Privacy Policy

Rizzard OÜ, a limited liability company registered in Estonia (registry number 17283924), located at Narva mnt 5, 10117 Tallinn, Estonia, operates the Roostavo mobile application ("App") and website at roostavo.com ("Website") (collectively, the "Service").

This Privacy Policy explains how we collect, use, share, and protect your personal information when you use the Service. We are committed to protecting your privacy in compliance with the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act (CCPA), and other applicable data protection laws.

The short version: Roostavo is a device-first alarm app. We do not operate a backend server that receives your alarm, camera, motion, location, or mission data. Almost everything stays on your iPhone. The limited data that leaves your device covers subscriptions, product analytics showing which screens and features are used, optional website quiz download-link requests if you choose to leave an email, and optional, consent-based install attribution, as described below. We do not record your screen.

1. Lawful Basis and Transparency

We process personal data based on:

Contract: To provide the Service (e.g., alarm and mission functionality, subscription entitlements).

Consent: For IDFA-based advertising attribution (via Apple's App Tracking Transparency), for product analytics where you are in the European Economic Area, the United Kingdom, or Switzerland, for optional website quiz download-link emails, and for optional device permissions (Camera, Motion & Fitness, Location, Screen Time).

Legitimate Interests: For operating and securing the Website, for preventing repeated use of the free access period, for product analytics outside the European Economic Area, the United Kingdom, and Switzerland (which you can switch off at any time, as described in Section 2h), and for fraud prevention in subscription management, balanced against your rights.

Legal Obligation: To comply with laws (e.g., tax and accounting requirements).

We inform you of data collection via this Privacy Policy, accessible on roostavo.com and in-app. Processing is fair, not detrimental, unexpected, or misleading.

2. Information We Collect

We minimize data collection for specific purposes. Roostavo does not operate its own backend; the following data is processed as described:

a. Account (optional, local only) Data: If you use Sign in with Apple, we receive your first name (if you choose to share it). Roostavo uses Sign in with Apple only to set up your local profile. Your name is stored locally on your device; your email address and Apple user identifier are not persisted by Roostavo and are never transmitted to a Roostavo server (we do not operate one). Where product analytics is active, your first name is also sent to our analytics processor and associated with your analytics record, as described in Section 2h. Your Apple user identifier is not used as an analytics identifier and is not sent to our analytics processor. Purpose: Personalizing your home screen and letting returning users skip onboarding.

b. App Settings and Onboarding Data: Alarm schedules, mission type and targets, wake times, onboarding questionnaire answers, UI preferences, and streak data. Purpose: Core alarm and mission functionality and personalization. Storage: Locally on your device (including a shared App Group container used by the Screen Time extension). Your alarm schedules, alarm labels, and streak data never leave your device. Where product analytics is active (Section 2h), a limited subset of your onboarding answers is sent to our analytics processor: your chosen stop method, your target wake-up time, whether you want to block apps in the morning, and whether you are happy with your current wake-up time. No other questionnaire answers are sent.

c. Mission and Sensor Data: Camera frames (scan and exercise missions), step counts, accelerometer data, and (for speedometer missions) GPS speed plus walking pace during active missions. Purpose: On-device mission verification – object detection and body-pose repetition counting via Apple's Vision framework, movement verification via Apple's CoreMotion framework, and speed verification via Apple's Core Location and Core Motion frameworks. Storage & Sharing: Processed in real time, entirely on your device, using Apple's on-device frameworks (Vision, CoreMotion, Core Location, AVFoundation). Camera frames and location readings are never stored, uploaded, or shared. Where product analytics is active, we record only that a mission of a given type was started or completed — never any image, video, frame, sensor reading, route, or other content from the mission itself. We do not perform facial recognition, biometric identification, or identity verification, and we do not extract or store face geometry, face templates, or biometric identifiers.

d. Screen Time Selections (optional) Data: The apps or app categories you select for morning blocking, and the block duration. Purpose: Morning app blocking, if you enable it. Storage & Sharing: Handled on-device by Apple's Screen Time frameworks (FamilyControls, ManagedSettings, DeviceActivity). Apple's frameworks are designed so that we cannot see which apps you select or block. This data does not leave your device. Where product analytics is active, we receive only whether you chose to use morning app blocking during onboarding — never which apps or categories you selected.

