The data controller for the personal data described below is Bohdan Ivanov, conducting business activity as a sole proprietorship under the name Bohdan Ivanov, entered in the Polish CEIDG register, address: ul. Chodkiewicza 2, 02-593 Warszawa, Poland, NIP: 8982281481, REGON: 522802505. We have not appointed a Data Protection Officer. For any privacy question, request, or complaint, contact support@gopakto.com or write to the address above. We respond within one month, as required under the GDPR.

We collect only what the Service needs to function:

• Account data: email address, username, display name, date of birth (for age verification), and password hash. Sign-in via Apple / Google returns only the fields you authorise them to share.
• Profile content: avatar, bio, profile visibility, and any content you publish (Pacts, Journeys, check-ins, comments, Circles). Public content is visible to anyone; private content is visible only to you and your invited members.
• Commitment data: your Pact details, schedule, verification method, streaks, check-in photos / videos / notes, missed and recovered days.
• Payment / subscription metadata: when you subscribe or purchase Grain in the app, Apple or Google shares a receipt identifier and a subscription status; when you pay on gopakto.com, Stripe shares a customer identifier, the purchase, its status and your billing country. We never see your full card number, bank details, or Apple / Google account credentials.
• Device & log data:device model, OS version, app version, IP address, coarse timezone, crash and error diagnostics.
• Push tokens if you enable notifications, so we can deliver check-in reminders.
• Ad data (iOS app, when an ad is shown to you): collected by Google AdMob, not by us — see Section 5.

We do not sell your personal data. We do not use your commitment or check-in data for advertising.

We do not connect to Apple Health, Google Health Connect, Screen Time, Digital Wellbeing or any other health or fitness data source, and we do not ask you for health information. If you choose to describe something personal in a Pact, note or check-in (for example a fitness or sobriety commitment), you decide what to share and whether it is private or public; we process it only to show it as you set it.

• Contract: to provide the core Service — your account, Pacts, Journeys, Circles.
• Consent: to deliver push notifications, to show ads in the iOS app where the law requires consent (EEA, UK and Switzerland), or to process any optional data. You may withdraw consent at any time in the app's settings or your device settings; withdrawal does not affect processing that already took place.
• Legitimate interest: to keep the Service secure, prevent abuse, and diagnose crashes.
• Legal obligation: to respond to lawful requests and to comply with tax / consumer protection law where applicable.

We share personal data only with the providers we need to run Pakto. Service providers acting on our behalf are bound by a data-processing agreement:

• Amazon Web Services — hosting, storage, database and transactional email (EU / US regions).
• Resend — transactional email delivery (fallback provider).
• Apple & Google — App Store / Play Store distribution, in-app purchases, push delivery.
• RevenueCat — subscription entitlement management.
• Stripe — payment processing for any web-based purchases.
• Sentry / crash-reporting providers — diagnostics.
• Google AdMob — optional rewarded ads in the iOS app (see Section 5).

We do not sell or rent your personal data, and we never give advertisers, brokers or marketing platforms your profile, Pacts, check-ins or email address. We may disclose data if compelled by valid legal process (court order, subpoena) or to protect the rights, safety, or property of the Developer, our users, or the public.

The iOS app shows ads served by Google AdMob in two places: a “Sponsored” card between posts in the feed (not shown to Pro subscribers), and optional rewarded videos you can choose to watch in your wallet to earn Grain. The website and the Android app show no ads.

• Not personalized. Ads in the app are non-personalized. We do not ask for tracking permission, do not use your device's advertising identifier, and do not share your profile, Pacts, check-ins or email with Google.
• What Google receives. When an ad loads, Google's software in the app collects your IP address, device and app information (such as model, operating system, language and app version), how you interact with the ad, and an identifier limited to the app, for frequency capping, fraud prevention and ad measurement.
• Rewards. To credit your Grain, Google sends our server an anonymous one-time token. It does not contain your user ID, name or email.
• Your choice. In the EEA, the UK and Switzerland, Google's consent message is shown before any ad is requested, and ads load only if your choice allows it. You can review or withdraw that choice at any time in Settings → Ad privacy options. Elsewhere, we rely on our legitimate interest in funding the free version of the Service; a Pro subscription removes the feed ads.
• Google's role. Google processes this data under its own terms, in part as an independent controller. See how Google uses information from apps that use its services.

