Habitcount Privacy Policy

Effective date: 24 September 2026
Last updated: 1 October 2026

This policy explains what information the Habitcount app and its servers collect, why we collect it, who we share it with, how long we keep it, and the choices and rights you have. It applies to the current Habitcount app for iOS and to the servers that support it. Android is not part of this release.

If you live in Washington, Nevada or another place with a law specific to health data, please also read our Consumer Health Data Privacy Policy (https://apps.iesllc.ge/app-e7f4e392/legal/health).


The short version


1. Who we are

Habitcount is published by Intelligent Energy Solutions LLC, a limited liability company registered in the country of Georgia by the National Agency of Public Registry under identification number 445839816, with its registered address at 58 St. Andrew the First-Called Highway, Apartment 605, Block III, Batumi, Georgia ("we", "us", "our").

For information we process on our servers, we are the controller (the organisation that decides how and why it is used).


2. What we collect

What we collect depends on how you use Habitcount.

2.1 Using Habitcount without an account

Everything you create stays on your device, in a local database inside the app:

We do not receive any of this unless you create an account and agree to sync (section 2.2), contact support (section 2.3), or unless usage statistics are on (section 2.4).

A small amount of information still reaches our server when you use the app without an account:

Habitcount 1.0 does not schedule reminders or collect a push-notification token.

2.2 If you create an account (backup and sync)

You can create an account with Sign in with Apple or email and password. We then collect:

CategoryWhat exactly
Sign-in detailsYour email address. If you use Sign in with Apple and choose "Hide My Email", this is an Apple relay address. We also store your sign-in method, the unique ID that Apple gives us for you, and your name if Apple provides it and you allow that. For each Apple sign-in authorization, we encrypt and store the Apple refresh token so we can revoke that authorization when you delete your account. We do not store your Apple password.
Password (email accounts only)We never store your password. We store a one-way Argon2id hash of it with a random salt, so the password cannot be read back from the hash. When you choose a password, our server checks it against passwords known from data breaches using the Have I Been Pwned service. Only the first 5 characters of the password's SHA-1 fingerprint are sent, which cannot identify the password or you. We also store whether and when you verified your email address, and a count of recent failed sign-in attempts with a temporary lock time, to protect you against password guessing.
Verification codes and reset linksFor email accounts we send a 6-digit verification code, which expires after 24 hours, and password-reset links, which expire after 30 minutes. The token table stores hashes; the short-lived delivery job holds an encrypted copy until the email is sent and the job is pruned. Our email provider receives the message so it can deliver it.
SessionsHashed sign-in ("refresh") tokens, each linked to the device ID that signed in, with their creation, expiry (60 days) and revocation times.
Registered devicesThe app's random device ID, platform (iOS), app version, operating-system version, time zone and when the device last connected.
Synced counters and entriesEverything listed in section 2.1 that you choose to sync: counter details including goals and prices, and entries with date, time, local day, time zone, amount, how the entry was made (for example a tap or a manual entry), optional note (up to 280 characters) and optional price. We also store your own templates and daily totals we calculate from your entries (number of entries, total amount, first and last time of the day, and whether a goal was met).
SettingsLanguage, time zone, when your day starts, which day your week starts, default currency, haptics, sounds and appearance, and the date you first opened the app, which is used for the free period.
Friend challenges (only if you use them)When you challenge a friend: a random link code, which of your counters it is for, a copy of that counter's name, emoji, colour, type, unit and goal, and when the link expires (30 days after you last shared it). When you or a friend accept a challenge: which two counters are paired, who invited whom, when the challenge started and, if it was stopped, when and by whom. The name you choose for challenges is stored as your display name. See section 3.1 for what your friend sees.
Subscription statusSee section 2.5.
Account-deletion receiptIf you request account deletion, we keep your account's random ID and the time of your request in a limited-retention receipt. We also encrypt this minimal record and store a separate copy so that an older backup cannot accidentally restore your deleted account. It contains no counter names, entries, notes or health details.

When you use Sign in with Apple, our server checks Apple's signed sign-in token and exchanges Apple's single-use authorization code with Apple. We do not receive your Apple password.

Security data. To stop abuse, our server keeps your IP address, and for email sign-in your email address, in memory for up to 24 hours. It uses them to count repeated attempts, for example too many sign-in or password-reset attempts. They are not written to our database.

2.3 If you contact support

The in-app support form sends us:

The form never attaches your counter names, entries, notes or amounts. We store the ticket on our server and email it to our support inbox, with your address as the reply-to. The conversation then continues by ordinary email. Please don't include health details in your message unless you need to.

