1. Who we are
The Pill (the “App”) is developed and published by Federica Benacquista, an individual developer, Via del Lido 106, 04100 Latina (LT), Italy (“we”, “us”). For any personal data we decide how to use, we are the data controller under Regulation (EU) 2016/679 (the “GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
Contact for every privacy matter: support@copycut.it. We have not appointed a Data Protection Officer because we are not legally required to.
2. Scope
This policy covers the App for iPhone, including its widgets and Live Activities, and this website (thepill.web.app). It explains what information is involved when you use them, who processes it, why, and what rights you have.
The App helps you remember to take a contraceptive pill and keep track of your pack, supply and period. Information about your pill routine and periods is health data, a “special category” under Article 9 GDPR. We designed the App so that this data never reaches us.
3. Data stored only on your device
The App stores the following information locally on your iPhone, inside the App’s private storage and in a shared container (an “App Group”) that only The Pill’s own widgets and Live Activities can read:
- Your routine: your usual pill time, time zone, pack type (active, inactive and break days), pills per blister and lateness window.
- Your dose history: when each pill was scheduled, when you marked it taken, and any edits, missed pills, late pills or pauses (including any reason you type).
- Your pill details: the pill name or nickname you choose, start and end dates and any notes.
- Your supply: pills, blisters and boxes remaining, and your low-stock threshold.
- Period information (optional): start and end dates, flow, “unusual bleeding” flags, notes, and cycle length if you enter it.
- Preferences: the name the App uses to greet you, reminder style (direct or discreet), any custom reminder text, widget settings and appearance.
- Purchase status: whether you own The Pill Pro, cached in your iPhone’s Keychain. This contains no health data.
We do not operate a server that receives this information. It is not sent to us, to advertisers or to analytics providers. Because it never reaches us, we cannot view, recover, correct or export it on your behalf. You control it directly in the App.
Reminders, widgets and the Lock Screen
Reminders are local notifications scheduled by your iPhone. Their content is never sent through any server of ours. Notifications, widgets and Live Activities can appear on your Lock Screen, where people near your phone may see them. If you choose discreet style, pill reminders do not mention a pill (for example, the title “Hey” with “It’s time.”). Supply and new-pack reminders, and widgets not set to discreet mode, may still use words such as “blister” or show your pill name. You can turn off Lock Screen previews in iOS Settings.
Push notification tokens
The App registers with Apple Push Notification service and creates a random installation identifier, keeping both on your device. They are prepared for future Live Activity updates and are not currently sent to us or anyone else. If that changes, we will update this policy before it happens.
4. Data processed by Apple and Google when you use the App
4.1 Advertising: Google AdMob
The free version of the App shows banner and occasional full-screen ads provided by Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and its affiliates, including Google LLC). There are no ads in notifications, widgets or Live Activities, on the main Settings page or on the purchase page.
- Personalised only with your permission. Ads are personalised (chosen using information about your interests) only if you agree in Google’s consent form, where it is shown, and allow tracking in Apple’s prompt. Otherwise the App asks Google for non-personalised ads, which are not selected on the basis of a profile of you. In every case, the App never passes any health data, pill name, schedule or period information to Google.
- What Google may process to deliver ads: your IP address (and an approximate location derived from it), device and operating-system information, the App’s identifier, the identifier for vendors (IDFV), the advertising identifier (IDFA) only if you allow tracking in Apple’s prompt, and information about ads shown and tapped. Google uses this to serve ads, cap how often you see them, measure performance and detect fraud.
- Consent. During setup, users in the European Economic Area, the UK and Switzerland first see a consent form provided by Google (built on the IAB Europe Transparency & Consent Framework), and then Apple’s tracking prompt. The Google Mobile Ads SDK is not started, and no ads from Google are requested, until a consent result allows it. If you decline, Google may still show non-personalised or limited ads that use only the data strictly needed to deliver and protect ads, as described in Google’s policies.
For data Google processes for its own purposes, Google acts as an independent controller. See How Google uses information from apps that use its services and the Google Privacy Policy.
4.2 Usage statistics: Google Analytics for Firebase
The App includes Google Analytics for Firebase (Google Ireland Limited) to understand, in aggregate, how many people use the App and on which devices and system versions. Collection is switched off by default. It is only switched on if you give consent in the consent form and allow tracking in Apple’s prompt. Even then:
- The App records a single event of its own, “app opened”. Firebase adds standard technical events such as first open, session start, engagement time and screens viewed.
- Firebase may process a random app-instance identifier, the IDFV, device model, operating-system version, language, App version and country or region derived from your IP address.
- We do not send any user ID, name, health information, pill details or period details. Advertising storage, ad-user-data and ad-personalisation signals are always set to “denied”.
For this service Google acts as our data processor under the Firebase Data Processing and Security Terms.
4.3 Purchases: Apple App Store
If you buy The Pill Pro, the purchase is handled entirely by Apple under its own terms and privacy policy. We never receive your name, Apple ID, payment card or billing details. The App checks with Apple, on your device, whether your purchase is valid. No receipt is sent to any server of ours.
4.4 When you contact us
If you write to us, for example with “Contact support” in the App, we receive your email address, your message and anything you attach. To help us fix problems, the App’s support email draft includes technical details: App version, iOS version, device model, language, region, time zone, low-power mode, and the name of your active pill and number of blisters left. You can see and remove any of these before you press Send. If you choose to tell us about your health, we use that information only to answer you.
5. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Showing ads that keep the App free | Device and ad data processed by Google (section 4.1) | Your consent (Art. 6(1)(a)) and Art. 122 of the Italian Privacy Code for storing or reading information on your device. Personalised ads require your consent and your permission in Apple’s tracking prompt. Where you decline, Google’s non-personalised/limited ads rely on legitimate interest in funding a free service and preventing fraud (Art. 6(1)(f)). |
| Aggregate usage statistics | Analytics data (section 4.2) | Your consent (Art. 6(1)(a)), which you can withdraw at any time. |
| Providing The Pill Pro | Purchase status on device | Performance of a contract (Art. 6(1)(b)). |
| Answering your messages | Email, message, diagnostics you send | Taking steps at your request / our legitimate interest in supporting users (Art. 6(1)(b) and (f)). Any health details you choose to share: your explicit consent (Art. 9(2)(a)). |
| Complying with the law and defending legal claims | Correspondence where relevant | Legal obligation and legitimate interest (Art. 6(1)(c) and (f); Art. 9(2)(f)). |
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
6. What we never do
- We never sell your personal data.
- We never share health data with advertisers, data brokers, analytics providers or employers.
- We never use health data for advertising or to build a profile of you.
- We never ask for access to your contacts, photos, location, camera, microphone or Apple Health.
7. International transfers
Google may process data in the United States and other countries outside the European Economic Area. Where that happens, transfers rely on the EU-US Data Privacy Framework, under which Google LLC is certified, and on the European Commission’s Standard Contractual Clauses included in Google’s data-processing terms. Apple’s processing is governed by Apple’s own safeguards.
8. How long data is kept
- Data on your device: until you delete it or delete the App.
- Analytics data: event-level data is kept for the retention period set in our Google Analytics settings, and in any case no longer than 14 months, then deleted. Aggregated reports contain no personal data.
- Advertising data: according to Google’s retention policies, which Google describes in its privacy policy.
- Support emails: up to 24 months after the conversation ends, unless we must keep them longer to meet a legal obligation or defend a legal claim.
9. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you and receive a copy (Art. 15);
- rectify inaccurate data (Art. 16);
- erase your data (Art. 17);
- restrict processing (Art. 18);
- data portability (Art. 20);
- object to processing based on legitimate interest (Art. 21);
- withdraw consent at any time, without affecting processing carried out before you withdrew it (Art. 7(3)).
Because your App data stays on your device, you can exercise most of these rights directly in the App or by deleting it. For anything we hold (mainly support correspondence), write to support@copycut.it or use the ready-made requests on our Support page. We will reply within one month, extendable by two further months for complex requests as allowed by Art. 12(3) GDPR. We may ask for information to confirm it is really you. For data Google processes as an independent controller, you can also contact Google directly.
You have the right to lodge a complaint with a supervisory authority, in particular in the EU country where you live or work. In Italy this is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it. We would appreciate the chance to address your concern first.
10. Your choices and controls
- Consent: review or change your ads and analytics choices in the App under Settings → Manage Consent.
- Tracking: allow or deny tracking for The Pill at any time in iOS Settings → Privacy & Security → Tracking. If tracking is denied, the advertising identifier is not shared and usage statistics stay off.
- Notifications: manage them in iOS Settings → Notifications → The Pill, including whether previews appear on the Lock Screen.
- Discreet mode: choose discreet reminders and discreet widgets in the App.
- No ads: buying The Pill Pro removes ads.
11. Young people
The App is intended for people aged 14 and over, the age at which a person can consent to online services on their own under Italian law (Art. 2-quinquies of the Italian Privacy Code). Where the law of your country sets a higher age, that age applies. If you are younger, please use the App only with the involvement of a parent or guardian, who can give or refuse consent to ads and analytics on your behalf. We do not knowingly collect personal data from children. If you believe a child has contacted us, write to us and we will delete the correspondence.
12. Security
The App keeps your data in iOS’s sandboxed storage, which iOS encrypts when your iPhone is locked with a passcode. Purchase status is stored in the iOS Keychain. Because we do not collect your health data, it cannot be exposed through a breach of our systems. You protect it best by using a device passcode and keeping iOS up to date. If a personal-data breach affecting data we control occurs, we will notify the supervisory authority and you where the GDPR requires it.
13. This website
This website is a static page hosted on Google Firebase Hosting. It uses no cookies, no analytics, no advertising and no third-party fonts or scripts. To deliver the page and protect it from abuse, Google’s servers necessarily process your IP address and standard request information (browser type, time and page requested) in short-lived technical logs, as our processor. The legal basis is our legitimate interest in running a secure website (Art. 6(1)(f)).
14. Information for US residents
We do not sell personal information. Ads in the App are personalised only if you allow tracking in Apple’s prompt (and consent where Google’s form is shown); if you do, Google may use your advertising identifier for cross-context behavioural advertising, which some state laws call “sharing”. You can opt out at any time by turning off tracking for The Pill in iOS Settings → Privacy & Security → Tracking, or in Settings → Manage Consent in the App. Health information is never shared. We do not use or disclose sensitive personal information, including health information, for purposes other than providing the App. Where state law gives you rights to know, delete or correct personal information, or to appeal a decision, you can exercise them by writing to us. We will not discriminate against you for doing so. Consumer health data, as defined by laws such as Washington’s My Health My Data Act, stays on your device and is not collected, shared or sold by us.
15. Changes to this policy
We may update this policy when the App or the law changes. We will change the “Last updated” date above. For significant changes, for example a new way of processing data, we will also tell you in the App before the change takes effect and, where required, ask for your consent again.
16. Contact
Federica Benacquista
Via del Lido 106
04100 Latina (LT), Italy
Email: support@copycut.it