e. Subscription and Free Access Data: The date your free access period began and ends, the expiry time of any limited-time offer shown to you (stored on your device), subscription status, and reminder preference (stored locally); transaction and entitlement data processed via Apple's App Store (StoreKit) and Superwall (paywall events, device/app identifiers, subscription status signals). The start of your free access period is additionally stored in your device keychain and in your iCloud key-value storage, so that the free access period is not restarted if you delete and reinstall the App. This record is deliberately retained when you delete the App or delete your local profile. Purpose: Providing free access to the App during the initial free access period, providing access after that period if you subscribe or purchase, managing subscriptions, preventing repeated use of the free access period, and (optionally) reminding you locally before your free access ends. Apple acts as merchant of record; we never receive your payment card details.

f. Advertising Attribution and Measurement (optional / consent-based) Data: Your device's Identifier for Advertisers (IDFA), only if you grant permission via Apple's App Tracking Transparency (ATT) prompt; conversion and purchase event signals (e.g., free access started, subscription purchase); and privacy-preserving attribution data via Apple's SKAdNetwork / AdAttributionKit, which does not identify you individually and works without ATT consent. Purpose: Understanding which advertising campaign led to your install and measuring ad effectiveness. IDFA-based attribution is processed via Superwall.

We use advertising measurement partners to understand which campaigns lead to installs and purchases. Today the App integrates Meta's software development kit. We also expect to add Google Ads as a measurement partner; where we do, it receives the same categories of conversion and purchase event data on the same basis described here. Two different things happen depending on your ATT choice:

The App works identically whichever choice you make. No personal data such as your name, alarm data, or camera content is ever shared with advertising partners. We do not use Firebase or AppsFlyer SDKs in the App.

Our product analytics processor (PostHog, Section 2h) is used for first-party product analytics only. It does not receive your IDFA, does not track you across other companies' apps or websites, and is not used for advertising or ad targeting.

g. Website Data (roostavo.com only) Data: Standard request metadata (IP address, request headers, TLS metadata) and any security/session cookies set by our hosting provider Cloudflare. If you complete the optional morning-person quiz and ask us to email a download link, we send that message from hey@roostavo.com via Cloudflare Email Sending, record the email, your quiz type, a compact answer code, an optional first name you typed for the badge, and any campaign parameters present on the quiz URL in PostHog Cloud EU, and post the same details to Slack so we can see new requests. We do not keep quiz leads in a Roostavo database. Purpose: Serving and securing the Website, sending the App Store link you asked for, and understanding who requested it. Legal Basis: Legitimate interests for request metadata; consent for the quiz email. Note: Our Website code sets no analytics or advertising cookies. The quiz result and badge are shown without an email.

h. Product Analytics

Data: A randomly generated analytics identifier created on your device, together with your first name where you have provided it via Sign in with Apple; in-app events such as screen and paywall views, onboarding step completion and the limited subset of onboarding answers listed in Section 2b, alarm creation, mission start and completion, mission type, free access period start and end, offer displayed and offer expiry, and subscription purchase or restore; and technical context such as app version, iOS version, device model, language, and time zone. Your IP address is used in transit to derive an approximate country and is not stored.

Purpose: Understanding how the App is used, so that we can find and fix problems, measure whether features work, and improve onboarding and the App generally.

Processor and location: PostHog Inc., using PostHog Cloud EU. Data is stored on servers in Frankfurt, Germany.

What we do NOT send to analytics: camera frames or any image content; the content or results of missions beyond the fact that a mission of a given type was started or completed; your configured alarm times or alarm labels (your target wake-up time from onboarding is sent, as described in Section 2b); the apps or categories you select for Screen Time blocking; your email address from the App; your Apple user identifier; or your IDFA. We do not record your screen. We do not build advertising profiles from analytics data. Website quiz download requests are a separate flow and may include your email in PostHog, as described in Section 2g.

