Privacy Policy

How to read this page. Each section ends with a shaded plain English summary. The summaries are there to help; if a summary and the full text differ, the full text applies.

1. Who we are

This Privacy Policy explains how Odds on Me (the “App”) handles personal data. The App is developed and published by Noaman (“we”, “us”, “our”), an individual developer based in India. We do not publish a street address; please contact us by email.

Under India’s Digital Personal Data Protection Act, 2023 (the “DPDP Act”), we are the Data Fiduciary for the limited personal data described in section 9, and you are the Data Principal. Under the EU and UK General Data Protection Regulations we would be the controller for that same limited data. For everything you enter into the App, there is no controller other than you, because that data never reaches us.

“The App” means everything delivered in the same download: the main app, the Home Screen widgets, the large “Last 5 calls” widget, the Lock Screen widgets, the Control Center control, the Siri and Shortcuts actions, the share-card maker and the export tools. This policy also covers emails you send us. It does not cover Apple’s services, which are governed by Apple’s own privacy policy, or any website that hosts this document (see section 7.13).

This policy is written in English. You may ask us at [email protected] for this notice in Hindi or in any other language listed in the Eighth Schedule to the Constitution of India, and we will provide it.

2. The short version

Odds on Me is built so that what you write stays on your iPhone.

• We run no servers for the App. There are no accounts, no sign-in, no analytics, no advertising, no tracking and no third-party software development kits (SDKs) inside the App.
• Your predictions, results, scores, streaks, levels, captions and settings are stored only on your device. We never receive them and have no way to read them.
• The App does not collect your name, email address, phone number, contacts, location, photos, camera, microphone, health data, advertising identifier, device identifier or IP address.
• We do not sell, rent, trade or share personal data, we do not use it for advertising, and we do not build profiles.
• The only things that involve other parties are things you choose to do (subscribing through Apple, sharing a card, emailing us) and standard features of iOS (such as device backups, Siri or notifications), which are handled by Apple under Apple’s terms.
• You can export or delete everything yourself, at any time, from inside the App.

3. Scope and how to read this policy

This policy applies to everyone who uses the App, anywhere in the world. Section 1 to section 21 apply to all users. Appendix A adds information required by the laws of particular countries and regions, starting with India. Where a local law gives you more protection than this policy, that law applies to you.

Each section ends with a shaded Plain English Summary. The summaries are there to help you. If a summary and the full text differ, the full text is what counts.

We use these terms:

4. Information that exists on your device

The App works entirely on your iPhone. This section lists what is stored on your device so that you know exactly what exists. None of it is sent to us.

4.1 Things you create

4.2 Things the App works out for you

Your score, skill, level, streak, freezes, calibration curve, weekly Mirror, category patterns, “Resurface” cards and share-card headlines are calculated on your device from the records above. Most are not stored at all; they are recalculated whenever they are shown.

4.3 Housekeeping values

The App keeps a few technical values on your device: whether you have finished onboarding; which reveal lines you saw recently (so lines do not repeat); which upgrade prompts and “Remember this one?” cards you have already seen or dismissed; and a copy of whether your Pro subscription is active (so the widget can show the right theme). After you tap Yes or No on a widget, a copy of the reveal is kept for 10 minutes so the widget can show it, and then it expires.

4.4 Where it is kept

All of this is stored in the App’s private storage on your device. The main app and its widgets share one protected storage area (an iOS “App Group”) so that widgets can show your calls and handle Yes and No taps. Nothing is stored in iCloud, CloudKit, Firebase or any cloud service run by us, and nothing is synced between devices.

5. What the App does not collect

The App does not collect, access or request: your name; email address; phone number; postal address; contacts; calendar; photos or camera; microphone; precise or approximate location; health, fitness or biometric data; financial information; browsing or search history; advertising identifier (IDFA); vendor or device identifiers; IP address; usage analytics; crash logs (other than through Apple, if you opt in, see section 7.10); or any information from other apps.

