Privacy Policy - Ninety: 90 Day Challenge Tracker

Last updated: May 4, 2026

1. Introduction

EasyTech Agency ("we," "our," or "us") operates the Ninety: 90 Day Challenge Tracker mobile application (the "Service" or "App"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service.

Ninety is built on a privacy-first principle: all of your program data — including your daily disciplines, completion history, progress photos, journal entries, and streak record — stays on your device. We do not run servers that store your personal data.

2. Data We Collect

2.1 Locally Stored Data (never leaves your device)

The following data is stored on your device only and is not transmitted to any server:

• Onboarding answers (goals, fitness level, schedule, blockers, why-now reason)
• Your selected pillars (areas of focus) and daily disciplines
• Your 90-day program: daily plans, task completion records, day-fully-completed timestamps
• Streak record (current streak, longest streak, total resets)
• Progress photos and workout-evidence photos
• Journal entries (gratitude, reflections, MIT lists, appreciation messages)
• Notification preferences
• App settings and customization preferences

Photos are stored in the App's sandbox storage on your device. They are never uploaded to our servers and are not visible to other apps. You may explicitly export individual photos to your iOS Photos library at your discretion (in which case Apple's standard Photos handling applies).

2.2 Camera Access

The App requests camera permission to capture progress photos and workout-evidence photos. Camera access is used only when you explicitly invoke a photo task. We never record without your action, and we do not access your microphone.

2.3 Notifications

All reminders are scheduled and delivered locally by your device using Apple's local-notification system. We do not operate any push- notification servers and we do not store your notification preferences off-device.

3. Subscriptions and Payments

In-app purchases and subscriptions are managed by RevenueCat, a third-party service. RevenueCat may collect:

• An anonymous identifier to manage your subscription
• Your in-app purchase history
• No payment information (handled directly by Apple)

For more information, see the RevenueCat Privacy Policy.

4. Analytics

We use PostHog to collect anonymized usage analytics to improve the App. We capture only essential funnel events such as:

• Onboarding step completion and overall completion
• Pillars and disciplines selected (counts and ids, not personal context)
• Paywall views, purchases, dismissals, and trial-expiry lockouts
• Program-day completion and milestone reaches
• Soft-reset offers and the option chosen
• Streak-card share events

Analytics events are anonymous, are not linked to your identity, and cannot be used to identify you individually. For more information, see the PostHog Privacy Policy.

5. Advertising Attribution (App Tracking Transparency)

Ninety uses the TikTok Business SDK to measure which advertising channels help people discover the App. This is a tracking SDK as defined by Apple, and it is governed by Apple's App Tracking Transparency framework.

• On first launch, the App will ask you for permission to track. You may deny this prompt at any time, in which case no device identifier is shared with TikTok and ad-attribution events are not sent.
• If you allow tracking, an Apple-issued advertising identifier may be shared with TikTok along with conversion events such as registration completion and subscription start.
• You can change your decision at any time in iOS Settings → Privacy & Security → Tracking → Ninety.

For more information, see the TikTok Privacy Policy.

6. Data Sharing

We do not sell, trade, or transfer your personal information to third parties, except in the following cases:

• With your explicit consent
• To comply with a legal obligation
• To protect our rights or your safety
• With service providers who assist in operating the App (RevenueCat, PostHog, TikTok Business SDK) — under strict data processing agreements and limited to the categories above

7. Data Security

We take data security seriously. Your program data, photos, and journal entries are stored locally on your device and are protected by your device's built-in security features. Subscription data is secured by Apple and RevenueCat.

8. Your Rights

You have the right to:

• Access your personal data — all of it is on your device
• Delete your data by uninstalling the App (this removes everything)
• Withdraw your tracking consent at any time in iOS Settings
• Object to data processing
• Lodge a complaint with a supervisory authority (CNIL in France)

9. Children's Privacy

The App is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe we have collected data from a child under 13, please contact us immediately.

10. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. Changes will take effect upon publication. We encourage you to review this page periodically.

11. Contact

If you have any questions about this Privacy Policy, contact us at:
contact@easytech-agency.net