2.4 Usage statistics (only if you turn them on)

The setting "Share usage statistics" (You → Data) is off by default. You can turn it on or off at any time. If your three bonus days (the free period) have ended, the subscription screen still offers
"Turn off usage statistics" when this setting is on. Turning it off also deletes any unsent usage events on your phone; events already received by us follow the retention period in section 7. The events are pseudonymous, not anonymous: they carry a random device ID. While it is off, the app does not record or send usage events. Phone-only mode also blocks them, whatever the setting says (section 9.2). Region signals may not reflect where you actually live.

While it is on, the current app may send us events from a fixed list of nine names: template selected, counter created, first tap, paywall viewed, paywall dismissed, trial started, purchase completed, sign-in and free period expired. We do not record a first-launch event before you opt in, or claim that an App Store rating prompt was displayed when iOS may not show it. Each event includes its time, the app version, your platform and the app's random device ID. It may also include a few fixed details, such as which plan you picked or which sign-in method you used. If you are signed in, events are linked to your account.

Usage events never contain note text, amounts, counter names or anything you type. We use them only to understand how the app is used, for example how many people finish setting up their first counter, and to improve it. You can turn the setting off at any time. The app then stops sending events.

2.5 Subscriptions and payments

Habitcount Pro is sold through the Apple App Store. Apple processes your payment, and we never receive your card number or billing address.

We use RevenueCat to confirm purchases and track subscription status. Before you sign in, RevenueCat knows you only by a random anonymous ID. After you sign in, it is linked to your Habitcount account ID. We receive and store:

2.6 What we do not collect


Habitcount is a counting tool, and you decide what to count. Some counters can reveal information about your health or habits, for example cigarettes, alcoholic drinks, pills or medication, calories, water, caffeine, exercise or meditation. The notes you add to entries can do the same. We treat all synced counters, entries, notes and the statistics derived from them as potentially health-related, including "data concerning health" under the EU and UK GDPR and "consumer health data" under US state laws.

3.1 Friend challenges

Friend challenges let you compare one counter with friends. They are off until you use them, and they need an account with sync, because the totals go through our server.


The table below lists the legal bases we rely on under the EU and UK GDPR. Similar bases apply under the Law of Georgia on Personal Data Protection.

PurposeInformation usedLegal basis
Creating your account, signing you in, keeping sessions, sending verification codes and password-reset emailsSign-in details, password hash, sessions, registered devicesPerformance of our contract with you (Art. 6(1)(b))
Storing, backing up and syncing your counters and entriesSynced counters, entries, notes, templates, settings, derived statisticsPerformance of our contract with you (Art. 6(1)(b)). For health-related information, your explicit consent (Art. 9(2)(a))
Protecting accounts and our service: rate limits, lockouts, abuse prevention, securityIP address, email address, device ID, failed-attempt countsOur legitimate interest in keeping accounts and the service secure (Art. 6(1)(f))
Honouring account-deletion requests even after recovery from an older backupAccount ID and deletion-request timeOur legitimate interest in preventing deleted accounts from being restored (Art. 6(1)(f)) and, where applicable, our legal obligation to honour deletion requests (Art. 6(1)(c))
Serving exchange rates and app configurationIP address and request data, used only to deliver the responseOur legitimate interest in providing app features (Art. 6(1)(f))
Answering support requestsTicket contents, reply-to email, device ID, app version, platform, diagnostics, account IDOur contract with you when the request concerns your account or subscription (Art. 6(1)(b)), otherwise our legitimate interest in helping you (Art. 6(1)(f))
Managing subscriptions and access to Pro featuresSubscription status and purchase eventsPerformance of our contract with you (Art. 6(1)(b)). Keeping records where the law requires it (Art. 6(1)(c))
Friend challenges: showing a friend your chosen name and daily totals for one counterChallenge links, pairings, display name, daily totals for the challenged counterYour explicit consent (Art. 6(1)(a) and Art. 9(2)(a)), given when you start or accept a challenge; withdrawn by stopping it
Usage statisticsUsage events, device ID, account IDYour opt-in consent (Art. 6(1)(a)); you can withdraw it at any time by turning the setting off. Also blocked when the app detects a phone-only region. Detection may be inaccurate.
Complying with the law and defending legal claimsAny relevant informationLegal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)). For health-related information, Art. 9(2)(f)

Where we rely on legitimate interests, you can object (section 9). We do not use automated decision-making that has legal or similarly significant effects on you, and we do not profile you.

