Privacy Policy

1. Introduction

Baby Novum ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we handle information when you use the Baby Novum mobile application ("App").

2. Information We Collect

2.1 Data You Create in the App (Stored Locally)

All data you enter into Baby Novum is stored locally on your device using an encrypted SQLite database. This includes:

• Pregnancy information (due date, gestational age, baby name)
• Health metrics (weight, blood pressure, kick counts, contraction logs, ultrasound records, lab results, swelling data)
• Nutrition data (supplement logs, hydration records)
• Wellbeing data (mood check-ins, diary entries, EPDS screening results, breathing session logs)
• Photos and media (belly photos, ultrasound images)
• Personal letters to your baby
• Birth preparation data (hospital bag checklists, birth plan, budget, shopping lists)

This data never leaves your device unless you explicitly choose to export it (e.g., via the PDF export feature, which saves the file locally to your device).

2.2 Subscription and Payment Data

If you purchase a Premium subscription, payment is processed entirely by Apple (App Store). We use RevenueCat to manage subscription status (active/inactive). RevenueCat receives an anonymized app user ID and subscription status — it does not receive your name, email, health data, or any other personal information.

2.3 Crash Reports

The App may collect anonymized crash reports to help us identify and fix technical issues. These reports do not contain any of your personal health data, diary entries, or photos. You can opt out of crash reporting in your device settings.

2.4 Advertising Measurement and Analytics (Meta, TikTok, PostHog and Google Analytics for Firebase)

We run advertising campaigns for Baby Novum on Facebook, Instagram and TikTok. To find out which of those ads actually bring people to the App — and stop paying for the ones that do not — the App includes two advertising SDKs: the Meta (Facebook) SDK, which feeds Meta's advertising measurement and attribution system (Meta Audience Network), and the TikTok Business SDK, which does the same for TikTok's advertising (TikTok Events Manager).

So that we can see the same funnel ourselves rather than only in the advertising platforms' reports, the App also sends the same events to PostHog, a product-analytics service that works for us as our processor. It is hosted in PostHog's EU Cloud in Frankfurt, Germany.

For the same reason the App also includes Google Analytics for Firebase, Google's app-analytics service, which gives us a second, independent count of the same funnel. Google processes those events for us as our processor.

On iOS all four are switched off until you agree to it. At first launch the App shows Apple's App Tracking Transparency prompt once, and that one answer covers all four SDKs; if you decline, or never answer, nothing described in this section is ever sent — to Meta, to TikTok, to PostHog or to Google. See Section 7.

If you allow tracking, Meta and TikTok each receive:

That is the complete list. There is no other event and no additional field.

PostHog receives the same, minus the advertising identifiers:

Google Analytics for Firebase receives the same, minus the advertising identifiers, plus Firebase's own usage measurements:

What is never sent — to Meta, to TikTok, to PostHog, to Google or to anyone else:

3. How We Use Information

We do not collect the personal data described in Section 2.1, so we cannot and do not use it for anything.

The anonymized crash data in Section 2.3 is used solely to improve the stability and performance of the App.

The advertising events in Section 2.4 are used for one purpose: working out which advertising campaigns bring people who go on to find Baby Novum useful, so we can spend the advertising budget on those instead of the rest. The copies sent to PostHog and to Google Analytics for Firebase serve the same purpose: they show us how many people finish onboarding, see the subscription screen, start a trial and subscribe, in our own analytics. None of these events is used to build a profile of you inside the App, and the App never reads anything back from Meta, TikTok, PostHog or Google. Your experience of Baby Novum is identical whether you allow tracking or not — no feature is locked, delayed or degraded either way.

4. Data Security

We take the security of your data seriously:

• AES-256 encryption — all diary entries, letters to baby, and sensitive health data are encrypted at rest on your device.
• Biometric protection — you can enable Face ID or fingerprint authentication to protect access to the App.
• No cloud sync — your pregnancy data is never uploaded to external servers.
• The ads and analytics SDKs are isolated — the Meta, TikTok, PostHog and Firebase SDKs described in Section 2.4 run alongside the App, not inside its database. Each receives the events we explicitly pass to it plus the automatic events listed for it there, and has no route to anything else.

