Privacy Policy

1. Introduction

This Privacy Policy explains how Frontetica Ltd. ("Company," "we," "us," or "our") handles information in connection with LuluBoo ("the App"), an iOS pregnancy-tracking application.

LuluBoo helps you follow your pregnancy week by week: it shows the current week and estimated due date, a visual size comparison for the baby, and tools to log kicks, contractions, weight, mood, symptoms and a preparation checklist.

LuluBoo is not a medical device. It does not provide medical advice, diagnosis, or treatment. It presents general educational information about pregnancy and records information you choose to enter yourself. Always consult a qualified healthcare provider about your pregnancy and any symptoms or measurements that concern you.

By downloading, installing, or using LuluBoo, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

2. Our core commitment: no accounts, no tracking, no data sales

Before the details, the short version:

• There is no account, sign-up, login, or user profile on any server. LuluBoo has no backend of its own.
• Everything you enter - your name, dates, weight, mood, symptoms, notes, kicks, contractions, and checklist items - stays on your device. None of it is transmitted to us or to any third party.
• We do not use any analytics SDK, advertising SDK, attribution SDK, or crash-reporting SDK. There is no advertising in the App.
• We do not collect an Advertising Identifier (IDFA) and the App never shows the App Tracking Transparency prompt, because it has nothing to ask permission to track.
• We do not sell, rent, or share your personal data with third parties for their own marketing or advertising purposes. We have no such data to share.
• The App requests no device permissions - no notifications, no camera, no photo library, no location, no contacts, no microphone, no HealthKit.

The only third-party service integrated in LuluBoo is Adapty, which manages the App's subscription (see Section 5). The only other recipient of any data is Apple, through the App Store purchase mechanism and system features you choose to use (see Section 6).

3. Information you provide directly

During a one-time "Personalization" step and afterward in Settings, you may provide:

Afterward, depending on which parts of the App you use, you may enter:

• Kick-counting sessions - start/end times, individual tap timestamps, and the counting method used.
• Contraction sessions - start/end times of each contraction, grouped into sessions.
• Health Log entries - one per day: weight, belly circumference, mood (five-point scale), symptoms (from a preset list or typed by you), and a free-text note.
• Checklist progress - which of the 91 bundled checklist items are ticked, and any items you add yourself.

None of the above is required to use the free parts of the App, and each field is independently optional - for example, you can log only a mood without entering anything else.

We treat pregnancy status and health-related information (weight, belly circumference, mood, symptoms, and fetal-movement or contraction data) as sensitive information. As described in Section 4, this data is stored only on your device and is never transmitted by us to any server, to Adapty, or to any other third party.

4. Where your information is stored

LuluBoo stores information in two places, both on your device only:

1. UserDefaults in a shared App Group container - used for your profile settings (name, pregnancy dating, units, language), app preferences, and a locally cached subscription status. This container is shared only between the App and its own Home Screen widgets (which are a separate process on iOS), so the widgets can display the same information. No other app can read this container. 2. A local database (SwiftData), inside the App's own private container - used for kick sessions, contractions, Health Log entries, and checklist ticks and custom items.

iCloud sync is not used. Neither storage location is configured for CloudKit, so LuluBoo itself does not back up your data to iCloud. (If you use Apple's own iPhone backup feature, that backup may include the App's data as it would for any app - that is a feature of your device provided by Apple, not something LuluBoo initiates.)

The 41-week pregnancy content, illustrations, and checklist catalogue are fixed content bundled inside the App itself; nothing is downloaded from a server at runtime.

5. Adapty - subscription management

LuluBoo uses Adapty (adapty.io), a third-party subscription-infrastructure provider, for two purposes only:

• retrieving the paywall content configured for the App, and
• processing and validating your subscription purchase.

In doing so, Adapty creates and maintains an **anonymous installation profile** and receives standard App Store transaction and receipt data needed to validate your purchase.

We do not send Adapty any information that identifies you. LuluBoo never calls Adapty's user-identification or attribution APIs and never sends Adapty your name, pregnancy dates, weight, mood, symptoms, notes, kicks, contractions, or checklist data.

Whatever device- or installation-level data Adapty's SDK collects on its own behalf (for example, device and installation identifiers or purchase events) is governed by Adapty's own privacy documentation. **For that data, Adapty acts as an independent data controller, not as our processor** - it decides why and how that data is processed, and it is responsible for its own legal basis and safeguards (see Section 13 for international transfers). We encourage you to review Adapty's own documentation:

• Adapty Privacy Policy: https://adapty.io/privacy
• Adapty End-User Privacy Policy: https://adapty.io/end-users-privacy

6. Apple

Because LuluBoo is distributed exclusively through the App Store and billed through Apple's in-app purchase system, Apple receives your purchase transaction directly as the merchant of record. Apple is also the recipient of information if you use:

• Restore Purchases (Settings) - handled through Apple's App Store purchase records.
• Rate App (Settings) - opens Apple's system App Store review prompt.
• Share App (Settings) - opens the system share sheet with an App Store link; where you send it is your choice.

Apple's handling of this information is governed by Apple's own privacy policy, available at https://www.apple.com/legal/privacy/.

7. Files you choose to export or share

LuluBoo can generate the following files, entirely on your device, and hand them to the standard iOS share sheet so you decide where they go (for example, Messages, Mail, Files, AirDrop, or a printer). LuluBoo does not upload any of these files anywhere itself.

