Privacy policy

1. Data controller

Chaltra is built and run by Kevin Pugliese, a sole proprietor based in the province of Quebec, Canada. In this policy, "we", "us" and "our" mean Kevin Pugliese, and "you" means the person using Chaltra.

Kevin Pugliese is the person responsible for protecting the personal information Chaltra holds. Quebec's Law 25 asks us to name that person, so here it is in writing.

You can reach us at hello@chaltra.com. There is no separate privacy department, because the business is one person. Your message goes straight to the person who can act on it.

2. Introduction

Chaltra is a challenge tracker. You pick a goal, log progress against it, and a picture fills toward the target. When the picture is full, the challenge is done. You can export that picture and share it.

Chaltra is an iPhone app. There is no Android app, and there is no web app you can sign in to. The website at chaltra.com is a marketing site, a blog, and these legal pages.

By using Chaltra you agree to this policy. If you do not agree with it, please do not use Chaltra.

This policy sits alongside our terms of service. The terms cover what you may do with Chaltra; this policy covers what we do with your data.

3. Information we collect

We collect as little as we can get away with. Here is the whole list.

• Account details. If you create an account, we store the account identifier your sign-in provider gives us, the email address attached to it, and the name it shares with us, if any. If you sign in with Apple and choose to hide your email, we only ever see Apple's relay address. If you sign in with Google and your Google account has a profile picture, we store its web address, but Chaltra never shows it or publishes it.
• A username. It is your public handle. One is made for you when you create an account, from the name you typed when you first opened the app, the name your sign-in provider gave us, or the start of your email address. You can change it in Settings.
• What you tell us when you first open the app. Chaltra asks four short questions: what to call you, where you heard about us, your age range, and your gender. Three of the four can be skipped, and skipping stores nothing at all. Your name is used to greet you inside the app, and if you create an account, to suggest your first username (Léa becomes @lea). You can change that username at any time, and it only appears on a public page if you publish one. The other three tell us which kinds of people Chaltra reaches and which of them stay, which is how we decide where to advertise. Your answers are saved on our servers, tied to a random install id, even if you never create an account. Deleting the app does not erase them. Deleting your account erases the name and detaches the rest from you, and without an account you can email us to have them erased.
• Challenge data. The title, description, target, unit, start and end dates, chosen picture, colours, data source names, reminder settings, and the progress values you log on each date. This is the app, so this is most of what we hold.
• Subscription status. Whether a subscription is active, when it renews, and whether there is a billing problem. We never see your card number.
• Usage events. A fixed, short list of things that happen in the app, such as the app opening, a challenge being created, an export finishing, or a paid limit being reached. See the analytics section below for exactly what is in them.
• Crash reports. When the app crashes, we record the error message, the error name, a shortened stack trace, and whether it was fatal.
• Screen recordings. The app records what its screens look like while you use it, with all text covered first. See the analytics section below for what a recording shows and what it never shows.
• Device and app details. The platform, the app version, your language, and your time zone. These are attached to usage events, and the app uses them on your phone to show dates and reminders in the right language and at the right local time.
• Install and ad measurement details. When the app first opens, it records the random install id, your device's vendor identifier (an id Apple gives this app that is different in every other company's apps), your answer to Apple's tracking prompt, and Apple's Search Ads install token. The section on ad measurement explains what they are for.
• Support messages. If you send feedback from inside the app, we store your message, the account it came from if you have one, the random install id, your language, and the app version.
• Website server logs. Our website host keeps standard request logs, which can include your IP address, the page you asked for, and your browser type.

Here is what we do not collect. We do not collect payment card details, precise location, your contacts, the photos in your library, health or fitness data from Apple Health, or biometric data. Chaltra shows no ads and contains no advertising software. Your device's advertising identifier is read only if you allow tracking when the app asks, and then only by RevenueCat, as the section on ad measurement explains.

