Privacy Policy

1. The data controller

The controller of your data is PixelPaw SRL, a company registered in Romania, which publishes the FumStop app and this website. "Controller", in the language of the General Data Protection Regulation — Regulation (EU) 2016/679 — means the one who decides why and how data is processed; for the little that is processed here, that is us.

Write to us at contact@fumstop.ro. It is the same address for questions about your data and for the requests by which you exercise the rights in section 8.

This policy covers two things that do not work the same way: the FumStop app on iPhone, which keeps everything you enter on the phone and sends out only the two things described in section 2, and the fumstop.ro website, which measures its traffic if you let it. Everywhere the difference matters, we say which of the two we are talking about.

2. What data we collect

In the app you enter a few things yourself: the date and time of your last cigarette, how many cigarettes you smoked a day, how many are in a pack and what it costs, and as you go, the cravings you log, each with its intensity and time. From these the app calculates your smoke-free days, the money you have kept, the time you have gained and the recovery milestones.

FumStop has no accounts. We do not ask you for your name, email address, a password, a phone number or an address, and we do not touch your contacts, your photos or your location. What you enter — your habit, your start date, your cravings — stays on your phone, in the storage reserved for the app: this data does not reach us and we have no way of seeing it. It leaves the phone in one way only: iCloud sync, which you turn on yourself — section 5.

Two things do leave the app, and neither of them is what you wrote in it. The first concerns the subscription: in order to know whether your subscription is active, the app communicates with RevenueCat, the service through which we administer subscriptions. What goes there is an identifier generated by the app — a random string, not your name — the history of the purchase made through the App Store, and data about the device: the model, the iOS version, the app version, the language, and the country derived from the IP address.

The second concerns how the app is used: which screens are opened, which buttons are tapped, and the errors that occur, sent to PostHog. These are events about moving through the app, not about your smoking: your figures — days, cigarettes, money, dates — are not attached to these events and do not leave the phone. The events are not tied to an account, because there are no accounts, but to a random identifier the app keeps on your phone.

On the website you enter nothing: there is no form, no account and no basket, and the only thing you can do here is open the app in the App Store. If you accept traffic measurement, how the site is used is recorded — the pages opened, taps on the download button and where on the page they were made from, the questions opened in the frequently asked questions section, and how far you scrolled. This is data about browsing a website, not about your smoking, and it never meets what is in the app.

The answer you give the banner stays in your browser, so that we do not ask you on every visit — whether you accept or refuse. If you accept, the measurement also keeps there an identifier that links visits made from the same browser to one another, so that you are not counted as somebody new each time. Neither of them contains your name, your email address, or anything else by which we could recognise you.

If you write to us, we receive your email address and what you wrote — we have no other way of replying.

3. Health data

How much you smoke and how long you have not smoked say something about your health. Article 9 of the Regulation treats data concerning health as a special category of data, with stricter protection than the rest, and we regard it the same way.

Your figures go nowhere: they stay on your phone, and we do not store them, read them or analyse them. It has to be said plainly, though, what can be seen in the events described in section 2: the fact that someone opened panic mode shows that they had a craving, even if it does not say which one, how strong it was, or which smoke-free day they were on. We treat these as what they are — they are about your health, however poor in detail — and that is why we do not tie them to you and do not use them for anything other than seeing which parts of the app are used. To the extent that processing your figures were nonetheless attributable to us, the basis is your explicit consent within the meaning of Article 9(2)(a): you give it at the moment you enter the data into the app, for the sole purpose of having it shown back to you as days, money, time gained and recovery milestones.

You withdraw that consent by deleting the data, at any time and without asking us: a reset from the app’s settings, or uninstalling the app, deletes it from the phone. If you have used sync, delete the iCloud copy as well, as section 5 explains. Withdrawal takes effect immediately and requires no explanation from you.

We do not ask you for diagnoses, treatments or other medical information, and please do not send us any by email: we have no use for it.

4. The basis and purpose of processing

The data in the app — your habit, your start date, your cravings. Purpose: to show you your figures and to open panic mode when you need it. The processing happens on your phone and under your control, and we receive none of it; the basis, to the extent it is attributable to us, is your explicit consent, Article 9(2)(a), which you give by entering the data and withdraw by deleting it.

