Privacy Policy

1. Introduction

This Privacy Policy explains how 2 Bears Software Limited (“we”, “us”, “our”) handles personal data when you use SoulBalm, SleepMore, or AffirmMind (“the Apps”). These Apps provide wellbeing‑focused audio and visual experiences, including relaxing soundscapes, sleep‑support audio, mood‑light displays, and positive affirmation playback.

We are committed to protecting your privacy and complying with applicable data protection laws worldwide, including (where applicable) the UK GDPR, EU GDPR, Data Protection Act 2018, CCPA/CPRA, PIPEDA, Australia’s Privacy Act 1988, Brazil’s LGPD, India’s DPDPA 2023, and other equivalent privacy standards.

For the purposes of applicable data protection laws, 2 Bears Software Limited is the data controller. The Apps are designed to operate with minimal data collection. All core app functionality operates locally on your device.

2. Data We Collect

2.1 No Personal Data Collected by the Apps Directly

The Apps themselves do not collect, store, transmit, or access:

• Names
• Email addresses
• Contact details
• Photos, videos, or audio recordings created by you
• Device files or folders
• User accounts or login information
• Payment information (handled solely by the App Store or Google Play)

We do not monitor, access, review, or moderate any audio content, custom experiences, or preferences you create or use within the Apps. You are solely responsible for any content you record or import.

2.2 User‑Added Audio Files (Custom Experiences)

Some versions of the Apps allow you to create custom experiences using audio files stored on your device.

• Audio files you record within the App or import from your device remain stored only on your device.
• They are never uploaded, transmitted, or accessible to us, Firebase, or any third party.
• The Apps may record only the fact that a custom option was created, not the content of the audio file.

2.3 Local Processing on Your Device

The following processing happens only on your device:

• Audio playback
• Mood‑light visual effects
• Sleep or affirmation playback
• Storage of your selected options and custom experiences
• Subscription or purchase verification (via the app store)

No data from these processes is transmitted to us.

3. Analytics and Crash Reporting (Firebase)

The Apps use Firebase Analytics and Firebase Crashlytics, services provided by Google LLC, to collect technical data. This helps us understand general usage patterns and diagnose technical issues.

Firebase may collect:

• Device model and operating system version
• App version and installation source
• App‑instance identifier (pseudonymous, not your real identity)
• Device identifiers, which may include the Android Advertising ID
• Country‑level location (approximate, not precise)
• Session data (e.g., number of sessions, session duration, first opens, app updates)
• Screen views and general feature usage (e.g., which moods, sleep tracks, or affirmations are used)
• Performance data such as load times and stability metrics
• Crash logs, stack traces, and device state at the time of a crash

Firebase does not collect personal information such as names, email addresses, audio files, custom content, or anything stored on your device.

Analytics and crash data collected by Firebase, including any device identifiers, is pseudonymous rather than fully anonymous. While it cannot directly identify you by name, device identifiers such as the Android Advertising ID may be considered personal data under some privacy laws. This data is used solely to maintain and improve the Apps.

Firebase Analytics and Crashlytics data is processed by Google LLC. See the International Data Transfers section for details. You can reset or limit the use of your Advertising ID through your device settings under Google > Ads.

4. Advertising Data (Free Versions Only)

Free versions of the Apps display non‑personalised ads via Google AdMob. Ads are selected based on the context of the app, not on your personal browsing history or behaviour. AdMob may collect:

• Device identifiers
• Approximate location
• App interaction data

This data is processed under Google’s own Privacy Policy. We do not receive, store, or access this advertising data.

5. How We Use Data

We use data only to:

• Provide audio playback and visual effects
• Save your preferences locally
• Verify subscription or purchase status
• Display ads in Free Versions
• Improve app stability and performance through Firebase Analytics
• Diagnose crashes and technical issues through Firebase Crashlytics

We do not use your data for profiling, behavioural advertising, or cross‑app tracking.

6. Legal Basis for Processing

Where required by law, we process data under:

• Performance of the Apps’ core functions requested by you
• Legitimate interests in ensuring app stability, diagnosing crashes, and improving performance through anonymised or pseudonymous technical data
• Legitimate interests in displaying non‑personalised advertisements in Free Versions of the Apps
• Your consent, where required by applicable law for Firebase Analytics data including device identifiers such as the Advertising ID — in jurisdictions where consent is required, Google’s own consent mechanisms may apply

Where processing is based on consent, you may withdraw consent by resetting or limiting your Advertising ID in your device settings, or by uninstalling the Apps.

7. User‑Supplied Content

Where the Apps allow you to record or import audio, you are solely responsible for ensuring that any content you use is owned by you or that you have the right to use it. We are not responsible for any third‑party rights that may apply to user‑supplied audio content.

8. No Automated Decision‑Making

The Apps do not use automated decision‑making or profiling as defined under the UK GDPR or EU GDPR (Article 22). No decisions with legal or similarly significant effects are made about you automatically.

9. Data Sharing

We do not sell, rent, or trade personal data. The only third parties involved are:

• Google AdMob — advertising in Free Versions only
• Firebase Analytics and Crashlytics — pseudonymous technical and usage data
• App Store / Google Play — payments and licensing

These services operate under their own terms and privacy policies. We are not responsible for their independent processing, outages, policies, or continued availability.

