Privacy Policy

Last Updated: October 19, 2026

1. Introduction

Hugo Prione Duarte ("we," "us," "our," or "Company") operates the SmartTracker App (the "App"), available on iOS, iPadOS, and macOS. This Privacy Policy explains how we handle information in connection with the App and our commitment to protecting your privacy.

We are committed to maintaining the highest standards of privacy protection. Our App is designed with privacy as a core principle: the things you track never leave your devices and your iCloud account. We collect only anonymous data on how the App is used, described in Section 3, and you can turn that off at any time.

2. Information We Collect

We do not collect anything you track, and nothing that identifies you. This includes, but is not limited to:

• Personal identification information (name, email address, phone number)
• Your Apple ID, your device's advertising identifier, or any hardware identifier
• Location data
• The web pages you open or browse inside the App
• Search queries or product tracking data: the URLs, product names, prices, selectors, collections and notes you track

All data related to your price tracking activities is stored exclusively on your device or in your personal iCloud account. We have no access to, and do not collect, any of this information.

The only exception is the anonymous usage data described in Section 3.

3. How the App Is Used: Anonymous Data

The only data we collect is how the App is used. We collect it anonymously, and you can turn it off at any time. This applies from the version of the App that introduces it, which tells you about it on its welcome screen or in a one-time notice; earlier versions send none of this data.

Why. It helps us find where people get stuck, see which features are used, check that price alerts arrive, and decide what to build next.

What is sent. The App sends short usage events, for example "onboarding completed", "paywall shown, from the item limit", "purchase completed, annual, with trial", "price alert delivered". Each event carries:

• a random identifier created on your device when you first use the App. It is not your Apple ID, not your device's advertising identifier, and not derived from anything about you or your device;
• your platform (iOS, iPadOS or macOS), and the App's version and build;
• whether you have Premium;
• your App Store country (from the App Store, not from your location);
• whether the event came from the App or from its macOS background helper.

Counts are rounded into ranges (for example "6-10 items"), never exact.

What is never sent. The URLs, product names, prices, selectors, collections or notes you track; your name, email, contacts or location; any advertising identifier. No price, currency or transaction ID is sent with purchase events.

Who processes it. Events go to PostHog, Inc., acting as our processor, and are stored in PostHog's EU Cloud, in the European Union. PostHog is configured to discard your IP address, not to derive any location from it, and not to create user profiles. Processing is governed by a data processing agreement (DPA) we signed with PostHog on October 19, 2026.

How long it is kept. Up to 7 years, after which it is deleted.

Your choice. Sharing is on by default. It is described on the App's welcome screen or, if you started using the App before this version, in a one-time notice. You can turn it off at any time in the App's Settings (on a Mac, Settings › General) with "Share anonymous usage data". Turning it off stops all sending immediately, deletes any events not yet sent, and deletes the random identifier. If you turn it back on, a new, unrelated identifier is created.

Legal basis. Our legitimate interest in improving the App (GDPR Art. 6(1)(f); LGPD Art. 7, IX), balanced by the data being anonymous in practice, minimal, and easy to switch off.

4. App Store Connect Analytics

The only data we receive is aggregated, non-personal analytics data through Apple's App Store Connect platform. This data may include:

• General usage statistics
• App performance metrics
• Crash reports (without personal identifiers)
• App version and device type information

This information is provided by Apple and does not identify you individually. We use this data solely to improve the App's performance and user experience.

5. Website Analytics (smarttracker.tech)

The information in Sections 2 to 4 above describes the SmartTracker app. This section covers the separate SmartTracker website at https://smarttracker.tech.

The website uses Google Analytics 4, a service provided by Google LLC, to understand how the site is used. Unlike the App's anonymous usage data, this does involve processing personal data, and we ask for your consent before it happens.

We ask first. Google Analytics is loaded with Google Consent Mode v2 and every storage type set to "denied" by default. On your first visit you will see a banner with two equally available choices, Accept and Decline.

If you accept:

• Cookies are set on your browser by Google Analytics (typically _ga and _ga_*), used to recognise returning visits.
• Your IP address is processed by Google in order to derive an approximate location (country/region). Google Analytics 4 does not store IP addresses in its reports.
• Aggregate behaviour is recorded: pages viewed, referring source, approximate location, device and browser type, scroll depth, and which buttons and links you click.

If you decline, or ignore the banner entirely:

• No cookies are set and no identifiers are stored on your device.
• We receive only anonymous, cookieless, aggregate counts: a page was viewed, with no way to connect it to you or to any other visit.
• Declining is treated exactly the same as never answering. It is not a temporary state that later flips to consent.

You can change your mind at any time by clearing this site's data in your browser, which resets your stored choice and shows the banner again.

What we never do: we do not sell your data, we do not use Google Signals, we do not enable advertising personalisation or remarketing, and we run no ads on this site.

The website analytics are entirely separate from the App's anonymous usage data (Section 3): different services, and nothing links the two.

