SETL Privacy Policy

SETL helps you put your phone down at night. To do that it works with your Screen Time data. That data is personal, so we built SETL to keep it on your iPhone. This policy explains what stays on your phone, the small amount that leaves it, and the rights you have.

The short version

• Your Screen Time data stays on your iPhone. We never receive it and we cannot see it.
• SETL has no accounts and no passwords. We do not ask you to sign up.
• SETL does not ask for your email address.
• We do not use advertising, analytics or tracking tools. We do not sell your data.
• Apple handles every payment. We never see your card details.
• We use a company called RevenueCat to check whether your subscription or lifetime purchase is active.
• Deleting SETL deletes the data it keeps on your iPhone.

1. Who we are

SETL is run by Jacob Redshaw, trading as SETL ("SETL", "we", "us"). You can contact us at jacob@setlsleep.com.

ICO registration number: pending

We are the controller of the personal data described in this policy. This means we decide how and why it is used. The law that applies is the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What stays on your iPhone

Most of what SETL knows about you never leaves your phone. We cannot see any of it.

Screen Time data. SETL uses Apple's Screen Time tools (called Family Controls, Device Activity and Managed Settings) to block the apps you choose and to show how you used your phone. Apple does not give SETL the names of your apps or websites. It gives SETL anonymous codes, called tokens, that only make sense on your phone. Your daily usage figures are drawn by an Apple extension that runs in a sealed space on your phone. Apple does not let that extension send anything over the internet. SETL keeps your app choices, your block schedule and your usage on your iPhone. None of it is sent to us.

Your settings and progress. This includes your name, wake and bed times, reminder choices, the apps you block, your sessions and blocks, your nights record, your moons and your time zone. It is stored in SETL's own storage on your iPhone. A shared storage area on the same phone lets SETL's widgets, block screen and Screen Time extensions read it. It is not sent to us.

Your onboarding answers. The answers you give when you first set up SETL are used to shape what you see. They stay on your iPhone.

Notifications. Your bedtime reminders, morning messages and trial reminder are created and scheduled on your iPhone. SETL does not use a push notification server.

Siri and Shortcuts. If you ask Siri to start a session, Apple handles your voice request under Apple's privacy policy. SETL only receives the session length you asked for.

Your iPhone backups and Apple's own services are covered by Apple's privacy policy, not this one.

3. What leaves your iPhone, and why

Your purchase

SETL is a paid app. You can choose a weekly, monthly or yearly subscription, or a one time lifetime purchase. Some plans start with a free trial. When you start a trial, subscribe, buy lifetime access or restore a purchase, Apple processes the payment. Apple shares the result with SETL. We never receive your card details, your billing address or your Apple ID password.

To check your purchase, SETL uses RevenueCat. RevenueCat receives:

• an anonymous app user ID that RevenueCat creates for your copy of SETL
• your purchase details from Apple: the plan, trial status, purchase and renewal dates, price and currency, and Apple's transaction references
• the country or region of your App Store account
• technical details needed to answer the request, such as your device type, iOS version, SETL version and IP address

RevenueCat does not receive your name, your email address or your Screen Time data. The app user ID is not linked to your name or contact details.

We use this to unlock SETL while your trial, subscription or lifetime purchase is active, to restore your purchase on a new phone, to show your plan and renewal date in Settings, to remind you on your iPhone before a trial ends, to prevent fraud, to keep our business and tax records, and to see how many people subscribe and cancel.

Messages you send us

SETL does not collect your email address. If you choose to email us at jacob@setlsleep.com, for example with the Email support button, we receive your email address, your message and anything you attach. We use it only to reply to you and help you. We do not add you to any mailing list and we do not send marketing emails.

Crash reports and app statistics shared through Apple

SETL does not contain any crash reporting or analytics tools of its own. Apple asks iPhone users whether to share crash and usage information with app developers. If you said yes, Apple may pass us crash reports and performance data for SETL. Apple also gives us summary figures about downloads and usage from people who agreed to share them. This information does not include your name or contact details, and we do not use it to identify you. You can change this choice in your iPhone's Settings under Privacy and Security, then Analytics and Improvements.