10. Third‑Party Services

The Apps rely on:

• Firebase Analytics — pseudonymous usage analytics
• Firebase Crashlytics — crash and performance reporting
• Google AdMob — advertising in Free Versions
• App Store / Google Play — payments and licensing
• Device‑level audio and visual rendering services

These services operate independently of us. We are not responsible for their data collection practices, outages or errors, privacy policies, or continued availability or accuracy.

11. International Data Transfers

All core app data (preferences, custom audio selections) is stored solely on your device and is never transferred internationally by us.

Firebase Analytics, Firebase Crashlytics, and Google AdMob data is processed by Google LLC, which operates servers in the United States and other countries. For users in the UK and EEA, these transfers are carried out under:

• Google’s Standard Contractual Clauses (SCCs) approved by the European Commission
• The UK International Data Transfer Agreement (IDTA) for UK users

Google LLC is certified under the EU‑US Data Privacy Framework. No other personal data is transferred internationally by us.

12. Data Storage & Security

• All user preferences and custom audio selections are stored locally on your device.
• Custom audio files remain entirely on your device and are never transmitted to us.
• We do not store personal data on external servers.
• Firebase analytics and crash data, including device identifiers, is stored on Google’s infrastructure.
• Local app storage relies on Android’s app sandboxing and device‑level security controls.
• You are responsible for backing up your own device data.
• We are not responsible for data loss, corruption, or deletion caused by device failure, user action, or third‑party services.

13. Data Retention

Locally stored app data (preferences, custom audio selections) remains on your device until you delete it, clear app data, or uninstall the Apps.

Firebase Analytics and Crashlytics data is retained by Google in accordance with Google’s own retention policies. We do not control Google’s retention schedules for this data.

Emails you send us are retained for up to 24 months for support and record‑keeping purposes only. They are not shared with third parties and are deleted when no longer needed to resolve your enquiry.

14. Accuracy and Reliability

The Apps provide audio and visual experiences for relaxation, sleep support, and wellbeing. While we aim for a smooth experience, we cannot guarantee uninterrupted audio playback, perfect synchronisation of visual effects, or error‑free operation. You must not rely on the Apps in situations where accuracy or reliability is essential.

Nothing in the Apps or this Privacy Policy constitutes medical, therapeutic, or legal advice.

15. Children’s Privacy

The Apps are not intended for children under 13. We do not knowingly collect personal data from children.

16. Your Rights (UK and EU/EEA Users)

If you are located in the UK or EU/EEA, you have rights under the UK GDPR or EU GDPR to:

• access information about how your data is processed
• request rectification of inaccurate data
• request erasure of your data
• object to or restrict certain processing
• data portability where applicable
• withdraw consent at any time
• lodge a complaint with a supervisory authority

Because we do not store personal data on our own servers, most of these rights apply to data held by Google (Firebase, AdMob). For requests relating to data held by Google, please refer to Google’s own privacy controls and privacy policy.

If you are in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Our ICO Registration Number is ZC116025.

If you are in the EU or EEA, you have the right to lodge a complaint with your local Data Protection Authority (DPA).

To exercise any right that requires our assistance, contact us at 2BearsSoftware@gmail.com.

17. US Residents — CCPA / CPRA

If you are a resident of the United States, including California, you may have rights under the CCPA/CPRA to know, delete, and opt out of the sale or sharing of personal information.

We do not sell or share personal information. Core app data remains on your device and is not collected by us. Firebase and AdMob data is processed by Google under their own policies. You may contact us at 2BearsSoftware@gmail.com with any privacy‑related requests.

18. Canadian Residents — PIPEDA

We collect only limited pseudonymous technical data through Firebase for the purpose of app stability and improvement. We do not share personal data with third parties beyond the Google services described above. You may request access to or deletion of any data we hold by contacting us.

19. Australian Residents — Privacy Act 1988

We handle personal information in accordance with the Australian Privacy Principles. You have the right to access and correct personal information we hold about you. Contact us at 2BearsSoftware@gmail.com.

20. Brazilian Residents — LGPD

We process your personal data on the basis of your consent (Art. 7, I, LGPD) and our legitimate interests in maintaining app stability and performance (Art. 7, IX, LGPD). You have the rights of confirmation, access, correction, anonymisation, deletion, portability, and information about sharing. Contact us to exercise these rights.

21. Indian Residents — DPDPA 2023

We process personal data only for the purposes described in this policy and only with your consent. You have the right to access information, correct inaccuracies, and withdraw consent. Contact us at 2BearsSoftware@gmail.com.

22. Governing Law and Jurisdiction

This Privacy Policy, and any dispute or claim arising out of or in connection with it or your use of the Apps, shall be governed by and construed in accordance with the laws of England and Wales.

Where legally permitted, any legal proceedings relating to this Privacy Policy or your use of the Apps must be brought exclusively in the courts of England and Wales.

Nothing in this section affects any mandatory rights you may have under the laws of your country of residence, including any right to bring proceedings before your local courts that cannot be waived or restricted by applicable law.

23. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of the Apps after changes are published constitutes acceptance of the updated policy. The effective date at the top of this page will reflect the date of the most recent update.

If we introduce new features that materially change what personal data the Apps collect, store, transmit, or share, we will update this Privacy Policy before or when those features become available. Where a new feature requires new consent or a materially different use of personal data, we will request the relevant consent before that feature is used.

24. Contact