The app asks for three permissions, each at the moment it matters: notifications, when you turn a reminder on; adding to your photos, if you save an export there from the share sheet, which lets the app add a picture but never see your library; and tracking, once, after the first-run screens. Saying no to any of them changes nothing else in the app.

4. Data that stays on your device

This is the part of Chaltra that is unusual, so it gets its own section.

Chaltra works fully without an account. "Continue without account" makes you a guest: there is no sign-in and no account on our servers. Everything you build stays in the app's own storage on your iPhone.

Cloud sync is a paid feature. If you have an account but no subscription, your challenges and progress also stay on the device and are never sent to our database. Writing to our servers is not something a free user is stopped from doing by a rule. It is something the app simply never does.

In both cases, your challenges are never sent to us. What does leave your phone is: your answers to the four first-open questions, the anonymous usage events and crash reports, the screen recordings described in the analytics section, the install record described in the section on ad measurement, and any support message you choose to send us.

Two consequences worth knowing. Because your challenges are only on the device, we cannot recover them for you, and deleting the app deletes them unless they are inside a backup of your iPhone that you made yourself. And if you later subscribe and sign in, the app copies what is already on the device up to our database so it can sync across your devices. That copy happens once, at that moment, and you can see it coming.

The pledge you can sign when you start a challenge is saved with that challenge. On the free plan that means on your phone only. With a subscription it is backed up with your challenges, so it comes back on a new phone. Only your account can read it unless you choose to show it. You can switch it on for a picture or clip you are about to share, and for a challenge's public page. It is off until you do, every time. One thing never leaves the phone, whatever your plan: the copy of your challenges that the home-screen widget draws, signature included. Anyone who can see your home screen can see what the widget shows.

5. How we use your data

We use what we collect for these purposes and no others.

• To run the app. Showing your challenges, drawing the picture, counting progress, and remembering your settings.
• To sync. For subscribers who are signed in, copying your challenges between our database and your devices so they match.
• To know whether you are a subscriber. So paid features unlock and locked ones explain themselves.
• To schedule reminders. Your reminder times and weekdays are used by your iPhone to raise a local notification.
• To publish a challenge, if you ask for that. See the section on public pages.
• To answer you. When you write to us, we use your message and your email address to reply.
• To improve Chaltra. Usage events tell us which parts of the app people reach and where they get stuck. Crash reports tell us what is broken.
• To decide where to advertise. Your age range, your gender and where you heard about us are counted together with everyone else's answers, so we can see which groups and which channels bring people who stay. That decides where we buy ads. These are totals. We do not build a profile of you, and we never hand your answers to an ad network.
• To measure our ads. To see whether an ad we paid for, such as an Apple Search Ads ad, led to an install, and whether those people stayed. See the section on ad measurement.
• To keep Chaltra safe. Detecting abuse, stopping automated sign-ups, and protecting the service and its users.
• To meet legal obligations, when we are required to.

We do not sell your personal information, and we do not give it to data brokers. An ad network only ever receives what the section on ad measurement describes, and only if you allow tracking. We do not use it to build a profile of you, and we do not use your challenge data to train anything.

We do not make decisions about you by automated means that produce legal or similarly significant effects.

6. Data sharing and third parties

We share your data with the service providers listed in the next section, and only what each one needs to do its job. They process it on our instructions and are not free to use it for their own purposes.

Meta is the one exception. It is an ad network, not a company working on our instructions, and it handles what it receives under its own policy. The section on ad measurement says what that is, and it only happens if you allow tracking.

Beyond that, we may disclose data in three situations.

• When the law requires it. A valid court order, subpoena, or legal request from an authority with jurisdiction over us. We will tell you when we are allowed to.
• To protect rights and safety. To investigate fraud or abuse, to enforce our terms, or to protect the rights, property or safety of you, us or anyone else.
• In a business transfer. If Chaltra is ever sold, merged, or transferred, your data would move with it. You would be told before that happened, and this policy would keep applying until you were given notice of a new one.