Data may be processed on servers located outside your country of residence, including in the United States and the European Union. Where we transfer personal data outside the EEA / UK, we rely on Standard Contractual Clauses approved by the European Commission, or on the provider's own approved transfer mechanisms.

• Account data: for the life of the account.
• Pacts, Journeys, check-ins: for the life of the account, unless you delete them earlier.
• Payment / subscription receipts: 7 years, to meet tax obligations.
• Log & crash data: 90 days.
• Backups: rolling 35-day window; deletion propagates within that window.

When you delete your account, we erase your identifiable data and content within 30 days, except where retention is legally required (e.g. tax records).

gopakto.com uses only cookies that are strictly necessary for the Service or that remember a choice you made. There are no advertising, analytics or tracking cookies, and no third-party scripts set any. Product analytics are recorded on our own servers and do not use cookies. This section covers the website; ads in the iOS app are described in Section 5.

• pakto-session: keeps you signed in. Strictly necessary; until you sign out or the session expires.
• pakto-oauth-state: protects “Continue with Google” against forged requests. Strictly necessary; a few minutes.
• pakto-locale: the language you chose. Preference; 1 year.
• pakto-workspace: whether you last used your Personal or Organization workspace. Preference; 1 year.

Your browser’s local storage also keeps your recent searches, whether you have dismissed a prompt, and that you have seen our cookie notice. It never leaves your device.

Because none of this is used for advertising or tracking, it does not need your consent under EU and UK ePrivacy rules. You can still block or delete cookies in your browser; signing in will then not work.

Depending on where you live (EEA, UK, California, and other jurisdictions), you have the right to:

• Access the data we hold about you.
• Correct data that is inaccurate.
• Delete your data (“right to be forgotten”).
• Export your data in a portable format.
• Object to or restrict certain processing.
• Withdraw any consent you previously gave.
• Lodge a complaint with a data-protection supervisory authority — in Poland, the President of the Personal Data Protection Office (Prezes UODO, ul. Stawki 2, 00-193 Warszawa), or the authority in your country of residence.

To exercise any of these rights, email support@gopakto.com from the address on your account. We may request additional verification to confirm your identity.

You must be at least 13 years old to use Pakto, and we ask for your date of birth to check this. We do not knowingly collect personal data from anyone under 13.

In some countries you can only give consent to data processing yourself from an older age — 16 in Poland and Germany, for example. If you are below that age where you live, a parent or guardian must agree before you accept optional consent-based processing, such as the ads consent message in the iOS app.

If you believe a child under 13 has provided us with data, contact us at support@gopakto.com and we will delete it.

We use industry-standard measures to protect your data: TLS in transit, encryption at rest, hashed passwords (argon2id), least-privilege database access, and short-lived credentials for backend services. No online service can guarantee absolute security, but we take reasonable and proportionate steps to reduce risk.

Pakto may link to external websites (App Store, Play Store, Stripe, etc.). We are not responsible for their content or their privacy practices. Review their policies before providing them any personal data.

In line with Apple App Store requirements, our full data-type disclosures appear on the app's App Store product page (“App Privacy” card). The categories listed there mirror the categories described in this Policy. No data collected by Pakto is used for cross-app tracking as defined by Apple's App Tracking Transparency framework, and the app does not access the advertising identifier (IDFA).

We may update this Policy from time to time. If a change is material (e.g. expanded processing, new recipients, weaker user rights), we will notify you in-app and by email at least 14 days before it takes effect. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

Privacy enquiries, data requests, and complaints: support@gopakto.com, or by post to Bohdan Ivanov, ul. Chodkiewicza 2, 02-593 Warszawa, Poland. We answer every message.