The subscription. Purpose: to open the app features you have paid for. Basis: performance of the contract between you and us, Article 6(1)(b). Payment goes through Apple, not through us: we do not see your card details and we do not know who you are. From Apple we receive aggregated reports about sales and subscriptions, which do not identify you.

Measuring traffic on the website. Purpose: to know what is read and where the download button is pressed from, so that we can make the site better. Basis: your consent, Article 6(1)(a), asked for by the banner on your first visit. Until you give it, the measurement tool does not load at all.

Checking the subscription in the app. Purpose: for the app to know whether your subscription is active, so that it can open the paid features. Basis: performance of the contract, Article 6(1)(b) — without this check we cannot give you what you bought.

Measuring use of the app. Purpose: to see which screens are used and where the app breaks, so that we can fix it and make it better. Basis: our legitimate interest in knowing whether the product works, Article 6(1)(f). Unlike the website, the app does not currently ask for your agreement before it starts — if you do not want this measurement, write to us at contact@fumstop.ro and we will stop the events tied to your app’s identifier; you have the right to object, under Article 21.

Correspondence with us. Purpose: to answer what you wrote to us. Basis: our legitimate interest in replying to a person who writes to us, Article 6(1)(f), and if you write to us about the subscription, performance of the contract.

5. iCloud sync

Sync is optional and turned on by you. For as long as you do not turn it on, the app’s data does not leave the phone.

When you turn it on, a copy of it passes through your own iCloud account, so that you find it again on your other devices. That account is yours, not ours: the copy sits in your storage, is governed by Apple’s terms and privacy policy as well, and we have no access to it and cannot read it.

With sync turned on, the statement that the data stays on the phone is no longer complete — it passes through Apple’s infrastructure. It remains true that it does not reach us.

You turn sync on and off in the app’s settings, and you control the app’s access to iCloud from your phone, in Settings, under your account, in the iCloud section. Turning it off does not delete the copy already uploaded: if you want it gone, delete FumStop’s data from iCloud, in those same phone settings.

6. Third parties and transfers

Apple. Distributes the app through the App Store and is the seller of the subscription: payment is taken from your Apple account, and Apple processes that transaction’s data under its own privacy policy. We do not see your card details. Apple also hosts the iCloud copy, if you have turned sync on.

PostHog, for measurement — on the website and in the app alike. The data is processed in the service’s European Union region. On the website it covers strictly the four behaviours in section 2 and starts only if you accept. In the app it covers screens opened, buttons tapped and errors, and it starts with the app: the two do not work the same way, and section 4 says why.

RevenueCat, for administering subscriptions. It receives the app’s random identifier, the purchase history and the device data described in section 2. It receives nothing of what you entered in the app. It is a company in the United States and processes this data as our processor, under a data processing agreement.

On the website, measurement starts only if you accept. The banner on your first visit asks, and until you accept, the library does not load; if you refuse, it never loads. A refusal does not mean the tool loads and stays quiet. In the app there is at present no equivalent question — section 4 says what we rely on and how you can object.

Vercel. The website is hosted there, and the servers that serve it record the requests they receive, including the IP address and the browser type, as any hosting does, so that the site works and withstands abuse.

Apple, PostHog, RevenueCat and Vercel are connected to companies outside the European Economic Area. Where processing reaches them, the transfer relies on the mechanisms provided for by the Regulation: the standard contractual clauses, or an adequacy decision of the European Commission, such as the EU–US Data Privacy Framework.

That is all. We do not sell data to anyone, we do not place social network tracking pixels, we do not build advertising profiles and we do not do remarketing. The site carries no advertising.

7. How long we keep data

The data in the app stays on your phone for as long as you keep it there. We do not keep it, because we do not have it. A reset from the app’s settings deletes it, and uninstalling the app takes with it everything the app kept on the phone.

The iCloud copy, if you have used sync, stays in your account until you delete it — including after you have uninstalled the app. Deleting the app from your phone does not clear iCloud as well.

