Privacy Policy

Last updated: [TODO: date you publish]

1. Who we are

Chetely is a habit tracking app for friends ("Chetely", "we", "us", "our"). Chetely is operated by Alikhan Daulet, an individual based in the United Kingdom [TODO: confirm the operator's name and that they are UK based. This must match the seller name shown on the App Store.]

For the purposes of UK data protection law, including the UK GDPR and the Data Protection Act 2018, Alikhan Daulet is the controller of the personal data described in this policy. [TODO: add ICO registration number once the data protection fee is paid.]

You can contact us at support@chetely.com.

This policy covers the Chetely app on iOS and Android and the website chetely.com.

2. What we collect

Information you give us

• Account details: your name, email address, profile photo (avatar) and the way you sign in (email, Apple or Google). If you use Sign in with Apple and choose to hide your email, we receive a private relay address from Apple instead.
• Habits and activity: the habits you create (names, emoji, schedules, targets and units), your check-ins and when you made them, counter values and timer sessions.
• Things you share with a group: photos you attach to check-ins, reactions, nudges, habit suggestions you send to a group owner, and, if you own a group, the group name, shared habits and the penalty text you set.
• Reports: if you report content or block someone, we keep a record of the report or block and the content involved.
• Support messages: anything you send us by email.

Information created as you use Chetely

• Group information: which groups you belong to, your role (owner or member), group streaks, badges and weekly summaries.
• Settings: your time zone, reminder time and notification preferences.
• Subscription status: whether you have Chetely Plus, your plan, trial status, renewal and expiry dates and store transaction identifiers. We receive these from Apple or Google through our subscription provider. We never receive your card or bank details.
• Device and technical data: a push notification token, device model, operating system and app version, an app user ID and technical logs. Our providers may also process your IP address when your device connects to them. [TODO: confirm with Newly whether crash or error reporting is collected, and by which tool.]
• Usage analytics: events such as opening the app, creating or joining a group, checking in, viewing the subscription screen and starting a trial.
• Install source: if you install Chetely from a link shared by a creator or partner, we record which campaign or link brought you (for example a UTM tag), so we can measure and reward those partnerships.

[TODO: name the analytics tool. Confirm whether it uses the device advertising identifier (IDFA). If it does, the app needs Apple's App Tracking Transparency prompt and this section needs updating.]

What we do not collect

We do not collect your precise location, your contacts, or health data from Apple Health or Google Health Connect. [TODO: confirm none of these are collected.] Chetely only uses your camera or photo library when you choose to add a photo.

3. How we use it, and our lawful bases

UK data protection law requires us to have a lawful basis for each way we use your personal data. Here is what we do and why.

Where we rely on legitimate interests, we have considered your interests and rights and believe they are not overridden. You can object at any time (see Your rights).

We do not use your data to make decisions about you that have legal or similarly significant effects based solely on automated processing.

4. Who can see your information

• Members of your groups can see your name and avatar, your check-ins on that group's shared habits, photos you post in that group, your reactions and nudges, and your contribution to the group streak and badges.
• The group owner can also see habit suggestions you send them and can remove members from the group.
• Your personal habits are private to you, unless you choose to share a milestone with a group.
• Anyone with your group's invite code or link can see the group's name and member count before choosing to join. Only share invites with people you want in the group. The owner can create a new code at any time.

Chetely has no public profiles. Remember that people in your groups can take screenshots, so only share what you are comfortable with them seeing.

5. Service providers

We use trusted providers to run Chetely. They process personal data on our behalf, under contract, and only for the purposes we set.

When you pay for Chetely Plus, Apple or Google process the payment as independent controllers under their own privacy policies.

We do not sell your personal data and we do not share it with data brokers. We may disclose information if the law requires it, to protect the safety of any person, to protect our rights, or as part of a sale or transfer of Chetely, in which case we will tell you first.

6. International transfers

Some of our providers are based in, or store data in, countries outside the UK, including the United States. When your data is transferred outside the UK, we make sure it stays protected, by relying on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework where the provider is certified) or the International Data Transfer Agreement or Addendum issued by the ICO. Contact us if you would like more detail.

7. How long we keep it

• Account, habits and check-ins: for as long as your account is active.
• After you delete your account: we delete or anonymise your personal data within 30 days. Copies in backups are removed within a further 90 days. [TODO: confirm both periods with Newly.]
• When you leave a group: [TODO: decide what happens to your past check-ins and photos in that group, for example deleted, or kept and shown as "former member".]
• Photos in a group feed: until you delete the post, the group is deleted or your account is deleted. [TODO: confirm, or set an automatic deletion period.]
• Reports and blocks: up to 12 months after a report is resolved, or longer if we need them to deal with a legal claim or repeated abuse.
• Analytics: up to [TODO: 14 or 26] months, after which it is deleted or aggregated so it no longer identifies you.
• Subscription records: for as long as needed to manage your subscription, and up to 6 years after a transaction where we need them for tax, accounting or legal claims.
• Support emails: up to 2 years after the conversation ends.

8. Deleting your account

You can delete your account in the app: go to You, tap Settings, then Delete account. If you own any groups, you will be asked to delete them first. You can also email us and we will do it for you.

Deleting the app from your phone does not delete your account. Deleting your account does not cancel a Chetely Plus subscription: cancel it in your App Store or Google Play settings, as explained in our Terms.

9. Your rights

Under UK data protection law you have the right to:

• get a copy of your personal data (access);
• have inaccurate data corrected (rectification);
• have your data deleted (erasure);
• ask us to limit how we use your data (restriction);
• object to us using your data based on legitimate interests;
• receive your data in a portable format and have it sent to another service (portability);
• withdraw any consent you have given, at any time.

To use any of these rights, email support@chetely.com from the address linked to your account. We will reply within one month. We may need to confirm your identity first.

If you are unhappy with how we handle your data, please contact us first so we can try to fix it. You also have the right to complain to the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, phone 0303 123 1113.

10. Notifications and permissions

• Notifications: Chetely asks before sending push notifications. You can choose which kinds you get in the app's settings, or turn them all off in your phone's settings.
• Camera and photos: Chetely only asks for access when you choose to add a photo. You can change this at any time in your phone's settings.

11. Children

Chetely is for people aged 13 and over. We do not knowingly collect personal data from children under 13. If you believe a child under 13 is using Chetely, please contact us and we will delete their account.

If you are between 13 and 17, please talk to a parent or guardian before buying a subscription. Groups on Chetely are private and invite only, and there are no public profiles.

[TODO: because 13 to 17 year olds can use Chetely, check the app against the ICO's Age Appropriate Design Code (Children's Code), for example privacy by default and no nudging towards sharing more data.]

12. Security

We protect your data with encryption in transit (HTTPS), access controls at our providers and secure storage of sign-in tokens on your device. No system is perfectly secure, but we work to protect your information and will tell you and the ICO about a data breach where the law requires it.

13. Changes to this policy

We may update this policy as Chetely changes. We will change the date at the top, and if the changes are significant we will let you know in the app or by email before they take effect.

14. Contact us

Questions or requests about your privacy: support@chetely.com.

Alikhan Daulet, operating Chetely, United Kingdom. [TODO: postal address is optional, but helpful if you have one you are happy to publish.]