The App contains no third-party SDKs: no analytics, advertising, attribution, crash-reporting, social-login or tracking code of any kind. The App does not use cookies, web beacons or fingerprinting. The App makes no network requests of its own; the only connections it causes are those iOS makes to Apple for purchases (section 8).

6. How the App works without collecting data

Everything that needs computing (scoring, levels, streaks, category suggestions, reveal-line selection, Mirror summaries, share-card rendering, exports and the widget timeline) happens on your device. The App’s category suggestion uses a fixed list of keywords stored inside the App; nothing you type is sent anywhere to be analysed.

The App includes the privacy manifest that Apple requires. It declares that the App does not track and collects no data types, and it records the only system features the App uses for its own purposes: reading and writing its own preferences (Apple reason codes CA92.1 and 1C8F.1) and reading the dates of files in its own storage (reason code C617.1). For the App Store privacy label, the App is declared as Data Not Collected.

7. What can leave your device, and who handles it

We have no servers, so nothing goes to us. The following are the only ways information connected to the App can leave your device. Each one is either something you choose to do or a standard iOS feature, handled by the party named, under that party’s terms.

7.1 Purchases (Apple)

Subscribing, restoring and managing Odds on Me Pro happen through Apple. Details are in section 8.

7.2 Device backups (you and Apple)

Depending on your settings, App data may be included in iCloud Backup or in a backup to a computer, and may be copied when you set up a new device or use Quick Start. Backups are controlled by you and Apple, not by us. iCloud backups are stored by Apple, which may store them outside your country. Use encrypted backups or iCloud’s Advanced Data Protection for stronger protection. Old backups may keep a copy of your data even after you delete it from the App.

7.3 Sharing cards (you)

When you tap Share, the App draws a picture on your device and hands it to the iOS share sheet. You choose where it goes. Depending on your choices, the card can show: the result, the stat line, your prediction, your confidence, the reveal line, the category, the date, your level, how many calls you have resolved, your score, your streak, a small calibration chart, and your caption. Each detail can be switched off. If you save a card to Photos, it is stored in your photo library (and in iCloud Photos, if you use it).

7.4 Exports (you)

Settings > Export creates a file on your device (a complete JSON file for everyone; a CSV file and a stats report with Pro) and hands it to the share sheet. The JSON file contains every prediction, result, time, category and reveal line. Files are created in the App’s temporary storage, which iOS clears from time to time, and Delete all data removes any that remain.

7.5 Anything you share goes where you send it

Once you send a card or file to a person, an app or a service (for example WhatsApp, Instagram, email or cloud storage), that recipient’s privacy practices apply. We cannot recall or delete anything after you have shared it.

7.6 Siri, dictation and Shortcuts (Apple)

If you use the “Make a Call” action with Siri or the Shortcuts app, or dictate text instead of typing, Apple processes your voice and words under Apple’s privacy policy. The App then saves the prediction on your device. iOS may also learn, on your device, which App actions you use in order to make suggestions. If you never use these features, none of this applies.

7.7 Apple Intelligence and notification summaries (Apple)

On devices that support it, if you turn on Apple Intelligence features such as notification summaries or priority notifications, iOS may read the text of App notifications (which include your prediction text, see section 11) to summarise or prioritise them. Apple says this processing happens on the device or through its Private Cloud Compute service. We have no access to it. You can switch these features off in iPhone Settings.

7.8 Keyboards (you and your keyboard provider)

The App uses the standard iOS text fields. If you have installed a third-party keyboard and given it “Full Access”, that keyboard’s maker may be able to receive what you type in any app, including this one. Apple’s own keyboard does not do this. If that concerns you, use Apple’s keyboard when writing predictions.

7.9 Notifications on your other devices (Apple)

iOS may show App notifications on your paired Apple Watch, on a Mac through iPhone Mirroring, or in your car through CarPlay, depending on your settings. Those notifications include prediction text. This mirroring is done by Apple.

7.10 Diagnostics (Apple, only if you opt in)

If you have chosen, in iPhone Settings > Privacy and Security > Analytics and Improvements, to share analytics with app developers, Apple may give us anonymous crash and energy reports and aggregated usage statistics about the App. These come from Apple, are not linked to your identity, and do not contain your predictions. If you have not opted in, we receive nothing.