Our iOS Privacy Manifest declares tracking (NSPrivacyTracking = true), because sharing the advertising identifier with Meta and TikTok is tracking under Apple's definition and we are not going to describe it as anything else. What that declaration covers is the advertising identifier and the app events in Section 2.4 — no health or pregnancy data is declared, because none is collected.

While we implement strong local security measures, the security of your device itself (lock screen, operating system updates) also plays a role in protecting your data.

5. Device Permissions

The App requests certain device permissions to provide its features. We only request permissions that are necessary for specific functionality:

• Camera — to capture belly photos and ultrasound images
• Photo Library — to save and load pregnancy photos from your gallery
• Microphone — to record voice diary entries
• Face ID / Biometrics — to protect your private diary and letters
• Notifications — to send reminders for supplements, appointments, and kick counting sessions (local notifications only, no remote servers involved)
• Calendar — to add pregnancy appointments to your device calendar (optional)
• App Tracking Transparency — to ask permission before using your advertising identifier for the measurement described in Section 2.4. One answer covers Meta, TikTok, PostHog and Google Analytics for Firebase. Declining costs you nothing inside the App.

You can manage these permissions at any time in your device's Settings app. Revoking a permission will disable the corresponding App feature but will not affect your existing data.

6. Third-Party Services

Baby Novum uses a minimal set of third-party services:

• Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) — advertising measurement and attribution via the Meta / Facebook SDK and Meta Audience Network. Receives only the identifiers and events listed in Section 2.4, and only if you allow tracking. Meta Privacy Policy
• TikTok — advertising measurement and attribution via the TikTok Business SDK. For people in the EEA, the UK and Switzerland this is TikTok Technology Limited (The Sorting Office, Ropemaker Place, Dublin 2, D02 HD23, Ireland) together with TikTok Information Technologies UK Limited (Kaleidoscope, 4 Lindsey Street, London EC1A 9HP, United Kingdom); in the United States, TikTok USDS Joint Venture LLC; elsewhere, the TikTok entity named in TikTok's Privacy Policy for your region. Receives only the identifiers and events listed in Section 2.4, and only if you allow tracking. TikTok Privacy Policy
• PostHog, Inc. (2261 Market St., #4008, San Francisco, CA 94114, United States) — product analytics, hosted in PostHog's EU Cloud in Frankfurt, Germany. Acts as our processor. Receives only the events and details listed for it in Section 2.4, and only if you allow tracking. PostHog Privacy Policy
• Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States) — app analytics via Google Analytics for Firebase. Acts as our processor. Receives only the events and details listed for it in Section 2.4, and only if you allow tracking. Google Privacy Policy · Privacy and Security in Firebase
• RevenueCat — subscription management. Receives anonymized subscription status only. RevenueCat Privacy Policy
• Apple App Store — payment processing. Governed by Apple's privacy policy.
• Google Fonts — fonts are loaded from Google's CDN on our website only (not in the App).

Meta is a separate controller, not our processor

For the advertising data in Section 2.4, Meta Platforms Ireland Limited acts as an independent data controller in its own right — not as a processor acting on our instructions. Once an event reaches Meta, Meta decides on its own how it is processed, for how long it is retained and how it is combined with other data it holds, under its own Privacy Policy. We cannot delete it on your behalf. Your rights over that data are exercised against Meta directly — Section 7 explains how.

TikTok is a joint controller with us for collecting the data

TikTok's terms divide the roles differently. For collecting the data in Section 2.4 in the App and transmitting it to TikTok, and for the campaign measurement reports TikTok produces from it, we and TikTok are joint controllers under Article 26 GDPR. We have entered into TikTok's Joint Controller Terms, which set out who is responsible for what: we are responsible for telling you about this processing, which this section does, and TikTok is responsible for enabling your rights under Articles 15–20 GDPR — access, rectification, erasure, restriction and portability — for the data TikTok stores or otherwise processes once it has received it.

Everything TikTok does with the data after that — using it to build audiences and target ads, to improve and personalise its advertising, and for safety, security and fraud prevention — it does as an independent controller, on a legal basis it establishes itself. How TikTok processes personal data, the legal bases it relies on and how to exercise your rights against it are set out in the TikTok Privacy Policy. We cannot delete data TikTok holds on your behalf; Section 7 explains how to reach TikTok directly.

