Privacy Policy

1. Introduction

ButterPass ("App," "we," "us," or "our") is developed and operated by William Termini (ABN 47 283 458 067). This Privacy Policy explains what data we collect, how we use it, and your choices regarding your information. This policy applies to all users of ButterPass on Android smartphones and Wear OS smartwatches, and on iPhone, iPad, and Apple Watch.

2. What We Don't Collect

• No Cloud Storage: We do not store, sync, or transmit your card data to any cloud servers.
• No User Accounts: No sign-in or personal contact info (email/phone) is required.
• No Tracking By Us: We do not track your location or profile your card usage. Where you consent to personalized ads, Google's advertising SDK may use an advertising identifier for targeting (see "Advertising & Consent"); we never store it or link it to your cards.
• No Personal Information Collected By Us: We do not ask for or store your name, address, or age.

3. What Data Is Processed

A. Card Data (Local Only)

Any card information you enter, scan, or import (names, barcodes, QR codes, images) is stored exclusively on your device. It is never sent to our servers, and the only time it leaves your device is the optional watch sync described below.

Watch Sync: If you use ButterPass on a smartwatch, card data is synced from your paired phone to the watch — via Google's Wearable Data Layer API on Wear OS, or Apple's Watch Connectivity framework on Apple Watch. On Apple Watch, sync happens directly between your paired devices. On Wear OS, sync uses the direct Bluetooth or Wi-Fi link where available; if your devices are not directly connected, Google's Data Layer may relay the sync data, encrypted in transit, through Google's servers as an intermediary (see Google's privacy policy). Sync data never passes through our servers. Watch widgets and complications read a reduced local snapshot that excludes PINs and barcode data.

B. Purchases & Unlock Status

Premium: Purchase status is managed by Google Play Billing or Apple's App Store and can be restored through the store you bought it from. We do not receive your payment details.

Rewarded Unlocks: Watch-sync slots unlocked by viewing rewarded ads are recorded on your device (and may be included in your device's standard system backup). No card data is ever backed up to the cloud by the App.

C. Technical Data (Third-Party)

While we do not host a server to collect your data, the following services process technical identifiers:

• Crash Reports: Provided by Google Play (Android) or Apple (iOS, subject to your device's analytics-sharing setting). These are anonymized and help us fix bugs.
• Ad Identifiers: If ads are enabled, Google AdMob uses your device's advertising identifier (Android Advertising ID, or Apple's IDFA where you have allowed tracking) to serve ads. We do not store these identifiers or link them to your cards.
• Purchase History: Processed by Google Play Billing or Apple's App Store to manage Premium and restore purchases. We do not receive your card numbers.

4. How We Use Your Data

We process data locally to provide:

• Display & Management: Showing, editing, and customizing your cards.
• Barcode Scanning: Processing images via your camera (on-device only).
• Image Processing: Allowing you to crop and customize card images locally.

5. Permissions

App data is sandboxed from other apps on both platforms. We request only what a feature needs, when it needs it:

• Camera (Android & iOS): To scan barcodes and photograph cards. Active only while scanning or capturing; no images are sent anywhere.
• Photos: On Android we access only the images you select (Scoped Storage). On iOS, picking images uses the system photo picker, which shares only the photos you choose — the App has no access to your photo library and requests no library permission.
• Notifications (iOS): Requested only the first time your watch asks the phone to show an "Open on iPhone" notification. These are local notifications; we send no push or marketing notifications on either platform.
• Internet: To load ads and, on Android, to sync with Wear OS. Network access cannot reach your card data.

6. Advertising & Consent

Ads & Premium: We show banner ads powered by Google Mobile Ads unless you purchase Premium. On the free tier you may also choose to watch rewarded ads to unlock watch sync slots.

Consent (GDPR/CCPA): In regulated regions, we use Google's required consent flow before any ad is requested. If you refuse consent, ads will be non-personalized or limited — you still see ads, but they are contextual only, with no advertising identifier.

App Tracking Transparency (iOS): On iOS, personalized ads additionally require your permission through Apple's App Tracking Transparency prompt. If you decline, ads are served without the IDFA.

Withdrawing Consent: You can change or fully withdraw your consent at any time — in Android system settings, in iOS Settings → Privacy & Security → Tracking, and through the App's in-app privacy options where a persistent consent entry point is required.

7. Third-Party Services

• Google Mobile Ads (Android & iOS): Uses advertising identifiers as described above. We do not link them to your identity. Google and its partners may use these identifiers to serve ads based on your visits to this and other apps.
• ML Kit (Android): Used for barcode scanning. Processing happens locally; Google may collect anonymized telemetry for performance monitoring.
• Apple Vision (iOS): Used for barcode scanning and detection. Processing happens entirely on-device.
• UCrop (Android): Open-source library for local image cropping.

8. Data Retention & Deletion

Your Control: You can delete individual cards or the entire database within the app at any time.

Uninstalling: Uninstalling ButterPass deletes all card data from your device storage. If you manually exported a backup file (e.g., a .bpass file saved to your cloud drive or storage), that file remains under your control and must be deleted manually.

9. Your Privacy Rights

Data Controller Status: Under privacy laws like the GDPR, William Termini is the Data Controller for the App. Because your card data is stored exclusively on your device, we have no technical access to it.

Right to Access/Delete: You exercise these rights yourself by viewing or deleting cards within the app. We cannot fulfill "Right to Access" requests via email because we do not possess your data.

Right to Portability: You can export or share your cards through the App's built-in export features on both platforms.

10. Children's Privacy

ButterPass is not intended for children under 16. We do not knowingly collect any information from children. If you believe a child has provided us with information (e.g., via support email), please contact us for deletion.

11. Legal Necessity & Law Enforcement

Because ButterPass does not collect, store, or access your card data, we cannot provide user data to law enforcement, government bodies, or courts, even if legally compelled. We have no database of user information to subpoena.

12. International Users & Compliance

GDPR (EU/EEA): We follow data minimization. Since no personal data is transmitted to us, your "Right to be Forgotten" is exercised by you deleting the app.

CCPA/CPRA (California): We do not "sell" your personal information.

13. Changes to This Privacy Policy

We may update this policy to reflect changes in technology or law. Material changes will be communicated via the App. Continued use after changes constitutes acceptance.

14. Store Disclosure Summaries

Google Play — Data Safety

• Device or other IDs: The Android Advertising ID is used by Google AdMob for advertising (see "Advertising & Consent"). We do not collect device identifiers ourselves.
• Approximate location: May be inferred by Google AdMob for ads/analytics. We do not store location ourselves.
• Purchase history: In-app purchases are processed by Google Play Billing; we receive purchase status/receipts (not card numbers) for app functionality.
• App interactions: Ad impressions/clicks may be collected by Google AdMob for ads/analytics. Card interactions remain on-device.
• Crash logs/diagnostics: May be collected by Google Play services for stability.

Apple App Store — App Privacy

• Identifiers (Device ID): Used by Google AdMob for advertising, only where you allow tracking via App Tracking Transparency. Not linked to your identity by us.
• Purchases: Purchase status is processed by the App Store for app functionality.
• Diagnostics: Crash data may be shared with us via Apple subject to your device's analytics-sharing setting.
• Data used to track you: Advertising identifiers, only with your ATT permission; declining disables tracking.

15. Contact

William Termini (ABN 47 283 458 067) Email: legal@butterpass.app Support: support@butterpass.app