Links you open

If you tap a link in SETL, such as this policy or Manage subscription, it opens in Safari or the App Store. Those pages have their own privacy terms.

4. Our lawful basis

UK GDPR says we must have a lawful reason for each use of your personal data. Data that stays on your iPhone is never received by us.

Where we rely on legitimate interests, we have weighed our interests against your rights. You can object at any time (see section 10).

5. Who we share data with

We only share data with the services below, and only for the reasons in this policy.

We do not sell your data. We do not share it with advertisers or data brokers. We may share data if the law requires it, or to protect our rights or the safety of others.

6. International transfers

RevenueCat and Vercel are based in the United States. Google and our font providers may also process data outside the UK. When your data leaves the UK, we make sure it is protected by an approved safeguard. This will be the UK Extension to the EU US Data Privacy Framework where the provider is certified, or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. You can ask us for details.

7. How long we keep data

• Data on your iPhone stays until you delete SETL.
• Purchase records at RevenueCat are kept while your subscription or lifetime purchase is active and for six years after it ends, so we can handle restores, refunds, disputes and our tax records. You can ask us to delete them sooner (see section 9), unless the law requires us to keep them.
• Emails you send us are kept for two years after we last hear from you.
• Waitlist emails are kept until you ask us to remove them, or until 12 months after SETL launches, whichever is sooner.
• Website visit records are kept by Vercel for a short period under its own retention rules.
• Crash and performance data from Apple is kept for as long as Apple makes it available to us.

8. Your Screen Time data and deleting SETL

When you delete SETL from your iPhone, iOS removes the data SETL stored on it. This includes your Screen Time choices, settings, history and moons. iOS also removes SETL's Screen Time permission and lifts any blocks SETL set.

A few things are not on your phone, so deleting the app does not remove them:

• your subscription, which is held by Apple and continues until you cancel it
• your purchase record at RevenueCat

Deleting SETL does not cancel your subscription. To cancel, open Settings on your iPhone, tap your name, then tap Subscriptions.

9. Asking us to delete data we hold

Email jacob@setlsleep.com and tell us what you would like deleted. SETL has no accounts, so to help us find your purchase record, please include the order ID from your Apple receipt. We will reply within one month.

10. Your rights

Under UK GDPR you have the right to:

• access the personal data we hold about you
• rectification, so we correct data that is wrong
• erasure, so we delete your data
• restriction, so we limit how we use it
• objection, so we stop using it where we rely on legitimate interests
• portability, so you receive your data in a common format
• withdraw consent at any time, where we rely on consent

To use any of these rights, email jacob@setlsleep.com. We do not charge for this. We may need to confirm who you are first. We will reply within one month.

Because we never receive your Screen Time data, we cannot provide it, correct it or delete it for you. It stays under your control on your iPhone.

If you are unhappy with how we handle your data, please tell us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk or on 0303 123 1113.

11. Children

SETL is made for adults. You must be 18 or over to use it. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.

12. Security

We keep the data we hold to a minimum. Data on your iPhone is protected by iOS, including your passcode and the encryption Apple provides. Data sent to RevenueCat is encrypted in transit. We limit who can access our accounts and protect them with strong passwords and two step sign in. No system is perfectly secure, but we take reasonable steps to protect your data.

13. Our website

This policy also covers setlsleep.com. The website has no adverts, analytics or tracking cookies. If you joined our waitlist, the email you gave us is stored in a Google Sheet through Google's Apps Script service. We use it only to tell you when SETL launches. Your browser also keeps a note that you joined, so the page remembers you. That note stays in your browser and we cannot read it. The website loads fonts from Google and Fontshare, which means they receive your IP address when the page loads. Vercel hosts the website and receives basic request details, such as your IP address, when you visit. You can ask us to remove your waitlist email at any time.

14. Changes to this policy

We may update this policy when SETL changes or the law changes. We will post the new version here with a new date. If a change is significant, we will also tell you in the app before it takes effect.

15. Contact us

Jacob Redshaw, trading as SETL

Email: jacob@setlsleep.com