Privacy policy for Culm

Without an account, everything you enter (habits, check-ins, bend days, settings) stays on your phone. We do not receive it. Reminders are scheduled on your phone and are not sent through us.

When you sign in or subscribe, we process:

• Account details (identifiers): the account ID from Apple or Google, your email address (with Apple this can be a private relay address) and your first name if you share it. To recognize you across phones.
• Your habits (content you create), synced with the Grove plan: habit names, weekly target or fixed days, reminder time, category and phase, the kept weeks they have grown, check-ins and bend days with their date and time of day, and settings such as your time zone and week start. To keep them safe and let you use them on more than one phone.
• What you grow (preferences you give us): if you plant from the catalog, the language, activity, subject, practice or interest it is about. Shown to you under You, removable there, and used only inside the app to suggest habits. Never used for ads and never shown to other people.
• Shared groves: the display name you choose, the grove’s name and invite code, your stalk’s summary, and sunshine you send or receive. See section 3.
• Purchases (commercial information): which plan you have, receipts and purchase history, price, currency and country. To give you the Grove plan you paid for.
• Technical data: device type, operating system and app version, and IP address, as part of signing in, syncing and checking your subscription.

We do not collect your location, contacts, photos, camera, microphone or browsing activity, and we do not track you across apps or websites.

You name your habits yourself, and a name such as “Take my medication” or “Meditate” can say something about your health. We treat everything you write as sensitive: it is used only to show and sync your habits, is never used to infer anything about you, never shared, never sold and never used for ads. It is never shown to the people in your shared groves. If you prefer, give a habit a name that only you understand.

Members of a grove you start or join see only the grove’s name, your display name, your stalk (kept weeks, leaves and whether it is rooting) and this week’s count against your target. They never see which days you missed, your bend days, the name of your habit, your other habits or what you grow. Sunshine is seen only by the two people it is between. Leaving a grove removes your stalk from it.

Synced data for every user, in every country, is stored in one place: Google Cloud Firestore in data centers in the European Union (region eur3). Keeping it in one region means it is always covered by the EU’s data protection law, the GDPR, which is among the strictest in the world.

If you live outside the EU, for example in the United States, your data is transferred to the EU to be stored there, and it gets exactly the same protection as anyone else’s. Subscription status is handled by RevenueCat in the United States; see section 7.

• Data is encrypted in transit (TLS) between the app and our providers, and encrypted at rest on their servers.
• Access rules let each account read and write only its own data. Grove members can read only the summaries described in section 3.
• Inside our team, only the people who run Culm can access the systems, and they do not look at your habits unless you ask us for help and share them yourself.
• If a breach puts your data at risk, we will tell you and the relevant authorities as the law requires.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising or targeted advertising. We do not use it for profiling that has legal or similarly significant effects. We use no analytics or advertising tools and work with no data brokers. Because of this there is nothing to opt out of, and a Global Privacy Control signal changes nothing; we already treat everyone as opted out.

We use these providers only to run Culm, under contracts that limit them to processing data on our behalf:

• Google Ireland Ltd. / Google LLC (Firebase Authentication and Cloud Firestore): accounts, sync and shared groves. Data is stored in the EU.
• RevenueCat, Inc. (USA): subscription status, using an app user ID and purchase records.
• Apple and Google: payment, and sign-in if you choose it. They process data under their own privacy terms.

Where data from the EEA, UK or Switzerland is processed in the United States, this relies on the EU-US Data Privacy Framework (and its UK and Swiss extensions) and/or the European Commission’s standard contractual clauses.

Data on your phone stays until you delete it or the app. Synced data is kept for as long as you have an account. When you delete your account in the app (You → Account → Delete account), we delete your account and everything synced to it, remove you from every shared grove along with sunshine you sent or received, and erase the habits on your phone. Signing out keeps your synced data safe on your account.

Purchase records at RevenueCat, Apple and Google are kept as long as needed to provide the subscription and meet tax and accounting duties. Deleting your account does not cancel a subscription; you do that in the App Store or Google Play.

Everyone who uses Culm can:

• Get a copy of their data: You → Download your data gives you everything Culm holds about you, on the phone and on your account, free on every plan.
• Correct anything they have entered, in the app.
• Delete single habits and check-ins, everything on the phone (Settings → Erase all habits), or the whole account (You → Account → Delete account).
• Ask us for anything else, such as information about how we use their data, at hei@appivate.com.

We answer requests within one month (45 days for US state law requests), free of charge, and may ask you to confirm it is your account. Using your rights never changes the price or quality of the app for you.

Under the GDPR (and the UK GDPR and Swiss law), we process your data because it is necessary to provide the app, sync, shared groves and the subscription you ask for (Art. 6(1)(b)), and, for purchase records, to meet legal duties (Art. 6(1)(c)). Signing in and joining groves are optional. You also have the right to restriction, to data portability, and to object to processing. You can complain to the Norwegian Data Protection Authority (datatilsynet.no) or the authority where you live or work.

Residents of California and other states with consumer privacy laws (including Colorado, Connecticut, Virginia, Utah, Texas, Oregon and others) have the right to know what personal information we collect, use and disclose; to access and get a portable copy of it; to correct and delete it; and to opt out of its sale, sharing for targeted advertising, and profiling. We do not sell or share personal information and do not use it for targeted advertising or profiling, and have not done so in the past 12 months.

The categories we collect are described in section 1: identifiers, customer records, commercial information, content you create, preferences (what you grow), and device and network information. Sensitive personal information is used only to provide the app (see section 2), never to infer characteristics about you. We disclose personal information only to the service providers in section 7, for the business purposes described there.

You can make a request at hei@appivate.com, or through an authorized agent with your written permission. If we decline your request, you can appeal by replying to our answer; we will respond within 45 days, and if you disagree with the outcome you can contact your state attorney general.

Culm is not directed at children under 13 and we do not knowingly collect their data. If you believe a child has given us data, contact us and we will delete it.

We update this policy when the app changes. The date at the top shows the latest version, and we will let you know in advance of any change that affects how your data is used.

• Appivate AS
• Øvre Kråkenes 17, 5152 Bønes, Bergen, Norway
• hei@appivate.com