Privacy Policy

1. Introduction and scope

This Privacy Policy ("Policy") is issued by Smit Machhi("Company", "we", "us", or "our") and governs the Plump mobile application (the "App") and the website located at https://plumpapp.com (the "Site"). Together, the App and the Site are referred to as the "Services".

This Policy applies to all users of the Services. By downloading, installing, or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you must discontinue use of the Services.

For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679) and the UK Data Protection Act 2018, the Company is the data controller in respect of the personal data described in this Policy.

2. Definitions

• "Personal data" means any information relating to an identified or identifiable natural person.
• "Application token" means the opaque identifier issued by Apple's Family Controls framework in respect of an application, category, or website you select. An Application token contains no application name, no bundle identifier, and no icon.
• "On-device data" means information stored locally within the App's container or within the application group shared with the App's own extensions, and which is not transmitted to the Company.
• "Biometric identifier" means data generated from measurements of a person's physical characteristics that can be used to identify that person, including face geometry, fingerprint, voiceprint, and iris or retina scan. The Company does not create, store, or process a Biometric identifier. See section 3.1.
• "Services" means the App and the Site collectively.

3. Information we collect

3.1 Camera data

The App requires access to your device's camera in order to count exercise repetitions. Camera access is requested by the operating system on first use and may be withdrawn at any time in iOS Settings under Privacy and Security, then Camera.

When a session is active, the following occurs:

1. A camera frame is captured in volatile memory. It is not written to persistent storage.
2. A pose estimation model distributed within the App, MediaPipe, provided by Google LLC, processes the frame on your device to derive body landmark positions.
3. The App compares those landmark positions against a squat motion and increments a repetition counter upon completion.
4. The frame is released and is not retained.

No image, video recording, or camera frame is stored, transmitted, disclosed, or sold. The App does not access the camera otherwise than during a session you have initiated. The App stores the repetition count on your device. During onboarding, it also sends the first-squat completion event described in section 3.4.

The pose estimation model is bundled with the App. It is not downloaded at runtime and does not transmit data.

3.1.1 Biometric data

This section addresses biometric privacy laws in the United States, including the Illinois Biometric Information Privacy Act ("BIPA"), the Texas Capture or Use of Biometric Identifier Act ("CUBI"), and Washington Revised Code chapter 19.375.

• The App does not create a Biometric identifier. The pose model derives body landmark positions from a frame. Those positions are not converted into a face template, a faceprint, or any other identifier that could recognise you.
• The App does not perform facial recognition. It does not identify you, verify who you are, or distinguish you from any other person.
• Landmark positions are transient. They exist in volatile memory while a frame is being evaluated and are discarded when the frame is released. Landmark positions are not written to storage.
• No disclosure. Landmark positions are not transmitted, disclosed, sold, leased, traded, or shared with any third party, including the Company's service providers. Section 6 lists every recipient of any data; none of them receives camera or landmark data.
• The pose model runs on your device. MediaPipe is distributed inside the App. It does not send frames or landmarks anywhere.

A small number of the landmark positions the model returns sit near the face, such as the nose, eyes, and ears. They are used only to determine whether your body completed a squat, and they carry no information about your identity.

3.1.2 Consent

The App does not access the camera until you grant permission in the iOS prompt. That permission is your explicit consent to the processing described in this section. You may withdraw it at any time in iOS Settings under Privacy and Security, then Camera, and the App will cease all camera processing.

Withdrawing consent stops the App counting repetitions, so you can no longer earn coins. It does not affect any other part of the Services, and it does not remove coins you have already earned.

3.2 Screen Time data and application tokens

The App uses Apple's Family Controls, Managed Settings, and Device Activity frameworks (collectively, "Apple Screen Time Frameworks"). Your use of those frameworks is also subject to Apple's own terms and privacy practices.

Application selection. When you select applications, categories, or websites to restrict, iOS presents Apple's own picker interface and returns an Application token to the App. The Company does not receive, and cannot derive, the identity of the applications you selected. Application tokens are retained solely to enable the App to apply and remove restrictions.

Usage durations. Screen Time durations are generated by a Device Activity Report extension operating within a privacy sandbox controlled by Apple. The App renders that report for display. The Company does not receive the underlying usage data and does not store it.

No correlation. The App deducts access minutes from a single aggregate balance. The Company does not associate any individual coin with any individual application, does not rank or profile application usage, and does not maintain a history of application usage.

3.3 On-device data

The App stores the following information on your device. Sections 3.4 and 3.5 explain the separate analytics and purchase information sent to our service providers.

Deleting the App removes all On-device data. Apple may restore a verified purchase, but cannot restore coin balances, repetition counts, stated objectives, or onboarding responses.

3.4 Analytics data

The App transmits limited product analytics to PostHog, Inc. ("PostHog"), which processes such data on our behalf and stores it in the United States at us.i.posthog.com. We use this data to understand which setup steps users complete and where they have problems.

The attempt identifier is a randomly generated value created on your device for a single onboarding attempt. It is not linked to your name, your Apple Account, or any advertising identifier. PostHog also creates a persistent random app-user identifier and session identifiers. These identifiers can link records from the same app installation, even though the App does not send your name or the values of your onboarding answers.

PostHog receives event times and technical details such as the App version, iOS version, phone model, language, and time zone. It receives your IP address and can use it to estimate your city and country. These estimates are approximate. The App does not request GPS location access.

The first-squat event reports that you completed the first squat during setup. It does not include camera frames, body landmarks, detailed squat counts, or your exercise history. Those records stay on your device.