For more information about how Google processes this data, see https://policies.google.com/privacy (opens in a new tab) and https://support.google.com/analytics/answer/11593727 (opens in a new tab) (Google Analytics and data privacy).

6. Third-Party Services

The App uses one third-party processor, PostHog, Inc., for the anonymous usage data in Section 3. It contains no third-party SDK: the App sends these events itself. We do not share App data with advertisers or marketing companies, and we never sell it.

The website uses one third-party processor, Google LLC, for the analytics described in Section 5, and only where you have consented. This means data may be transferred to and processed on Google's infrastructure outside your country; see Section 16. We share no data with advertisers or marketing companies from either the App or the website.

7. Data Storage and Security

• On-Device Storage: All of your price tracking data remains stored on your device
• iCloud Synchronization: The App supports iCloud synchronization to sync your data across your Apple devices. This synchronization is managed entirely by Apple's iCloud service, and we have no access to, nor do we store, your iCloud data on our servers
• No Server Infrastructure: We do not run servers or databases of our own. The only App data held outside your devices and iCloud is the anonymous usage data in Section 3, held by PostHog

Your data is protected by your device's security features and Apple's iCloud encryption standards.

8. Data Retention

Your price tracking data stays under your control on your device and in your iCloud account; we hold none of it. Anonymous usage events are kept for up to 7 years and then deleted.

9. User Authentication

The App does not require user authentication, login credentials, or account creation. You can use the App immediately upon download without providing any personal information.

10. In-App Purchases

The App offers two paid options to unlock Premium features:

• A one-time, non-consumable purchase for lifetime access.
• An auto-renewing annual subscription, billed yearly through your Apple ID.

Both options unlock the same Premium features. The free version of the App does not contain advertisements.

Payment processing. All in-app purchases, including subscription renewals, are handled exclusively by Apple through the App Store and your Apple ID. Apple collects and processes payment information according to their own privacy terms. We do not have access to your payment method, billing address, transaction history, or subscription identifiers. The App receives only the local StoreKit entitlement status (a flag indicating whether Premium is unlocked on the device). The anonymous usage data in Section 3 includes whether Premium is unlocked and, for a purchase made in the App, the option chosen (annual or lifetime) and whether it began with a free trial; never a price, payment detail or transaction identifier.

Subscription management. If you choose the annual subscription, renewals and cancellations are managed entirely through your Apple ID settings (on iOS: Settings > Apple ID > Subscriptions; on macOS: System Settings > Apple ID > Media & Purchases > Manage). The Developer cannot initiate, modify, or cancel renewals on your behalf.

Family Sharing. Both Premium options support Apple Family Sharing. Sharing is managed by Apple through your Family group settings; the App is not informed which family member purchased the entitlement.

11. Children's Privacy

The App does not knowingly collect any information from children under 13 years of age (or the applicable age of digital consent in your jurisdiction). The App is suitable for all ages, as it collects no personal information from anyone, and only the anonymous usage data in Section 3. If you believe we have inadvertently collected information from a child, please contact us immediately.

12. Your Rights

Depending on your location, you may have certain rights regarding your personal data:

• Right to Object / Opt-Out: turn sharing off in the App's Settings (Section 3). This takes effect immediately and deletes unsent events and the identifier on your device.
• Right to Access, Deletion and Portability: the usage events are not linked to you, and the App does not show its random identifier, so we cannot single out events from a particular person. Turning sharing off deletes the identifier, after which nothing can connect past events to your device; they are deleted at the end of the retention period in Section 8.

All of your App data remains entirely under your control on your device and iCloud account.

13. Compliance with Regulations

We are committed to complying with applicable privacy laws and regulations, including:

• GDPR (General Data Protection Regulation) for users in the European Union
• CCPA (California Consumer Privacy Act) for users in California
• LGPD (Lei Geral de Proteção de Dados) for users in Brazil
• Other applicable privacy laws globally

Our privacy-first approach is designed to comply with these regulations: the App collects only the anonymous usage data in Section 3, processed in the EU by PostHog under the data processing agreement we have with PostHog.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy within the App or on our website and updating the "Last Updated" date. Your continued use of the App following the posting of revised Privacy Policy means you accept and agree to the changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Hugo Prione Duarte Email: support@hprione.com Location: Uberlândia, Minas Gerais, Brazil

We will respond to all inquiries as promptly as possible, typically within 30 days of receipt.

16. International Data Transfers

Your price tracking data remains on your device and iCloud account under Apple's data processing terms. The App's anonymous usage events are processed in the EU by PostHog, Inc., a US company; our data processing agreement with PostHog, and the transfer safeguards it sets out, apply. Website analytics are covered in Section 5.

17. Your Responsibilities

To maintain the privacy of your App data:

• Keep your device secure with a strong passcode or biometric authentication
• Maintain your iCloud account security with a strong password
• Review Apple's privacy and security practices for iCloud

By using the SmartTracker App, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

For the most current version of this Privacy Policy, please check the App's information section or contact us directly.