arc LockIn PRIVACY POLICY

Effective date: October 11, 2026 arc LockIn is operated by Sharif Zafar, an individual based in Türkiye, who is the data controller for the processing described in this Policy. "arc LockIn", "we", "us", and "our" refer to this operator. This Policy covers the arc LockIn mobile application, the website at app.arclockin.com, and related services (together, the "Service"). References to the "App" mean the mobile application. Features and permissions differ by platform and version. Contact: hello@arclockin.com 1. Information We Access or Collect Account and identity information: - Email address, account identifier, authentication records, and session information. - Basic account information and identity tokens received when you choose a third-party sign-in option. - Information needed to confirm your identity, protect your account, and process account-deletion requests. Health and fitness information: If you enable Health Performance and grant device permissions, the App may read and display the health and fitness record types you authorize, including: - Activity and fitness information, such as steps, distance, floors climbed, elevation, exercise sessions, speed, power, and active or total energy burned. - Heart, recovery, and respiratory information, such as heart rate, resting heart rate, heart-rate variability, oxygen saturation, respiratory rate, and estimated aerobic fitness. - Sleep sessions and sleep stages. - Nutrition and hydration records, including calories, macronutrients, nutrients, meals, food names, and water intake. - Body measurements and metabolism information, such as height, weight, body fat, and basal metabolic rate. - Vital and metabolic measurements, such as blood glucose, blood pressure, and body temperature. - Reproductive health information, such as menstrual flow, menstrual periods, and cervical mucus. - Record dates and times, units, source-app information, and device metadata associated with health records. The App writes health entries to the device health platform only when you choose to log or save them and grant the required permission. The App may write weight, height, body fat, hydration, nutrition, sleep sessions, blood glucose, blood pressure, heart rate entered with a blood-pressure log, exercise sessions, and active calories associated with a completed workout. Health profile and manually entered information: - Target weight, age, weight-change pace, activity level, gender selection, main goal, diet preference, goal start date, and unit preferences. - Account-linked gym, Bend, calisthenics, and diet progress, including completed/skipped routines, challenge days and meal identifiers, learning goals, and recorded attempts and progress timestamps, where supported. - Health entries you choose to log, including serving selections and meal labels, hydration, sleep times, weight and body measurements, blood glucose and insulin details, blood pressure and medication-status details, and the date and time of an entry. - Calculated or inferred wellness information, such as trends, targets, energy and recovery scores, stress indicators, nutrition recommendations, and estimated health age. These outputs are estimates generated from available records and profile information; they are not medical diagnoses. App activity, settings, and locally saved progress: - Reminder, alarm, notification, Flow, widget, feed, stamp-source, theme, and other preferences. - Cognitive-exercise and game difficulty settings, completion times, best scores, and related progress. - Self-reported alarm information, such as sleep duration or sleep quality, and movement-challenge records. - Favorite food identifiers, food-search terms and selections, health unit preferences, and temporary food-search results. - Custom audio files you select for supported features, which are copied to App storage on your device. - Local session and cache information needed to keep you signed in and make the App work. Lock In Time and installed-app information: - On supported devices, the App reads names, package identifiers, and icons of installed launchable apps so you can search and select up to six allowed apps per bag. - Selected bags/apps, duration, early-exit choice, session start/end times, actual focused seconds, and completion status are stored on your device. Active session state is also stored by the native session component to resume after an App restart. - Where the blocking feature uses an Accessibility service and that service is enabled, the App receives app/window-change events, including the package name of the opened app. During an active session it uses that name locally to return you to the focus screen if the app is outside your allowed group. Where supported, it may dismiss the notification shade. - The service is configured without access to window contents. It does not read screen text, messages, passwords, keystrokes, microphone audio, or camera images. Installed-app lists and Accessibility app-switch information are not uploaded by the current Lock In Time implementation or sent to advertising providers. Smart Scan photos and results: - Photos you capture/select for food analysis, temporary download links, estimated foods and portions, nutrient estimates, and account-linked daily scan counts and last-scan time. - Capturing a photo prepares it locally. Starting "Identify foods" sends selected photos for online analysis as described in Section 2. Avoid including faces, documents, medical records, or other private information in meal photos. User content and communications: - Images, quotes, text placement, colors, fonts, visibility