Privacy Policy — Fold Clock

Fold Clock has no account and nothing to buy. Its sounds are made on your device, and it never uses the microphone. Your settings and any photo you choose stay on your device. The only thing that leaves it is usage analytics, which you can turn off: which features are used, sent under a random identifier the app creates, which isn’t tied to you.

White, pink and brown noise and the rain are made on your device as they play: there are no recordings to download and nothing is streamed. Fold Clock never uses the microphone and records nothing. Your settings, such as your last sound, volume and sleep timer, your theme and font, and your world clocks and cues, are stored on your device only.

If you set one of your photos as the clock’s background, you choose it in the system photo picker, which gives Fold Clock only the photo you pick and no access to the rest of your library. The photo stays on your device and is never uploaded.

Fold Clock sends usage events so we can see which features are used. Ours record that the app was launched, with its version; that a theme or a font was chosen; that a sound started, with which sound and the sleep timer's length; that a sound stopped, with which sound and why (you paused it, the sleep timer ended, headphones were unplugged, or the Lock Screen paused it); that the phone was set in a new position, such as partially folded or closed; and that night mode was turned on or off. Our analytics library also records that the app was installed, updated, opened or sent to the background, and which screen was showing. When the app starts, the library asks our analytics provider for its settings. Each event carries a random identifier that the app creates on your device the first time it starts and keeps until you delete the app, and a session identifier that changes after 30 minutes without use. It also carries the app's version; your device's maker, model and type, with a generic name such as “iPhone”, never the name you gave it; the iOS version; whether the app came from TestFlight, and whether it runs on a Mac or in a simulator; the screen size and how far the phone is folded (closed, partially open or open); your language and time zone; and whether you're on Wi-Fi or cellular. Events never include your name, email address, photos, contacts or anything you type, and we never ask our analytics provider to connect them to a person, so they aren’t linked to you. Our analytics provider receives the network address each event comes from and may use it to estimate an approximate location, such as a country or city. Fold Clock records no screen sessions and sends no crash reports, and it doesn’t track you across other companies’ apps or websites. You can turn usage analytics off at any time in Settings with Share usage data, and from that moment the app sends nothing. Deleting the app stops the events too, and removes its identifier.

Your settings and photo stay on your device until you delete the app. Usage events are kept for as long as they are useful for understanding how the app is used; they never contain your name, contact details or anything you type.

Because Fold Clock has no account and its identifier is random, we can’t tell which usage events came from you, and deleting the app removes the identifier from your device. You can still email privacy@bravely.dev with any question or request, and we will answer it.

Fold Clock is suitable for all ages and never asks anyone for personal information. We do not knowingly collect personal information from children under 13, or under 16 in places where 16 is the relevant age for information-society services.

Depending on where you live, you have rights over the personal data we hold about you. We honor these rights for everyone who asks, regardless of where you live. • Access — ask what personal data we hold about you and get a copy. • Correction — ask us to fix data that is wrong or incomplete. • Deletion — ask us to delete your personal data by emailing privacy@bravely.dev from the address on your account. Where a product has a built-in Delete Account control you can use that instead; bravely.dev/delete-account explains what applies to each product. • Portability — ask for your data in a portable, machine-readable format. • Objection and restriction — ask us to stop or limit certain processing. • Withdraw consent — where we rely on consent (for example, marketing email), you can withdraw it at any time without affecting processing that already happened. • Non-discrimination — we will not degrade your service or charge you more for exercising any of these rights. EEA and UK residents also have the right to lodge a complaint with your local supervisory authority. California residents may use an authorized agent; we may verify the agent's authority and confirm the request with you first. Other US states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others as they take effect) have equivalent rights, including a right to appeal a denied request — reply to our decision email with "Appeal" and we will respond in writing within the period the law requires. Canadian residents have access, correction, and consent-withdrawal rights under PIPEDA; Australian residents have access and correction rights under the Australian Privacy Principles. To exercise any right, email privacy@bravely.dev. We respond within the timeframe the applicable law requires — generally 30 days under GDPR and 45 days under the CCPA, with an extension where the law permits one. We may need to verify your identity before acting, usually by confirming control of the email address on the account.