Legal Basis and how to switch it off:

If you are in the European Economic Area, the United Kingdom, or Switzerland: your consent. We ask you when you first set up the App, and no analytics data is collected unless you agree. You can change your answer at any time in the App under Settings → Share usage data.

If you are elsewhere: our legitimate interest in measuring and improving the App. Analytics is active by default and you can switch it off at any time in the App under Settings → Share usage data.

In both cases, switching it off stops further collection. The App works identically either way, and access to the App and its paid features never depends on whether you allow analytics.

Explicitly not collected by Roostavo: no cloud upload of camera photos or video; no facial recognition or biometric data; no third-party AI analysis of your photos; no user accounts on a Roostavo server; no cross-app tracking without your ATT consent; no session replay or screen recording; no microphone recording; no sale of personal data.

3. Purpose and Data Minimization

We collect only data necessary for declared purposes. Mission verification runs entirely on your device. The data that leaves your device is limited to what is needed for your subscription, for product analytics where it is active, for advertising measurement as described in Section 2f, and for optional website quiz leads described in Section 2g. We do not process data beyond stated purposes.

4. Data Accuracy and Security

Accuracy: Data such as your name and preferences is under your direct control in the App's settings. Contact hello@roostavo.com with any concerns.

Security: The most sensitive data (camera, motion, location speed, Screen Time) never leaves your device by design. Data that is transmitted (e.g., subscription validation and product analytics events) is encrypted in transit, and analytics data is stored on servers within the European Union. We implement industry-standard technical and organizational measures; no system is fully secure.

5. Storage Limitation

On-device data (settings, onboarding answers, streaks, local name): stored until you delete it or delete the App. Deleting the App deletes this data.

Camera frames and sensor data: not stored at all – processed in real time and discarded.

Free access record stored in your device keychain and iCloud key-value storage: retained for as long as needed to prevent the free access period from being restarted. This record is deliberately not deleted when you delete the App, delete your local profile, or reinstall — that is what makes the once-per-Apple-Account limit work. It contains only the date your free access began, and no name, email address, or contact details.

Product analytics data: retained for a maximum of 12 months from collection, then deleted.

Website quiz download requests (email, type, answer code, optional name, campaign parameters): stored in PostHog Cloud EU for a maximum of 12 months, and visible in our Slack workspace per that workspace's retention. Ask us to delete the PostHog record via hello@roostavo.com.

Subscription records: retained by Apple and Superwall per their policies; our related business records are kept as required by Estonian tax and accounting law (generally 7 years).

Attribution data (IDFA-based): retained by Superwall per its privacy policy; you can withdraw ATT consent at any time in iOS Settings.

6. Privacy by Design

We embed privacy by design via: on-device processing of all mission, camera, motion, location speed, and Screen Time data (speedometer missions read GPS speed and walking pace on-device and do not store a route); no Roostavo backend or cloud database holding your alarm, mission, or Screen Time content; no session replay or screen recording; product analytics hosted in the European Union under a 12-month retention limit, with no advertising identifiers attached, switchable off at any time, and requiring your prior consent in the EEA, UK, and Switzerland; Sign in with Apple used only for local profile setup, without persisting email or identifiers and without using your Apple user identifier for analytics; IDFA-based attribution strictly gated behind Apple's ATT consent; preference for Apple's privacy-preserving SKAdNetwork/AdAttributionKit measurement; and no analytics or advertising cookies on the Website.

7. Controller-Processor Contracts

We work with the following providers:

Apple Inc.: Authentication (Sign in with Apple), payments and subscriptions (App Store / StoreKit – Apple is merchant of record for in-app purchases), alarm delivery (AlarmKit), Screen Time / Family Controls, local notification delivery, iCloud key-value storage (used to record the start of your free access period so it is not restarted by reinstalling the App), privacy-preserving ad attribution (SKAdNetwork / AdAttributionKit), and the App Store review prompt. Apple acts as an independent controller for its own services (see apple.com/legal/privacy).

Superwall Inc. (USA): Paywall and subscription infrastructure and install attribution. Processes device/app identifiers, paywall events, and subscription status signals via StoreKit; processes your IDFA only when you grant ATT consent (see superwall.com/privacy). Roostavo does not operate its own payment backend.

PostHog Inc. (PostHog Cloud EU): Product analytics and optional website quiz download-request records. Processes a randomly generated analytics identifier, your first name where you have provided it, in-app event data, and technical device context, in order to help us understand and improve how the App is used; and, if you ask for a download link from the Website quiz, your email, quiz type, answer code, optional name, and campaign parameters. Data is stored within the European Union. PostHog acts as our processor under a data processing agreement (see posthog.com/privacy).

Advertising measurement partners – Meta Platforms, Inc. (USA/Ireland) and Google Ads (Google Ireland Ltd. / Google LLC): Receive conversion and purchase event data for advertising measurement, as described in Section 2f – with your IDFA only if you grant ATT consent, and without any advertising identifier if you decline (see facebook.com/privacy and policies.google.com/privacy). Meta's software development kit is integrated in the App; Google Ads may be added as a measurement partner on the same basis.

Slack Technologies, LLC (Salesforce): Internal notifications when someone requests a download link from the Website quiz. Processes the email address, quiz type, optional name, and campaign parameters (see slack.com/trust/privacy/privacy-policy).

Cloudflare Inc. (USA): Website hosting and security for roostavo.com, and transactional email (download links from hey@roostavo.com). Processes visitor request metadata such as IP address and request headers, and the recipient address of emails you ask us to send (see cloudflare.com/privacypolicy).

We maintain data processing agreements or rely on processor/partner terms with these providers as applicable. These stipulate responsibilities, security measures, and data return/deletion upon contract end.

8. Data Subject Rights

You have the following rights:

Informed: This Policy details data practices.

Access: Request a copy of your data.

Rectification: Correct inaccurate data.

Erasure: Delete your data. Note that most Roostavo data exists only on your device – deleting the App deletes it, and we have no server-side copy. For product analytics data, contact hello@roostavo.com quoting the analytics ID shown in the App under Settings → About; if you no longer have access to the App, give us your first name and the approximate date you installed it and we will do our best to locate the records. Please note that the free access record described in Sections 2e and 5 is retained for abuse prevention and is not deleted on request; it contains only a date and cannot be used to identify or contact you.

Restriction: Limit processing.

Portability: Export data in a machine-readable format (where applicable).

Object: Oppose processing based on legitimate interests. Where product analytics runs on our legitimate interest (see Section 2h), you can give effect to this immediately by switching it off in the App under Settings → Share usage data.

Automated Decisions: No decisions producing legal or similarly significant effects are made by automated means. Mission verification is an on-device technical function under your control.

Withdraw Consent: Withdraw consent at any time where applicable – in particular, ATT consent can be withdrawn in iOS Settings → Privacy & Security → Tracking, and product analytics can be switched off in the App under Settings → Share usage data.

For California residents (CCPA):

Right to Know: Request details about the personal information we collect, use, or disclose.

Right to Delete: Request deletion of your personal information, subject to exceptions.

Right to Opt-Out: Rizzard OÜ does not sell personal information, so no opt-out is needed.

Exercise rights via hello@roostavo.com. We respond within one month, extending if complex. Requests may be denied if legally permitted (e.g., unverifiable identity).

9. Data Protection Inquiries

For data protection inquiries or supervisory authority interactions, contact us at hello@roostavo.com.

10. International Data Transfers

As an Estonian company, we are established in the EU/EEA, and your data is predominantly processed on your own device. Product analytics data and session recordings are processed and stored within the European Union (Frankfurt, Germany). Where our providers (Superwall, Meta, Google, Cloudflare) process data in the United States, we ensure such transfers comply with GDPR/UK GDPR – via the EU–U.S. Data Privacy Framework where the provider is certified, and/or Standard Contractual Clauses – and CCPA where applicable.

11. Data Breach Reporting

If a breach risks your rights and freedoms, we notify the Estonian Data Protection Inspectorate (AKI) within 72 hours and affected users without undue delay. Processors must notify us immediately.

