Privacy Policy
Nocala Privacy Policy
Effective date: 9 October 2026
Last updated: 9 October 2026
Nocala helps you build a calmer path from the last daytime decisions to sleep. It is designed to work on your device, without an account. This policy explains what stays on your device, what little leaves it, and what rights you have.
1. Short version
- No account, no backend. We do not run a server that stores your routine, your sleep times or your garden.
- Your routine stays on your iPhone. Bedtime, wake-up time, runway steps, morning answers, experiments and garden progress are stored locally.
- We cannot see which apps you choose to shield. Screen Time selections are private, opaque Apple tokens. Nocala does not read, derive or transmit app, category or website identities.
- Anonymous usage statistics are optional. They contain coarse counts and product events, never app names, free text or exact routine history.
- Purchases are handled by Apple. We never see your payment details.
- We do not sell your data and we do not use it for advertising or cross-app tracking.
2. Who is responsible
The controller of personal data processed under this policy is the developer of Nocala. Contact: hello@nocala.app
Website: https://nocala.app
For privacy requests, write to hello@nocala.app. We do not have a Data Protection Officer; the email above is the contact point for all data protection matters.
3. What data is processed, and where
3.1 Data that stays on your device
The following is created and stored only on your iPhone, in Nocala’s app container and the shared App Group used by Nocala’s own extensions (Screen Time shield, activity monitoring, report, widgets). It is not sent to us or to any third party by Nocala.
- Wake-up time, desired sleep window and weekday/weekend differences
- Your Sleep Runway steps and their settings
- Wake-up Support mode, phone location and wake-method answers from onboarding
- Notification preferences
- Morning flow answers and the small routine experiments you accept or decline
- “Tonight is different” exceptions
- Garden progress and the record that prevents crediting an interval twice
- The opaque Screen Time selection token(s) you choose
Because this data lives on your device, it is removed when you delete Nocala. If you use iCloud Backup or an encrypted device backup, Apple may include the app’s local data in that backup under Apple’s own terms and privacy policy.
Sleep timing and routine information can reveal things about your health. For that reason we deliberately keep it on your device and out of our reach.
3.2 Screen Time (FamilyControls, ManagedSettings, DeviceActivity)
If you choose to use app shielding, Nocala asks Apple’s Screen Time framework for authorization. You pick apps, categories and websites in Apple’s own picker. Apple returns opaque tokens that Nocala can pass back to the system to apply or lift a shield; Nocala cannot turn them into app names or website addresses and does not attempt to.
Usage figures that Nocala may display (for example in the onboarding usage reveal) are rendered by an Apple-sandboxed report extension. Nocala does not receive that data and it is not transmitted off your device.
Individual Screen Time authorization can be revoked by you at any time in iOS Settings. Nocala then stops shielding.
3.3 Notifications and alarms
Runway reminders are local notifications. Wake-up Support uses Apple’s AlarmKit system alarms. Both are scheduled on your device; no notification content or alarm schedule is sent to us. You can turn off notification and alarm permissions at any time in iOS Settings.
3.4 On-device personalization
Personalization of your runway uses deterministic local rules and, where available on your device, Apple’s on-device capabilities. Nothing you enter for personalization is sent to us or to a cloud AI service. Any suggestion must be approved by you before it changes your schedule, alarms or shields.
3.5 Anonymous usage statistics (Amplitude, EU)
If you allow it, Nocala sends product events to Amplitude, a product analytics provider, using Amplitude’s EU data center. Events describe the product state, for example that onboarding finished, that a permission was granted or denied, that a shield interval completed, or how many apps and categories were selected (counts only).
What these events contain:
- Event name and coarse properties (counts, time buckets, step types, outcomes)
- A random per-install identifier generated by the Amplitude SDK. We never set a user ID, name, email or any account identifier.
- Technical data that the SDK attaches automatically, such as app version, iOS version, device model, language and time zone, and a session identifier. Amplitude may also see your IP address when the event arrives, which it may use to infer an approximate region.
What they never contain: app, category or website names or tokens; free text; your answers to morning questions (we only record that a question was answered); your exact routine history; bathroom-awakening information; or model prompts and responses.
Legal basis: your consent (Art. 6(1)(a) GDPR), which you can give or withdraw at any time in Nocala’s Settings. Nocala works fully without it. Withdrawing consent does not affect processing before the withdrawal.
Retention: event data is kept for up to [24] months, then deleted or irreversibly aggregated.
3.6 Purchases (Apple and Superwall)
Nocala’s paid plan is purchased through the App Store. Apple processes the payment and manages your subscription; we do not receive your card or Apple ID details. Apple tells us whether a purchase is valid.
To present the paywall and read subscription status, Nocala uses Superwall (Superwall, Inc., United States). Superwall receives a random identifier for the installation, basic device and app information (for example OS version, device model, locale, app version), your IP address as part of the network request, whether you saw or closed a paywall, and your purchase and subscription status from StoreKit. Nocala does not give Superwall your name, email, routine or Screen Time information.
Legal basis: performance of the contract with you (Art. 6(1)(b) GDPR) for showing the offer, validating your entitlement and restoring purchases, and our legitimate interest (Art. 6(1)(f)) in understanding and improving how the offer is presented.