If you are in the EEA or UK, we rely on these lawful bases under the GDPR and UK GDPR: • Performance of a contract — creating and securing your account, delivering the features you paid for, syncing your content, processing purchases, and providing support. • Legitimate interests — keeping the service secure and reliable, preventing fraud and abuse, understanding how our products are used through usage events tied to an installation or to your account, and improving the product. We balance these against your rights and do not use them to justify intrusive tracking. Where an app lets you turn its usage analytics off, doing so is one way to object. • Consent — marketing email, and anything else we ask your permission for before we collect it. You can withdraw consent at any time. • Legal obligation — keeping tax, accounting, and consent records, and responding to lawful requests.

Bravely Studios LLC is a US company. We and our sub-processors process data in the United States and in other countries where they operate. For personal data originating in the EEA, UK, or Switzerland, we rely on appropriate transfer safeguards in our processor agreements — such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum — where those safeguards are required. Email privacy@bravely.dev if you want more detail about the safeguards that apply to you.

For California residents, the categories of personal information we collect for this product are: • Identifiers: a random identifier the app creates on your device for its usage events. • Internet or other electronic network activity: the usage events described under "Usage Analytics", with your device model, iOS version, app version, language, time zone, screen size and type of network connection. • Coarse geolocation: an approximate location, such as a country or city, that our analytics provider may estimate from the network address an event arrives from. We collect this from you, your device, and our own systems, and we use it to run the product, honor what you have bought, keep the service secure, and support you. We disclose it to the service providers listed under "Sub-processors," each for a business purpose under a written contract. We do not sell your personal information and we do not share it for cross-context behavioral advertising, as those terms are defined by the CCPA and CPRA, and we have not done so in the preceding 12 months. We do not use or disclose sensitive personal information for any purpose that would trigger the right to limit. If that ever changes we will update this policy and provide the required opt-out before the practice begins. Retention is described under "Data Retention" above and, for account-level data, in the Bravely Account privacy policy.

We use the following service providers to run this product. They receive only what they need to perform their service for us, and each is bound by the data-processing terms that apply to our use of their service. Where a provider is not yet covered by a written data-processing agreement with us, its entry below says so. If you need a data-processing agreement in place before you use this product, email privacy@bravely.dev: • Apple Inc.: distributes the app through the App Store. See apple.com/legal/privacy. • PostHog Inc.: product analytics, receiving the usage events described under "Usage Analytics" on its servers in the United States. See posthog.com/privacy. If we add or change a sub-processor in a way that materially changes how your data is processed, we will update this policy and give additional notice where the law or our data-processing commitments require it.

We protect your data with authenticated accounts, encryption in transit, access controls on our backend systems, and a deliberately small number of people who can reach production. No system is perfectly secure, and we do not claim guarantees we have not built and verified. Where a product makes a specific security claim, that claim appears in the app-specific sections above and is limited to what we have actually shipped. If we become aware of a breach affecting your personal data, we will notify you and the relevant regulators as required by law.

We may update this Privacy Policy from time to time. If we make a material change — a new category of data, a new sub-processor, a new purpose, or a new legal basis — we will update the "Last updated" and "Effective" dates and give additional notice where the law requires it. Where a change requires fresh consent under the GDPR, UK GDPR, CASL, or a similar regime, we will ask for it before relying on the new purpose. Non-material changes (typos, clarifications, link fixes) are reflected by updating the "Last updated" date.

Bravely Studios LLC Privacy and data rights: privacy@bravely.dev Product support: support@bravely.dev Website: https://bravely.dev Postal address: available on request to privacy@bravely.dev.