Privacy Policy

Effective Date: April 4, 2026  |  Last Updated: April 4, 2026

This Privacy Policy ("Policy") describes how Euler Soft, operated by Halis Bilal Kara ("Euler Soft," "we," "us," or "our"), collects, uses, discloses, and protects information in connection with our iOS mobile applications (collectively, the "Apps") and our website located at the domain where this Policy is hosted (the "Site"). By downloading, installing, or using any of our Apps, or by accessing our Site, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

The Apps covered by this Policy are: Blood Sugar Tracker – Glucose; Plant Identifier & Water Diary; Insect Identifier: Bug & Bite; Antique: Identify & Value; Baseball Card Value Scanner; Blood Pressure: Diary & Log; Card Centering Calculator; Intermittent Fasting Tracker; Class Planner & AI Math Solver; Pitch Counter – Radar Gun; and Birth Control Reminder – Pill.

1. Data Controller & Contact Information

1.1 Identity of the Data Controller

The data controller responsible for the processing of personal data under this Policy is:

Halis Bilal Kara / Euler Soft
Republic of Turkey
Email: eulersoft@outlook.com

1.2 Contact for Privacy Inquiries

For all privacy-related requests, questions, complaints, or the exercise of data subject rights, please contact us at eulersoft@outlook.com. We will respond within thirty (30) days of receiving a verifiable request, or within any shorter timeframe required by applicable law.

2. Scope and Applicability

2.1 Apps and Services Covered

This Policy applies to all current and future iOS applications published under the "Euler Soft" developer name on the Apple App Store, as well as the Euler Soft website.

2.2 Third-Party Links

Our Apps and Site may contain links to third-party websites or services. This Policy does not apply to those third-party properties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party service you visit.

3. Information We Collect

3.1 Information You Provide Directly (On-Device Only)

Certain Apps invite you to enter personal health, fitness, or lifestyle data. All such data you enter is stored exclusively on your device using Apple's local storage mechanisms (Core Data / UserDefaults) and is never transmitted to Euler Soft servers. Examples include:

• Blood glucose readings, timestamps, and meal notes (Blood Sugar Tracker)
• Blood pressure and pulse measurements (Blood Pressure: Diary & Log)
• Fasting windows, eating windows, and body weight entries (Intermittent Fasting Tracker)
• Medication schedules and reminder times (Birth Control Reminder – Pill)
• Plant watering schedules and care notes (Plant Identifier & Water Diary)
• Class schedules, assignments, and math problems (Class Planner & AI Math Solver)
• Pitch counts, velocity estimates, and game notes (Pitch Counter – Radar Gun)

3.2 Camera and Photo Library Access

Apps that offer AI-powered identification (Plant Identifier & Water Diary; Insect Identifier: Bug & Bite; Antique: Identify & Value; Baseball Card Value Scanner) may request access to your device camera or photo library to capture or select an image for analysis. Image processing is performed entirely on your device using Apple's CoreML and Vision frameworks. Image data is not transmitted to external servers. Captured images are not stored by the App beyond the session unless you explicitly save an identification result.

3.3 Advertising Data (Google AdMob)

Apps that display advertisements use Google AdMob, a third-party advertising service provided by Google LLC. AdMob may automatically collect the following categories of data when you view or interact with an advertisement:

• Device Identifiers: Apple's Identifier for Advertisers (IDFA), if you have granted tracking consent via the App Tracking Transparency (ATT) prompt; or a non-personalized identifier if consent has not been granted.
• Device and Network Information: Device model, operating system version, IP address (coarse location derived), mobile carrier, and Wi-Fi network name.
• Ad Interaction Data: Impressions, clicks, view duration, and ad unit identifiers.
• Approximate Location: Derived from IP address only; precise GPS location is not collected for advertising.

Where required by applicable law (including the EU Digital Markets Act, GDPR, and Apple's ATT framework), we request your explicit consent before enabling personalized advertising. If consent is denied or not granted, only non-personalized advertisements will be shown and IDFA will not be accessed. You may change your advertising preferences at any time in your device Settings under Privacy & Security > Tracking, or by adjusting Limit Ad Tracking options. Google's privacy practices are governed by the Google Privacy Policy . For AdMob-specific data practices, see How Google uses data when you use our partners' sites or apps .