7.11 App Store statistics (Apple)

As the developer, we can see aggregated reports in App Store Connect, such as the number of downloads, subscribers, cancellations and revenue by country. These reports do not identify you.

7.12 TestFlight (Apple, beta testers only)

If you test a beta version through TestFlight, Apple shares with us the email address or name you used to accept the invitation, together with any feedback, screenshots and crash reports you choose to send. We use this only to improve the beta, and delete it when testing ends or when you ask.

7.13 Our website and support email (us and our service providers)

If you email us, see section 9. If you read this policy on a website, the hosting provider of that website (https://celsitudostudio.com) may keep standard server logs, such as IP address, browser type and time of visit, under its own policy. We do not add analytics or tracking to that page.

7.14 Managed devices (your employer or school)

If your iPhone is managed by an organisation (Mobile Device Management), that organisation may be able to back up, inspect or wipe app data under its own policies. We have no part in this.

8. Purchases and subscriptions

Odds on Me Pro is an auto-renewing subscription sold and billed by Apple. When you subscribe, restore or manage it, your device communicates with Apple’s App Store using Apple’s StoreKit.

• Apple processes your payment, billing, taxes, refunds and payment-method details under Apple’s privacy policy. We never see or store your payment card, UPI ID, bank details, Apple Account email or name.
• The App checks on your device, using cryptographically signed records from Apple, whether your subscription is active, when it renews or ends, and whether a payment is being retried. It uses this only to switch Pro features on or off and to show your subscription status in Settings.
• We do not run a receipt-validation server and we do not receive Apple’s server notifications about your purchases.
• Apple may share with us, in App Store Connect, aggregated or pseudonymous transaction information (for example, that a subscription was bought in a particular country on a particular date). We use it only for accounting, tax and improving the App.

9. Personal data we do process

9.1 Support and privacy emails

If you contact us, we receive your email address, your name if you include it, and whatever you choose to write or attach.

Please do not email us your predictions or any sensitive information. We do not need it to help you.

9.2 Beta testing

See section 7.12.

9.3 Nothing else

We do not process any other personal data about you. We do not buy data about you from others, and we do not combine information from different sources.

10. Permissions the App asks for

The only permission the App asks for is Notifications, and only after you save your first real prediction. If you allow it, the App schedules local notifications on your device. If you decline, the App still works fully, but you will not be reminded when a prediction is due. You can change this at any time in iPhone Settings > Notifications > Odds on Me.

The App does not ask for, and cannot use, your location, contacts, photos, camera, microphone, calendar, health data, Bluetooth, local network or tracking permission. Saving a share card to Photos uses the iOS share sheet; if iOS asks for permission to add to Photos, that permission is granted to the share action, and the App cannot read your photo library.

11. Notifications, widgets and who can see your screen

Due reminders. When a prediction comes due, the App shows a local notification titled “Did it happen?” with the text of your prediction, and Yes, No and “Snooze a day” buttons. After you answer from a notification, a second notification shows your result and reveal line (not your prediction text).

Sunday Mirror reminder. If notifications are allowed, a weekly reminder is scheduled for Sunday evening. It contains no personal content, and you can turn it off in Settings.

Widgets. The Home Screen, large and Lock Screen widgets can show the text of your predictions, your confidence and your recent results to anyone who can see your screen, including on a locked phone, depending on your iOS settings.

To keep things private on screen: turn on Settings > Hide prediction text on widget, or set “Prediction text” to Hide on any individual widget (long-press the widget, then Edit Widget); turn off “Show confidence” per widget; and set iPhone Settings > Notifications > Show Previews to “When Unlocked” or “Never”.

All notifications are created and delivered on your device. No notification server is involved.

12. Security

Your data is protected by iOS: app sandboxing (other apps cannot read the App’s storage), hardware-backed file encryption tied to your passcode, and your Face ID, Touch ID or passcode lock. The App does not add its own passcode, PIN or encryption on top of iOS. Anyone who can unlock your iPhone can open the App.

