BREAKR — PRIVACY POLICY

1. INTRODUCTION & GENERAL PRINCIPLES

Thank you for using Breakr. Breakr is owned, sold, and operated by 99 Degrees Creative Studio LLC (the legal vendor and data controller). Our mission is to help individuals reclaim their time, conquer digital distractions, and build deep focus habits. We believe in clear, unambiguous, and strict rules when it comes to user privacy.

Here are the core principles driving how we handle your data:

• Private Data Stays on Your Device: On iOS, we utilize Apple's official Screen Time API (FamilyControls, ManagedSettings, DeviceActivity) to block apps and restrict distractions. Detailed app-usage data, blocked app selections, and browsing activity processed through these frameworks remain strictly on your device. We do not transmit or store this data on our servers.
• Minimize Data Collection: Our objective is to minimize or eliminate the collection of your personal data. We are committed to absolute transparency and explicit user consent.
• No Selling of Personal Data: We never sell, rent, trade, or monetize your personal data to advertisers or third-party data brokers.
• You Pay for the Product: Breakr is funded through optional Pro/Premium subscriptions. We do not rely on behavioral advertising trackers or monetizing user attention.

2. DATA WE COLLECT (SUMMARY)

A. Data Linked to You (Account & Support):

If you contact our support team or register an account, we may process your email address, name, or support ticket identifiers. This is strictly used to correspond with you, resolve technical issues, or verify your subscription status.

B. Data Not Linked to You (Technical & Diagnostics):

Anonymous technical information including app crash logs, iOS version, device hardware model, installation timestamp, and aggregate feature engagement counts. This data cannot be used to identify you and serves solely to improve app stability and performance.

C. Screen Time & App Restriction Data (100% On-Device):

Breakr does not collect, inspect, or transmit the specific apps, websites, or categories you choose to block. All restriction logic is executed locally via Apple's sandboxed APIs.

3. REFUND POLICY

• App Store Purchases (iOS): All in-app purchases and subscriptions made through the Apple App Store are processed directly by Apple. Breakr does not collect or hold your credit card or billing details. Consequently, we cannot issue refunds directly. To request a refund, please follow Apple's official refund process at https://reportaproblem.apple.com.
• Direct Purchases (if applicable): For any purchases made directly via our official website, refund requests submitted within 30 days of purchase to support@99degrees.studio from the purchasing email will be reviewed and processed in accordance with applicable consumer laws.

4. END USER LICENSE AGREEMENT (STANDARD EULA)

Apps made available through the App Store are licensed, not sold, to you. Your license to Breakr is governed by this End User License Agreement:

• a. Scope of License: Licensor (99 Degrees Creative Studio LLC) grants you a non-transferable, non-exclusive license to use Breakr on any Apple-branded products that you own or control, subject to the Apple Media Services Terms and Conditions. You may not distribute, sublicense, reverse-engineer, disassemble, modify, or attempt to derive the source code of the App or any updates thereof.
• b. Consent to Use of Technical Data: You agree that Licensor may collect and process anonymous technical data and diagnostic information to facilitate software updates, product support, and continuous service improvements.
• c. Termination: This license is effective until terminated by you or Licensor. Your rights terminate automatically without notice if you fail to comply with any terms of this agreement. Upon termination, you must cease all use and delete all copies of the App.
• d. External Services & Third-Party Materials: The App may enable access to third-party services. You use such services at your sole risk. Licensor is not responsible for evaluating or guaranteeing third-party content or availability.
• e. NO WARRANTY: YOU EXPRESSLY ACKNOWLEDGE THAT USE OF THE APP IS AT YOUR SOLE RISK. TO THE MAXIMUM EXTENT PERMITTED BY LAW, BREAKR IS PROVIDED "AS IS" AND "AS AVAILABLE", WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND. LICENSOR DISCLAIMS ALL WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY, AND NON-INFRINGEMENT.
• f. Limitation of Liability: TO THE EXTENT NOT PROHIBITED BY LAW, IN NO EVENT SHALL LICENSOR BE LIABLE FOR PERSONAL INJURY, INCIDENTAL, SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES WHATSOEVER, INCLUDING LOSS OF PROFITS, DATA LOSS, OR BUSINESS INTERRUPTION. IN NO EVENT SHALL LICENSOR'S TOTAL LIABILITY EXCEED FIFTY DOLLARS ($50.00).
• g. Export Compliance & Governing Law: You represent that you are not located in a U.S.-embargoed country or listed on any U.S. government restricted-party list. This agreement is governed by the laws of the State of Wyoming, USA, excluding conflict of law principles. For European Union, Swiss, Norwegian, or Icelandic residents, governing law shall be the laws of your habitual residence.

