Pulsey Privacy Policy

Effective date: 2025-11-12

Publisher: Codivo (“we”, “us”, “our”)

Pulsey (the “App”) helps you listen to body sounds during pregnancy and keep personal records. This Policy explains what we collect, how we use it, and your choices.

If you do not agree with this Policy, please do not use the App.

1) Summary

  • We collect: (a) device advertising identifiers for advertising/measurement (e.g., Apple IDFA/IDFV) and (b) App user IDs we generate to provide core functionality (e.g., session history, receipts, feature access).
  • We do not collect: audio recordings or pregnancy notes from the App to our servers. These remain on device unless you share or back them up with third parties.
  • We do not sell personal information. We may “share” identifiers with ad partners for cross-context behavioral advertising as defined by certain laws; you can opt out (see Section 10).

2) Data We Process

A. Identifiers for Ads and Measurement

  • What: Apple IDFA (if you grant permission via Apple’s App Tracking Transparency), Apple IDFV, IP-derived coarse signals, and related event metadata (ad clicks/views attributed to installs).
  • Why: deliver, measure, and cap ads; detect fraud; analyze campaign performance; personalize ads if you consent.

B. App Functionality Identifiers

  • What: an App-specific user ID we generate (and device IDFV) to enable core features (e.g., unlocking purchases, keeping local history coherent, feature flags, account restoration if applicable).
  • Why: provide and secure the service; prevent abuse; handle subscriptions/entitlements.

C. Support Communications (if you contact us)

  • What: email address, message content, attachments, and meta (timestamps).
  • Why: respond to your request and improve support quality.

We do not collect: audio contents you record in the App, pregnancy notes you enter in the App, precise geolocation, contacts, photos, calendars, or motion/fitness data from your device.

3) On-Device Audio and Pregnancy Info

  • Recording, enhancement, playback, history logs, week counters, and due-date countdowns operate on your device.
  • We do not upload your audio or pregnancy notes to our servers.
  • You can delete recordings in-app or via iOS settings.

4) Legal Bases (GDPR/UK GDPR)

  • Consent: advertising identifiers (IDFA), ad personalization/measurement where consent is required.
  • Legitimate interests / Contract: app user ID, service provision, fraud prevention, security, purchase verification, customer support.

5) How We Use Data

  • Provide, secure, maintain, and improve the App.
  • Manage purchases, entitlements, and access.
  • Measure ad performance; frequency capping; fraud detection; (where consented) personalize ads.
  • Respond to support requests and fix issues.

6) Sharing and Recipients

We may share limited data with:

  • Advertising & measurement partners (receive IDFA/IDFV where permitted) for attribution, caps, fraud checks, and (if consented) personalization.
  • Payment/entitlement providers (e.g., App Store) to validate purchases.
  • Cloud/email providers for support communications only.
  • Authorities if required by law or to protect rights/safety.

We do not sell personal information. Some laws treat targeted advertising as “sharing.” See opt-out in Section 10.

7) Retention

  • Advertising identifiers/events: typically up to 13 months (industry norm) unless law or partner policies require shorter/longer.
  • App user ID / entitlement records: for your active use and up to 24 months after last activity (or longer if legally required).
  • Support emails: up to 90 days after resolution unless law requires longer.

We delete or de-identify data when no longer needed.

8) Security

We apply technical and organizational measures appropriate to the data we handle. Most sensitive activity (audio/notes) stays on device under iOS protections. No system is 100% secure; keep your device updated and protected.

9) International Transfers

If our email or limited backend services are hosted outside your country, transfers occur under recognized safeguards (e.g., SCCs) where applicable. We do not maintain a cloud store of your on-device audio/notes.

10) Your Choices

A. Apple App Tracking Transparency (ATT)

  • The App shows Apple’s tracking permission prompt if/when needed.
  • If you deny, we will not access IDFA; ads may still appear but are not personalized via IDFA.

B. Opt-Out of “Sale/Sharing” (CPRA)

  • We do not sell data. To the extent ad personalization is deemed “sharing,” you can opt out in-app (Settings > Privacy > Ads) and via OS controls. We honor Do Not Sell or Share requests for ad personalization.

C. OS-Level Controls

  • Reset/limit ad tracking (Settings > Privacy & Security > Tracking / Ads).
  • Revoke microphone/storage permissions (may limit features).

D. Rights (GDPR/UK/US and others)

You may have rights to request access/deletion or to object/withdraw consent (where we rely on consent). Contact us (Section 13). If we only hold your support emails, we will process the request for that context.

11) Children

The App is intended for adults. We do not knowingly collect children’s personal information. If a child has contacted us, email us to delete the message.

12) Changes to This Policy

We may update this Policy. We will post changes at the URL below and update the effective date. Material changes will be highlighted.

13) Contact

� 2025 Codivo. All rights reserved.