choices, created stamps, liked stamp identifiers, and content you choose to import or create. - Help requests, contact messages, issue reports, feature suggestions, titles, descriptions, affected feature names, and screenshots or images you attach. - A selected response to the account-deletion feedback question. The current deletion process uses this response to complete the request and does not retain it after the request is processed. Subscription and transaction information: - Subscription status, plan type, product identifier, store, renewal status, purchase and expiration events, and related transaction identifiers. - Purchases are processed by the applicable app store and subscription provider. We do not receive or store your full payment-card number. Technical, security, and anti-abuse information: - When the App communicates with online services, we and our providers may process IP address, request time, device or browser information, authentication and anti-abuse tokens, service responses, and diagnostic or security logs. - We use this information to deliver network features, prevent fraud and automated abuse, apply rate limits, troubleshoot errors, and protect users and the App. Device permissions and user-selected access: - Health-record access is requested only for health features you choose to connect or use. Connecting Health Connect requests the read permissions used for the App's dashboards, reports, trends, and insights. A write permission is requested separately only when you use a feature that saves that type of entry or completed workout to Health Connect. - Camera access captures food photos for Smart Scan. Photo/media access lets you select meal photos, stamp images, or support attachments. Camera permission alone does not start an online scan. - Lock In Time uses the permissions and system capabilities required by your device platform. Where the blocking feature uses Accessibility, that permission is required. Notifications and battery-optimization exemption are optional where offered. Lock In Time does not request permission to draw over other apps. - Phone/camera shortcuts open the device's external apps. These shortcuts do not read contacts, call logs, or camera output. - File access is used through the system picker when you select a supported audio file. - Notification access supports reminders, alarms, trial reminders, and focus-session status. On supported devices, alarm features may also use exact-alarm, full-screen notification, background audio, or device-restart scheduling capabilities to deliver the alarm you configure. - Vibration supports interaction feedback and focus countdown cues. Audio may pause when another app plays audio or a phone call interrupts it, without reading the call's contents. - The App does not intentionally request or collect precise location, contacts, SMS messages, or microphone recordings through its current features. 2. Where Health Information Is Processed Health records read from the device health platform are processed on your device to display metrics and calculate App insights. Under the App's current implementation, raw records read from the device health platform are not uploaded to arc LockIn's servers or shared with our cloud, subscription, nutrition, or advertising providers. Health entries you choose to save are written to the device health platform. Other apps or devices that you separately authorize may be able to access those entries under your device health settings. Most health profile details, health unit preferences, manual-log companion details, cognitive-exercise scores, and similar settings are stored locally. Some profile and companion details use protected device storage where supported. The exceptions are account-linked gender selection and main goal, and supported gym, Bend, calisthenics, and diet progress. These are saved locally and synchronized with Supabase to restore them when you sign in or reinstall. Changes may wait for a connection before syncing. Clearing local storage or uninstalling does not delete these cloud copies or overwrite them with empty values. Signing in to the same account may restore previously synchronized information. Unsynchronized local information may be lost. Food-search terms and food identifiers are sent to our online service and a nutrition-information provider to return search results. These requests do not include your raw device health records or your locally stored health profile. If you choose a food and save it, the nutrition entry is written to your device health platform. Smart Scan is a separate cloud feature. Starting a scan uploads selected JPEG images to tmpfiles.org with a requested expiry of 3,600 seconds (about one hour). Download links are sent to our Supabase Edge Function and Replicate, which runs a Google Gemini model to identify food and estimate nutrition. The scan request does not include raw Health Connect/Apple Health records, gender, goals, or workout history. Providers can also process request metadata and operational logs. Temporary image links are accessible to anyone who possesses the link; they are not protected by your arc LockIn account login. The current integration has no immediate deletion control for an already uploaded tmpfiles.org image. Expiry is handled by that provider. Replicate documents automatic cleanup of API prediction inputs, outputs, and logs after one hour by default; this is a provider policy, not a guarantee that every provider backup or operational record is erased at that time. We do not use your meal photos to train our own AI models. Provider processing remains subject to their terms and retention practices. Smart Scan estimates return to the App for your review. The current database stores account-linked usage counts/timestamps to enforce limits, rather than a permanent meal-photo gallery or prediction history. Saving a nutrition entry writes it to the device health platform with your permission. Health information voluntarily included in support messages or uploads is processed as user content. Created-stamp and support images currently use Cloudflare R2/CDN download URLs accessible to anyone who has the URL. Do not upload confidential documents or sensitive images. Database access restrictions do not make these image URLs private. 