3.4 Subscription and Purchase Data (RevenueCat)

For Apps offering auto-renewable subscriptions or one-time in-app purchases, we use RevenueCat, Inc. ("RevenueCat") as our subscription management platform. RevenueCat processes the following data on our behalf:

• Transaction Data: Apple App Store receipt tokens, purchase dates, subscription status, and entitlement identifiers. Payment card details are processed exclusively by Apple and are never accessible to Euler Soft or RevenueCat.
• Anonymous App User ID: A randomly generated, non-personally-identifying string used to associate purchase records with your device installation.
• App Version and Platform: To manage entitlement delivery and compatibility.

RevenueCat's data practices are governed by the RevenueCat Privacy Policy . RevenueCat acts as a data processor on our behalf under a Data Processing Agreement consistent with GDPR requirements.

3.5 Apple HealthKit Integration

Certain Apps (Blood Sugar Tracker – Glucose; Blood Pressure: Diary & Log; Intermittent Fasting Tracker) may, with your explicit consent, read from or write to Apple HealthKit. HealthKit data is governed by Apple's HealthKit framework restrictions:

• HealthKit data will never be used for advertising or shared with advertisers.
• HealthKit data will never be disclosed to third parties without your express consent.
• HealthKit data is processed exclusively on your device and is not transmitted to our servers.
• You may revoke HealthKit access at any time in iOS Settings > Privacy & Security > Health.

3.6 AI and Machine Learning Features (On-Device Only)

Apps offering identification or analysis features (plant identification, insect identification, antique identification, baseball card scanning, math problem solving) use Apple's CoreML and Vision frameworks for on-device inference. Specifically:

• All ML model inference is performed locally on your device.
• No image data, text data, or model inputs are transmitted to external servers.
• No ML-derived outputs (identification results, analysis) are transmitted to external servers.
• Pre-trained model weights are bundled with the App and updated only through App Store updates, not through runtime data collection.

3.7 Anonymous Analytics and Crash Reporting

We may collect anonymized, aggregated usage analytics and crash reports through Apple's built-in frameworks (App Store Connect analytics, TestFlight crash logs) to improve App stability and performance. This data is aggregated and cannot be used to identify you personally.

3.8 Website Cookies and Tracking Technologies

Our website uses only technically necessary cookies and does not deploy third-party analytics cookies or advertising trackers. Specifically:

• Essential Cookies: Session cookies required for site navigation. These expire when you close your browser.
• No Analytics Cookies: We do not deploy Google Analytics, Facebook Pixel, or equivalent third-party tracking scripts on our website.
• No Advertising Cookies: No cross-site advertising cookies are set by our website.

You may configure your browser to refuse all cookies or to alert you when cookies are being sent. Disabling cookies will not impair your ability to access our website content.

4. How We Use Information

4.1 Lawful Bases for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, our processing of personal data is based on the following lawful grounds under GDPR Article 6:

• Consent (Art. 6(1)(a)): Personalized advertising via AdMob (where ATT consent is granted); HealthKit read/write access.
• Contract Performance (Art. 6(1)(b)): Processing purchase receipt tokens via RevenueCat to deliver purchased subscription entitlements.
• Legitimate Interest (Art. 6(1)(f)): Anonymized crash reporting and App stability analytics to maintain and improve our services, where such interests are not overridden by your data protection rights.

For special categories of personal data (health data processed via HealthKit under GDPR Article 9), we rely exclusively on your explicit consent (Art. 9(2)(a)).

4.2 Specific Purposes

We use the information collected for the following purposes:

• To provide and operate App features and functionality
• To deliver and manage in-app purchases and subscription entitlements
• To display advertisements (personalized where consent is granted; otherwise non-personalized)
• To diagnose crashes and technical errors
• To comply with legal obligations
• To respond to your privacy requests and inquiries

5. Information Sharing and Disclosure

5.1 No Sale of Personal Data

We do not sell, rent, trade, or otherwise transfer your personal data to third parties for monetary or other valuable consideration. This applies under all applicable laws, including the California Consumer Privacy Act (CCPA/CPRA) definition of "sale" and "sharing."