3.7 Contacting us
If you email hello@nocala.app, we process your email address, the content of your message and any attachment you send, to answer you. Please do not send health details or screenshots you would not want us to read. Legal basis: our legitimate interest in handling support requests (Art. 6(1)(f)), or the contract with you where the request concerns your purchase. We keep support emails for up to [24] months after the matter is closed, unless we need them longer to defend legal claims.
We use an email service provider to receive and store support messages.
3.8 Information we receive from Apple
Apple provides aggregated App Store sales, subscription and (if you opted in to share them with developers) crash and usage diagnostics. These are not linked to you personally. Apple processes your data as an independent controller under its own privacy policy.
3.9 Our website
Nocala is a static page. It does not set cookies, use analytics, or include third-party embeds. If this changes, this section and any required cookie notice will be updated.
4. Legal bases (GDPR)
| Purpose | Legal basis |
|---|---|
| Provide the app and its on-device features | Contract (Art. 6(1)(b)). Local processing on your device is not performed by us. |
| Anonymous usage statistics | Consent (Art. 6(1)(a)) |
| Screen Time, notification and alarm permissions | Your choice in the iOS permission prompt |
| Paywall, purchase validation, restore | Contract (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f)) |
| Support and security | Legitimate interest (Art. 6(1)(f)) |
| Accounting and tax obligations | Legal obligation (Art. 6(1)(c)) |
5. Who receives data
| Recipient | Role | Location |
|---|---|---|
| Apple Inc. | App Store, payments, Screen Time, AlarmKit, notifications; independent controller | EU / US |
| Amplitude, Inc. | Processor, product analytics, EU data center | EU storage; US parent company |
| Superwall, Inc. | Processor, paywall and subscription status | United States |
We do not sell personal data, we do not share it for cross-context advertising, and we do not track you across other companies’ apps and websites. We may disclose information if required by law.
6. International transfers
Superwall is based in the United States and Amplitude is a US company with EU data storage. Where personal data is transferred outside the European Economic Area, we rely on the EU-US Data Privacy Framework where the recipient is certified, or on the European Commission’s Standard Contractual Clauses, together with supplementary measures. You can request a copy of the safeguards by writing to hello@nocala.app.
7. How long we keep data
- Local app data: until you delete the app or its data.
- Amplitude events: up to [24] months.
- Superwall data: according to our configuration and Superwall’s retention terms.
- Support emails: up to [24] months after resolution.
- Accounting records: as long as Polish law requires.
8. Your rights
Under the GDPR (and the UK GDPR for UK users) you have the right to:
- access the personal data we hold about you,
- have it corrected,
- have it erased,
- restrict its processing,
- object to processing based on legitimate interests,
- receive it in a portable format,
- withdraw consent at any time, with effect for the future.
Write to hello@nocala.app. We aim to answer within one month.
Because we hold no account and usage events are linked only to a random identifier, we usually cannot tell which events came from you. We may ask for that identifier or other information strictly needed to locate data; if we cannot identify you, we will say so (Art. 11 GDPR). The simplest way to stop analytics is to switch usage statistics off in Settings; deleting the app removes everything stored on your device, and reinstalling creates a new, unrelated identifier.
Complaints. You may complain to a supervisory authority, in particular in the EU country where you live or work. In Poland this is the Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, https://uodo.gov.pl. UK users can contact the Information Commissioner’s Office (ico.org.uk).
9. Automated decisions
Nocala makes no decisions that produce legal or similarly significant effects on you. Suggestions are generated locally from your settings, are explained, and take effect only when you approve them.
10. Children
Nocala is intended for people aged 17 and over. We do not knowingly collect personal data from anyone under 17. If you believe a child has used Nocala and data has reached us, contact hello@nocala.app and we will delete it.
11. Security
Data is stored in the iOS app sandbox and protected by iOS device encryption when your device is locked with a passcode. Transmissions to our service providers use encrypted connections. No system is perfectly secure, so keep your device updated and locked. We will notify authorities and affected users of a personal data breach where the law requires it.
12. Information for residents of the United States
This section supplements the rest of the policy for residents of California and other US states with privacy laws.
- Categories collected (only if you consent to analytics or make a purchase): identifiers (random device/install ID, IP address), internet or app activity (product events), commercial information (subscription status), device information.
- Sources: your device and Apple.
- Purpose: operating and improving the app, and providing purchases.
- Disclosure: to the service providers listed in Section 5, under contracts that restrict their use of the data.
- Sale or sharing: we do not sell personal information and do not share it for cross-context behavioral advertising. We do not use sensitive personal information to infer characteristics about you.
- Your rights: to know, access, correct, delete and to non-discrimination for exercising them. Email hello@nocala.app. You may use an authorized agent.
- Do Not Track / Global Privacy Control: the app does not track you across third-party apps or sites.
13. Other countries
If you are located outside the EU, UK or US, you may have additional rights under local law. Write to hello@nocala.app and we will handle your request in line with the law that applies to you.
14. Not medical advice
Nocala supports bedtime behavior. It does not diagnose, treat or prevent any condition, including insomnia or ADHD. If you are concerned about your sleep or health, speak to a qualified professional.
15. Changes to this policy
We will update this policy when our practices change. For material changes we will tell you in the app or on this page before they take effect, and ask for consent again where the law requires it. The “Last updated” date above shows the current version.