To keep your data safe, we recommend that you: use a strong passcode; keep iOS up to date; turn on Find My; use encrypted backups; avoid unknown third-party keyboards; and do not use the App on a jailbroken device, which removes iOS’s security protections.

If the App ever cannot open its storage, it shows a warning instead of silently losing your data.

Because we hold no central database of your App data, there is nothing of yours on our side to be breached. If we learn of a security problem in the App itself that could put your data at risk, we will fix it promptly in an update and explain it in the release notes. Where the law requires, we will notify affected people and the relevant authorities. In India this includes the Data Protection Board of India and CERT-In, within the time limits those laws set (see Appendix A.1). If we suffer a breach of our support email account, we will tell affected people without delay.

13. How long data is kept, and how you delete it

Because we hold no copy of your App data, you decide how long it is kept. It stays on your device until you delete it.

Locked records. Once a prediction is resolved, its text, confidence and times cannot be edited, and it cannot be deleted on its own. This is deliberate: it keeps the record honest, so nobody can rewrite what they believed after the fact. Resolved predictions can only be removed by deleting all data or deleting the App. Section 16 explains how this works with your rights.

Support emails are kept as described in section 9.1.

14. Special situations

14.1 Information about other people

If you write about another person, that person may be identifiable from what you write. Because this is information you keep on your own device for your own personal purposes, it generally falls outside data-protection laws (for example, the DPDP Act does not apply to data processed for a personal or domestic purpose, and the GDPR has a similar “household” exemption). That changes if you publish it. You are responsible for anything you share about others and for respecting their privacy and the law.

15. Children

The App is not directed at children under 13, and we do not knowingly collect personal data from anyone of any age through the App.

• India. A child is anyone under 18. Under the DPDP Act, processing a child’s personal data needs verifiable consent from a parent or lawful guardian, and tracking, behavioural monitoring and targeted advertising aimed at children are not allowed. The App does none of these things for anyone. Users under 18 should use the App and subscribe only with a parent’s or guardian’s permission.
• United States. We comply with the Children’s Online Privacy Protection Act (COPPA). We do not collect personal information from children under 13.
• EU, EEA and UK. The age at which a child can consent to online services ranges from 13 to 16 depending on the country. We follow the principles of the UK Age Appropriate Design Code: no tracking, no profiling, no nudges, high privacy by default.
• Elsewhere. Where local law sets a higher age, that age applies.

If you are a parent or guardian and think your child has emailed us, contact [email protected] and we will delete the email. Parents can use Apple’s Screen Time and Ask to Buy to control their child’s use of the App and purchases.

16. Your rights

Depending on where you live, you have rights over personal data held about you (see Appendix A for your country). These commonly include the right to: know what is held and how it is used; get a copy (access) and take it elsewhere (portability); correct it; delete it (“right to be forgotten”); restrict or object to its use; withdraw consent; not be subject to automated decisions with significant effects; nominate someone to act for you (India); and complain to a regulator.

For your App data, you can exercise these rights yourself, instantly, because the data is only on your device:

For data we hold (support emails), write to [email protected]. We will respond within 30 days. In India we will respond within the time set by the DPDP Rules, and no later than 90 days. Where the law allows us more time, we will tell you why. We may need to confirm that you control the email address before acting. Exercising your rights is free, and we will never treat you differently for doing so.

Why we cannot look up your App data for you. We do not have it. If you ask us to access or delete your App data, we will explain how to do it yourself on your device. This is a design choice that protects you.

Complaints. You can complain to us first, and we would like the chance to put things right. You also have the right to complain to your data-protection authority (listed in Appendix A). In India, you must first use our grievance process, and then you may approach the Data Protection Board of India.

17. Law enforcement and legal requests

We respond only to requests that are valid under the law that applies to us, which is primarily Indian law. We can only provide what we have. We have no copy of your predictions, results, scores, captions or settings, no account records, and no device or advertising identifiers. In practice, the most we could ever provide is the contents of emails you have sent us. Information about your purchases is held by Apple, so any request for it must go to Apple. Unless the law forbids it, we will try to tell you before disclosing anything.