The App configures the analytics library so that:

• personal profiles are disabled;
• session recording and replay are disabled;
• screen view and element interaction capture are disabled;
• application lifecycle event capture is disabled; and
• automatic method swizzling is disabled.

The App does not upload your name, email address, telephone number, contacts, photographs, or HealthKit records. The App does not request App Tracking Transparency permission. We use the services described here for app operation and analytics. We have no advertising-service connections configured.

3.5 Purchase information

Apple Inc. sells subscriptions and lifetime access. Apple processes payment and sends the App a signed confirmation of access, including an expiry date for subscriptions. The Company does not receive your payment card details, billing address, or name.

Superwall, Inc. delivers the paywall content. To show paywalls and manage purchase access, its library sends app-user and device identifiers, including Apple's identifier for vendor, and device and App information. This information can include the phone model, iOS and App versions, language, time zone, and screen settings. Superwall receives your IP address and can estimate your city and country. It also processes purchase and subscription access information. It does not receive camera frames, body landmarks, Screen Time reports, or your application selections.

The App enables Superwall's internal events, including app sessions, paywall views, checkout results, loading times, and errors. We use these records to link purchases to the paywall shown and to diagnose payment problems. The App shares a random app-user identifier between PostHog and Superwall so we can connect setup, checkout, and access records.

The App sends setup milestones and purchase outcomes to PostHog. Superwall also sends payment events from Apple's server notifications, including trial starts, purchases, renewals, cancellations, refunds, and expiry. These records can include transaction identifiers, product, price, currency, and event time. We use them to measure setup completion and subscription results. They do not contain payment card details.

4. How we use information

• To provide, operate, and maintain the Services;
• to verify entitlements and manage subscription access;
• to apply and remove restrictions you have configured;
• to diagnose faults and improve the onboarding experience; and
• to comply with applicable legal obligations.

The Company does not use personal data for advertising, does not sell personal data, and does not use personal data to train machine learning models.

5. Legal bases for processing

Where the EU or UK General Data Protection Regulation applies, the Company relies on the following legal bases:

• Performance of a contract (Article 6(1)(b)) in respect of entitlement verification, coin accounting, and application restrictions, which cannot function without such processing.
• Legitimate interests (Article 6(1)(f)) in respect of the analytics described in section 3.4, being the Company's interest in identifying and remedying friction in the onboarding flow. You may object to this processing at any time using the contact details in section 14.
• Consent (Article 6(1)(a)) in respect of camera access, which is requested by the operating system and may be withdrawn at any time in iOS Settings.

6. Disclosure of information

The Company discloses personal data only to the following categories of recipient, and only to the extent necessary:

• Apple Inc., as the provider of the App Store, the Screen Time Frameworks, and payment processing;
• PostHog, Inc., as processor for the analytics described in section 3.4;
• Superwall, Inc., for paywall delivery, purchase access, and the event processing described in section 3.5; and
• Competent authorities, where disclosure is required by law or necessary to establish, exercise, or defend legal claims.

The Company does not otherwise disclose, sell, rent, or trade personal data.

7. Data retention

The App keeps local data until you delete it or remove the App. PostHog and Superwall hold server records under the retention settings and policies that apply to those services. These periods depend on the type of record and the service configuration. Deleting the App does not delete records already held by either provider. Contact us using section 14 to request access or deletion. Apple retains purchase records under its own policies.

8. Security

On-device data is protected by the iOS application sandbox and, where configured, by your device passcode and hardware encryption. Data in transit to PostHog and Superwall is protected using HTTPS. The Company reduces risk by minimising the volume of personal data it holds. No method of transmission or storage is entirely secure, and the Company cannot guarantee absolute security.

9. International transfers

PostHog and Superwall process data in the United States. Where personal data is transferred from the European Economic Area, the United Kingdom, or Switzerland to a jurisdiction not subject to an adequacy decision, the transfer is made pursuant to the European Commission's Standard Contractual Clauses or an equivalent safeguard incorporated into the Company's agreement with the relevant processor.

10. Your rights

Subject to applicable law and to the exemptions available to the Company, you may have the right to:

• request access to personal data held about you;
• request rectification of inaccurate personal data;
• request erasure of personal data;
• request restriction of, or object to, processing;
• request portability of personal data you provided; and
• lodge a complaint with a supervisory authority.

Deleting the App removes its local data. It does not delete data already sent to PostHog or Superwall. To exercise your rights for those records, contact plumpscroll@gmail.com. We may need additional details to locate records because the App has no user account. The Company will respond within thirty (30) days.

11. Children's privacy

The App is for users aged 13 and over. The data practices described in this Policy also apply to users aged 13 to 17. The App asks for an age bracket during setup to tailor its messaging. That answer stays on the device; it is not proof of age. If you believe a child under 13 has used the App, contact the Company using section 14 so we can investigate and delete any associated personal data we can identify.

12. Notice to California residents

The Company does not sell personal information and does not share personal information for cross-context behavioural advertising, as those terms are defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act. These restrictions on sale and advertising-related sharing also apply to users aged 13 to 17.

13. Changes to this policy

The Company may amend this Policy from time to time. The effective date stated at the top of this page reflects the current version. Material changes will be notified within the App before taking effect. Continued use of the Services following an amendment constitutes acceptance of the amended Policy.

14. Contact

Questions regarding this Policy, or requests to exercise the rights set out in section 10, should be addressed to plumpscroll@gmail.com.

For assistance with the App generally, contact plumpscroll@gmail.com.