5.2 Service Providers (Data Processors)

We share limited data with the following third-party service providers solely to the extent necessary to operate our Apps:

• Google LLC (AdMob): Advertising delivery and measurement. Data transferred to the United States. Google is certified under the EU-U.S. Data Privacy Framework.
• RevenueCat, Inc.: Subscription management and entitlement tracking. Data transferred to the United States under a Data Processing Agreement with Standard Contractual Clauses.
• Apple Inc. (App Store / StoreKit): Payment processing for in-app purchases. Apple's privacy practices govern payment data.

5.3 Legal Obligations

We may disclose information if required to do so by law or in good-faith belief that such disclosure is reasonably necessary to: (a) comply with a legal obligation, court order, or governmental request; (b) enforce our Terms of Use; (c) protect the rights, property, or safety of Euler Soft, our users, or the public; or (d) detect, prevent, or address fraud, security, or technical issues.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, personal data may be transferred to the acquiring entity. We will provide notice before personal data is transferred and becomes subject to a different privacy policy.

6. International Data Transfers

6.1 Cross-Border Transfers

Euler Soft is based in the Republic of Turkey. By using our Apps, your data may be transferred to and processed in countries other than your country of residence, including the United States, where our service providers (Google, RevenueCat) operate. These countries may have data protection laws that differ from those in your jurisdiction.

6.2 Transfer Safeguards

For transfers of personal data from the EEA, United Kingdom, or Switzerland to third countries, we rely on the following mechanisms:

• EU-U.S. Data Privacy Framework (DPF): Google LLC is certified under the DPF.
• Standard Contractual Clauses (SCCs): Incorporated into our Data Processing Agreement with RevenueCat.
• Apple's Data Processing Addendum: Governs transfers related to StoreKit and App Store Connect.

For transfers of personal data from Turkey, we comply with the cross-border transfer provisions of the Turkish Personal Data Protection Law No. 6698 (KVKK), relying on adequacy decisions or explicit data subject consent where required.

7. Data Retention

7.1 On-Device Data

Health records, measurements, logs, and other data you enter into our Apps are retained on your device indefinitely until you: (a) delete individual records within the App; (b) uninstall the App; or (c) erase your device. We have no ability to access or delete data stored exclusively on your device.

7.2 RevenueCat Subscription Records

Purchase receipt tokens and subscription status records are retained by RevenueCat for the period necessary to manage your entitlements and comply with legal obligations, typically not exceeding seven (7) years from the date of the last transaction, in accordance with applicable tax and commercial record-keeping requirements.

7.3 Advertising Data (AdMob)

Advertising identifiers and ad interaction data are retained by Google in accordance with Google's data retention policies. Refer to Google's Privacy Policy for applicable retention periods.

7.4 Correspondence

Emails and support messages sent to eulersoft@outlook.com are retained for a period of three (3) years from the date of last correspondence, after which they are deleted.

8. Data Security

8.1 Security Measures

We implement commercially reasonable technical and organizational measures to protect the data processed in connection with our Apps, including reliance on Apple's iOS security architecture (hardware-based data protection, sandboxing, and Keychain encryption) for on-device data storage.

8.2 No Absolute Security Guarantee

No method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach affecting data under our control, we will notify affected users and competent supervisory authorities as required by applicable law.

9. Children's Privacy (COPPA)

9.1 Age Restriction

Our Apps are not directed to children under the age of 13 (or 16 in EEA jurisdictions where a higher age of digital consent applies). We do not knowingly collect personal information from children below the applicable age threshold.

9.2 Parental Notice

If you are a parent or guardian and believe that a child under the applicable age threshold has provided personal information through our Apps, please contact us at eulersoft@outlook.com. Upon verification, we will take prompt steps to delete such information and, to the extent possible, prevent the collection of further information from that child.

9.3 COPPA Compliance

We do not knowingly present behavioral advertising to children under 13. If we discover that a user is under 13 and has been shown personalized advertisements, we will promptly disable personalized advertising for that user.

10. Your Privacy Rights

10.1 Rights Under GDPR (EEA / UK / Switzerland)

If you are located in the EEA, United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation and applicable national legislation:

• Right of Access (Art. 15): Request a copy of personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
• Right to Erasure (Art. 17): Request deletion of your personal data where there is no compelling reason for its continued processing.
• Right to Restriction of Processing (Art. 18): Request that we restrict processing of your data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interests, including for direct marketing.
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: Lodge a complaint with your local data protection supervisory authority (e.g., your national DPA). A list of EEA supervisory authorities is available at edpb.europa.eu.

