Privacy
Policy.

This Privacy Policy explains how Lionscraft Pte. Ltd. (“Lionscraft”, “we”, “us”, or “our”) handles information in connection with PookieScroll.

PookieScroll is designed to minimise data collection. We do not operate a backend server for user profiles, do not require user accounts, do not use analytics SDKs in the iOS app, do not show ads, and do not track users across apps or websites.

PookieScroll is provided by Lionscraft Pte. Ltd., a company incorporated in Singapore.

1. Summary

PookieScroll is an iOS app for digital wellbeing and screen time self-management.

In general:

• Your screen time usage data is processed on your device.
• Your screen time usage data is not sent to Lionscraft.
• We do not create user accounts.
• We do not ask for your email address, phone number, or name inside the app.
• We do not use advertising SDKs in the iOS app.
• We do not use analytics SDKs in the iOS app.
• We do not sell your personal data.
• We do not share your personal data for cross-context behavioural advertising.
• Limited subscription-related information may be processed by Apple and RevenueCat to provide purchases and subscription entitlement status.
• The PookieScroll website uses cookieless analytics, as described in Section 17.

2. Who Controls Your Data

For the limited personal data we determine how and why to process, the data controller or responsible organisation is:

For certain App Store purchase and Apple ID-related information, Apple may act as an independent controller under Apple’s own privacy terms.

RevenueCat provides subscription entitlement infrastructure to us and generally acts as a service provider, processor, or data intermediary for subscription-related data it processes on our behalf.

3. Information We Do Not Collect

PookieScroll does not collect or send the following to Lionscraft:

• your screen time usage history;
• the list of apps you use;
• the amount of time you spend in specific apps;
• your browsing history;
• your messages;
• your contacts;
• your photos;
• your precise location;
• your health data;
• your advertising identifier for tracking;
• behavioural analytics events from the iOS app;
• crash or diagnostic analytics through third-party SDKs in the iOS app;
• user-generated posts or social content.

PookieScroll does not use Firebase, Mixpanel, Sentry, ad networks, social tracking pixels, or similar analytics or advertising tools in the iOS app.

4. Information Processed On Your Device

PookieScroll may process information locally on your device to provide app functionality, including:

• screen time and device activity information made available through Apple’s Screen Time, DeviceActivity, and Family Controls frameworks;
• your selected routines, app limits, and blocking preferences;
• your Pookie Score or similar in-app status indicators;
• your app settings;
• locally generated mood cards or share images.

This information is used to operate the app on your device. It is stored on your device and/or in an Apple App Group container. It is not sent to Lionscraft.

You can revoke Screen Time / Family Controls permission at any time in iOS Settings.

PookieScroll does not use iCloud sync in this version.

5. Subscription and Purchase Information

PookieScroll uses Apple StoreKit for in-app purchases and RevenueCat to help manage subscription entitlement status.

Apple may process information associated with your Apple ID, payment method, App Store account, purchase history, tax, billing, and refund handling under Apple’s own terms and privacy policy.

RevenueCat may process limited subscription-related information for entitlement management, such as an anonymous app user identifier, purchase or subscription events, product or entitlement information, subscription status, device type, operating system, Apple receipt information, last-seen time, and limited technical metadata associated with normal HTTPS requests, such as IP address or locale information where technically received.

PookieScroll does not use an advertising identifier (IDFA) and does not use this information, or any other information, to track you across apps or websites. We do not use advertising, attribution, or analytics SDKs in the iOS app.

RevenueCat does not process your payment card details for PookieScroll. Payments are processed by Apple.

6. Support Communications

If you contact us for support, we may process the information you choose to provide, such as:

• your email address;
• your name, if you provide it;
• the content of your message;
• screenshots or diagnostic details you choose to send;
• information needed to respond to your request.

Please do not send us sensitive personal information unless it is necessary for your request.

7. Local Sharing Through iOS Share Sheet

PookieScroll may allow you to create a local image or mood card and share it using your device’s native iOS share sheet.

You choose whether to share the image and which app or recipient to share it with. Lionscraft does not receive the shared image unless you separately send it to us.

Third-party apps or platforms you share content with are governed by their own terms and privacy policies.

8. How We Use Information

We use the limited information described in this Privacy Policy to:

• provide and operate PookieScroll;
• enable subscriptions and paid features;
• verify subscription entitlement status;
• respond to support requests;
• maintain app security and prevent fraud or abuse;
• operate and improve the PookieScroll website at an aggregate level;
• comply with legal, tax, accounting, App Store, and regulatory obligations;
• protect our rights, users, and business.

We do not use your information for targeted advertising or cross-app tracking.

9. Legal Bases for EU/EEA/UK Users

Where the GDPR or similar laws apply, we rely on the following legal bases:

• Contract: to provide the app, subscriptions, and paid features you request.
• Legitimate interests: to maintain app functionality, respond to support requests, secure the service, prevent fraud, operate the website, understand aggregate website usage, and manage our business, where those interests are not overridden by your rights.
• Legal obligation: to comply with applicable legal, tax, accounting, regulatory, and App Store obligations.
• Consent: where required by law, for example if we ever introduce optional features that require consent.

10. How We Share Information

We may share limited information with:

Apple: for App Store distribution, in-app purchases, subscriptions, billing, refunds, and Apple platform functionality.

RevenueCat: for subscription entitlement management and purchase status syncing.

Google: for cookieless website analytics on pookiescroll.app, as described in Section 17.