Anything you publish yourself is public by definition. That is covered in its own section below.

7. Third-party services

These are every outside company involved in running Chaltra. There are no others.

• Supabase. Our database, sign-in, and file storage. Your account details, a subscriber's challenges and progress, usage events, first-open answers, install records, support messages, and a copy of whether your subscription is active, which decides whether your public pages are live, are stored here. Supabase is our data processor.
• RevenueCat. Handles subscriptions and tells the app whether yours is active. It receives your account identifier, and your email address and the name your sign-in provider gave us (or the start of your email address) as subscriber attributes. If you answered them when you first opened the app, it also receives your age range, your gender and where you heard about us, so we can see which groups of subscribers stay. It also receives the app's language, your answer to the tracking prompt, Apple's Search Ads install token, and, only if you allow tracking, your device's advertising identifier and vendor identifier. It never receives the name you typed at first open, and it never receives your challenge data.
• Apple. Sign in with Apple, the App Store, all payments, and Apple Search Ads. Apple processes your purchase and gives us only the subscription status, never your card details. For Search Ads, our server can send Apple the install token described in the section on ad measurement, and Apple answers with the campaign that led to the install, if there was one. Apple's own handling of your data is governed by Apple's policy.
• Google. Google Sign-In, if you choose that way in. Google tells us your account identifier, your email address, your name and the web address of your profile picture. It receives nothing else from us.
• Cloudflare. Hosts and serves the chaltra.com website, including public challenge pages. It sees the requests your browser makes and provides bot and abuse protection.
• PostHog. Stores the screen recordings and a short list of usage events, both described in the analytics section. It receives the random install identifier, your phone model, the iOS version, the app version, your language and your time zone, and, if you answered them, your age range, your gender and where you heard about us. It never receives your account identifier, your email address, your name, or a crash report. Like any server, it sees the IP address your phone connects from; we do not use it to work out where you are. PostHog is our data processor, and its servers for our project are in the United States.
• Meta. Runs Facebook and Instagram, where we buy ads. The app sends Meta nothing and contains no Meta software. While our ads run there, RevenueCat tells Meta about trials and purchases made by people who allowed tracking, as the section on ad measurement describes. Meta is not our data processor: it decides what it does with that under its own policy.

Each of these has its own privacy policy, and we suggest reading the ones that apply to you.

• Supabase: https://supabase.com/privacy
• RevenueCat: https://www.revenuecat.com/privacy
• Apple: https://www.apple.com/legal/privacy/
• Google: https://policies.google.com/privacy
• Cloudflare: https://www.cloudflare.com/privacypolicy/
• PostHog: https://posthog.com/privacy
• Meta: https://www.facebook.com/privacy/policy/

8. Public challenge pages and profiles

A subscriber can publish a challenge. Publishing puts it on a page on chaltra.com at an address built from the challenge, and that page is visible to anyone who has the link. There is no password on it.

When you publish a challenge, these things become public:

• The title and description you wrote.
• The target, the unit, and the start and end dates.
• Every progress value you logged, day by day, because that is what the page plays back.
• The picture, its style and its colours, and the names you gave your data sources.
• Your username, as the byline.
• Whether it is finished, and when you published it and last updated it.

Your profile picture is not published. Neither is your email address, the name you typed at first open, or any challenge you have not published. The signature on your pledge is not published either, unless you switch it on for that page. It goes off again when you unpublish.

There is also a public profile page at chaltra.com, at an address made from your username, which lists your most recent published challenges. If you have published nothing, there is nothing there.

Your username may have been created for you when you made your account, from the name you typed at first open, the name your sign-in provider gave us, or the start of your email address. If you plan to publish anything, check it first in Settings and change it if it says more about you than you want a stranger to know.

You can unpublish at any time from the same switch you used to publish. Unpublishing takes the page down and deletes the stored preview image.

