DIO Privacy Policy: Privacy Policy

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect very little, and your content stays on your device.

The personal information we collect depends on how you interact with the Services. It is limited to:

• A Sign in with Apple identifier and an optional display name. These are stored only on your device and your own iCloud, and are never transmitted to or stored on our servers. If you use guest mode, no account information is stored at all.

Your content. Your brain dumps, to-dos, check-ins, preferences, and manually entered calendar items are stored on your device using app storage, and sync only to your own iCloud if enabled. We do not operate servers, we do not receive this content, and we cannot access it.

Sensitive Information. We do not process sensitive information.

Payment Data. If you purchase a subscription (DIO Pro), all payment data is handled and stored by Apple. We never receive or store your card or payment details. You may review Apple's privacy notice at https://www.apple.com/legal/privacy/.

Application data

If you use our application, we may process the following:

• Mobile Device Access. We may request permission to certain device features, including your calendar (read-only) and notifications. You can change these permissions at any time in your device settings.
• Mobile Device Data. Through our anonymous analytics provider, we collect limited, non-identifying device information such as device model, operating system version, and app version, along with an anonymous device identifier. This information does not identify you and is not used for cross-app tracking.
• Push Notifications. With your permission, we may send you notifications related to reminders and features of the app. You can turn these off at any time in your device settings.

Information collected automatically

In Short: We collect a limited amount of anonymous usage data to keep the app working and to improve it.

When you use the Services, our analytics provider (TelemetryDeck) automatically collects anonymous information that does not reveal your identity or include your content. This includes:

• Usage Data. Anonymous, aggregate information about which features are used and how the app is performing (for example, that a feature was opened, or that an error occurred). This never includes the text of your brain dumps, to-dos, check-ins, or any content you create.
• Device Data. Non-identifying information such as device model, operating system version, and app version, and an anonymous device identifier.

This information is used only to maintain the security and operation of the Services and for our internal analytics and reporting.

2. How Do We Process Your Information?

In Short: We process a limited amount of information to provide, secure, and improve the Services.

We process information for the following purposes:

• To facilitate account creation and authentication. If you sign in with Apple, we use your Apple-provided identifier so the app recognizes you and your data can sync across your own devices.
• To deliver our Services. We process information as needed to provide the app and its features to you.
• To respond to inquiries and offer support. If you contact us, we use your message to respond and resolve your issue.
• To fulfill and manage your orders. We process subscription status (through Apple) to provide and manage DIO Pro access.
• To protect our Services. We use anonymous diagnostic information to keep the app safe, stable, and working.
• To identify usage trends. We use anonymous usage data to understand how the app is used so we can improve it.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We process your personal information only when we have a valid legal reason to do so.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. We may rely on the following:

• Consent. You can withdraw your consent at any time.
• Performance of a Contract. To provide the Services you request, including subscriptions.
• Legitimate Interests. To analyze how our Services are used so we can improve them, and to diagnose problems and prevent fraudulent activity, in ways that do not override your rights.
• Legal Obligations. Where necessary to comply with our legal obligations.
• Vital Interests. Where necessary to protect the vital interests of any person.

If you are located in Canada

We may process your information where you have given consent (express or implied), which you can withdraw at any time. In limited exceptional cases permitted by law, we may process information without consent (for example, for fraud detection and prevention, or where required to comply with a subpoena, warrant, or court order).

4. When and With Whom Do We Share Your Personal Information?

In Short: We share limited data only with the service providers that make the app work.

We may share your information with third-party service providers who perform services for us and require access to do that work. We have contracts in place with these providers designed to safeguard your information; they may only use it as we instruct and may not share it with anyone else. The service providers we work with are:

• Payments & Billing: Apple (App Store in-app purchases)
• Sign-in & Authentication: Sign in with Apple
• Anonymous Analytics: TelemetryDeck
• App Testing & Distribution: TestFlight (Apple)

We may also share information in connection with a business transfer, such as a merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. Is Your Information Transferred Internationally?

In Short: Limited data may be processed by our service providers in countries other than your own.

