Privacy Policy

Last updated: January 26, 2025

This privacy notice for Viral App Dev LLC (doing business as Promise) (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at team@withpromise.app.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find more details by using our table of contents below to navigate to each section.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  14. DO WE MAKE UPDATES TO THIS NOTICE?
  15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us: We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You: The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Information automatically collected: We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

Information related to VPN Monitoring (if enabled)

If you enable the Advanced Monitoring feature inside Promise, the App creates a local VPN connection on your device. Through this VPN, we process DNS queries (domain names) that your device attempts to reach to detect and block explicit or restricted content. We log:

These records are stored locally in your App Group storage and securely synced to our servers for accountability purposes. We never inspect message content, passwords, or full page contents. The data collected is used only to provide accountability and partner notifications, and is never sold or shared with advertisers.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law. Depending on your location, the legal basis may include:

You may withdraw consent at any time by turning off Advanced Monitoring in the App's settings or adjusting your tracking preferences in your device settings.

4. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

We may share your information in the following situations:

Monitoring summaries never include full browsing history or content. We do not sell, rent, or disclose any VPN data to advertisers or unrelated third parties.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

App Tracking Transparency: We participate in Apple's App Tracking Transparency (“ATT”) framework. Before accessing your device's advertising identifier (IDFA) or engaging in any tracking across apps or websites owned by other companies, we will request your permission through the ATT prompt. You may change your tracking preferences at any time in your device's Settings under Privacy > Tracking.

Analytics: We use analytics tools to understand how users interact with our Services. This data helps us improve the user experience. If you have opted out of tracking, we will not use cross-app tracking for analytics purposes.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your information. We will protect your information in accordance with this privacy notice and applicable law.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information. VPN monitoring logs are automatically deleted or anonymized after 90 days.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. VPN monitoring data is encrypted in transit using TLS and at rest using industry-standard encryption. Local logs are stored in Apple App Group containers and synchronized securely. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

9. DO WE COLLECT INFORMATION FROM MINORS?

The Services are intended for users who are at least 13 years of age. Users under 18 must have verifiable parental or guardian consent to use the Services. We do not knowingly collect data from children under 13. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as quickly as possible. If you become aware of any data we may have collected from children under age 13, please contact us at team@withpromise.app.

10. WHAT ARE YOUR PRIVACY RIGHTS?

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

You can disable VPN monitoring at any time in the App's settings, remove your accountability partner, or request deletion of collected data by contacting us.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. However, you can opt out of tracking through Apple's App Tracking Transparency settings.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Residents: California Civil Code Section 1798.83 (“Shine the Light” law) permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are a California resident under the age of 18 and a registered user of the Services, you may request removal of content or information you have publicly posted. Please note that such removal does not ensure complete removal of the content or information.

California Consumer Privacy Act (CCPA): If you are a California resident, you have the right to:

To exercise these rights, please contact us at team@withpromise.app.

Other U.S. State Privacy Laws: Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights. Please contact us to exercise any applicable rights.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

European Economic Area (EEA) and UK Residents: If you are a resident of the EEA or UK, you have certain data protection rights under the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information. You also have the right to lodge a complaint with your local data protection authority.

Canadian Residents: We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA). You may access and correct your personal information by contacting us.

Australian Residents: We comply with the Australian Privacy Principles. You may access and correct your personal information and lodge a complaint about a breach of the Australian Privacy Principles by contacting us.

14. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at:

Viral App Dev LLC
22 Cushing St, Boston, MA
Email: team@withpromise.app

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To delete your account: You can delete your account directly within the Promise app by navigating to Settings > Account > Delete Account. This will permanently remove your account and associated data from our systems.

To request your data: You may request a copy of your personal data or request corrections by contacting us at team@withpromise.app. We will respond to your request within 30 days.