Unpublishing cannot undo what already happened. Copies held at our edge cache can serve for up to five minutes afterward. Search engines, social networks, messaging apps and link preview services keep their own copies on their own schedule, and anyone who saw the page may have saved or screenshotted it. Public challenge pages ask search engines not to index them, but link preview crawlers ignore that request, which is the whole reason previews work.

Public pages are part of Premium. If your subscription ends, your pages pause: anyone who opens a link sees that the challenge is paused and none of its content, and your profile page says you have put your challenges away. They come back if you subscribe again. To take them down for good, unpublish them or delete your account.

The short version: publish nothing you would not be comfortable seeing on a stranger's screen a year from now.

9. Sharing and exporting your progress art

Exported images and videos are drawn on your iPhone, by your iPhone, and handed to the iOS share sheet. They are not uploaded to us. We never see them and we have no copy of them.

Where they go after that is up to you and to whichever app you send them to. Once an image is posted somewhere, that platform's rules apply to it, not ours.

There is one exception. When you publish a challenge, the app renders a preview card on your phone and uploads it so that link previews show a picture instead of a grey box. That file sits in a storage area that is readable by anyone who has its address, and it is deleted when you unpublish.

Every export carries the chaltra.com wordmark. It does not carry your name, your username, or anything else from your account.

10. Notifications

Chaltra sends local notifications only. A reminder is scheduled by the app on your own iPhone, and your iPhone raises it at the time you chose. Nothing is sent from a server.

There is no push notification service in Chaltra, no device push token is registered anywhere, and we hold nothing that could be used to send a message to your phone.

The app asks for notification permission only when you turn a reminder on, either on the reminders screen or by saving a challenge with its reminder on. If you say no, the app tells you the reminder will not ring. You can change your mind in iOS Settings at any time, and you can turn any reminder off inside the app.

11. Account deletion

You can delete your account from inside the app: Settings, then Delete account. You will be asked to type the word DELETE, because this cannot be undone.

Deleting your account removes your profile, your challenges and your progress from our database. Any challenge you published stops being public.

In the same step as the deletion, we detach your account identifier from your device record, from every usage event we already hold and from your first-open answers, erase the name you typed at first open, and remove the device identifiers from your install record, so what remains is a set of counts that points at nobody.

Deletion does not cancel your subscription, because Apple bills it and only Apple can stop it, so cancel it in your Apple account settings first. It does clear your challenges from the app on your phone, along with its widget and its reminders.

If you cannot reach the in-app option for any reason, email hello@chaltra.com and we will do it for you once we can confirm the account is yours.

12. Data retention

We keep your account details, challenges and progress for as long as your account exists. When you delete your account, they are deleted.

Usage events and crash reports are kept while they are useful for product decisions. Once your account is deleted, they carry no link to you and exist only as aggregate counts.

Answers to the first-open questions and install records are kept while they are useful for deciding where to advertise. Deleting your account erases the name, detaches the answers from you, and removes the device identifiers from the install record.

Support messages are kept while we may still need them to help you or to understand a recurring problem.

Deleted rows can survive for a short time in our provider's automatic database backups before those backups rotate out. This is normal for any hosted database, and those backups are not used to bring an account back.

Published pages and their preview images are held in an edge cache for up to five minutes at a time, so an unpublish can take that long to be felt everywhere.

Server logs are kept for a short period by our hosting providers for security and troubleshooting.

13. Data security

Everything travels over encrypted connections. Your sign-in tokens are held in the iPhone Keychain, which is hardware backed, and not in ordinary app storage.

Our database uses row level security, which means the rules about who can read a row live in the database itself rather than in app code that could forget to ask. One account cannot read another account's challenges.

The analytics tables are closed by default: no client can read them at all, and writes only go through a single function that checks the shape and size of what it is given.