3. How We Use Information We use information to: - Create, authenticate, secure, and manage your account. - Provide requested features and sync account-based content, gender/main-goal choices, and supported workout/diet progress. - Run focus sessions, apply allowed-app choices locally, and display actual focus statistics. - Analyze selected meal photos online, return estimated nutrition, and enforce scan limits. - Read, display, organize, and write health information with your permission. - Generate wellness, nutrition, recovery, activity, stress, goal, and performance insights on your device. - Save preferences, exercise progress, reminders, alarms, widgets, and locally selected content. - Search food and nutrition information and save the entries you choose. - Process, verify, and restore subscriptions and provide paid features. - Store, display, and manage created and liked stamps and other user content. - Respond to help requests, bug reports, contact messages, and feature suggestions. - Prevent abuse, enforce our Terms, troubleshoot, maintain security, and protect our rights and users. - Measure website performance/visits and app installs, registrations, onboarding completion, checkout, and subscription attribution through the providers and controls described below. - Comply with legal obligations, lawful requests, and app-store requirements. We do not use health information to make decisions that produce legal or similarly significant effects about you. 4. Health Data Commitments We limit access to health and fitness information to features visible in the App and to the permissions you choose to grant. We do not: - Sell health information or sell other personal information for money. See Section 5 for advertising measurement and the broader meaning of sale/sharing under some laws. - Transfer or use device health-platform data for advertising, personalized advertising, data-broker services, credit decisions, lending, or insurance eligibility. - Use device health-platform data for a purpose unrelated to the health and wellness features shown in the App. - Upload raw device health-platform records for human review under the current implementation. Authorized support/infrastructure personnel may access cloud account data or content you submit to resolve a request or security incident; this is separate from raw health-platform records. The App is not a medical device and does not diagnose, treat, cure, or prevent any medical condition. Consult a qualified healthcare professional for medical advice, diagnosis, or treatment. 5. How We Share Information We share information only as reasonably needed for the following purposes: - Supabase supplies authentication, databases, and backend functions for account data, gender/main-goal choices, supported workout/diet progress, support records, subscription/access information, and scan usage records. Our current Supabase project is hosted in Singapore. - Cloudflare supplies uploaded-image storage/delivery through R2 and security/anti-abuse services including Turnstile. - tmpfiles.org and Replicate (including the Google Gemini model used through Replicate) process selected scan images, links, requests, and results as described in Section 2. - Vercel hosts the website and supplies Web Analytics and Speed Insights for visit/performance measurement. - Sign-in providers process identity and authentication information when you choose their sign-in option. - Security and anti-abuse providers process tokens and technical information used to distinguish legitimate users from automated or abusive activity. - Apple App Store, Google Play, RevenueCat, and the web payment provider (currently Paddle) process purchases, billing, account identifiers, subscriptions, and transaction information. Website purchases use web checkout; App purchases use the applicable store. We do not receive your full payment-card number. - Meta receives app/website event and attribution information as explained below. RevenueCat may receive device/attribution identifiers to connect installs or visits to subscriptions. - FatSecret processes food-search terms and identifiers to return nutrition information. This integration is separate from Smart Scan image analysis. - Operating-system and device-platform providers process permissions, notifications, locally stored files, health records, and other platform functions according to your device settings and their own privacy terms. - Email, communications, and sharing providers process information when you contact us, open an external link, or choose to share content. We may also disclose information: - When required by law, legal process, or a valid government request. - To protect the rights, safety, and security of users, the public, arc LockIn, or others; investigate abuse; or enforce our Terms. - In connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate confidentiality and notice requirements. - At your direction or with your