Privacy Policy
The short version
- Tortli has no account or login, no ads, no third-party analytics, no crash reporting and no tracking.
- Your water log, goal, profile details and settings are stored only on your device. We never receive them.
- Purchases are handled by Apple. Your Premium status is managed by RevenueCat using a random, anonymous ID.
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:
- your water log (drink type, amount and time of each entry), daily goal and units;
- profile details you can enter to calculate a goal: sex (optional), weight, activity level and climate;
- reminder settings (on/off, start and end time, interval) and your language;
- streaks, streak freezes, challenges, pool game scores, chosen skins, floats and pool toys, and the tilt-steering setting;
- a cached copy of your Premium status;
- a small local event log (max. 500 entries) of purchase-screen events, such as “paywall shown” or “purchase started”. It never leaves your device.
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:
- a random, anonymous app user ID created by RevenueCat. It is not linked to your name or Apple ID email;
- purchase information from the App Store, such as product, purchase and expiry dates, trial status and transaction IDs (receipt data);
- technical data, such as app version, iOS version, device model, language, country or App Store storefront, and your IP address, as with any internet connection.
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
- No user accounts, no login, no cloud sync run by us.
- No advertising and no advertising identifier (IDFA).
- No third-party analytics, crash reporting or tracking across apps or websites.
- No selling or sharing of personal data for marketing.
- No location, contacts, photos, camera, microphone or Apple Health access.
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
| Recipient | Role | What |
|---|---|---|
| RevenueCat, Inc. (USA) | Processor | Anonymous app user ID, purchase/receipt data, technical device data, IP address |
| Apple Inc. / Apple Distribution International | Independent controller | Payment and App Store purchase handling |
| Microsoft (Outlook.com) | Email provider | Only if you email us |
9. How long data is kept
- On your device: until you delete it, reset it, or delete the app.
- RevenueCat: as long as it is needed to provide and restore your purchases and for fraud prevention and statistics. We delete it sooner if you ask (see section 10).
- Apple: according to Apple’s own policies.
- Support emails: see section 7.
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.
- Data on your device: “Reset data & restart onboarding” in Settings clears your water log and settings. Deleting the app removes all data Tortli has stored on your device. Copies may remain in your own device backups.
- RevenueCat data: email tortliapp@outlook.com. As we do not know who you are, please include something that lets us find your record, such as the Order ID from Apple’s purchase receipt email, or the product and date you bought it. We will have the data deleted and reply within one month.
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.