That said, no service on the internet is perfectly secure, and we cannot promise that a determined attacker will never succeed. If a breach affects your personal information, we will notify you and the relevant authorities as the law requires, including reporting confidentiality incidents to Quebec's Commission d'accès à l'information where that applies.

14. Analytics and tracking technologies

Chaltra runs its own analytics, on our own database. One outside company is involved, PostHog, and only for the screen recordings and the short list of events described below. There is no Google Analytics, no Firebase, no Amplitude, no Mixpanel, and no software development kit from an advertising company anywhere in the app.

Measuring our ads is separate from these events, and it has its own section, next.

The identity behind an event is a random identifier created the first time the app launches. It is not derived from your phone's hardware, it carries nothing about you, and it is stored in ordinary app storage so that deleting the app ends it.

The events are a fixed list, written down in our code, not a free-form log. They record the shape of what happened, never its contents. Creating a challenge records the kind of target, the picture style, the colours, the length in days and the number of units. It does not record the title, the description, your notes, or the names you gave your data sources.

The answers you give at first open ride along with these events, so we can tell whether a group we advertised to went on to stay. Your name is the exception and never leaves for this purpose: the events record only whether a name was given, never what it was. Deleting your account erases the name and detaches the rest.

If you later create an account, the events already recorded on that device get your account identifier attached, which is how we can see whether a first run led anywhere. Deleting your account detaches it again.

These events leave the device even in guest mode. A guest has no account and no synced data, but the app still reports these anonymous events so we can tell whether the free experience works. Events are queued on the device and sent in batches, so being offline never blocks anything and never loses the queue.

Crash reports go through the same path and contain the error message, the error name, a shortened stack trace, and whether the crash was fatal.

Screen recordings. The app records what its screens look like while you use it, so we can see where people get stuck. Before a recording leaves your phone, every piece of text on the screen is covered, and so are the fields you type in and the signature on a pledge. What is left is the layout, where you tapped, and the pictures the app draws. A picture can carry a challenge's title or its numbers, for example the preview of an image you are about to share.

PostHog, the company that stores these recordings, also receives a short list of the events described above, so a recording can be found by what happened in it: the app opening, the first-run steps and questions, and the subscription screen, including whether a purchase went through. They carry the same details as our own copy, which means your age range, your gender and where you heard about us if you answered, and never your name. At PostHog, recordings and events are tied to the random identifier described above and never to your account, your email address or your name. PostHog receives no crash reports.

15. Ad measurement and the tracking prompt

Chaltra shows no ads. We do pay for ads elsewhere, and we want to know which ones bring people who stay. This section covers the two ways we measure that, and the one choice you have over them.

Apple Search Ads. When the app first opens, it asks iOS for a token that says whether the install came from an Apple Search Ads ad. We save that token in our database with the random install id and your device's vendor identifier, and RevenueCat receives the token too. Our server can send the token back to Apple, which answers with the campaign, ad group and keyword that led to the install, or says there were none. Apple does not treat this as tracking, so it does not need your permission, and it does not use your advertising identifier.

The tracking prompt. Once, after the first-run screens, the app shows Apple's App Tracking Transparency prompt. If you allow tracking, RevenueCat receives your device's advertising identifier and vendor identifier, so that an ad network we work with can tell us whether one of its ads led to a subscription. If you ask the app not to track, the advertising identifier is never read, and nothing else in the app changes. Your answer is saved with the install record and sent to RevenueCat. You can change it at any time in iOS Settings, under Privacy & Security, then Tracking.

Meta. Meta runs Facebook and Instagram, and it is the one ad network we work with. While our ads run there, and only if you allowed tracking, RevenueCat tells Meta when you start a trial, subscribe, renew or buy Chaltra, and how much it cost, so Meta can match that to an ad it showed. To make the match, RevenueCat may send your device's advertising identifier and vendor identifier, the IP address your phone connects from, and, if you have an account, your email address as a scrambled code that Meta can only match against an email address it already holds. Meta never receives your challenges, your name, or your answers to the first-open questions. If you asked the app not to track, Meta receives nothing about you. When we have no ads running there, Meta receives nothing at all.