PostHog is our processor

Unlike Meta and TikTok, PostHog decides nothing about this data. It processes the events only on our documented instructions, under a data processing agreement, and may not use them for its own purposes or for advertising. We are the controller of that data.

PostHog knows your installation only by the random ID its SDK creates. It holds no name, email address or account, so we generally cannot tell which events are yours (Article 11 GDPR). Deleting the App deletes that ID, after which nothing in PostHog can be linked to your device.

Google is our processor for Google Analytics for Firebase

Like PostHog, and unlike Meta and TikTok, Google decides nothing about the Firebase events. It processes them only on our instructions, under the Google Ads Data Processing Terms that cover Google Analytics, and because our property's data-sharing settings are switched off it may not use them for its own products, for advertising or to build profiles. We are the controller of that data.

Google knows your installation only by the random app-instance ID the Firebase SDK creates. It holds no name, email address or account, so we generally cannot tell which events are yours (Article 11 GDPR). Deleting the App deletes that ID, after which nothing in Google Analytics can be linked to your device.

We do not sell your personal data, and no data broker has ever been given access to anything. Apart from the identifiers and events in Section 2.4, we share nothing with advertisers.

7. Advertising Consent and How to Withdraw It

Legal basis: your consent. Everything in Section 2.4 is processed on the basis of consent — Article 6(1)(a) GDPR — collected through Apple's App Tracking Transparency (ATT) prompt shown at first launch. There is no legitimate-interest fallback here: if you decline, no advertising identifier and no event is sent, then or later.

Withdrawing consent on your iPhone

You can withdraw consent at any time, as easily as you gave it, and without giving a reason:

• Settings → Privacy & Security → Tracking, then switch Baby Novum off.
• To do the same for every app at once, turn Allow Apps to Request to Track off in the same screen.

The change takes effect immediately: iOS stops handing out your advertising identifier and all four SDKs stop sending events. Nothing in the App changes and nothing you have stored is affected.

Data that has already been sent

Withdrawing consent stops future events; it does not reach back into Meta's, TikTok's, PostHog's or Google's systems. For data they have already received:

• Meta — use Meta's own controls, Meta Ad Preferences, or contact Meta directly under its Privacy Policy.
• TikTok — if you have a TikTok account, the ad settings under Settings and privacy in the TikTok app let you clear the activity advertising partners have shared about you and stop it being used for the ads you see (TikTok Help: Ads and data). Whether or not you use TikTok, you can ask TikTok for access, deletion or objection through its privacy request form.
• PostHog — here we are the controller, so write to us rather than to PostHog. Deleting the App removes the random ID that links those events to your device; Section 6 explains why we generally cannot pick out your events without it.
• Google Analytics for Firebase — as with PostHog, we are the controller, so write to us rather than to Google. Deleting the App removes the app-instance ID that links those events to your device; Section 6 explains why we generally cannot pick out your events without it.

You can also write to us at [email protected] and we will confirm your opt-out in writing.

8. Do Not Sell or Share My Personal Information (California)

We do not sell personal information and never have — we receive no money or other value for it.

We do, however, have to be straight about the other half of the CPRA. Passing your advertising identifier and app events to Meta and TikTok so they can measure and target advertising counts as "sharing" for cross-context behavioural advertising under the California Consumer Privacy Act as amended by the CPRA. Treat it as sharing, because that is what it is.

• Categories shared: identifiers (advertising identifier, SDK-generated device IDs, the identifier for vendor sent to TikTok, IP address) and internet/device activity (device model, OS version, App version, language and region settings, install and app-open events, the four conversion events including plan, subscription amount and currency).
• Purpose: advertising attribution and campaign measurement.
• Recipients: Meta Platforms Ireland Limited; TikTok USDS Joint Venture LLC.
• Not shared or sold: the events sent to PostHog and to Google Analytics for Firebase. PostHog and Google are our service providers and process them only on our behalf, so they are neither sold nor shared.
• Never shared or sold: the sensitive personal information in Section 2.1 — health and pregnancy data, diary entries, photos and letters. None of it is shared, sold, or used to infer anything about you.