18. International transfers

We do not transfer your App data anywhere, because we never receive it. Support emails may be stored by our email provider outside India or outside your country. Where the law requires, we make sure appropriate safeguards are in place (for example, standard contractual clauses for data from the EU, EEA, UK or Switzerland), and we respect any restrictions the Government of India places on transfers to particular countries under section 16 of the DPDP Act. Data handled by Apple (purchases, backups, Siri) is processed by Apple in the countries where Apple operates, under Apple’s policies and safeguards.

19. No selling, no sharing, no targeted advertising

We do not sell personal data. We do not share personal data for cross-context behavioural advertising. We do not use personal data for targeted advertising or profiling, and we do not process sensitive personal data. These statements hold under every definition of those words in the laws listed in Appendix A, including the California Consumer Privacy Act. Because we do not track you, signals such as Do Not Track and Global Privacy Control need no special handling: you are already treated as having opted out of everything they cover.

20. Changes to this policy

We will update this policy when the App changes or when the law requires. The version and date are shown at the top. For a material change, we will tell you in the App and in the App Store release notes before it takes effect, and where the law requires, we will ask for your consent.

Our promise: we will not start collecting your App data, add accounts, add cloud sync, add analytics, or add advertising or tracking without first updating this policy, telling you clearly inside the App, and asking for your consent where required. If a future version needs to collect anything, it will be optional wherever possible.

Earlier versions of this policy are available on request.

21. Contact and grievances

Noaman, India. Email: [email protected]

Grievance Officer: Noaman, [email protected]. We will acknowledge your grievance within 48 hours and aim to resolve it within one month, and in any case within the time limits set by Indian law.

If you are not satisfied with our response, you may approach the authority listed for your country in Appendix A. In India, that is the Data Protection Board of India.

Appendix A. Information for your country or region

The App is offered from India to users in many countries. This appendix adds information required by local laws. It does not reduce any right you have under the main policy. We do not collect your App data in any country, so most obligations apply only to the support emails described in section 9.

A.1 India

A.2 European Union, European Economic Area and Switzerland

A.3 United Kingdom

UK GDPR and the Data Protection Act 2018 apply in the same way as A.2. We follow the Age Appropriate Design Code (Children’s Code). You may complain to the Information Commissioner’s Office (ICO). We have not appointed a UK representative, for the same reason as in A.2.

A.4 United States

A.5 Canada

We follow the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, including Quebec’s Act respecting the protection of personal information in the private sector (as amended by Law 25). The person responsible for the protection of personal information is named in section 1. You may complain to the Office of the Privacy Commissioner of Canada or, in Quebec, to the Commission d’accès à l’information.

A.6 Brazil

Under the Lei Geral de Proteção de Dados (LGPD), you have the rights listed in Article 18, including confirmation, access, correction, anonymisation, portability, deletion and information about sharing. Our contact for data-protection matters (encarregado) is Noaman, [email protected]. You may complain to the Autoridade Nacional de Proteção de Dados (ANPD).

A.7 Australia and New Zealand

We follow the Australian Privacy Principles under the Privacy Act 1988 (Cth) and the New Zealand Privacy Act 2020 as if they apply to us. You may complain to the Office of the Australian Information Commissioner (OAIC) or to the New Zealand Privacy Commissioner.

A.8 Japan, South Korea and China

• Japan: We follow the Act on the Protection of Personal Information (APPI). Support emails are the only personal information we hold. Regulator: the Personal Information Protection Commission (PPC).
• South Korea: We follow the Personal Information Protection Act (PIPA). We do not collect resident registration numbers or any App data. Regulator: the Personal Information Protection Commission (PIPC).
• Mainland China: The App may not be offered in mainland China. If it is, the Personal Information Protection Law (PIPL) applies to any personal information we handle. Regulator: the Cyberspace Administration of China.

A.9 Other countries

Wherever you are, you can exercise the rights your local law gives you by emailing [email protected]. In every country, the core fact is the same: the App does not collect your data.

Appendix B. Data inventory

Appendix C. Apple App Privacy answers