics settings. Withdrawing consent does not affect the lawfulness of processing performed before withdrawal. The app will continue to function normally without analytics.

Right to Lodge a Complaint

If you are in the EU/EEA, you have the right to lodge a complaint with your local data protection supervisory authority if you believe your data has been processed unlawfully. A list of EU data protection authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

12. Your Rights Under Brazilian Law (LGPD)

If you are in Brazil, you have the following rights under the Lei Geral de Proteção de Dados (LGPD):

• Confirmation and access: Know whether we process your data and access it
• Correction: Request correction of inaccurate data
• Anonymization, blocking, or deletion: Of unnecessary or excessive data
• Deletion: Delete your account and data through the App's settings
• Information about sharing: Know which third parties receive your data (see Third-Party Services above)
• Consent withdrawal: Revoke analytics consent through the App's analytics settings
• Opposition: Object to processing that violates the LGPD

Our Data Protection contact for LGPD purposes: support@findfreetime.com

We will respond to LGPD requests within 15 days.

13. Changes to This Privacy Policy

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

14. Contact Us

If you have questions about this Privacy Policy:

• Email us at support@findfreetime.com
• Visit our Contact page to get in touch

We will respond to privacy-related inquiries within 30 days.