We send only service emails: verification codes, password resets and replies to your support requests. We do not send marketing emails.


5. Who we share information with

We do not sell your personal information. We do not share it for cross-context behavioural advertising or targeted advertising, and we don't give it to data brokers.

We use a small number of service providers (processors). They handle data only on our instructions and only to run Habitcount:

ProviderWhat they doWhat they receiveLocation
3HCloud (server hosting)Runs our server and database, and holds a local backup copyAll server-side data described in section 2Poland (EU)
Cloudflare R2 (off-site recovery storage)Holds a nightly database backup and a separate minimal deletion-request ledger, both encrypted before upload; Cloudflare does not have the decryption keyEncrypted database copy and encrypted account ID/request-time recordsEuropean Union jurisdiction
Tucows (hosted email for iesllc.ge)Holds our mailboxEmails you send us and our repliesCanada
RevenueCat, Inc.Confirms purchases and tracks subscription statusApp user ID (anonymous, or your account ID after sign-in), purchase and subscription records, and the technical details needed to validate purchasesUnited States

Independent companies with their own privacy policies:

Friends you challenge. If you start or accept a friend challenge, that friend sees your chosen name and your daily totals for that one counter from the day the challenge started, as described in section 3.1. Anyone you send a challenge link to can see the counter's name, emoji and goal and your chosen name. We don't share anything else with them.

Other disclosures. We may disclose information when the law requires it, for example to answer a valid court order. We may also disclose it to protect the rights, safety or property of our users or others, or as part of a merger, acquisition or sale of assets. In a sale, we will tell you in advance, and this policy or an equally protective one will continue to apply. We will not share your information for any other purpose without your consent.


6. International transfers

We are based in the country of Georgia. Our server is located in Poland, in the European Union, and some service providers, including RevenueCat, are in the United States. Your information may therefore be processed outside the country where you live.

When we transfer personal information from the European Economic Area, the United Kingdom or Switzerland to a country that does not have an adequacy decision, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, or rely on the recipient's certification under a recognised framework. Our server is in the EU, so hosting needs no transfer safeguard; Canada, where our mailbox is hosted, has an EU adequacy decision; for RevenueCat in the United States we rely on the Standard Contractual Clauses in its data processing agreement. You can ask us for a copy of these safeguards using the contact details in section 12.


7. How long we keep information

InformationHow long we keep it
Data on your deviceUntil you delete it or delete the app. Deleting your account does not delete the data on your phone.
Account, synced counters, entries, templates, settings and registered devicesUntil you delete your account. After you ask to delete it, it is permanently deleted from our live database within 72 hours. We schedule deletion at 71 hours to allow time for processing. Until deletion completes you are signed out everywhere and the account cannot be used.
Habitcount session refresh-token hashesA session token expires after 60 days. We keep its hash through expiry to detect reuse of a rotated token, then delete the record seven days after expiry. Deleting your account removes these records sooner.
Apple sign-in refresh tokensStored encrypted while your account exists. When you ask to delete your account, we request revocation of every Apple authorization token we hold. We keep an encrypted copy only while a revocation needs to be retried, then delete it after Apple accepts the request. A failed revocation is monitored for follow-up.
Friend challenge links and pairingsA link stops working 30 days after you last shared it. Challenges and expired links are kept until the counter or your account is permanently deleted (see the rows above and below), so a stopped challenge can't reappear on another device. They contain no entries or totals; totals are calculated when a friend's Stats are shown.
Items you delete while keeping your accountMarked as deleted so your other devices can remove them too, then permanently removed 90 days later.
Verification-code and reset-link recordsHashes are deleted 7 days after they expire. Records of the email-sending job, which contain your email address and the code or link, are deleted automatically about 7 days after the email is sent.
Support tickets24 months after you send them, then deleted automatically. Tickets you sent while signed in are deleted sooner, with your account.
Usage statistics (while the setting is on)13 months, then deleted.
Subscription statusDeleted with your account. When your account is permanently deleted, we also ask RevenueCat to delete its subscriber record. Apple keeps its own purchase records under its own policies.
Purchase events received from RevenueCat3 years after we receive them, then deleted automatically. We keep them to document purchases and resolve billing disputes. When you delete your account, we remove the direct account link, but the retained event may still contain a RevenueCat subscriber ID or Apple transaction ID and therefore may remain identifiable. We do not treat these records as anonymous.
Security data in memory (IP address, email for rate limits)Up to 24 hours.
Server access logs14 days. They record the IP address, time, and page or API address of each request, and are used only to keep the service running and secure.
BackupsNightly database backups are kept on our server in Poland and, encrypted before upload, in Cloudflare R2's European Union jurisdiction. Both copies are deleted after up to 30 days. Data you delete may remain in older backups until they expire. If we ever restore a backup, we will delete again anything that was deleted after the backup was made.
Account-deletion receiptsWe keep the account ID and request time in our live database and an encrypted, separate recovery ledger for about 45 days after the request, long enough to cover the life of an older backup. We then delete these records on their respective scheduled retention cycles. They contain no counter content.

