Privacy Policy

1. Introduction

Pouches Tracker (“we,” “us,” “our,” or “app”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our iOS mobile application.

2. Information We Collect

Pouches Tracker is designed with privacy in mind. The app operates primarily offline and stores your data locally on your device.

Data We Collect:

• Nicotine pouch consumption logs (timestamp, pack information)
• Pack details (name, price, nicotine strength)
• Usage statistics derived from your logs

Purchase & Measurement Data:

• Purchase and transaction records, processed through RevenueCat
• A random, non-personal app-user identifier we generate
• App events, such as installs and purchases, sent to TikTok to measure the performance of our advertising
• Only if you grant permission through the iOS tracking prompt: your device’s advertising identifier (IDFA), along with related identifiers (IDFV, IP address), shared with RevenueCat and TikTok to measure advertising

Data We Do Not Collect:

• Personal identification information (name, email, phone)
• Location data
• Health or medical data beyond pouch consumption

3. Data Storage

Your consumption logs and pack details are stored locally on your device using Apple’s SwiftData framework — we do not sync, store, or access that data on remote servers, and it remains entirely within your control on your device. However, purchase transactions and app events are transmitted to and stored by RevenueCat and TikTok, and — with your permission — device identifiers are also shared with those providers and with Apple for Search Ads attribution.

If you back up your iPhone to iCloud, your Pouches Tracker data may be included in that backup as part of your device’s standard backup process. This is controlled by Apple’s iCloud backup settings.

4. Data Sharing

We never sell your data. We share purchase data with RevenueCat, our purchase infrastructure provider, and app events with TikTok to measure our advertising. Only with your consent, we share your advertising identifier with RevenueCat and advertising partners such as TikTok and Apple, to measure which ads bring new users. Your consumption logs and pack details are never shared and remain on your device only.

5. Third-Party Services

We use RevenueCat, a third-party service that processes purchase and device data (see RevenueCat’s privacy policy). We use the TikTok Business SDK to measure the performance of our advertising, which processes app events and device data (see TikTok’s privacy policy). We use Apple’s AdServices for Apple Search Ads attribution. And we request permission through App Tracking Transparency to collect the IDFA for advertising measurement, which you can decline or later turn off in iOS Settings.

6. Data Security

We implement appropriate technical measures to protect your data:

• Local encryption through SwiftData
• Secure coding practices
• Regular security updates

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Your Rights

Since all data is stored locally on your device, you have complete control:

• View all your data within the app
• Edit or delete any consumption log
• Delete all data by uninstalling the app
• Access your data at any time

Declining the tracking prompt — or disabling it later in Settings → Privacy & Security → Tracking — is fully supported and does not affect app functionality.

8. Children’s Privacy

Pouches Tracker is not intended for use by children under 18 years of age. We do not knowingly collect information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of any material changes by updating the “Last Updated” date at the top of this policy. Your continued use of the app following the posting of revised Privacy Policy means that you accept and agree to the changes.

10. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

honza.kubes@icloud.com

11. Compliance

Pouches Tracker complies with applicable privacy laws and regulations, including:

• Apple App Store Privacy Guidelines
• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)

Under the GDPR, our processing of the IDFA relies on a lawful basis: your consent, given through the App Tracking Transparency prompt. Under the CCPA/CPRA, sharing the IDFA for cross-context advertising counts as “sharing,” which you can opt out of — declining the tracking prompt (or turning it off in iOS Settings) serves as that opt-out.