Privacy Policy

1. Who we are

Count'n Pick (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 and iPad and this website (countnpick.web.app). It explains what information is involved when you use them, who processes it, why, and what rights you have.

The App keeps score with counters and makes draws: picking names, splitting teams, drawing an order or numbers. It was designed so that what you type into it never reaches us.

3. Data stored on your device

The App stores the following information on your device, inside the App's private storage:

• Counters: their names, counts, how much each tap adds, colour and order.
• Lists: list names and the names or entries you add to them, typed or pasted.
• Draws: results you choose to save, and, for No repeats and Who's in, who has already been picked from a list and who is sitting out today. With Count'n Pick Plus, who has been picked is kept after you close the App; in the free version it is kept only while the App is open.
• Preferences: for example whether you have seen the introductory tour.
• Purchase status: whether you own Count'n Pick Plus, cached in your device's Keychain.

Lists often contain other people's names, for example your students or the entrants to a giveaway. That information stays on your device and in your iCloud (section 4.1). We do not receive it and do not process it. Please use it only in ways the people concerned would reasonably expect.

We do not operate a server that receives this information. Because it never reaches us, we cannot view, recover, correct or export it on your behalf. You control it directly in the App: you can edit or delete any counter, list or saved draw. Deleting the App removes the data stored on that device. Your data may also be included in your own device backups under Apple's terms.

Paste and share. The App reads your clipboard only when you tap the Paste button to add names. When you tap Share, the App creates an image of the result and hands it to the iOS share sheet; where it goes is your choice, and we do not receive it.

4. Data processed by Apple

4.1 iCloud sync

If you are signed in to iCloud on your device and iCloud is turned on for the App, your counters, lists and saved draws are synced between your devices through Apple's CloudKit, in the private database of your own iCloud account. This data is stored and processed by Apple under the Apple Media Services Terms and Apple's Privacy Policy, and is protected by your Apple Account. We cannot access your private iCloud database. To support sync, iOS may receive silent push notifications from Apple when your data changes on another device; these show nothing on screen.

You can turn iCloud off for the App in iOS Settings → [your name] → iCloud. The data then stays only on the device.

4.2 Purchases: Apple App Store

If you buy Count'n Pick Plus, the purchase is handled entirely by Apple under its own terms and privacy policy. We never receive your name, Apple Account, 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. Apple provides us with aggregated, non-identifying sales and usage reports through App Store Connect.

5. Promos in the free version

The free version shows small promos for other apps by the same developer, and lets you watch a short promo to unlock a larger draw or backups once. These promos are built into the App and chosen on your device. The App contains no third-party advertising SDK and no analytics SDK, does not use the advertising identifier (IDFA), does not ask for tracking permission, and does not send any information about you or your use of the promos to us or to anyone else. Tapping a promo opens that app's page on the App Store. Count'n Pick Plus removes the promos.

6. When you contact us

If you write to us, for example with Contact us in the App's Settings, we receive your email address, your message and anything you attach. The email the App prepares has a subject line with the App's name, version and build number, so we can tell which version you are using. You can change it before you press Send. We use this information only to answer you.

7. Purposes and legal bases

Your counters, lists and draws are not on this list because we do not process them: they stay on your device and in your iCloud. We do not make decisions about you based solely on automated processing.

8. What we never do

• We never sell your personal data.
• We never track you across other companies' apps or websites.
• We never read your lists, counters or draws.
• We never ask for access to your contacts, photos, location, camera, microphone or Apple Health.

9. International transfers

Apple may store and process iCloud and App Store data in the United States and other countries outside the European Economic Area, under its own safeguards, including the EU-U.S. Data Privacy Framework and the European Commission's Standard Contractual Clauses. Google, which hosts this website (section 14), relies on the same mechanisms.

10. How long data is kept

• Data on your device and in your iCloud: until you delete it, delete the App, or delete it from iCloud. Who is sitting out resets every day.
• 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.
• Website logs: for the short period Google keeps hosting logs.

11. 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).

Because your App data stays on your device and in your iCloud, you can exercise most of these rights directly in the App or in iOS Settings. For anything we hold (mainly support correspondence), write to support@copycut.it. 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.

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.

12. Children

The App is used at home, at game nights and in classrooms, including by children. It has no account, no analytics and no third-party ads, and it does not collect personal data from anyone who uses it. The only personal data we can receive is an email someone chooses to send us. If you are under 14, 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), please ask a parent or guardian before writing to us. If we learn that we have received a message from a child without that consent, we will delete it. Purchases are made through Apple, where parents can use Ask to Buy and Screen Time.

13. Security

The App keeps your data in iOS's sandboxed storage, which iOS encrypts when your device is locked with a passcode, and purchase status in the iOS Keychain. iCloud data is protected by your Apple Account; turning on Advanced Data Protection in iOS adds end-to-end encryption for many iCloud data categories. Because we do not collect your App data, it cannot be exposed through a breach of our systems. If a personal-data breach affecting data we control occurs, we will notify the supervisory authority and you where the GDPR requires it.

14. This website

This website is a set of static pages hosted on Google Firebase Hosting (Google Ireland Limited). It uses no cookies, no analytics, no advertising and no third-party fonts or scripts, and the draw you can try on the home page runs entirely in your browser. To deliver the pages and protect them 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.

15. Information for US residents

We do not sell or share personal information for cross-context behavioural advertising, and we do not use or disclose sensitive personal information. 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.

16. 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.

17. Contact