We do not operate our own servers. Your content stays on your device and your own iCloud. The limited anonymous and payment-related data used to run the Services is processed by our service providers (Apple and TelemetryDeck), whose infrastructure is located in the United States and Germany. Regardless of your location, your information may therefore be processed in the United States, Germany, and other countries where these providers operate.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. We take appropriate measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses. Where applicable, we and our service providers rely on the European Commission's Standard Contractual Clauses for transfers of personal information originating from the EEA or UK. These clauses require recipients to protect that information in accordance with European data protection law. Further details can be provided upon request.

6. How Long Do We Keep Your Information?

In Short: Your content stays on your device until you delete it. We keep no server-side copy.

Because your content lives on your device and your own iCloud, it remains available to you for as long as you keep the app and your account, and is removed when you delete it. We do not retain a server-side copy of your content or account. Anonymous analytics data that does not identify you is retained by our analytics provider in accordance with their retention practices.

7. How Do We Keep Your Information Safe?

In Short: Your content stays on your device, and we run no servers, so there is no central store to breach.

We have implemented appropriate technical and organizational measures designed to protect your information. Because your content stays on your device and your own iCloud (protected by Apple's account-level encryption, to which we have no key), and because we operate no servers, there is no central database of your content for an attacker to target. We never ask for or store a password. However, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security. You should keep your device secure with a passcode and Face ID or Touch ID.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age (or the equivalent age specified by law in your jurisdiction), nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of a minor and consent to their use of the Services. If we learn that personal information from a user under 18 has been collected, we will take reasonable measures to promptly delete it. If you believe we may have collected such information, please contact us at dio@elitechq.com.

9. What Are Your Privacy Rights?

In Short: Depending on where you live, you may have rights to access and control your personal information. Because your data lives on your device, you can exercise most of these directly in the app.

In some regions (like the EEA, UK, Switzerland, and Canada), you have rights under applicable data protection laws. These may include the right to request access to and a copy of your personal information, to request correction or erasure, to restrict processing, to data portability, and not to be subject to automated decision-making. You may make such a request by contacting us using the details in the section "How can you contact us about this notice?" below.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent, you may withdraw it at any time by contacting us. This will not affect the lawfulness of processing before its withdrawal.

Managing your information

Because DIO stores your data on your own device and iCloud (not on our servers), you are in control of it:

• You can review and edit your data directly in the app at any time.
• To delete everything, go to Settings and use Delete Account to permanently remove your account and all associated data from your device and iCloud.
• You can revoke Sign in with Apple access anytime in your iOS Settings under your Apple ID.

We have no server-side copy of your account or content to delete on your behalf. If you have questions about your privacy rights, email us at dio@elitechq.com.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature you can activate. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. If a standard is adopted that we must follow, we will inform you in a revised version of this Privacy Notice.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific rights regarding your personal information.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

Note on identifiers: We disclose an anonymous device identifier to our analytics provider (TelemetryDeck) for anonymous analytics. This identifier is not linked to your identity and is not used for cross-app tracking. We do not collect identifiers on our own servers.

Your rights

You have rights under certain US state data protection laws. These are not absolute and in some cases we may decline a request as permitted by law. These rights include:

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling with legal or similarly significant effects

We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We do not use your personal information for targeted advertising.

How to exercise your rights

To exercise these rights, contact us by visiting https://elitechq.com/dio/support or by emailing dio@elitechq.com. We may need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf, subject to proof of authorization.

Appeals

If we decline to take action on your request, you may appeal by emailing dio@elitechq.com. We will inform you in writing of any action taken or not taken and the reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about categories of personal information we disclosed to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please contact us using the details below.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top. If we make material changes, we may notify you by posting a notice or sending a direct notification. We encourage you to review this Privacy Notice frequently.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at dio@elitechq.com or contact us by post at:

14. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or US state of residence, you may have the right to request access to the personal information we hold, correct inaccuracies, or delete it. Because your data lives on your own device, the fastest way to review, update, or delete it is directly in the app (Settings → Delete Account). You may also visit https://elitechq.com/dio/support or email dio@elitechq.com.