1. Introduction
369 Rituals is operated from England, United Kingdom. We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains what information we collect, how we use it, and your rights in relation to it. It applies to the 369 Rituals mobile application (“App”) and website at 369rituals.com.
2. Who We Are (Data Controller)
The data controller responsible for your personal data is:
369 Rituals
England, United Kingdom
Email: info@369rituals.com
3. What Data We Collect
We collect only the minimum data necessary to provide the service:
- Purchases: All purchases are processed by Apple through the App Store. We do not receive or store your payment details, and no third-party subscription service is used.
- Usage data (on-device only): Your ritual logs, streaks, and preferences are stored locally on your device using SwiftData. This data is never transmitted to our servers.
- Reminders: Ritual reminders are local notifications scheduled entirely on your device. No push token is created and nothing is sent to any server.
- Analytics: The App contains no analytics or tracking code. We collect no usage data whatsoever.
4. Legal Basis for Processing (UK GDPR)
We process your personal data on the following legal bases under UK GDPR Article 6:
- Article 6(1)(b) — Contract: Purchases are processed by Apple to perform the contract with you (providing access to premium features).
- Article 6(1)(f) — Legitimate interests: Sending notifications to remind you of rituals you have opted into supports your use of the App and is proportionate to your privacy rights.
- Article 6(1)(a) — Consent: Where we rely on your consent (e.g. notification permission), you may withdraw it at any time without affecting the lawfulness of prior processing.
5. How We Use Your Data
We use your data exclusively to:
- Provide and maintain the App and your subscription
- Send ritual reminder notifications (with your permission)
- Improve the App through your direct feedback
- Comply with our legal obligations
We do not sell, rent, or share your personal data with third parties for marketing purposes.
6. Third-Party Services
Apple: Apple processes your App Store purchase and may collect data in accordance with Apple’s Privacy Policy. We do not receive analytics or personal data from Apple.
7. Data Retention
We hold no subscription data ourselves — purchases are managed by Apple. On-device data (ritual logs) is retained until you delete the App or clear App data.
8. Data Storage and Security
Your on-device data is stored locally and protected by iOS device encryption. We take reasonable technical and organisational measures to protect your data against unauthorised access, loss, or disclosure.
9. Your Rights Under UK GDPR
If you are located in the UK or EEA, you have the following rights:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete data.
- Right to erasure: Request deletion of your personal data where there is no lawful reason to continue processing it.
- Right to restriction: Request that we restrict processing of your data in certain circumstances.
- Right to data portability: Request transfer of your data in a structured, machine-readable format.
- Right to object: Object to processing based on legitimate interests.
- Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior lawful processing.
To exercise any of these rights, contact us at info@369rituals.com. We will respond within one calendar month.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.
10. California Privacy Rights (CCPA)
If you are a California resident, you have the right to know what personal information we collect about you, the right to request deletion, and the right to opt out of the sale of your personal information. We do not sell your personal information. To exercise your California privacy rights, contact us at info@369rituals.com.
11. Children’s Privacy
The App is not directed to children under the age of 13 (or under 16 in the UK/EEA). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us immediately at info@369rituals.com and we will delete it promptly.
12. Tracking and Advertising
We do not use advertising trackers, third-party advertising networks, or cross-app tracking. We do not use the Identifier for Advertisers (IDFA). Apple’s App Tracking Transparency framework is respected and no tracking occurs without explicit permission.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the effective date at the top of this page and, where appropriate, by an in-app notice. Your continued use of the App after changes are posted constitutes your acceptance of the revised policy.
14. Contact Us
369 Rituals, England, United Kingdom
Email: info@369rituals.com