5. FULL PRIVACY POLICY

5.1 Introduction & Data Controller

99 Degrees Creative Studio LLC is the data controller responsible for the personal data collected through Breakr. If you have questions regarding this policy or our data practices, reach us at privacy@99degrees.studio.

5.2 Purpose & Standards

We maintain strict administrative, technical, and physical safeguards designed to protect personal and non-personal data against unauthorized access, loss, alteration, or disclosure.

5.3 User Consent

By downloading, accessing, or using Breakr, you consent to the collection, storage, and processing of your information as outlined in this Privacy Policy.

5.4 Children's Privacy (COPPA & GDPR Compliance)

Breakr does not knowingly collect personal data from children under the age of 13 (or under 16 in certain EU jurisdictions). If we discover that a child has provided us with personal information without parental consent, we will delete that data immediately. Contact us at privacy@99degrees.studio if you believe such information was submitted.

5.5 Information We Collect and Process

• Direct Communications: Name, email address, and correspondence history provided when seeking customer or technical support.
• Diagnostic & Log Data: IP address (processed temporarily for network routing), operating system version, device hardware specifications, crash logs, and time-stamped interaction events within the App.
• Apple Screen Time Data: Managed locally via Apple frameworks. Breakr does not receive, read, or export the list of selected applications, website URLs, or specific activity logs.

5.6 How Information Is Collected

• Direct Interaction: When you email us, report a bug, or participate in voluntary user surveys.
• Automated Technologies: Locally executed app logs and Apple framework telemetry. We do not employ third-party behavioral advertising cookies or cross-app tracking mechanisms (IDFA).

5.7 Security and Data Retention

We implement industry-standard encryption protocols (HTTPS/TLS) for any data in transit. Because application restriction rules and screen time preferences are stored locally on your device, deleting the Breakr application permanently purges this data. Customer support records are retained only as long as necessary to resolve inquiries and fulfill legal requirements.

5.8 Disclosure of Information to Third Parties

We do not sell, trade, or rent personal data. We disclose information only under the following limited circumstances:

• Service Providers: Trusted technical infrastructure and diagnostic providers operating under strict confidentiality and data protection agreements.
• Legal Compliance: In response to lawful requests by public authorities, subpoenas, court orders, or applicable statutory mandates.
• Corporate Transactions: In connection with any merger, financing, acquisition, or sale of company assets, where personal data is transferred as a business asset under this Privacy Policy.

5.9 International Data Transfers

If you access the Service from outside the United States, your information may be processed in the United States or other jurisdictions where our cloud infrastructure resides. We ensure appropriate safeguards are implemented, including standard contractual clauses approved by the European Commission where applicable.

5.10 Rights for European Economic Area (EEA) & UK Residents (GDPR)

Under the General Data Protection Regulation (GDPR), users located in the EEA and UK hold the following rights:

• Right of Access & Portability: Request confirmation and copies of personal data processed.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of personal records.
• Right to Restriction & Objection: Restrict or object to legitimate-interest data processing.
• Right to Lodge a Complaint: File a complaint with your local Data Protection Authority.

5.11 Additional Disclosures for California Residents (CCPA / CPRA)

Pursuant to the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• No Sale of Personal Information: Breakr does not sell or share personal information for cross-context behavioral advertising.
• Categories Collected (Past 12 Months): Identifiers (support emails, device IDs), Internet/Electronic network activity (diagnostic logs), and Inferences related to app performance.
• Consumer Rights: California residents have the right to request disclosure of data collection categories, request deletion of personal information, and receive equal service without discrimination.
• Shine the Light: We do not disclose personal information to third parties for direct marketing purposes. Requests may be directed to privacy@99degrees.studio.

5.12 "Do Not Track" Signals

Our systems do not track users over time across third-party websites; therefore, the App does not alter its behavior in response to browser "Do Not Track" (DNT) signals.

5.13 Policy Modifications

We reserve the right to amend this Privacy Policy and EULA at any time. Any changes will be posted on this page with an updated "Last Updated" date. Continued use of the Service following modifications constitutes acceptance of the revised terms.

5.14 Contact Us

For any inquiries regarding this document or your personal data: