THE SMALL PRINT, IN PLAIN SIGHT
Privacy policy · Tubli
Version 1.0 ·
Privacy, in a few words
- The content you create stays on your device. Syncing to your private iCloud is optional; the studio cannot access that private content.
- In friend challenges, participants see your nickname, avatar emoji, and progress through CloudKit sharing.
- We use Firebase Analytics and Crashlytics for usage analytics and crash reports. In the EEA, the UK and Switzerland, analytics stay off unless you agree; you can turn either one off at any time in Settings.
- Text you write is not included in analytics events sent by Tubli. Events use installation identifiers that the studio does not associate with your name, email, or Apple Account.
- Weekly reviews are processed on your device. We do not send your content to external AI services.
- There are no ads, data sales, or tracking across apps and websites.
1. Who we are
Tubli is developed and operated by Slumpy Shrimp Studios, registered under CNPJ 32.687.778/0001-07 (“we” or “the studio”).
For privacy questions and rights requests, email support@slumpyshrimp.com. For other studio enquiries, use contact@slumpyshrimp.com.
2. On-device content and optional iCloud sync
Habits, tasks, categories, sessions, history, medals, your display name, and avatar emoji are stored locally. Tubli does not operate its own server to store that content.
If you enable sync, content is synchronized through CloudKit in your own iCloud account's private database. Sync is optional and can be turned off in the app's Settings. The studio cannot view the private content in its developer console.
Challenge sharing, described in section 5, is a separate feature. Usage analytics, diagnostics, and support messages are also separate from your private content.
iCloud is provided by Apple and is subject to Apple's terms and privacy policy.
3. Screen Time and iOS permissions
Tubli uses FamilyControls, DeviceActivity, ManagedSettings, and ManagedSettingsUI with your authorization through iOS. You can manage and revoke that authorization in the system's Screen Time settings.
When selecting apps for limits and blocking, FamilyControls APIs provide opaque identifiers. These tokens do not disclose the selected apps' names or identifiers to the studio.
Detailed usage reports are rendered by Tubli's reporting extension in an environment isolated by iOS. That environment restricts network requests and the movement of sensitive content outside it. The studio does not receive this report.
Tubli locally records configured schedules, whether a limit was reached, and temporary unlocks. These records support habit tracking and weekly reviews. Protected Screen Time data is not sent to advertising services, Analytics, or Crashlytics.
Measurement is per device and starts when you activate tracking. Tubli does not retrieve earlier history or monitor someone else's device.
4. Usage analytics and crash reports
Google's Firebase Analytics helps us understand how Tubli is used: screens opened, features used, focus session duration, app version, and language. The duration of a focus session created in Tubli is an event from Tubli itself; it is not the protected report of other apps' usage.
Events are associated with installation or app-instance identifiers. The studio does not associate them with your name, email, or Apple Account. Because they can distinguish installations, we describe this information as pseudonymous technical data rather than guaranteeing absolute anonymity.
Before sending analytics events, Tubli removes user-provided text, replacing habit names and custom category names with markers. Text written in habits, tasks, and categories is not included in those events.
Firebase Crashlytics receives technical information to diagnose failures, such as device model, system and app versions, crash traces, and installation identifiers. The studio can review diagnostics in Firebase without accessing your private iCloud content.
If your device region is in the European Economic Area, the United Kingdom or Switzerland, usage analytics stay off unless you agree when the app first asks; elsewhere they are on by default. Crash reports are on by default everywhere, because they are how we find and fix problems that make the app stop working. You can turn either one off at any time in Settings — "Share Analytics" and "Send Crash Reports"; from that moment nothing more is collected. Data already sent is not linked to your identity and is deleted automatically at the end of the retention period described in section 9.
5. Challenges and competitions with friends
When you create or join a competition, your display name (nickname), avatar emoji, and progress are visible to the other participants in that competition. Tubli does not share your email with them.
Data is exchanged through CloudKit sharing between participants' iCloud accounts, without a content server operated by the studio. The internal identifier is the app's iCloud user record; it is not presented as your email or an identifier for other services.
Participation data is held in the competition creator's shared zone. Leaving a competition removes your participation. This does not make the habits, tasks, or other records in your private storage public.
6. Notifications and purchases
Tubli notifications are local and scheduled on your device. The studio does not operate a push notification server. You can control notification permissions in iOS Settings.