None of it includes your challenges, their titles or anything you logged. We use it to count which ads work, never to show you ads or to build a profile of you, and we never sell it. What Meta does with what it receives is set by Meta's own policy.

The App Store lists some of this under "Data Used to Track You", because Apple asks every app that shows its tracking prompt to declare the data that prompt covers that way.

16. Cookies on the website

The chaltra.com website sets no analytics cookies, no advertising cookies, and no third-party tracking cookies. There is no tracking script on any page. We do not store anything in your browser to recognise you on a later visit.

Our host, Cloudflare, may set strictly necessary cookies to keep the site up and to tell a person apart from a bot. These carry no profile of you and are used for nothing else.

Under Quebec's Law 25, PIPEDA and the GDPR, strictly necessary cookies of this kind do not need a consent banner, which is why you are not shown one. We list them here so that the absence of a banner is a fact you can check rather than something you have to take on trust.

The app does not use cookies at all.

17. Do Not Track signals

Some browsers send a Do Not Track header, and some send a Global Privacy Control signal. There is no agreed standard for what a website must do with either one.

Our answer is simple: we do not track visitors across other websites, the website shows no ads, and we sell nothing, so there is no behaviour for those signals to switch off. We comply by never doing the thing in the first place.

18. Your rights

Wherever you live, you can ask us to do the following, and we will.

• See what we hold about you.
• Get a copy of it in a portable, machine readable format.
• Correct anything that is wrong.
• Delete your account and the data attached to it.
• Withdraw a consent you gave, such as notification permission.
• Object to or restrict how we use your data.
• Complain to a privacy regulator without going through us first.

To make a request, email hello@chaltra.com. We reply within thirty days, and sooner when we can. If a request is unusually complex we will tell you and explain the delay.

We may need to confirm that the account is yours before acting, usually by asking you to write from the email address on the account. We will not charge you, unless requests are repetitive or clearly excessive, in which case we will tell you the cost before doing anything.

19. Rights for users in the European Economic Area and the United Kingdom

If you are in the EEA or the UK, the General Data Protection Regulation applies to you and Kevin Pugliese is the controller of your personal data.

You have the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, the right to object to processing based on legitimate interests, and the right to withdraw consent at any time without affecting what was done before you withdrew it.

You have the right to lodge a complaint with your national supervisory authority. In the UK that is the Information Commissioner's Office.

We do not carry out automated decision-making or profiling that produces legal effects or similarly significantly affects you.

You must be at least 16 to use Chaltra in the EEA, or the lower age your country sets where it sets one.

Where your data is transferred outside the EEA or the UK, it is covered by the standard contractual clauses our providers have in place. See the section on international transfers.

20. Rights for California users

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act gives you specific rights.

In the last twelve months we have collected these categories of personal information: identifiers, such as an account identifier, an email address, a random install id, your device's vendor identifier, and its advertising identifier if you allowed tracking; characteristics of protected classifications, in the form of the age range and gender you may give at first open; commercial information, in the form of your subscription status; internet or other electronic network activity, in the form of app usage events and install attribution; and geolocation only at the coarse level of a time zone and a language. Every one is described in detail in the section on what we collect.

We have not sold personal information in the last twelve months, and we do not sell it at all. One thing may count as sharing for cross-context behavioural advertising under California law: what Meta receives while our ads run there, described in the section on ad measurement. It happens only after a yes to the tracking prompt, whatever your age, and never otherwise.

We do not collect sensitive personal information as the CPRA defines it.

You have the right to know what we collect and why, the right to delete it, the right to correct it, the right to opt out of sale or sharing, and the right to limit the use of sensitive personal information. To opt out of sharing, ask the app not to track, turn tracking off for Chaltra in iOS Settings, under Privacy & Security, then Tracking, or write to us. There is no sale to opt out of and no sensitive personal information to limit.