How to exercise your right to opt out

The opt-out mechanism is the tracking control on your device, and it works before anything is shared rather than after:

• Decline the App Tracking Transparency prompt when the App first asks — nothing is ever shared.
• Or, at any time: Settings → Privacy & Security → Tracking → switch Baby Novum off.
• Or email [email protected] with the subject "Do Not Sell or Share My Personal Information" and we will process the request and confirm it.

No discrimination. Opting out costs you nothing. We will not deny you any feature, charge you a different price, or give you a lesser version of Baby Novum because you said no.

9. Your Rights (GDPR & CCPA)

Depending on your location, you may have the following rights regarding your data:

• Right to Access — Since all your data is stored on your device, you have full access to it at all times within the App.
• Right to Deletion — You can delete all your data at any time by using the "Delete All Data" option in the App's Settings screen. This permanently removes all locally stored data. Uninstalling the App will also remove all data.
• Right to Portability — You can export your data using the PDF export features available within the App.
• Right to Withdraw Consent — You can withdraw consent to advertising measurement at any time, without penalty. See Section 7.
• Right to Opt Out of Sale or Sharing — We do not sell your personal data. We do share the advertising identifiers and events in Section 2.4 with Meta and TikTok when you consent to it. See Section 8.
• Right to Object and to Complain — You may object to processing and lodge a complaint with your national data protection authority.

How to Delete Your Data

To delete all your Baby Novum data:

• Open the App → Settings → Account → Delete All Data
• Or simply uninstall the App from your device

10. Data Retention

Your data is retained on your device for as long as you use the App and have not deleted it. We do not retain copies of the data described in Section 2.1 on any servers.

The events in Section 2.4 sent to Meta and TikTok leave no copy with us. Each retains them under its own retention schedule, described in the Meta Privacy Policy and the TikTok Privacy Policy respectively.

The copy sent to PostHog is held in our PostHog project. We keep those events only as long as we need them to understand the funnel, and delete them at the latest when we close that project; PostHog then deletes its copy under our data processing agreement.

The copy sent to Google Analytics for Firebase is held in our Analytics property, with event-level data retention set to two months, the shortest period Google offers. After that Google deletes the events; what remains are aggregated reports, which contain totals rather than the events of any one installation.

11. International Users

Baby Novum is available globally. Your pregnancy data, diary, photos and letters stay on your device, so Baby Novum performs no international transfer of them — there is nothing to transfer.

The advertising data in Section 2.4 is the exception. If you allow tracking, it is sent to Meta Platforms Ireland Limited in Ireland and may be processed by Meta outside your country, including in the United States, relying on the transfer safeguards Meta sets out in its own Privacy Policy (Standard Contractual Clauses and the EU–U.S. Data Privacy Framework).

Data sent to TikTok may be stored on TikTok's servers in the United States, Malaysia and Singapore, and accessed remotely by companies in TikTok's corporate group in other countries, including China, relying on European Commission adequacy decisions or Standard Contractual Clauses as described in the TikTok Privacy Policy.

Data sent to PostHog is hosted in PostHog's EU Cloud in Frankfurt, Germany. PostHog, Inc. is a US company, and it and some of its sub-processors may process that data outside the EU, including in the United States, relying on the EU–U.S. Data Privacy Framework, in which PostHog participates, and Standard Contractual Clauses, as set out in PostHog's data processing agreement.

Data sent to Google Analytics for Firebase is processed by Google LLC and may be stored and processed in the United States and in other countries where Google or its sub-processors operate, relying on the EU–U.S. Data Privacy Framework, in which Google LLC participates, and Standard Contractual Clauses, as set out in the Google Ads Data Processing Terms.

If you decline tracking, no data leaves your device for this purpose — to Meta, to TikTok, to PostHog or to Google.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of significant changes through the App. The "Last updated" date at the top of this page indicates when the policy was last revised. Your continued use of the App after changes are posted constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your data, please contact us:

Email: [email protected]

We will respond to privacy-related inquiries within 30 days.