12. How We Use Your Information

We process your information to provide the Service (contract), pursue legitimate interests (Website operation, SKAdNetwork-based measurement, prevention of repeated free access, product analytics outside the EEA, UK, and Switzerland, fraud prevention), comply with legal obligations, or with your consent (product analytics in the EEA, UK, and Switzerland, ATT-based attribution, device permissions). Uses include:

Service Delivery: Firing alarms, verifying missions on-device, enabling morning app blocking, and managing your free access period and subscription entitlements.

Product Improvement: Understanding which screens, features, and onboarding steps are used or abandoned, so that we can fix problems and improve the App. This never includes your camera view, mission content, configured alarm times, or Screen Time selections, and never involves recording your screen.

Improvement & Marketing Measurement: Measuring which advertising campaigns lead to installs and purchases – via Superwall, Apple's privacy-preserving SKAdNetwork/AdAttributionKit, and conversion data shared with our advertising measurement partners as described in Section 2f.

Communication: Responding to support requests; optional local notifications (e.g., a reminder before your free access ends) that you can disable.

Compliance: Meeting legal requirements (e.g., GDPR, CCPA) and preventing fraud.

13. Sharing Your Information

We share information only as follows:

Apple: Sign in with Apple authentication flow; subscription and payment processing for in-app purchases through the App Store; iCloud key-value storage of the start date of your free access period; privacy-preserving ad attribution via SKAdNetwork/AdAttributionKit.

Superwall: Paywall and subscription-related events and identifiers; IDFA only when ATT consent is granted, for install attribution.

PostHog: Product analytics events, a randomly generated analytics identifier, your first name where you have provided it, and the limited subset of onboarding answers described in Section 2b, for measuring and improving how the App is used; and, if you request a download link from the Website quiz, your email and quiz details as described in Section 2g. Stored in the European Union.

Advertising measurement partners (Meta Platforms, Inc.; Google Ads): Conversion and purchase event data for advertising measurement, with your IDFA only if you grant ATT consent and without any advertising identifier if you decline (see facebook.com/privacy and policies.google.com/privacy).

Cloudflare: Website visitor request metadata, for hosting roostavo.com; and the recipient address when we send a download-link email you requested.

Slack: Internal notification of Website quiz download requests (email, quiz type, optional name, campaign parameters).

Legal Compliance: We may share data to comply with laws, respond to authorities, or protect our rights.

We do not: sell personal information (as defined by the CCPA); share camera, mission content, motion, Screen Time, or alarm data with anyone (it stays on your device); share your name, email address, or any content you create with advertising partners; share an App email address with any analytics partner (the App does not collect one); record or share recordings of your screen; or upload photos or biometric data to any processor.

User-initiated links (not data processors in the usual sense): tapping Contact Us opens your Mail app addressed to hello@roostavo.com; tapping Rate Roostavo opens Apple's system review prompt.

14. Child Users

The Service is not directed at children under 13. You must be at least 13 years old to use the Service. By using the Service, you represent and warrant that you meet this age requirement. We do not verify age automatically. If we learn that a user is under 13, we will block their access to the Service and delete any personal data we hold about them without undue delay.

15. Updates to This Policy

We may update this Policy to reflect Service changes or legal requirements. Updates will be posted on roostavo.com at least 7 days before taking effect, with in-app notices for material changes where required. Continued use after updates constitutes consent.

16. Contact

Rizzard OÜ is the data controller under GDPR.

Rizzard OÜ
Narva mnt 5
10117 Tallinn
Estonia

Email: hello@roostavo.com

For EU users, you can lodge a complaint with a supervisory authority (e.g., the Estonian Data Protection Inspectorate at www.aki.ee) or the authority of your habitual residence. For UK users, you can contact the Information Commissioner's Office at www.ico.org.uk. For California residents, you can contact the California Attorney General.

17. Additional Information for California Residents

We collect personal information (e.g., device identifiers, your first name, subscription data, and product usage data) for the purposes outlined above. We do not sell your personal information. In the past 12 months, we have disclosed subscription/attribution-related identifiers to Superwall, analytics identifiers, your first name, and usage data to PostHog, conversion and purchase events to our advertising measurement partners, and website request metadata to Cloudflare, as described in Sections 7 and 13. To exercise your CCPA rights, contact us at hello@roostavo.com.