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, or mission data. Almost everything stays on your iPhone. The limited data that leaves your device relates to subscriptions and optional, consent-based install attribution, as described below.
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), and for optional device permissions (Camera, Motion & Fitness, Screen Time).
Legitimate Interests: For operating and securing the Website, 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). 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 only (including a shared App Group container used by the Screen Time extension). This data never leaves your device.
c. Mission and Sensor Data Data: Camera frames (scan and exercise missions), step counts, and accelerometer data during active missions. Purpose: On-device mission verification — object detection and body-pose repetition counting via Apple's Vision framework, and movement verification via Apple's CoreMotion framework. Storage & Sharing: Processed in real time, entirely on your device, using Apple's on-device frameworks (Vision, CoreMotion, AVFoundation). Camera frames are never stored, uploaded, or shared. 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.
e. Subscription and Trial Data Data: Trial end date, subscription status, and trial-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). Purpose: Providing access to the App after your free trial, managing subscriptions, and (optionally) reminding you locally before your trial 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; anonymized conversion and purchase event signals (e.g., trial start, 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. If you grant ATT permission, anonymized conversion and purchase event data may be shared with advertising partners (currently Meta and Google Ads) solely to measure ad performance. Note: If you decline the ATT prompt, no IDFA is collected and the App works identically; ad measurement is then limited to Apple's privacy-preserving SKAdNetwork/AdAttributionKit. 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.
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. Purpose: Serving and securing the Website. Legal Basis: Legitimate interests. Note: Our Website code sets no analytics or advertising cookies.
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 sale of personal data.
3. Purpose and Data Minimization
We collect only data necessary for declared purposes. Mission verification runs entirely on your device; only your subscription needs a small amount of data to leave your device, and IDFA-based advertising attribution happens only with your explicit ATT consent. 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, Screen Time) never leaves your device by design. Data that is transmitted (e.g., subscription validation) is encrypted in transit. 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.
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, and Screen Time data; no Roostavo backend or cloud database; Sign in with Apple used only for local profile setup, without persisting email or identifiers; 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, 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.
Meta Platforms, Inc. (USA/Ireland): Receives anonymized conversion and purchase event data — only if you grant consent via Apple's ATT prompt – for advertising measurement purposes (see facebook.com/privacy).
Google Ads (Google Ireland Ltd. / Google LLC): Receives anonymized conversion and purchase event data – only if you grant consent via Apple's ATT prompt – for advertising measurement purposes (see policies.google.com/privacy).
Cloudflare Inc. (USA): Website hosting and security for roostavo.com. Processes visitor request metadata such as IP address and request headers (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.
Restriction: Limit processing.
Portability: Export data in a machine-readable format (where applicable).
Object: Oppose processing based on legitimate interests.
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.
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. Where our providers (Superwall, 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, fraud prevention), comply with legal obligations, or with your consent (ATT-based attribution, device permissions). Uses include:
Service Delivery: Firing alarms, verifying missions on-device, enabling morning app blocking, and managing your trial and subscription entitlements.
Improvement & Marketing Measurement: Measuring which advertising campaigns lead to installs and purchases – via Superwall, Apple's privacy-preserving SKAdNetwork/AdAttributionKit, and, with your ATT consent, anonymized conversion data shared with advertising partners (Meta, Google Ads).
Communication: Responding to support requests; optional local notifications (e.g., trial-ending reminder) 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; 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.
Meta Platforms, Inc.: Anonymized conversion and purchase event data for advertising measurement, only if you consent via Apple's ATT prompt (see facebook.com/privacy).
Google Ads: Anonymized conversion and purchase event data for advertising measurement, only if you consent via Apple's ATT prompt (see policies.google.com/privacy).
Cloudflare: Website visitor request metadata, for hosting roostavo.com.
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, motion, Screen Time, or alarm data with anyone (it stays on your device); share your name, email, or any content you create with advertising partners; 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. 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, subscription 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 and website request metadata to Cloudflare, as described in Sections 7 and 13. To exercise your CCPA rights, contact us at hello@roostavo.com.