Privacy Policy

1. Information the App Processes

The information the Service processes is set out below, distinguishing what is processed entirely on your device from what is transmitted off it. Nothing is sent to a server operated by us.

1. Health and motion information (step count): With your permission, we read your step count for the current day from iOS Health (HealthKit) and from this device's motion coprocessor. The step count is used solely to determine whether the conditions for lifting an app restriction are met and to display it on screen, and it is stored on your device. It is never transmitted to our servers or to any other external destination.
2. App restriction information: The applications you select for restriction are designated through Apple's Family Controls framework. By the design of that framework, the names and identifiers of the applications you select are not visible to us or to the Service. We cannot know which applications you have chosen to restrict.
3. Now-playing information: With your permission, we obtain information about the track currently playing on your device and display it on screen. This information is used only for display; it is neither stored nor transmitted externally.
4. Purchase information: If you purchase a Paid Plan, information such as your purchase status, purchase date and time, and product identifiers is collected through RevenueCat, Inc., described in Section 4.
5. Device information: Incidental to the purchase management described above, RevenueCat, Inc. automatically collects information such as your device type, operating system version, country or region, and an anonymous user identifier that does not enable us to identify you.

The Service does not collect your name, address, telephone number, email address, or any other information that directly identifies you. No account registration is required to use the Service.

2. Purposes of Use

We use the information collected under the preceding section for the following purposes.

1. To provide and maintain the Service and to deliver features that do not require user authentication.
2. To provide Paid Plans and manage purchase status.
3. To respond to your inquiries.
4. To respond to conduct that violates our Terms of Service or other rules.
5. To notify you of changes to this Policy or our Terms of Service.
6. To identify and fix defects in the Service.

We do not use health information or app restriction information for advertising or for measuring advertising effectiveness. We do not sell or rent this information to third parties.

3. Handling of Health Data

We handle information obtained from HealthKit and from this device's motion coprocessor as follows.

• We use it solely for the purpose of providing you with the features of the Service.
• We do not use it for advertising, marketing, or similar purposes.
• We do not disclose, sell, or share it with data brokers, information resellers, or other third parties.
• We do not transmit it to our servers without your express consent. In the Service as it currently stands, no such transmission takes place at all.

4. Third Parties and Information Collection Modules

The Service uses the following third-party services, which may collect information. Each company's handling of information is governed by its own privacy policy.

• RevenueCat, Inc. (United States): used to manage Paid Plan purchase status. It collects purchase status, purchase history, an anonymous user identifier, and information about your device and operating system.
• Apple Inc.: used to distribute the App and to process payment for Paid Plans. Payment information is processed by Apple, and we do not receive credit card numbers or other payment method details.

Except as described above, we do not provide collected information to third parties without obtaining your prior consent, other than where one of the following applies.

• Where we entrust all or part of the handling of information to a contractor to the extent necessary to achieve the purposes of use.
• Where information is provided in connection with a succession of business due to a merger or other cause.
• Where required by law.
• Where it is necessary to cooperate with a national government body, a local government, or a party entrusted by either of them in carrying out duties prescribed by law, and obtaining your consent risks impeding the performance of those duties.
• Where otherwise permitted under the Act on the Protection of Personal Information of Japan or other applicable law.

5. Stopping Collection

You may revoke the Health, Motion, Screen Time, and Media permissions granted to the Service at any time from the iOS Settings app. If you revoke a permission, we immediately stop collecting information through it.

If you revoke a permission, some or all of the Service may become unavailable.

If you delete the App from your device, the step count data and app restriction settings stored on that device are removed from it.

6. Retention Period

Information stored on your device is retained on that device until you delete the App.

Purchase information is retained by the third parties described in Section 4 for the period necessary to manage purchases and to keep records as required by law.

7. Disclosure, Correction, and Suspension of Use

If we receive a request for disclosure from you under the Act on the Protection of Personal Information of Japan, we will verify your identity and make the disclosure without delay. However, we may withhold all or part of the disclosure where doing so would fall under any of the following, in which case we will notify you without delay.

• Where it risks harming the life, body, property, or other rights or interests of you or a third party.
• Where it risks seriously impeding the proper conduct of our business.
• Where it would otherwise violate the law.

If we receive a request from you to correct, add to, or delete information on the ground that its content is not factual, or to suspend its use or erase it, we will carry out the necessary investigation without delay, take the necessary measures based on the results, and notify you accordingly.

Because the Service has no accounts, we may be unable to identify you on our own. In that case, we may ask you to provide additional information, such as a purchase identifier, in order to respond to your request.

8. Users Outside Japan

The Service is available to users outside Japan. The controller responsible for your personal data is our company, identified in Section 10.

For users in the European Economic Area (EEA) or the United Kingdom, our legal bases for processing are as follows.

• Information processed through the Health, Motion, Screen Time, and Media permissions: your consent (GDPR Article 6(1)(a)). You may withdraw consent at any time by revoking the relevant permission in the iOS Settings app.
• Managing Paid Plan purchase status: performance of a contract (Article 6(1)(b)).
• Identifying defects and keeping the Service secure: our legitimate interests (Article 6(1)(f)).

We are located in Japan and information is handled in Japan. Japan has been recognised by the European Commission and by the United Kingdom as providing an adequate level of protection for personal data, so transfers from the EEA and the UK to Japan require no additional safeguards. Separately, purchase information is handled in the United States through RevenueCat, Inc., as described in Section 4.

If you reside in the EEA or the UK, you have the right under applicable law to request access to, rectification of, or erasure of information about you, to request restriction of its processing, to data portability, to object to processing, and to lodge a complaint with a supervisory authority.

If you reside in California or another U.S. state, you may have the right under applicable law to know the categories of information collected and the purposes of its use, and to request its deletion. We do not sell the personal information of any user.

Retention periods are described in Section 6. To exercise any of these rights, please contact us using the details in Section 10.

9. Children's Privacy

The Service is not directed to children under 13. We do not knowingly collect information from children under 13. If we learn that we have collected information from a child under 13, we will delete it promptly.

10. Contact

For inquiries regarding this Policy, please contact us at the following.

• Reright, Inc.
• Tenjin First Building 7F, 4-6-28 Tenjin, Chuo-ku, Fukuoka 810-0001, Japan
• Personal Information Protection Manager: Takuya Matsuda
• Email: hello@dopawalk.com

11. Changes to This Policy

We will amend this Policy as necessary. However, where a change requires your consent under applicable law, we will obtain your consent by the method we prescribe.

When we amend this Policy, we will publicize the content of the amended Policy and its effective date by displaying it within the App or on our website.