Privacy Policy

This Privacy Policy explains how Ludosati SL ("Ludosati", "we", "us" or "our") processes personal data when you use the Spend Your Habits mobile app for iOS and Android and the website https://spendyourhabits.com (together, the "Service").

1. Who we are

The controller responsible for your personal data is:

• Ludosati SL, a Spanish limited company (sociedad limitada)
• Registered office: Calle De Valverde 17, 3C, 28004 Madrid, Spain
• NIF: B19831650
• Company registry: Registro Mercantil de Madrid, Hoja M-826660, Inscripción 1ª

Our full company details are on the Legal Notice page.

2. How to contact us

You can reach us about any privacy matter through:

• the contact form on our Support page, for questions, complaints and requests to exercise your rights;
• the data-deletion request form on our Support page, for erasure requests;
• our company email address, which the Show email button on the Legal Notice page reveals.

3. What this policy covers

This policy covers the app and the website, including its forms and tools. Apple and Google services are covered by their own privacy policies (see Section 7).

4. Data we process in the app

4.1 Account and sign-in

You need an account to use the app. You can sign up with an email address and password, with Sign in with Apple or with Google sign-in. We process your email address, an account identifier, the name Apple or Google shares if you use their sign-in, and the technical data needed to keep you signed in (with Apple, the address can be a private relay address). We send account emails, such as confirmation codes and password resets.

4.2 Your habit data and backups

The app is local-first. Your habits, rewards, completions, streaks, coins, savings, challenges and history are stored in a database on your phone.

To protect that data, the app automatically backs up a copy of the whole database to our cloud storage. Backups are sent over encrypted connections and kept in private storage protected by account-level access controls. We keep the current backup plus the three newest older copies, so an earlier state can be recovered if something goes wrong, for example after a mistaken reset. Older copies are deleted automatically.

4.3 One active device per account

An account is active on one device at a time. The app records which installation currently holds your data, and moves your data to a new phone through the backup.

4.4 Data export and account deletion

You can download a copy of your data in the app (Settings, Download my data, as JSON or CSV). You can delete your account in the app (Settings, Delete account) or through the data-deletion request form. Deleting your account removes your account, your backups and the account-linked data described in this policy, except where Section 10 says otherwise. Deleting your account does not cancel a store subscription: cancel it in your App Store or Google Play settings.

4.5 Subscriptions

Subscriptions are bought and paid for through the Apple App Store or Google Play. Apple and Google process the payment, and we never receive your card details. We receive subscription information, such as the plan, store transaction references, trial, renewal and cancellation status, to unlock the app and keep the records the law requires.

4.6 Affiliate links and offer codes

If you open a partner's link or enter an offer code, we link that partner or code to your account and record whether the account started a trial, paid, renewed, cancelled or was refunded, so we can apply the offer and credit the partner.

4.7 Bug reports, support and suggestions

• Bug reports. When you send a bug report from the app, we receive your description, any screenshots or screen recordings you add, technical details about the app and your phone, and references to related error reports. The report is linked to your account. Screenshots and recordings are kept until the report has been handled and then deleted. We may keep the written report as a support record.
• Error support and email. When you use the in-app error support form or email us, we receive your email address, your message and any technical details shown or included.

4.8 Founder's Notes and the feature board

The app shows Founder's Notes and a feature board where you can read updates, vote, answer polls, reply to notes and suggest features, optionally with a screenshot. We store your votes, read status, replies and suggestions. What you submit is private to our team and other users cannot read it. Poll results only show totals. If you delete your account, your votes and read status are deleted, and your suggestions and replies are kept anonymously as product feedback.

4.9 Crash and error reports

The app, the website and our servers automatically send technical crash and error reports to our crash reporting provider. Reports contain technical information such as the error, app version, phone model and operating system. They do not contain your account ID, your habit or reward texts or your database.

4.10 Product analytics

The app uses privacy-friendly product analytics to see how the app is used, such as which screens are opened. It uses a random ID created for each installation, not your account or your name. There are no ads, no advertising IDs and no tracking across other companies' apps or websites. When you add a card from the built-in Library, the app also sends an anonymous count for that card. To show how many people use each theme, the app sends the chosen theme when you pick it and about once a week, together with a second random ID created for each installation. This ID stays on that installation, is never linked to your account and is deleted from our server after 35 days without a report.

4.11 Notifications and permissions

Reminders are scheduled locally on your phone, without a push notification service. The app does not access your camera, location, contacts or microphone; the system picker only shares the screenshots or recordings you choose.

4.12 App updates

The app downloads updates from our app update provider, which receives a random installation identifier, version information and your IP address, but not your account or habit data.

5. Data we process on the website

5.1 Contact and data-deletion forms

We use the name, email address and message you send to answer you or handle your request. Deletion requests are handled by a person.

5.2 Website tools and AI

The website offers free tools, including the Habit System Creator, the Habit Ranker, a habit data importer, a support chat and a Pomodoro timer (which works only in your browser).

The AI features process what you type or upload, for example answers, habit names, goals, chat messages, and the screenshots or exports you give the importer. They are processed by an AI service provider. Before an AI tool starts, it asks for your consent to this processing. Please do not enter sensitive personal information.

Plans and Plan IDs. Finishing a plan or an import and creating its Plan ID is a separate step from agreeing to the AI processing. Only then do we store the plan, so you can open it in the app. Anyone with the complete Plan ID or link can view and import the plan, so share it only with people you trust. A plan is not linked to an account and is deleted automatically 30 days after it is created. If you want a plan removed earlier, ask us through the contact form.

5.3 Email verification

Some tools ask for your email address before showing your result. We send a short verification code. We store your verified address, the tool you used and your language. If you created a plan, we also email you its Plan ID. We do not track opens or clicks.

