Who this policy is for
This policy is for people protected by Washington State's My Health My Data Act (Washington residents, and people whose consumer health data is collected in Washington), and by similar consumer health data laws in other places. It sits alongside our main Privacy Policy.
Who we are: Ibtikar Al Ula for Information Technology and E-Marketing Co. Ltd., maker of the Soberwise app.
Contact: info@ibtikaralula.com
In short
- What you enter in Soberwise stays on your phone, and we never receive it.
- The only information about you that reaches us is a subscription record, through our subscription processor RevenueCat, and anything you choose to write to us yourself, such as a support email. Because Soberwise is about alcohol, that record could show that you looked for a health-related service, so we treat it as consumer health data.
- We don't sell consumer health data, and we don't share it with third parties.
1. Categories of consumer health data, and why
A. What you enter in the app. This stays on your phone and the app processes it there for you. We, the company, don't receive it, access it or store it. We list it so that you can see the whole picture:
- your start date, your day count, and the drinks you log;
- check-ins, mood, cravings, and which tools helped;
- journal entries, letters to your future self, reasons, plans, rewards and habits;
- your weight, if you choose to log it;
- your answers to the starting questions.
Purpose: to give you the app's features on your phone, such as your counter, your tree, your tools, your reminders and your history.
B. Your subscription record. RevenueCat processes it for us. A record exists for everyone who uses the app, not only buyers, because the app asks RevenueCat whether you have Premium each time it opens. The record contains:
- an anonymous ID created on your phone;
- if you buy, your Google Play purchase record: plan, dates, price, trial or introductory status, and renewal status;
- device type, Android version, app version and phone language;
- the country of your purchase, or, if there is none, the country worked out from your IP address. The IP address itself is then dropped.
Purposes:
- to unlock the Premium features you asked for;
- to restore them on a new phone;
- to show the plans offered in your country;
- to give us totals in reports, such as how many trials started.
We collect only what is necessary to provide the service you asked for. If we ever want to collect or use consumer health data for another purpose, we will ask for your consent first.
2. Where the data comes from
- From you: what you type into the app. It stays on your phone.
- From your phone: the anonymous ID and the technical details listed above.
- From Google Play: confirmation of your purchase, when you buy.
3. Consumer health data we share
None. We don't share consumer health data with third parties or affiliates, and we don't sell it.
We give your subscription record to RevenueCat, which processes it only on our behalf, to provide the subscription you asked for. Under the law, giving data to a processor for that purpose is not "sharing".
4. Third parties and affiliates who receive it
- Third parties: none.
- Affiliates: none.
- Processor: RevenueCat, Inc. (USA), which manages subscriptions.
Google receives your payment, and any rating you choose to give, directly from you under its own terms. We don't send Google any consumer health data.
We don't use GPS or your phone's location services, and we don't use geofencing. The only location-related data is the country described in section 1B.
5. Your rights, and how to use them
You have the right to:
- Confirm and access: ask whether we collect, share or sell your consumer health data, see it, and get a list of all third parties and affiliates that received it. (Today that list is empty.)
- Withdraw consent: withdraw any consent you gave us for collecting or sharing it.
- Delete: have it deleted.
- On your phone: use Me > My data > Delete all my data, or uninstall the app. This takes effect immediately.
- Your RevenueCat record: ask us. We delete it and tell RevenueCat, which must delete it too.
How to ask:
- Email info@ibtikaralula.com.
- Include the order number from your Google Play receipt (it starts with "GPA."). We use it only to find your record.
If you have never bought anything, there is no order number. Your record then holds only the anonymous ID, the technical details and the country, and nothing in it links it to you. So we can't tell which record is yours.
What to expect:
- We reply without undue delay, and within 45 days.
- If we need more time, we tell you within those 45 days, with the reason, and take at most 45 days more.
- Requests are free, up to twice a year.
- We won't treat you differently for using these rights.
If we say no. You can appeal by replying to our answer with the word "Appeal". We answer your appeal in writing within 45 days and explain what we decided and why. If we deny your appeal, you can complain to the Washington State Attorney General: https://www.atg.wa.gov/file-complaint
6. Changes
If we change this policy, we update the date above. Before we collect or share any new category of consumer health data, or use it for a new purpose, we will update this policy and ask for your consent first.