10.2 Rights Under CCPA/CPRA (California)

If you are a California resident, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act:

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you, the sources of collection, the business purpose for collection, and the categories of third parties with whom it is shared.
• Right to Delete: Request deletion of personal information we have collected about you, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information as defined by CCPA/CPRA. No opt-out mechanism is required, but you may contact us to confirm.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond the purposes authorized by CCPA/CPRA.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To submit a verifiable consumer request, contact us at eulersoft@outlook.com. We will respond within forty-five (45) days of receiving a verifiable request, with one permissible extension of an additional forty-five (45) days.

10.3 Rights Under LGPD (Brazil)

If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados Pessoais (LGPD) including the right to: confirmation of the existence of processing; access to data; correction of incomplete, inaccurate, or outdated data; anonymization, blocking, or deletion of unnecessary or excessive data; portability; deletion of data processed with consent; information about third parties with whom data is shared; the right to refuse consent and the consequences of such refusal; and revocation of consent. Requests may be submitted to eulersoft@outlook.com.

10.4 Rights Under DPDP (India)

If you are located in India, you have rights under the Digital Personal Data Protection Act, 2023 (DPDP Act) including the right to: access information about personal data processed; correction and erasure of personal data; grievance redressal; and nomination of another individual to exercise rights on your behalf in the event of death or incapacity. Requests may be submitted to eulersoft@outlook.com. We will respond within thirty (30) days.

10.5 Rights Under KVKK (Turkey)

If you are located in Turkey, you have rights under the Kişisel Verilerin Korunması Kanunu (KVKK, Law No. 6698) including the right to: learn whether your personal data is being processed; request information about the processing; learn the purpose and whether data is used appropriately; know the third parties to whom data is transferred domestically or abroad; request correction if data is incomplete or inaccurate; request deletion or destruction where the reasons for processing cease to exist; object to automated processing that results in a decision against your interests; and seek compensation for damages resulting from unlawful processing. To exercise your rights, submit a written request to eulersoft@outlook.com. We will respond within thirty (30) days.

10.6 How to Exercise Your Rights

To exercise any of the rights described in this Section 10, or to submit an inquiry:

• Email us at eulersoft@outlook.com with "Privacy Request" in the subject line.
• Identify the right you wish to exercise and the App(s) involved.
• Provide sufficient information to allow us to verify your identity and locate any relevant data.

We will not charge a fee for processing verifiable requests unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable administrative fee or decline to act.

11. App Tracking Transparency (ATT)

11.1 ATT Prompt

On iOS 14.5 and later, Apps that access the IDFA for personalized advertising present Apple's App Tracking Transparency (ATT) prompt requesting your permission to track your activity across other companies' apps and websites. If you deny tracking permission, we will not access your IDFA and will configure AdMob to serve non-personalized advertisements only.

11.2 Changing ATT Settings

You may change your ATT decision at any time by navigating to iOS Settings > Privacy & Security > Tracking.

12. Limitation of Liability for Privacy Breaches

12.1 On-Device Data

Because personal health, lifestyle, and tracking data entered into our Apps is stored exclusively on your device and is never transmitted to our servers, Euler Soft has no ability to access, disclose, or breach such data. You bear sole responsibility for the physical and software security of your device.

12.2 Third-Party Service Providers

Euler Soft is not liable for any privacy breach, data loss, or unauthorized disclosure attributable to the independent acts or omissions of third-party service providers (Google AdMob, RevenueCat, Apple) or any event beyond our reasonable control. To the fullest extent permitted by applicable law, our aggregate liability for any claim arising under this Policy is limited to the greater of (a) the total amount paid by you for the App giving rise to the claim in the twelve (12) months preceding the claim, or (b) ten United States Dollars (USD $10.00).

13. Changes to This Privacy Policy

13.1 Notification of Changes

We may revise this Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where feasible, provide in-App notification or App Store update notes summarizing the changes.

13.2 Continued Use

Your continued use of our Apps after any revision to this Policy constitutes your acceptance of the revised terms. If you do not agree to the revised Policy, you must discontinue use of the Apps.

14. Contact Us

For privacy inquiries, data subject rights requests, or any questions regarding this Privacy Policy, please contact:

Euler Soft — Privacy Team
Email: eulersoft@outlook.com
Response time: Within 30 days of receipt of a verifiable request.