Clumpet Privacy Policy

Effective Date: June 8, 2026

This Privacy Policy (“Policy”) constitutes a legally binding framework governing the data processing practices of the “Clumpet” mobile application (“Application”), an iOS software program designed for native focus tracking and screen time restriction.

1. General Principles and Zero-Server Architecture

The Application is fundamentally architected around an on-device, privacy-first processing paradigm.

• Zero Remote Transmission: The Application operates with zero server overhead and utilizes no external application servers, cloud databases, or remote telemetry infrastructure.
• No Identity Association: The Developer does not collect, store, or require personal identifiers, account registrations, or credentials from the user to execute any functional components of the Application.

2. Processing of Device Activity Data via Apple APIs

To deliver its core focus-tracking and application-blocking capabilities, the Application interfaces exclusively with native Apple system frameworks, including the FamilyControls, ManagedSettings, and DeviceActivity APIs.

• Local Sandboxing: All queries regarding restricted applications, screening hours, or active device blocks are evaluated locally within the secure sandbox environment provided by iOS.
• Absence of Visibility: By system design of the Apple Screen Time frameworks, third-party developers are legally and technically prohibited from accessing specific browsing histories, application usage logs, or personal messaging data. The Application merely signals to the operating system to enforce user-configured restrictions.

3. Local Data Persistence and Gamification Elements

Any data generated through the interactive operations of the Application—including focus durations, habit consistency, experience point (XP) tallies, and the procedural state configuration of the 3D character ("Pip") and island environment—is subject to the following strict conditions:

• Exclusive Device Retention: All tracking variables and state changes are written directly to local on-device storage arrays.
• Data Portability and Deletion: Because this data is never synchronized with external systems, it remains completely under the physical custody of the user. Deletion of the Application from the iOS device will immediately and permanently purge all locally stored configurations, XP records, and state tracking.

4. Third-Party Software Development Kits (SDKs) and Analytics

• Prohibition of Third-Party Trackers: The Application explicitly excludes marketing SDKs, programmatic advertising libraries, and third-party behavior-tracking scripts (such as Google Analytics or Firebase).
• Payment Processing Security: Digital product acquisitions, including monthly subscriptions, annual passes, or lifetime tier transactions, are processed exclusively through Apple’s native StoreKit infrastructure. Transaction verification data, token logs, and subscription metadata are handled entirely by Apple Inc. pursuant to standard App Store terms, with no financial details or payment instruments exposed to the Developer.

5. Compliance and Protections for Minors

Given that the Application relies on local system-level controls to enforce focus sessions, its internal systems do not gather data from any individual. The Application is fully compliant with the Children's Online Privacy Protection Act (COPPA) and the General Data Protection Regulation (GDPR), as no network transmission of metadata, device identifiers, or personal insights occurs under any operational circumstances.

6. Modifications to This Instrument

The Developer reserves the right to amend this Policy to align with future updates to native Apple API protocols or compliance guidelines. However, the fundamental operational baseline – stipulating absolute on-device data isolation and zero remote collection – shall remain unalterable. Any structural modifications will be explicitly declared within the App Store release notes.

7. Judicial and Administrative Contact

For formal legal inquiries regarding the Application's implementation of native privacy frameworks or local storage isolation, users may refer to the verified support and developer contact pathways hosted on the official App Store product listing.