Privacy Policy for NeonRoutine

Last Updated: March 2026

1. Introduction

This Privacy Policy applies to the use of the mobile application NeonRoutine (the “App”), developed and operated by Timon Polley (“we”, “us”, or “our”). We are committed to protecting your privacy and ensuring the security of your personal information in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.

2. Information We Collect & Lawful Basis (Art. 6 GDPR)

We collect the minimum amount of data necessary to operate the App effectively. Our processing is based on the following legal grounds:

• Local Habit Data: Your routines, subroutines, and execution logs are stored securely and locally only on your device (using Isar DB and SharedPreferences). This data is never transmitted to our servers. Lawful Basis: Legitimate Interest (Art. 6(1)(f) GDPR).
• In-App Purchases: Managed securely via RevenueCat and the respective app stores (Apple App Store / Google Play). We do not have access to your payment details. Lawful Basis: Performance of a Contract (Art. 6(1)(b) GDPR).
• Advertisements: We use Google AdMob to serve rewarded ads. Ad personalization is determined by user consent via the UMP (User Messaging Platform) consent dialog: EEA/UK users are presented with a GDPR consent form; iOS users are presented with an App Tracking Transparency (ATT) prompt. Users who do not consent receive non-personalized ads only. On iOS, users who accept the ATT prompt may have their device’s IDFA (Identifier for Advertisers) collected by Google for ad targeting and performance measurement. Lawful Basis: Explicit Consent (Art. 6(1)(a) GDPR).
• Push Notifications: Used to remind you of your routines. Lawful Basis: Explicit Consent (Art. 6(1)(a) GDPR).

3. Third-Party Services & Processors (Art. 28 GDPR)

The App uses third-party services that may collect information used to identify you. We have accepted Data Processing Agreements (DPAs) with these sub-processors:

• Google AdMob: Ad serving and related data processing. Data is processed in accordance with Google’s Privacy Policy.
• RevenueCat: Subscription and purchase management.
• Apple Inc. / Google LLC: Processing of App Store / Play Store transactions.

4. Your Rights (Art. 15–22 GDPR)

Under the GDPR, you have extensive rights regarding your data. You can exercise most of these directly within the App:

• Right of Access & Data Portability (Art. 15 & 20): You can export all your local habit data in JSON format at any time using the “Data Export” button in the App’s Settings.
• Right to Erasure (Art. 17): You can permanently delete all your data and reset the App to a clean state by using the “Wipe System” feature in the Settings.
• Right to Rectification (Art. 16): You can edit, modify, or delete individual habits effortlessly within the App.
• Right to Object & Withdraw Consent (Art. 21 & 7): You can update or withdraw your ad consent at any time via Settings → AD PREFERENCES in the App. Push notifications can be disabled via your device’s OS settings.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy.

• Local Data: Kept indefinitely on your device until you delete the app or use the “Wipe System” feature.
• Purchase History: Maintained by RevenueCat and App Stores as required for financial/tax compliance and subscription management.

6. Children’s Privacy (COPPA & GDPR)

The App carries a 4+ age rating and may be used by users of all ages, including children. We comply with the Children’s Online Privacy Protection Act (COPPA, US) and applicable child-directed data protection laws.

All habit data is stored exclusively on the user’s device and is never transmitted to our servers or shared with third parties.

Ad content is limited to a PG (parental guidance) content rating. Ad personalization is subject to explicit user consent as described in Section 2. No behavioral profiling occurs without consent.

If you are a parent or guardian and believe your child has provided personal data to us or our third-party processors without appropriate consent, contact us at dev@timonply.com and we will take prompt action to review and, where applicable, delete that data.

6a. Parental Consent

Children under 13 (or under 16 in the EU/EEA) must have verifiable parental or guardian consent before using features that involve third-party data processing, including in-app purchases and ad-supported content. A parent or guardian who accepts this Privacy Policy on behalf of a child confirms they have reviewed it and consent on the child’s behalf.

7. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, the right to delete it, and the right to opt-out of its “sale” or “sharing.” Because we use Google AdMob for advertising, this may be considered a “sale” or “sharing” under California law. You can opt-out at any time via Settings → AD PREFERENCES within the App.

8. International Data Transfers

Since some of our third-party processors (such as Google and RevenueCat) are located outside the European Economic Area (EEA), your information may be transferred to and maintained on computers located outside of your state, province, or country. These transfers are protected by Standard Contractual Clauses (SCCs) and adherence to the EU-US Data Privacy Framework where applicable.

9. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this document.

10. Contact

If you have any questions or suggestions about our Privacy Policy or wish to exercise your rights, please contact our Data Protection representative at: Email: dev@timonply.com