5.4 Bot protection and rate limiting

Our forms and tools use a bot protection service. It receives your IP address and technical browser signals to check that you are a person. We also limit how often each IP address or email address can use a form or tool. For these limits we store short-lived counters based on scrambled identifiers, not the raw address, and they expire automatically. Our hosting provider records IP addresses in its server logs for security.

5.5 No analytics or advertising on the website

The website has no web analytics, no advertising and no cross-site tracking.

6. Why we process your data (legal bases)

We rely on these legal bases under Article 6 GDPR:

• Contract (Art. 6(1)(b)): your account, the app's features, backups, device transfer, subscriptions, data export, bug reports, Founder's Notes and feature board, email verification and Plan ID delivery.
• Consent (Art. 6(1)(a)): the website AI processing. You can withdraw consent at any time, without affecting earlier processing: stop using the AI tool and clear its draft.
• Legal obligation (Art. 6(1)(c)): handling your privacy requests and keeping commercial and tax records.
• Legitimate interests (Art. 6(1)(f)): crash and error reports, product analytics, affiliate and offer code attribution, bot protection, rate limiting, security, answering enquiries and defending legal claims. We use only the data we need, and you can object (see Section 11).

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

7. Who receives your data

We do not sell your personal data. Service providers process data for us under data-processing agreements, in these categories:

• hosting and database;
• server hosting for our disaster-recovery backups;
• email delivery;
• crash and error reports;
• product analytics;
• payments and subscriptions;
• affiliate attribution;
• app update delivery;
• storage of tool email addresses;
• bot protection;
• link redirection (when you open one of our short links, this service receives your IP address and device and browser type to send you to the right page);
• AI processing.

The Apple App Store and Google Play process purchases, and Apple and Google provide sign-in. They act as independent controllers under their own privacy policies. Partners who promote the app receive only what is needed to credit them. We may also disclose data when the law or an authority requires it, or to defend legal claims.

8. International transfers

We keep data in the EU where possible. Some providers are based outside the European Economic Area or use support teams or subprocessors there. When data is transferred outside the EEA, we use the safeguards the GDPR requires, such as an EU adequacy decision or the European Commission's Standard Contractual Clauses. You can request a copy of the applicable safeguards through our contact form.

9. How long we keep data

• Account data: while your account exists.
• App data on your phone: until you delete it, reset the app or uninstall it.
• Backups: the current backup and the three newest older copies, while your account exists. They are deleted when you delete your account, apart from short-lived provider safety copies that expire on their own and our disaster-recovery backups below.
• Disaster-recovery backups: encrypted copies of the service, deleted after at most 45 days.
• Bug report screenshots and recordings: until the report has been handled.
• Support messages and form submissions: while we handle them, then only as long as needed for legal claims.
• Crash and error reports: a limited period, after which our provider deletes them automatically.
• Plans: 30 days from creation.
• Tool email address: we delete stored tool email addresses every 30 days, or earlier if you ask us to.
• Rate limit counters and server logs: a short period, then they expire automatically.
• Purchase and attribution records: as long as tax and commercial law require.

10. What account deletion does not remove

Account deletion does not cancel a store subscription; cancel it in the App Store or Google Play. It also does not remove:

• a shared Plan ID, which expires 30 days after it was created;
• messages and bug report emails in our support inbox, kept as Section 9 says;
• feature suggestions and replies kept anonymously as product feedback (Section 4.8);
• records we must keep by law, such as purchase and attribution records, for as long as tax and commercial law require;
• our encrypted disaster-recovery backups (Section 9), which expire within 45 days. If we ever restore the service from one, we delete your account again before the service goes back online.

You can delete your account in the app (Settings, Account, Delete account) or ask us through the data deletion form.

11. Your rights

Under the GDPR you have the right to:

• access your personal data;
• correct inaccurate data;
• have your data erased;
• restrict processing in some cases;
• receive your data in a portable format;
• object to processing based on legitimate interests;
• withdraw consent at any time.

Use the contact form, the data-deletion request form, or Download my data and Delete account in the app. We may ask you to confirm your identity first. We answer within one month, which can be extended by two months for complex requests, in which case we will tell you.

12. Complaints

You can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos (AEPD), at www.aepd.es, or to the authority in your EU country of residence or work.

13. Cookies and browser storage

The website sets no cookies of its own. The bot protection service may use strictly necessary cookies or tokens to do its job.

The website tools use your browser's storage only for their own features:

• local storage and the browser's database keep tool drafts (including files you give the importer) for a limited time, plus settings such as the tool theme and timer;
• session storage keeps the email verification step for the current session.

Starting over removes a tool's draft.

14. Children

The Service is only for people aged 16 or over. The Service is not designed for children, and we do not knowingly collect data from anyone younger or seek parental consent. If you believe someone under 16 has given us personal data, please tell us through the contact form and we will delete it.

15. Security

We protect your data with appropriate technical and organisational measures, including local-first storage, encrypted connections, private per-account storage, bot protection and rate limits. No system is completely secure. Keep your password and any Plan ID private.

16. California residents

If you live in California, you have the right to know, delete and correct your personal information, and not to be treated differently for using these rights. We collect identifiers, subscription information, content you submit and technical information, for the purposes above. We do not sell your personal information and do not share it for cross-context behavioural advertising. Use the Support page to make a request.

17. United Kingdom

If you live in the United Kingdom, the UK GDPR gives you the same rights described in this policy. You can also complain to the Information Commissioner's Office (ICO).

18. Changes to this policy

We may update this policy when the Service or the law changes. We will update the "Last updated" date above, and we will tell you in the app or on the website before important changes take effect.

19. Language

This policy is available in English, Spanish and German. The German version is a translation for convenience; if the versions differ, the English version prevails.