Measurement data — from the website and from the app — we keep for at most 12 months, after which it is deleted. If you withdraw your consent for the website sooner, measurement stops from that moment; if you object to measurement in the app, we stop it from the date of your request.

Subscription data stays with RevenueCat for as long as the subscription is active and for a reasonable period afterwards, as long as we need in order to answer a complaint about payment or renewal. We do not keep it longer than that.

Email correspondence we keep for as long as it is useful in order to resolve what you wrote about and to pick the conversation back up if you return to it — as a rule no more than three years — and then we delete it. Hosting logs rotate on their own, at the short intervals the provider sets.

8. Your rights

The Regulation gives you, in Articles 15 to 21, the right of access to your data, the right to its rectification, the right to erasure, the right to restriction of processing, the right to portability and the right to object to processing. Where the basis is consent, you also have the right to withdraw it at any time, without the withdrawal affecting the processing that came before it.

For the data in the app you exercise these directly, without us and faster than through us: you see all of it by opening the app, you correct it in the app’s settings — the pack price, the number of cigarettes, the start date — and you delete it with a reset or by uninstalling the app. We cannot show it to you, correct it or delete it, for the simple reason that we do not have it.

For the measurement data — from the website and from the app — for the subscription data and for email correspondence, write to us at contact@fumstop.ro. We reply within one month of the request, as Article 12 requires; if the request is complicated and we need more time, we tell you within that month why and how long.

An honest limit: the measurement data does not carry your name, your email address or any account, only the identifier in your browser, or the one the app keeps on your phone. If you ask us for access to it or its erasure and we cannot establish which of it is yours, we tell you so rather than sending you somebody else’s data — Article 11 of the Regulation provides for exactly this situation. Withdrawing consent remains within reach in any case: delete this site’s data from your browser, and the banner reappears on your next visit and you can refuse.

9. Security

The best security measure for what you entered in FumStop is that we do not have it: what does not leave your phone cannot be lost from our servers. That covers your habit, your cravings and your figures, which is the part that says something about your health. It does not cover the app usage events and the subscription data in section 2, which do leave — and for which we rely on the measures of the providers that hold them.

On the phone, the app’s data sits in the isolated space iOS gives each app, which other apps cannot reach. If the phone has a passcode, the system encrypts it as well. The iCloud copy is encrypted by Apple in transit and where it is stored.

The website is served only over an encrypted connection, HTTPS. Only we have access to the traffic measurement data, on the basis of authentication, and we do not pass it on.

Nobody can promise absolute security and we do not promise it either. What we can promise is that we do not gather data we do not need, and data not gathered is the only data that cannot leak.

10. Children

FumStop is for adults who smoke. You need to be at least 16 to use it, the same age the terms of use require.

Sixteen is the age Article 8 of the Regulation provides for consent given on one’s own to an online service, and Romania has not lowered it, as some other states have.

We do not design the app for children, we do not promote it to them, and we do not knowingly collect data from people under 16. Neither the app usage events nor the subscription data tell us anyone’s age, so in practice such a case would reach us through email correspondence. If we find that we hold such data, we delete it. If you are a parent and believe this has happened, write to us at contact@fumstop.ro.

11. Complaints

If something about your data does not sit right with you, write to us first, at contact@fumstop.ro. Most things are cleared up there, and faster than by any other route.

You have the right, however, to complain directly to the supervisory authority, without coming to us at all. In Romania this is the National Supervisory Authority for Personal Data Processing, B-dul General Gheorghe Magheru nr. 28–30, sector 1, 010336 Bucharest, anspdcp@dataprotection.ro, www.dataprotection.ro.

If you live in another European Union member state, you may equally address the supervisory authority there. You also retain the right to go to court.

12. Changes to this policy

We update this policy when the app or the website changes and when the law requires it. The version in force is always the one here, and the date of the last update sits at the top of the page.

If a change really matters to you — a new tool that processes data, a new purpose, a changed basis — we tell you in the app or on the website before it takes effect. And if the change concerns processing that rests on your consent, we ask you again, rather than assuming the old answer covers the new situation.

We do not keep an archive of previous versions here. If you need the version you read on a particular date, write to us at contact@fumstop.ro and we will send it to you.