Tortli

Privacy Policy

Effective date: 22 October 2026

The short version

1. Who is responsible (data controller)

Tortli is developed by Dennis Naci Hansen, a private individual in Denmark (“we”, “us”). He is the data controller for the processing described here.

Contact: tortliapp@outlook.com

2. Data stored only on your device

To work, Tortli saves the following in the app’s local storage on your iPhone:

This data is not sent to us or to anyone else. We cannot see or access it. It may be included in your device backups (for example iCloud Backup) if you have turned them on. Those backups are covered by Apple’s terms.

Because this data stays under your control on your device, we do not process it as a data controller. You can delete it at any time, see section 10.

3. Motion sensor (tilt steering)

In the pool mini-game, you can steer the turtle by tilting your phone. For this, the app reads the motion sensor (gravity and accelerometer data, via Apple’s CoreMotion) in real time while the pool screen is open. This data is used only on your device to move the turtle. It is not stored and not sent anywhere. You can turn tilt steering off in the pool screen.

4. Reminders (local notifications)

Water reminders, challenge reminders and the optional reminder two days before a free trial ends are local notifications. They are scheduled by iOS on your device. No push server is involved and no data is sent anywhere. Tortli only shows notifications if you allow them. You can change this at any time in the iOS Settings app.

4a. Apple Health (optional)

If you turn on Apple Health in Tortli’s settings, Tortli writes the water you log to Apple Health on your device (as “Water”). Tortli does not read any data from Apple Health. This data is never sent to us and is never used for advertising. You can turn it off at any time in Tortli’s settings, and manage or delete the data in the Health app.

5. Purchases: Apple and RevenueCat

Apple processes all payments through the App Store. We never receive your name, email address or payment details. Apple acts as an independent controller under its own privacy policy.

RevenueCat, Inc. (USA) runs the subscription management for Tortli as our data processor. When the app starts and when you buy or restore a purchase, the RevenueCat software in the app sends RevenueCat:

Tortli does not send RevenueCat your hydration data, any profile details, or your device’s advertising identifier.

Purposes: to show the right products and prices, unlock and restore Premium, verify purchases, prevent fraud, help you if you contact support, and give us anonymous, aggregated subscription statistics.

Legal bases (GDPR): performance of a contract, Art. 6(1)(b), for providing and restoring what you bought. Our legitimate interests, Art. 6(1)(f), for showing offers, checking Premium status, preventing fraud and keeping aggregated statistics.

RevenueCat processes this data in the USA under a data processing agreement that includes the European Commission’s Standard Contractual Clauses. See RevenueCat’s privacy policy.

6. What Tortli does not do

7. If you email us

If you contact us by email, we use your email address and your message to answer you. Legal basis: our legitimate interest in replying to you, Art. 6(1)(f), or a contract, Art. 6(1)(b), if it concerns a purchase. Our mailbox is provided by Microsoft (Outlook.com). We delete support emails when they are no longer needed, normally no later than 12 months after the matter is closed.

8. Recipients at a glance

RecipientRoleWhat
RevenueCat, Inc. (USA)ProcessorAnonymous app user ID, purchase/receipt data, technical device data, IP address
Apple Inc. / Apple Distribution InternationalIndependent controllerPayment and App Store purchase handling
Microsoft (Outlook.com)Email providerOnly if you email us

9. How long data is kept

10. Your rights and how to delete your data

Under the GDPR, you have the right to access, rectify and erase your personal data, to restrict processing, to data portability, and to object to processing based on legitimate interests.

Deleting data does not cancel a subscription. Cancel it in your Apple ID subscription settings. If you restore purchases later, a new record is created.

11. Children

Tortli is a general-audience app. It is not specifically directed at children, and we do not knowingly collect personal data from children. The app has no accounts, and hydration data stays on the device. Purchases require an Apple ID and are subject to Apple’s parental controls, such as Ask to Buy. If you believe a child has sent us personal data, email us and we will delete it.

12. Right to complain

You can complain to the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark, dt@datatilsynet.dk, www.datatilsynet.dk. You can also complain to the supervisory authority in the EU/EEA country where you live. We would appreciate the chance to help first, so please feel free to email us.

13. Changes

We may update this policy, for example if the app changes. The current version is always on this page, with its effective date. If a change is significant, we will also point it out in the app or on this page.