We may keep information longer where the law requires it or to establish or defend legal claims. We keep it only for that purpose.


8. How we protect information

No system is perfectly secure. If a breach affects your personal information, we will notify you and the relevant authorities where the law requires it.


9. Your rights and choices

9.1 Controls everyone has in the app

9.2 If you are in the European Economic Area, the United Kingdom or Switzerland

Habitcount is designed to use a phone-only mode when either the phone's region or the App Store account's country identifies one of these places. These signals can be wrong for someone travelling, living elsewhere, or using an account from another country. When this mode applies, new account sign-in and creation, Back up & sync, usage statistics and exchange-rate requests are switched off. New counters, entries and notes stay on your phone. If you signed in before phone-only mode applied, the app may keep your existing account identity on the phone so you can manage your subscription, sign out or request account deletion. It does not refresh your account profile or sync while phone-only mode is detected. Data synced before the mode applied may still be on our server until you delete your account. A sign-out or account-deletion request you choose to make may contact our server. Store billing and support can still contact their services. A request already in progress when the region signal changes cannot be recalled; the current App Store country may also become known after launch. The personal information we may receive while this mode applies includes:

We have not appointed a representative in these countries. Phone-only mode does not itself resolve whether one is legally required, because support and subscription information may still be processed. For questions or rights requests, contact us using the details in section 12. We will update this policy if our arrangements change.

You have the right to:

We reply within one month. For complex requests, we may extend this by up to two more months and will tell you if we do.

9.3 If Georgian law applies

Under the Law of Georgia on Personal Data Protection, you have the right to:

We respond within 10 working days. In special cases, we may extend this by up to 10 more working days and will tell you straight away if we do. You can complain to the State Audit Office of Georgia (sao.ge), which took over the supervisory functions of the Personal Data Protection Service on 2 March 2026, or you can go to court.

9.4 If you are a California resident

This section applies to the extent the California Consumer Privacy Act, as amended by the CPRA, applies to us.

What we collect (categories as named in the CCPA) in the last 12 months, and where it comes from:

CCPA categoryExamplesSource
IdentifiersEmail address, account ID, random device ID, IP address, Apple account identifierYou, your device, Apple
Customer recordsName (if Apple provides it), email addressYou, Apple
Commercial informationSubscription status and purchase eventsApple via RevenueCat
Internet or other electronic network activityUsage statistics (only if you turn them on), request dataYour device
Sensitive personal informationAccount login details (email and password), health-related information in synced counters and entriesYou

We collect these for the purposes in section 4 and disclose them only to the service providers in section 5, for those purposes. We keep them for the periods in section 7.

9.5 If you live in another US state with a privacy law

Residents of states with comprehensive consumer privacy laws (for example Virginia, Colorado, Connecticut, Utah, Texas and Oregon) may have the right to:

We process sensitive data, including health-related data, only with your consent. If we deny your request, you can appeal by replying to our decision or emailing the privacy contact with "Appeal" in the subject. We will answer within the time the law requires. If we deny the appeal, we will tell you how to contact your state Attorney General. Nevada residents: we do not sell covered information as defined in Nevada law.

9.6 Health-data laws (Washington, Nevada, Connecticut and others)

See our Consumer Health Data Privacy Policy for the rights specific to consumer health data, including how to confirm, access and delete it, withdraw consent and appeal.

9.7 How to make a request


10. Children

Habitcount is not directed at children. You must be 16 or older to create an account, and before you create an account the app asks for your year of birth. We use it only for that check and don't store it; we keep only the fact that you confirmed you are 16 or older. If the answer is under 16, the app doesn't let you create an account on that device. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us personal information, contact us and we will delete it.


11. Changes to this policy

We may update this policy when Habitcount or the law changes. We will change the "Last updated" date at the top. If we make a material change, we will tell you in the app before it takes effect. Where the law requires it, for example for a new use of health-related information, we will ask for your consent again.


12. Contact us