GitHub Pages: for hosting and serving the pookiescroll.app website.

Service providers: if we use providers for business operations such as email support, hosting of our public website or legal pages, or security, but only as needed for those purposes.

Legal or safety recipients: if required to comply with law, legal process, enforce our rights, prevent fraud, protect users, or respond to lawful requests.

Business transfers: if Lionscraft is involved in a merger, acquisition, financing, reorganisation, or sale of assets, information may be transferred as part of that transaction, subject to appropriate safeguards.

We do not sell personal data. We do not share personal data for cross-context behavioural advertising.

11. International Transfers

Lionscraft is based in Singapore. RevenueCat, Google, GitHub Pages, and other service providers, including their subprocessors, may process limited information in the United States or other countries.

Where personal data is transferred outside Singapore, we take steps designed to ensure that overseas recipients are bound by legally enforceable obligations to provide a standard of protection comparable to the protection required under Singapore’s Personal Data Protection Act 2012.

Where required by applicable law, we rely on appropriate safeguards for international transfers, such as contractual commitments, data processing terms, standard contractual clauses, or other legally recognised mechanisms.

12. Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Because PookieScroll does not operate user accounts or a backend user profile system, most app settings and screen time-related data are stored locally on your device and can generally be removed by deleting the app, subject to iOS behaviour.

Subscription-related records may be retained by Apple, RevenueCat, or us for as long as needed to provide entitlement status, handle billing or refund issues, comply with legal obligations, resolve disputes, prevent fraud, and maintain business records.

RevenueCat may retain subscription-related records according to its own retention schedule, including where needed for legal, tax, accounting, fraud-prevention, security, or service-operation purposes.

Website analytics information is used in aggregate form to understand website usage. GitHub Pages and Google may retain limited website request or measurement information according to their own service terms and retention practices.

Support emails may be retained for as long as reasonably necessary to respond to your request and maintain support records, unless a longer period is required or permitted by law.

13. Deletion

You may delete local app data by deleting PookieScroll from your device, subject to iOS behaviour.

Deleting the app does not cancel your Apple subscription. You must cancel subscriptions through your Apple ID account settings.

To request deletion of personal data that we control, contact us at contact@pookiescroll.app. Because we do not maintain user accounts, we may need limited information from you to identify relevant records, such as your support email address or information needed to locate subscription-related records.

Because PookieScroll does not use accounts, we may not be able to identify subscription-related records from your name or email address alone. We may ask you to provide information available in the app or from your Apple subscription record so that we can locate the relevant RevenueCat entitlement record.

For Apple purchase records, you may need to contact Apple directly. For RevenueCat entitlement data, we may coordinate with RevenueCat where we are able to identify the relevant anonymous user record.

You can prevent the website analytics signal by using a browser or browser extension that blocks Google Analytics.

14. Your Rights

Depending on where you live, you may have rights to:

• access personal data we hold about you;
• request correction of inaccurate personal data;
• request deletion of personal data;
• request restriction of processing;
• object to certain processing;
• request portability of certain personal data;
• withdraw consent where processing is based on consent;
• lodge a complaint with a data protection authority.

Singapore users may have rights under the Personal Data Protection Act 2012, including rights of access and correction, subject to applicable exceptions.

EU/EEA/UK users may have rights under GDPR or similar laws.

California users may have rights to know, access, correct, delete, and opt out of certain data practices. We do not sell personal information and do not share personal information for cross-context behavioural advertising.

Japan users may have rights under the Act on the Protection of Personal Information, subject to applicable conditions and exceptions.

To exercise your rights, contact us at contact@pookiescroll.app.

15. Children’s Privacy

PookieScroll is not directed to children under 13 years old, or under 16 years old where that higher threshold applies under local law.

We do not knowingly collect personal data from children below the applicable minimum age. If you believe a child has provided personal data to us, contact us at contact@pookiescroll.app and we will take appropriate steps.

PookieScroll is designed for self-management of screen time. It is not marketed as a child-monitoring or parental-control service in this version.

16. Security

We use reasonable technical and organisational measures to protect personal data we process. However, no app, device, platform, or transmission method is completely secure.

Because PookieScroll is designed to keep screen time data on-device, you should also protect your device using appropriate security settings, such as passcodes, biometric authentication, device updates, and Apple account protections.

17. Cookies and Tracking

The PookieScroll iOS app does not use cookies, tracking technologies, advertising SDKs, or analytics SDKs.

Our website at pookiescroll.app uses Google Analytics 4 in a cookieless configuration to measure aggregate visitor numbers. Google Consent Mode is configured so that analytics storage is denied. In this configuration, Google Analytics does not set analytics cookies, create a persistent identifier, or read information from your device for analytics storage.

Google may receive limited measurement information for each page view, such as the page URL, referrer, and general browser or device information. Google may also process IP address information as part of providing the analytics service. The website is hosted on GitHub Pages, which may process IP address and request information as needed to serve the website.

The iOS app contains no analytics code. The website analytics described above applies only to pookiescroll.app.

This website analytics configuration does not use advertising cookies or enable cross-site tracking. You can prevent the analytics signal entirely by using a tracker-blocking browser or browser extension that blocks Google Analytics.

If our website analytics configuration changes, for example if cookies, persistent identifiers, advertising technologies, contact forms, or marketing tools are introduced, we will update this Privacy Policy or provide a separate notice where required.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will take reasonable steps to notify you, such as updating the date above, posting the new policy, or providing in-app notice where appropriate.

19. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our handling of personal data, contact us at: