Privacy Policy for NeckAlign

1. Introduction & Scope

This Privacy Policy (the “Policy”) constitutes a legally binding disclosure governing the privacy practices and data processing operations of the NeckAlign: Posture Tracker mobile software application (the “Application” or “App”) distributed on the Apple App Store, created and operated by DN5F Studio - Damian Nowak (operating under the trade name DN5F Studio, “we”, “us”, “our”, or the “Data Controller”).

This Policy is formulated in accordance with the Apple App Store Review Guidelines (specifically Guidelines 5.1.1 and 5.1.2 regarding Data Collection and Storage), the European Union General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the United Kingdom General Data Protection Regulation and Data Protection Act 2018 (“UK GDPR”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (Cal. Civ. Code § 1798.100 et seq., “CCPA/CPRA”), the Children’s Online Privacy Protection Act (“COPPA”), and the California Online Privacy Protection Act (“CalOPPA”).

By downloading, installing, accessing, or using NeckAlign, you acknowledge the practices described in this Policy.

2. Data Controller Identity

For the purposes of the GDPR, UK GDPR, and other applicable global data privacy statutes, the Data Controller is:

• Legal Entity Name: DN5F Studio - Damian Nowak (operating as DN5F Studio)
• Website: https://dn5fstudio.com
• Official Privacy & Data Protection Email: contact@dn5fstudio.com

3. Nature and Mechanics of Data Processing

3.1 Real-Time Motion Sensor Telemetry (CoreMotion)

NeckAlign operates by interfacing with Apple’s native CoreMotion framework (specifically the CMHeadphoneMotionManager API) to read spatial orientation metrics (pitch, roll, yaw, and attitude quaternions) emitted by compatible headphone hardware (e.g., Apple AirPods or compatible Beats headphones):

• Transient In-Memory Processing: Motion sensor data is evaluated solely in volatile Random Access Memory (RAM) on your physical device for the singular mathematical purpose of comparing your current head tilt angle against your calibrated baseline posture.
• Immediate Disposal: Sensor measurements are continuously discarded and overwritten each processing cycle. Raw sensor streams are never recorded to persistent storage (such as disk memory), never cached in log files, and never transmitted across any network interface.
• No Biometric Identification: The motion orientation data processed by the Application reflects physical spatial orientation and does not constitute “Biometric Data” or “Biometric Information” under Article 4(14) of the GDPR or California Civil Code § 1798.140(c). The data cannot be used, and is never used, to uniquely authenticate or identify any natural person.
• Operating System Consent: Access to headphone motion metrics is subject to operating system permission controls implemented by Apple. You may grant or withdraw motion tracking authorization at any time through your device settings under Settings > Privacy & Security > Motion & Fitness.

3.2 Local On-Device Storage & Persistence

The Application maintains certain functional configuration data locally within the sandboxed storage partition allocated to NeckAlign by iOS:

• User Configuration: Custom posture sensitivity thresholds, smart alert delay intervals, sound preferences, and calibration baselines.
• Session Records: Aggregated session metrics (e.g., session duration, start/stop timestamps, posture compliance percentages) recorded via Apple’s local persistence frameworks (such as SwiftData and UserDefaults).
• Strict Sandboxing: All persisted parameters reside exclusively within the local application sandbox on your physical device. DN5F Studio maintains no remote servers, no cloud database, and no synchronization endpoints. Your data remains under your absolute and exclusive physical possession.

3.3 Audio Output & Microphone Exclusion

The Application uses standard iOS audio output services (AVAudioSession) exclusively to render gentle alert sounds when your posture exceeds your calibrated threshold. NeckAlign does not request microphone permission, does not record ambient audio, does not process acoustic signals, and does not access the device camera.

3.4 Background Operation & Local Notifications

When an active training session is initiated, NeckAlign utilizes Apple’s standard background audio and local notification protocols to sustain posture monitoring while the Application is minimized or the screen is locked. This operation is self-contained and involves no internet transmission or external telemetry.

4. In-App Purchases and Commercial Transactions

NeckAlign offers an optional, single one-time commercial upgrade (“Unlock Pro”) to remove daily session limits. All financial transactions, billing processing, and entitlement verification are executed through Apple Inc.’s proprietary StoreKit framework:

• Apple as Independent Controller: Apple Inc. acts as an independent data controller for all payment transactions. All payment instruments (credit cards, billing addresses, Apple ID credentials) are handled exclusively by Apple pursuant to the Apple Privacy Policy.
• No Developer Financial Access: DN5F Studio never receives, views, processes, or stores your credit card numbers, banking details, or billing addresses.
• Cryptographic Receipt Validation: The Application validates purchase status on-device via cryptographically signed StoreKit transaction receipts generated by iOS.

5. Absolute Prohibition of Third-Party Tracking & Analytics

In adherence to the highest standards of data minimization and privacy by design (GDPR Article 25):

• No Third-Party SDKs: NeckAlign contains zero third-party software development kits (SDKs), including analytics libraries, diagnostic crash trackers, or advertising frameworks.
• No App Tracking Transparency (ATT) Tracking: The Application does not collect or track user data across third-party apps or websites, and does not request or access the Identifier for Advertisers (IDFA).
• No Cookies or Fingerprinting: Neither the Application nor this static documentation website employs tracking cookies, browser fingerprinting, pixel tags, or behavioral analytics tools.

6. Statutory Disclosures Under Global Privacy Frameworks

6.1 European Union & United Kingdom (GDPR / UK GDPR)

• Legal Basis for Processing (Article 6): To the extent that local on-device processing constitutes “processing” under the GDPR, such processing is conducted pursuant to Article 6(1)(b) (necessity for the performance of a contract / delivery of requested app functionality) and Article 6(1)(a) (explicit consent granted via iOS system permission dialogs for Motion & Fitness and Notifications).
• Special Category Data (Article 9): NeckAlign does not process any special categories of personal data (such as genetic, biometric, or health diagnosis data). Headphone tilt angles serve exclusively as utility feedback and do not constitute health or medical records.
• Data Subject Rights (Articles 15–22): You maintain the legal right to access, rectify, restrict, or erase your data. Because all data is stored exclusively on your physical device, you exercise full unilateral control over your data. Deleting the Application immediately and permanently purges all local databases, session history, and preferences.
• Right to Lodge a Complaint: You have the right to lodge a complaint with an authorized Data Protection Authority (DPA) in your EU member state or the Information Commissioner’s Office (ICO) in the United Kingdom.

6.2 California Consumer Privacy Act & CPRA Disclosures

Under the California Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act (CPRA):

• Categories of Personal Information Collected: In the preceding 12 months, DN5F Studio has not collected any categories of personal information enumerated under Cal. Civ. Code § 1798.140(v) from users of the Application.
• Sale or Sharing of Personal Information: DN5F Studio has never sold, rented, leased, or shared personal information of consumers to third parties for monetary or other valuable consideration, nor for cross-context behavioral advertising, and will not do so.
• Non-Discrimination: We will not discriminate against any consumer for exercising any of their statutory rights under the CCPA/CPRA.

6.3 Children’s Online Privacy Protection Act (COPPA)

NeckAlign complies strictly with the Children’s Online Privacy Protection Act (“COPPA”) and equivalent international legislation. The Application does not knowingly collect, request, or maintain personal information from individuals under the age of 13 (or under 16 within the European Economic Area). If you are a parent or legal guardian and believe your child has provided personal information to us, please contact us immediately, and we will take prompt remedial action.

7. Data Security and Technical Safeguards

Because the Application is designed with a zero-transmission architecture, your data is inherently protected from transmission-level vulnerabilities, remote server breaches, and cloud database compromises. Local data is protected by the hardware-level encryption and sandboxing mechanisms provided natively by Apple iOS and the Apple Secure Enclave.

8. Data Retention and Erasure Protocol

DN5F Studio retains no personal data on external servers. Local application data (configuration preferences and historical posture session metrics) is retained on your device solely until you choose to remove it. You may permanently erase all data at any time by deleting the NeckAlign application from your iOS device (via Settings > General > iPhone Storage > NeckAlign > Delete App or directly from the Home Screen).

9. International Cross-Border Data Transfers

Because NeckAlign operates strictly offline on your physical hardware and maintains no communication channels with external servers, no cross-border transfers of personal data occur.

10. Modifications and Amendments

DN5F Studio reserves the right to amend, update, or revise this Privacy Policy periodically to reflect technological improvements, statutory updates, or modifications to Application features. Any revisions will be published directly at https://dn5fstudio.com/neckalign/privacy-policy with a revised “Effective Date.” Continued use of the Application following the publication of any modifications constitutes your acknowledgment of the updated terms.

11. Contact Information & Legal Inquiries

For questions, formal legal inquiries, regulatory communications, or requests regarding this Privacy Policy, please contact the Data Controller directly: