Privacy Policy
Last Updated: October 2026
Developer: Kaan Dındış
Contact Email: madebykd.app@gmail.com
## 1. Introduction
This Privacy Policy explains how Subzly ("the App"), developed by Kaan Dındış, handles your data.
Subzly is a local-first subscription tracker. All subscription records and user preferences are stored directly on your device using SwiftData. We do not operate our own backend servers, and your subscription data is never transmitted to external systems.
The only exceptions are subscription-related information processed securely by Apple's In-App Purchase infrastructure and RevenueCat, as described in Section 5.
## 2. What Data We Collect
Subzly collects only the minimum data required for core functionality.
The App does NOT collect:
- Email address
- Phone number
- Location data
- Advertising identifiers (IDFA)
- Cross-app or cross-website behavioral data
- Crash reports or remote analytics
### 2.1 User-Provided Data (Stored Locally Only)
#### A. Profile Information
Display name — stored via UserDefaults. The app starts with a default placeholder name that you can change at any time in Settings. The display name is used only inside the app on your device.
Profile photo (optional) — if you choose to set one, it is selected from your photo library and stored as a JPEG file on your device. It is never uploaded or shared.
#### B. Subscription Records
Each subscription entry may include:
- Name, category, billing cycle (weekly / monthly / yearly / free trial)
- Price and currency
- Next payment date, trial end date
- Reminder settings and notification identifier
- Logo preference (SF Symbol, letter, or brand catalog)
- Creation timestamp
All records are stored locally on your device. No data is sent to a remote server.
#### C. App Preferences
Stored locally on your device:
- Selected theme, language, and currency
- Notification preferences
- Onboarding status and selections
- Avatar display mode (photo / SF Symbol / letter)
### 2.2 Automatically Generated Local Data
- Local notification identifiers for scheduled reminders
- Local status used to present onboarding, the purchase screen, or the locked access screen
No analytics SDKs, logging services, or remote data collection mechanisms are used in the app.
### 2.3 A Note on "Analytics" in the App
The Analytics view within Subzly (weekly / monthly / yearly totals and charts) is a local computation module only. It calculates summaries from the subscription records stored on your device and does not transmit any data externally.
Analytics totals include scheduled expense charges only. Income tracking is not available in the app. Access to Analytics requires an active Subzly Pro subscription.
## 3. How We Use Your Data
All data remains on your device and is used solely to:
- Display and manage your subscription records
- Trigger local reminder notifications
- Manage Subzly Pro access
- Personalize the interface (theme, language, currency, profile)
- Present the appropriate onboarding, purchase, or locked access screen
Subzly does not:
- Track users across apps or websites
- Sell or share personal data
- Transmit subscription or profile data to external servers
- Use advertising identifiers
- Use third-party analytics or crash-reporting SDKs
## 4. Permissions We Request
### 4.1 Notifications
Used solely for local, device-scheduled subscription reminders. Subzly does not send remote push notifications from a server. All reminders are scheduled directly on your device.
You can enable or disable notifications in the app's Settings tab. If permission is denied, the app will prompt you to update your preferences in iOS Settings.
### 4.2 Photo Library
Requested only if you choose to add a profile photo. Your photo is saved locally on your device and is never uploaded or shared.
### 4.3 App Tracking Transparency (ATT)
ATT is not requested.
Subzly does not use advertising identifiers (IDFA), does not engage in cross-app tracking, and does not use any tracking-enabled SDK. No ATT permission dialog is shown.
- NSPrivacyTracking = false
- Tracking = Disabled
- IDFA = Not used
- ATT pop-up = Not shown
This is also reflected in the app's Privacy Manifest (PrivacyInfo.xcprivacy), which declares NSPrivacyTracking = false, no tracking domains, and no collected data types.
Subzly uses Apple's AdServices framework to measure attribution from Apple Search Ads campaigns. This does not require ATT consent and does not collect any personally identifiable information.
## 5. Third-Party Services
Subzly uses a limited set of third-party services solely for subscription management.
### 5.1 Apple App Store (Payments)
All purchases are handled securely by Apple. Subzly never receives or stores your payment details.
### 5.2 RevenueCat (Subscription Status)
RevenueCat is used only to verify whether your Subzly Pro subscription is active, including subscription, renewal, billing issue, grace period, expiration, refund, and restoration status provided through Apple.
RevenueCat may receive:
- An anonymous App User ID (generated by RevenueCat; not linked to your identity)
- Purchase and subscription status from Apple
- Device and network information (e.g., IP address), handled directly by RevenueCat for fraud prevention and security purposes
- Attribution token from Apple's AdServices framework (used to measure Apple Search Ads campaign performance; contains no personally identifiable information)
RevenueCat does NOT receive:
- Your subscription records or financial data entered in the app
- Your display name or profile photo
- Reminder settings or notification preferences
- Your Analytics calculations or reminder schedules
- Any user-created content
The app itself does not collect or transmit your IP address or any network identifiers. Any such data is handled directly by RevenueCat under its own privacy policy.
RevenueCat Privacy Policy: https://www.revenuecat.com/privacy/
## 6. Data Retention
Since all app data is stored locally on your device:
- Data persists as long as the app is installed
- If your Subzly Pro subscription expires or a billing grace period ends, access to the app is locked, but your locally stored subscription records are not deleted
- Renewing or restoring an eligible subscription allows you to continue with the locally stored data on that device
- Deleting the app permanently removes all local data, including subscription records, preferences, and your profile photo
Subzly does not use iCloud, CloudKit, or any cross-device sync. Your subscription records exist only on the device they were created on.
iOS may include app data in your encrypted iCloud Device Backup if you have that feature enabled in iOS Settings. This is managed entirely by iOS and is not controlled by Subzly. We do not have access to iCloud backups.
You can manually erase all app data at any time via Settings → Clear All Data within the app. Clearing local data or deleting the app does not cancel your Apple subscription.
We do not retain any of your data on external servers.
## 7. Data Security
Your data is protected by iOS platform-level safeguards:
- Secure app sandboxing
- Encrypted device storage (managed by iOS)
We do not have access to the data stored on your device.
## 8. Children's Privacy
Subzly is not directed at children under the age of 13. We do not knowingly collect personal data from children. Deleting the app removes all locally stored data.
## 9. GDPR Compliance (EU Users)
### Right to Access
All data is viewable directly within the app while you have active access.
### Right to Rectification
You can edit or delete any subscription record, preference, or profile data while you have active access.
### Right to Erasure
Use Settings → Clear All Data while you have active access, or delete the app.
### Right to Data Portability
Data is accessible within the app; no automated export tool is currently available.
### Right to Restrict / Object
Subzly does not transmit or process your personal subscription or profile data on external servers.
## 10. CCPA (California Residents)
We do not:
- Sell personal data
- Share personal data with third parties for advertising
- Track users
- Collect advertising identifiers
You may delete all local data through the app while you have active access, or by deleting the app.
## 11. Your Privacy Rights
You may:
- Delete your data via Settings → Clear All Data while you have active access, or by deleting the app
- Control notification permissions via iOS Settings
- Edit or delete any subscription record, preference, or profile information while you have active access
- Manage your Pro subscription via your Apple ID
- Contact us with any privacy-related questions
## 12. Changes to This Privacy Policy
We may update this Privacy Policy as the app evolves. Significant changes may be noted in the app or in App Store release notes. The "Last Updated" date at the top of this document reflects the current version.
## 13. Contact
For any privacy-related questions:
Email: madebykd.app@gmail.com
Developer: Kaan Dındış