Purchases are processed by the App Store. The studio does not receive card details or other payment credentials. Tubli checks with the system to confirm your entitlement to paid features. Apple handles purchase information under its own policies.
7. Weekly reviews and on-device intelligence
Weekly reviews use Tubli's own rules to propose habit adjustments. When Apple Intelligence is available on a compatible device, its on-device model writes the review text through the Foundation Models framework. The feature also works without Apple Intelligence.
We do not send your content to external AI APIs or use it to train AI models. Adjustment decisions are made by the app's rules; the model helps express them in natural language.
8. Services and international processing
Firebase Analytics, Crashlytics and the Google Workspace email service used for support are provided by Google LLC and may process data in the United States and other countries where Google operates. These transfers are covered by Google's data processing terms, which include the European Commission's Standard Contractual Clauses, and by Google's certification under the EU–U.S. Data Privacy Framework. For transfers from Brazil, they rely on the safeguards permitted by Article 33 of the LGPD. iCloud data is processed by Apple under Apple's own terms.
We do not display ads, sell or rent data to brokers, or track you across apps or websites. Tubli does not request ATT permission for advertising tracking.
- Apple iCloud / CloudKit: optional storage in your private account and sharing challenges with their participants.
- Apple Screen Time APIs: on-device authorization, measurement, reports, and blocking.
- Google Firebase Analytics: Tubli usage events and technical identifiers.
- Google Firebase Crashlytics: crash diagnostics and technical identifiers.
- Apple App Store: processing purchases and confirming access to paid features.
9. Retention, deletion, and support
- Your content (habits, tasks, sessions, profile) stays on your device and, if you turn on sync, in your private iCloud. We have no copy. It is kept until you delete it — item by item, or all at once in Settings → Clear All Data, which also removes it from iCloud.
- Usage analytics are kept for up to 14 months after the last time you use the app, and then deleted automatically; aggregate reports that identify no one may be kept longer.
- Crash reports are kept for 90 days.
- Support emails are handled through Google Workspace (Google LLC) and kept for up to 12 months after your request is resolved, unless the law requires longer.
10. Your rights and grounds for processing
Depending on applicable law, you may request confirmation of processing, access, correction, deletion, portability, and information about sharing, and exercise rights to object, restrict processing, or withdraw consent. The scope of these rights depends on your jurisdiction and applicable legal conditions.
You manage local and iCloud content through the app and system settings. For requests about diagnostics or information received by the studio, email support@slumpyshrimp.com. We do not require you to send all your private content to make a request.
We respond within the time limits required by applicable law. Under Brazil's LGPD, confirmation and access may be provided immediately in simplified form or through a complete statement within 15 days under Article 19. Other requests follow their own applicable deadlines and conditions.
The features you use are provided to perform our agreement with you. Crash reports rely on our legitimate interest in keeping the app working. Usage analytics rely on your consent in the European Economic Area, the United Kingdom and Switzerland, and on our legitimate interest in improving the app elsewhere — in both cases you can turn them off in Settings.
Because your content never reaches us, requests about it are fulfilled on your device: you can view, edit or delete it in the app at any time. Analytics and crash data are pseudonymous and we cannot link them to you; turning them off in Settings stops collection immediately, and what was already sent expires as described in section 9. We may ask you to confirm your identity before acting on a request about a support conversation. You may also lodge a complaint with your data protection authority — in Brazil, the ANPD.
11. Children and personal use
Tubli is not directed at children under 13 and does not knowingly collect their data. This intended audience does not remove additional protections for children and teenagers under local law. If you believe a child has provided data to us, contact support.
Tubli tracks usage on the user's own device. It is not a parental control tool and cannot monitor another person's device.
12. Security
Local content benefits from iOS protections, and synchronization uses iCloud infrastructure and access controls. Technical data sent to Firebase is handled under that service's security documentation. The studio does not operate its own database of your habits and tasks.
No system offers absolute security. Protections depend on the type of data, the service used, and your device and account settings.
13. Changes and contact
We may update this policy to reflect changes in the app or data handling. We will update the date and communicate material changes in the app or release notes. Where new consent is required, we will request it; continuing to use the app is not a substitute for that consent.
Privacy and support: support@slumpyshrimp.com. Studio contact: contact@slumpyshrimp.com.
Slumpy Shrimp Studios · CNPJ 32.687.778/0001-07.