Privacy Policy

Last updated: Jun 5, 2026

1. Overview

The Promise Challenge is a health and wellness app that helps you rebuild trust with yourself through small, daily habits. Your privacy matters. This policy explains what data we collect, how we use it, and your rights.

2. Who We Are

The Promise Challenge is operated by Mint Labs OOD, a company registered in Bulgaria (company no. 207040615), at G.S. Rakovski 21, 6303 Haskovo, Bulgaria. We decide how your data is handled, which makes us the data controller under privacy law. You can reach us at contact@mypromise.xyz.

3. What We Collect

We collect only the data necessary to provide and improve the app experience.

Stored on your device:

  • Daily check-in activity (e.g. whether you completed a promise)

  • Optional photos you choose to log for your personal progress

Collected for analytics (outside Europe only — see Section 8):

  • App usage, such as screens viewed, onboarding steps, and challenge progress

  • Basic device information (model, operating system, app version)

  • A pseudonymous identifier and approximate location (city or country) derived from your IP address

For subscriptions:

  • Subscription and purchase status, processed through Apple and RevenueCat

We do not collect personal identifiers like your name, email, or phone number, and we do not ask you to create an account.

4. How Your Data Is Stored

Your personal content — your check-ins and progress photos — is stored locally on your device. We do not upload, store, or process this content on external servers. If you delete the app, this content is deleted with it.

5. Photo Access

If you choose to add photos to your check-ins, The Promise Challenge will request permission to access your device's camera or photo library. These images are only used inside the app and remain stored on your device. We never upload or transmit them.

6. Sharing Your Content

The Promise Challenge allows you to share your check-ins or progress photos through your device's native sharing tools (e.g. social media or messaging apps). Sharing is optional and fully controlled by you. Once content is shared outside the app, we no longer have access to or control over it. Please refer to the privacy policy of any platform you share to.

7. Notifications

Any reminders the app sends are scheduled locally on your device. No notification data is sent to us.

7. Your Rights

Since all your data is stored locally, you can access and delete it at any time by deleting the app from your device.

If you have any concerns or questions about your data, you can contact us at:
contact@mypromise.xyz

8. Analytics (Outside Europe Only)

We use Mixpanel, a third-party analytics service, to understand how the app is used so we can improve it — but only for users outside Europe.

  • If you are in the EU, EEA, UK, or Switzerland, we check your region when the app opens and do not start analytics. No usage data is collected from you.

  • If you are located elsewhere, we collect pseudonymous usage data as described in Section 3. "Pseudonymous" means it is tied to a random identifier — not your name, email, or phone number — and cannot be traced back to you personally.

We use this data only to improve the app. We do not use it for advertising, we do not sell it, and we do not use it to track you across other apps or websites. You can read Mixpanel's privacy policy at https://mixpanel.com/legal/privacy-policy/.

9. Subscriptions and Payments

The Promise Challenge offers subscriptions through Apple's App Store. Apple processes the payment — we never see or store your card details. We use RevenueCat to manage your subscription status under an automatically generated anonymous identifier, not your email or anything that identifies you.

10. Service Providers

We share data with a small number of providers, none of whom receive your data for advertising:

We do not sell your data or share it for targeted advertising. We may disclose data if required by law, or in connection with a sale of the business, in which case we will update this policy.

11. International Data Transfers

Because we do not run analytics on European users, the only data that may leave Europe is your subscription information, handled by Apple and RevenueCat in the United States. Where this happens, we rely on the European Commission's Standard Contractual Clauses (with the equivalent UK and Swiss protections), and the EU–US Data Privacy Framework where a provider is certified under it.

12. Data Retention

  • On-device content (check-ins and photos): kept until you delete the app.

  • Analytics (users outside Europe): up to 12 months, then deleted or aggregated.

  • Subscription records: kept while your subscription is active, and afterwards for 10 years, as required by Bulgaria's Accountancy Act for records related to tax and accounting.

  • Support emails: kept only as long as needed to respond to you.

13. Legal Bases for Processing

For users in the EU, EEA, and UK, we rely on the following legal bases:

  • On-device content: this never reaches us, so we do not process it; it is part of providing the app you requested.

  • Analytics (users outside Europe): our legitimate interest in understanding usage and improving the app. This does not apply to European users, as we do not collect it.

  • Subscriptions: performance of our contract with you, and compliance with our tax and accounting obligations.

  • Support emails: our legitimate interest in responding to you.

14. Your Rights

Everyone: your check-ins and photos are stored on your device, so you can access or delete them at any time, or delete the app to remove everything. Outside Europe, you can stop analytics by deleting the app (and, where available, switching it off in Settings). In Europe, there is nothing to switch off, as we do not collect it.

If you are in the EU, EEA, or UK: because we do not run analytics on you, the only data we hold is your subscription status (through Apple and RevenueCat, under an anonymous identifier) and any email you have sent us. You have the right to access, correct, delete, restrict, or object to the processing of your data, and to data portability. Because the subscription identifier is a random code with no name attached, under Article 11 of the GDPR we may be unable to locate your specific records unless you can provide that identifier; we will help where we can. You may also lodge a complaint with Bulgaria's Commission for Personal Data Protection (https://www.cpdp.bg) or your local data protection authority.

If you are in California: the CCPA's thresholds mean it likely does not apply to a company of our size, but for transparency — for users outside Europe we may collect identifiers (a pseudonymous device ID and IP address), app usage, subscription status, and approximate location. We do not sell your personal information or share it for cross-context behavioral advertising, and we do not use sensitive information to infer characteristics about you. You may ask what we hold or request deletion, and we will not treat you differently for doing so.

To exercise any of these rights, contact us at contact@mypromise.xyz.

15. Children's Privacy

The Promise Challenge is a general-audience app intended for users aged 16 and over. It is not designed for or directed at children, and we do not knowingly collect data from anyone under 16. If you believe a child has used the app, contact us at contact@mypromise.xyz and we will delete any related data.

16. Our Website

Our website (mypromise.xyz) is informational, and we do not run analytics or tracking on it. Our website host, Framer, may set basic cookies necessary to deliver the site; see Framer's privacy policy for details.

17. Security

Because most of your data never leaves your device, the app's design is the primary safeguard. For the limited data we do handle, we rely on Apple's platform protections and our providers' security measures. No system is completely secure, but we take reasonable steps to protect the data involved.

18. Changes to This Policy

We may update this policy from time to time. When we do, we will revise the "Last updated" date above, and we will communicate significant changes within the app or on our website.

19. Contact

If you have questions about this privacy policy or how your data is handled, contact us at contact@mypromise.xyz.

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