consent. Advertising measurement, cookies, and browser storage: The App includes Meta App Events for install/activation, email-registration, onboarding-completion, and subscription-checkout measurement. Checkout events may include product/plan identifiers, price, and currency. Meta's SDK and RevenueCat attribution may process network, device, advertising, and anonymous app identifiers. On iOS, advertising-identifier collection is controlled by the system tracking-permission choice; denying it does not disable every operational or limited app event. Available identifiers also depend on operating-system settings. The website uses browser storage for sign-in sessions, preferences, onboarding state, and cookie choices. Vercel Web Analytics and Speed Insights collect visit/performance information such as page URL, referrer, browser/device type, approximate region, and timing measurements. Vercel describes its default Web Analytics visitor measurement as cookie-free and aggregated. When configured, the website uses Meta Pixel for page views and selected account/checkout events. Meta may use cookies and advertising/click identifiers. Where the site's regional controls require prior consent, the Pixel waits for an affirmative cookie choice; elsewhere the current implementation may enable it by default. Use the website's "Cookie preferences" control to reject optional Meta measurement. For users who permit measurement through a stored website choice, the checkout integration may send RevenueCat email, browser user agent, page URL, and available Meta browser/click identifiers for attribution. Rejecting optional advertising measurement does not remove subscription features. Our app/website event code does not attach raw device health records, meal photos, gender answers, workout/diet progress, installed-app lists, or Accessibility app-switch information to Meta events. We do not sell personal information for money. Advertising-identifier/event disclosures may nevertheless qualify as "sharing", targeted advertising, or a "sale" under some privacy laws. Where applicable, request an opt-out at hello@arclockin.com and use available cookie/device tracking controls. This Policy is not itself consent to advertising or sensitive-data processing. 6. Legal Bases for Processing Where applicable, account creation, sign-in, content storage, requested restoration, and subscription fulfillment are processed because they are necessary to provide the service you request or perform our contract. Security, abuse prevention, troubleshooting, and support may rely on legitimate interests where permitted and balanced against your rights. Accounting, lawful requests, and required records may rely on legal obligations. Optional permissions, advertising measurement, and sensitive information require consent where law or platform rules require it. Health-related information qualifying as a special category needs a separate lawful condition, such as explicit consent where required; accepting these Terms or this Policy is not that consent. Withdraw permission through available App, browser, or device controls, and contact us about cloud processing. Withdrawal does not invalidate processing that was lawful before withdrawal. Dependent features may stop working. For processing subject to Türkiye's Personal Data Protection Law No. 6698, relevant grounds are assessed under Articles 5 and 6. This Policy explains collection, purposes, recipients, and rights. Under GDPR/UK GDPR, the relevant Article 6 basis and an Article 9 condition for special-category data must apply where needed. Device permission is a technical access control and does not replace separate consent required by law. 7. Storage and Retention Cloud account data, synchronized gender/main-goal choices and workout/diet progress, created/liked stamps, and account-linked usage/access records ordinarily remain while your account exists, unless deleted through an available control. Signing out or uninstalling does not delete your cloud account. Support requests/attachments remain while needed to respond and resolve the issue. Technical, security, and anti-abuse records follow relevant provider settings and the need to investigate incidents, apply limits, and resolve disputes. Billing providers retain transaction records under their legal obligations and retention policies. Additional retention is limited to information needed for a documented legal, security, accounting, or dispute purpose. Contact us about a particular record or to request deletion. Local preferences, health-profile details, focus history, selected bags/apps, game scores, selected audio, and image caches may remain until removed through an available control, clearing storage, or uninstalling. Protected storage and device backups can survive these actions depending on the operating system. Raw device health records and entries written to the health platform are controlled separately; removing access or deleting your account does not necessarily delete them. For Smart Scan uploads we request one-hour expiry at tmpfiles.org, and Replicate documents one-hour default cleanup for API prediction data as described in Section 2. Account deletion does not immediately erase an image awaiting temporary-host expiry. Cached or shared copies may remain elsewhere. In-app deletion is designed to delete the authentication account and related database rows after confirmation. Uploaded-image cleanup is attempted separately and can fail; contact us if an uploaded image remains accessible. Verified email deletion requests are handled without undue delay within applicable legal deadlines. We aim to complete them within 30 days of verification and explain any lawful extension. Provider backups, cached files, security logs, and legally required records may remain after deletion until their applicable retention period ends. We do not promise a fixed backup-erasure deadline that has not been verified with the provider. Retained records are restricted to their remaining purpose. 8. Account Deletion and Other Controls You can delete your account in the App: Settings > Account management > Delete Account. If you cannot access the App, email hello@arclockin.com from the email address connected to your account with the subject line "arc LockIn Account Deletion Request". Account deletion removes the App account and associated cloud account data, including synchronized gender/main-goal choices, workout/diet progress, Smart Scan usage, created stamps, liked stamps, support requests, and subscription-access records, subject to the retention exceptions in this Policy. We also request deletion of user-owned uploaded images from cloud storage. Short-lived backup or system copies may remain temporarily until overwritten, and deletion may be delayed where required by law or necessary for security or dispute resolution. Account deletion clears ordinary App preferences stored in local App storage during the in-App deletion flow. Some information in protected device storage, device backups, or the device health platform may remain. To remove remaining local App data, clear the App's storage in device settings or uninstall the App. To review or delete health records written by the App, use the controls provided by your device health platform. You can also: - Change Lock In Time bags/duration and choose early exit before starting. Your device settings let you review or revoke its blocking permissions. - Avoid online Smart Scan by not starting "Identify foods". Denying camera access still allows supported photo-selection features. - Change advertising measurement through website Cookie preferences and available device tracking/privacy controls. - Grant, deny, or revoke individual health permissions in your device settings. - Turn off notifications in the App or device settings. - Deny photo or file access and avoid selecting content. - Delete created stamps using available App controls. - Remove favorite foods and change health or App preferences. - Log out of the App. Under Türkiye's Law No. 6698, you may ask whether data is processed; request information about processing, purposes, and whether use matches those purposes; learn recipients in Türkiye or abroad; request correction/deletion where legal conditions apply and notification of those actions to recipients; object to an adverse result from automated analysis; and seek compensation for unlawful processing where applicable. We respond within the statutory period, generally no later than 30 days for a properly submitted request, subject to lawful identity verification. You may contact Türkiye's Personal Data Protection Authority (KVKK) through its complaint procedures. Depending on where you live, you may also have rights to request access, correction, deletion, restriction, portability, or objection regarding personal information, or withdraw consent. You may also have the right to complain to a local data-protection authority. Contact us to make a request. We may need to verify your identity, and some rights are subject to legal exceptions. 9. Security We use reasonable technical and organizational safeguards designed to protect information. Measures include encrypted network transport, authenticated requests, protected session storage where supported, access controls, upload restrictions, and limits intended to prevent abuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. You are responsible for maintaining the security of your device and account credentials. 10. Children The App is not directed to children under 13, and we do not knowingly collect personal information from children under 13. Health-platform features are not intended for accounts that cannot lawfully consent to their use. If you believe a child has provided personal information unlawfully, contact us at hello@arclockin.com so we can review and delete it where appropriate. 11. International Processing The operator is based in Türkiye. Our current Supabase database is hosted in Singapore. Other providers may process data in the United States, Europe, and other countries where they or their subprocessors operate. These countries may have different privacy laws. Cross-border processing must have a lawful basis and required safeguards, including Türkiye's Article 9 rules and GDPR/UK GDPR rules where applicable. This Policy is a disclosure, not itself a transfer agreement or consent form. Contact us about recipients and transfer arrangements applicable to your data. 12. External Links and Third-Party Practices The App may link to external research, educational resources, app-store pages, or other third-party services. This Policy does not govern information that a third party collects directly under its own privacy policy, including information processed after you open an external link or direct your device to share content. 13. Changes to This Policy We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and may provide notice in the App or through other reasonable means. Where required by law, we will request consent before materially changing how sensitive information is used. 14. Contact For privacy questions, data requests, or account-deletion help, contact the operator/data controller: Sharif Zafar Based in Türkiye hello@arclockin.com