The Health report deliberately omits your notes, since a free-text note is the most personal thing you may record, and this report is designed to be shareable with a healthcare provider.

8. Data security

LuluBoo does not run its own servers, so there is no server-side security to describe. Security for the data described in Section 4 comes from the security of your iPhone itself, in a few concrete ways:

• App sandboxing. iOS keeps every app's storage in its own private container. No other app on your device can read LuluBoo's data, and LuluBoo cannot read other apps' data.
• Device-level encryption. iOS encrypts each app's local storage at rest using keys tied to your device passcode and biometrics (Face ID/Touch ID). This protection is provided by iOS itself, not by LuluBoo, and it is strongest when your device has a passcode set. If your iPhone has no passcode, this device-level protection is weaker - we recommend setting one regardless of which apps you use.
• The shared App Group container (Section 4) that lets the widgets read your profile is still restricted by iOS to LuluBoo and its own widgets; no other app or process can access it.
• A smaller attack surface by design. Because LuluBoo includes no analytics, advertising, or crash-reporting SDKs, there are fewer third-party code paths in the App that could mishandle your data.
• Network connections, where the App does make them (to Adapty or the App Store, described in Sections 5 and 6), use standard encrypted connections (HTTPS/TLS), consistent with Apple's platform requirements for all iOS apps.

Because responsibility for this security is shared with the platform, we cannot guarantee that any method of electronic storage is 100% secure, and we encourage you to keep your device's operating system up to date and to use a passcode, Face ID, or Touch ID to protect it.

9. What we do not do

To be explicit about what LuluBoo does not do:

• We do not use Google Analytics, Firebase Analytics, Facebook/Meta SDKs, or any other analytics or advertising SDK.
• We do not display advertising of any kind.
• We do not use a crash-reporting SDK.
• We do not collect your IP address, device identifiers, or advertising identifiers for our own purposes. (Adapty's SDK may process minimal installation-level data strictly to operate the subscription, as described in Section 5.)
• We do not build advertising or marketing profiles.
• We do not sell or "share" personal information as those terms are defined under the CCPA/CPRA.
• We do not combine your Health Log, kicks, contractions, or checklist data with any external dataset, because that data never leaves your device.

10. Children's privacy

LuluBoo is intended for people who are pregnant, trying to conceive, or supporting someone who is, and is not directed at children. We do not knowingly collect personal information from children. The App has no age gate because it requires no account and no personal information beyond what is described in Section 3, none of which is transmitted off your device. If you believe a child has used the App and that information about them has been shared with us directly (for example, by email), contact us at the address in Section 14 and we will address it.

11. Data retention and deletion

• We do not hold your personal or health data on any server - there is nothing for us to retain or delete on our side.
• Within the App, you can delete individual records yourself at any time: a kick session can be discarded, a Health Log entry can be cleared (clearing every field deletes the entry), and a checklist item can be unticked or removed.
• Deleting the App removes all of the data described in Section 4.
• Note: on some iOS configurations, the shared App Group container described in Section 4 can persist briefly after the App is deleted, so a reinstall may find your previous profile settings (name, dating, units, language) still present. This does not apply to your Health Log, kicks, contractions, or checklist data, which live in the App's own private container and are removed with the App.
• Retention of purchase and transaction records is governed by Adapty's and Apple's own retention policies (see Sections 5 and 6).

12. Your privacy rights

Because LuluBoo does not operate a server and does not hold your personal data outside your device, the most direct way to exercise access, correction, or deletion rights over the data described in Section 3 is within the App itself, or by deleting the App as described in Section 11.

12.1 Users in the EEA and United Kingdom (GDPR / UK GDPR)

Where GDPR or UK GDPR applies, you have the right to request access to, correction of, erasure of, or restriction on the processing of your personal data, and to object to certain processing. Since we do not hold your in-app data on any server, most of these rights are exercised directly in the App or by deleting it. For anything else, or for data processed by Adapty, you may:

• contact Adapty directly using the links in Section 5, or
• contact us at the address in Section 14, and we will assist where we can.

12.2 California residents (CCPA/CPRA)

Under the CCPA/CPRA, California residents have the right to know what personal information is collected, to request its deletion, to opt out of its "sale" or "sharing," and to non-discrimination for exercising these rights. We do not sell or share personal information. To exercise these rights regarding data held by Adapty, contact Adapty directly (Section 5). For general requests, email us at the address in Section 14.

12.3 Other regions

If you are in a jurisdiction with similar data-protection rights not listed above, the same approach applies: exercise in-app deletion where possible, contact Adapty for data it processes, or contact us and we will do our best to assist.

13. International data

We do not ourselves transfer your personal or health data internationally, because that data is never transmitted off your device.

With respect to the limited installation-level data described in Section 5 (such as an anonymous device identifier and purchase records), **Adapty acts as an independent data controller, not as our processor.** Adapty is responsible for putting in place its own lawful mechanisms for any international transfer of that data, and for its own compliance with applicable data-protection law. You can review Adapty's safeguards and exercise your rights directly with Adapty using the links in Section 5. Apple's handling of your purchase (Section 6) is likewise governed entirely by Apple's own terms.

14. Contact us

If you have questions about this Privacy Policy or how LuluBoo handles information, contact us at:

Frontetica Ltd.
Email: [email protected]

15. Changes to this policy

We may update this Privacy Policy from time to time, for example if the App's features or third-party providers change. Any changes will be posted on this page with an updated "Last Updated" date. Continued use of the App after an update constitutes acceptance of the revised policy.