Privacy Policy for Subtide
Effective date: October 18, 2026 Developer (data controller): Boris Spiro, individual developer Contact: spiroboris91@icloud.com
Subtide (“the App”) is designed to work without an account and to keep your data on your device. This policy explains what is collected, why, and your rights under the GDPR, the UK GDPR, the CCPA/CPRA and similar laws.
1. Data you create in the App
Everything you enter in the App is stored locally on your device: the contracts and subscriptions you add (name, type, country, amount, dates, minimum term, notice period, renewal, customer or account number, the provider’s address and cancellation page), your decisions (kept, cancelled, checked), and the name and address you save for letters. The widget and the Lock Screen countdown read the same data from a storage area shared only between the App and its widget on your device. We do not have access to any of it. If you delete the App, this data is deleted with it.
2. Letters you send
The App fills in cancellation and refund letters from templates. A letter leaves your device only when you share, copy or send it yourself, and only to the recipient and through the app you choose (for example Mail). We do not receive a copy.
3. Purchases
Subscriptions and purchases are processed by Apple through the App Store. Apple handles payment details; we never see your card number. We receive an anonymous transaction record from Apple to unlock the features you paid for. See Apple’s privacy policy at https://www.apple.com/legal/privacy/.
4. Anonymous usage analytics (only with your consent)
With your explicit consent, the App sends anonymous usage events (for example “screen opened”, “purchase completed”, device model, OS version, app version, country) to Yandex AppMetrica, an analytics service operated by Yandex. This helps us understand which features are used and find crashes.
- No advertising identifier (IDFA) is collected, and the App does not track you across other companies’ apps or websites.
- You can withdraw consent at any time in Settings → Share anonymous usage data. After that, no further events are sent.
- AppMetrica may process data on servers in the European Union (Finland) and in the Russian Federation under standard contractual clauses. AppMetrica’s own policy: https://appmetrica.yandex.com/about/privacy-policy
- Legal basis: your consent (GDPR Art. 6(1)(a)).
5. Crash and diagnostic data
Apple may share aggregated crash and performance data with us if you have enabled “Share with App Developers” in your iOS settings. We use it only to fix bugs.
6. Notifications
If you allow notifications, the App schedules local reminders on your device (for example, before the last day to cancel a contract or before a free trial ends). Buttons in these notifications, such as “Remind me tomorrow”, act only on your device. No notification data leaves your device.
7. What we do not do
- We do not sell or share your personal information (as defined by the CCPA/CPRA).
- We do not use your data for advertising.
- We do not knowingly collect data from children under 13. The App is not directed to children.
8. Data retention
Analytics events are retained by AppMetrica for up to 24 months and then deleted or aggregated. Local data stays on your device until you delete it or the App.
9. Your rights
Depending on where you live, you may have the right to access, correct, delete or export your personal data, to withdraw consent, and to lodge a complaint with a supervisory authority. Because analytics data is anonymous and local data never reaches us, most requests can be fulfilled by withdrawing consent in Settings or deleting the App. For anything else, email spiroboris91@icloud.com and we will respond within 30 days.
10. Changes
We will post any changes on this page and update the effective date. Material changes will be announced in the App.
11. Contact
Boris Spiro — spiroboris91@icloud.com