We will never treat you differently for exercising a right. There are no financial incentive programmes, and the app does not become worse if you ask us to delete something.

You can use an authorised agent to make a request on your behalf. We will ask for proof that you gave them permission.

21. Rights for Canadian users

We are based in Quebec, so the Personal Information Protection and Electronic Documents Act and Quebec's Law 25 both apply to us.

Kevin Pugliese is the person in charge of protecting personal information, reachable at hello@chaltra.com.

You may ask for access to your personal information, ask for it to be corrected, withdraw your consent to a use of it, and ask for a copy in a structured, commonly used technology format. Law 25 gives you that portability right, and we honour it.

Law 25 also gives you the right to ask us to stop disseminating your personal information or to de-index a link where the dissemination causes you serious injury. If you published a challenge and want it gone, unpublishing it in the app is the fastest route, and you can also write to us.

If a confidentiality incident presents a risk of serious injury, we will notify you and Quebec's Commission d'accès à l'information, and we keep a register of such incidents as the law requires.

If you are not satisfied with how we handle a request, you can complain to the Office of the Privacy Commissioner of Canada, or to the Commission d'accès à l'information for matters under Quebec law.

22. Legal basis for processing

Where the GDPR or a similar law asks us to name a legal basis, these are ours.

• Performance of a contract. Creating and holding your account, storing and syncing your challenges, and giving you the paid features you bought.
• Legitimate interests. Keeping Chaltra secure, preventing abuse, understanding how the app is used through anonymous events and screen recordings, fixing crashes, and measuring which of our Apple Search Ads ads bring people to Chaltra. We have weighed these against your rights and consider them proportionate, because none of them involves profiling you or sharing anything with an advertiser.
• Consent. Your answers to the first-open questions, notification permission, tracking permission, and publishing a challenge to a public page. You can withdraw any of these at any time: notifications and tracking in iOS Settings, publishing in the app, and your answers by writing to us.
• Legal obligation. Keeping records we are required to keep and responding to lawful requests.

If you object to a use that rests on legitimate interests, write to us and we will stop unless we have a compelling reason not to, which we would have to explain to you.

23. Children's privacy

Chaltra is not designed for or directed at children. You must be at least 13 years old to use it, and at least 16 in the European Economic Area or wherever local law sets a higher age.

We do not knowingly collect personal information from anyone below that age. If we learn that we have, we delete it and close the account.

If you are a parent or guardian and believe a child has given us data, write to hello@chaltra.com and we will remove it.

24. International data transfers

We are in Quebec, Canada. Our service providers operate globally, which means your data may be stored or processed outside Quebec and outside Canada, including in the United States and the European Union.

Privacy laws in those places are not identical to the ones where you live, and in some cases give local authorities access rights that your own country would not.

Before relying on a provider outside Quebec we consider the protection the information will actually receive there, which is what Law 25 requires of us. Where the GDPR applies, transfers rest on the standard contractual clauses our providers offer, or on an adequacy decision where one covers the country in question. Canada holds an adequacy decision from the European Commission for commercial organisations.

You can ask us where a specific piece of your data lives and we will tell you.

25. Changes to this policy

We may update this policy as Chaltra changes. When we do, the date at the top of this page changes with it.

If a change materially affects your rights or how we use your data, we will tell you inside the app, and where the law requires it we will ask for your consent before the change applies to you.

Continuing to use Chaltra after a change means you accept the updated policy. If you do not accept it, you can delete your account and stop using Chaltra.

We will not quietly widen what we do with your data and rely on you not reading the page.

26. Contact us

Kevin Pugliese, sole proprietor, Quebec, Canada.

Email: hello@chaltra.com. Write in English or in French. We answer in whichever you used.

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