Privacy Policy

This policy covers the Elements iOS app. It is separate from, and additional to, the general site privacy policy at thesolanalabs.com/privacy-policy/.

Elements is an iOS app that lets you design and place widgets. This policy explains, in plain terms, exactly what the app touches, what stays on your phone, and the few things that leave it.

1. Who we are

Elements is published by THE SOLANA LABS (PRIVATE) LIMITED (CUIN 0347376), a company incorporated in Pakistan.

• Registered office: Minhaj Chowk, Saghar, Talagang 48150, Pakistan
• Office: Street No 7, Shah Khalid Colony, Rawalpindi 46200, Pakistan

Email: [email protected]

For the purposes of the UK GDPR and EU GDPR, that entity is the data controller for the limited processing described in section 4.

2. What we do not do

We want to be specific, because “we value your privacy” is not information. Elements contains:

• No user accounts. There is nothing to sign up for and no password.
• No analytics SDK. We do not measure your usage, sessions, screens or taps.
• No advertising, no ad identifiers, no IDFA. The app never asks for App Tracking Transparency permission, because it has nothing to track you with.
• No crash-reporting or attribution SDK.
• No selling or sharing of personal information, for any purpose, ever. We do not sell or share personal information as those terms are defined under the California Consumer Privacy Act.
• No profiling and no automated decision-making.

3. What stays on your device

Everything you create in Elements is stored in the app’s own container on your iPhone and shared only with the app’s own widgets. None of it is transmitted to us or to anyone else. Deleting the app deletes all of it.

That includes:

• Your designs — themes, faces, backgrounds, accents, typography and layout choices.
• Your mini-app records — habits and check-ins, tallies and counters, subscription renewals, readings, canvases, quotes you write, saved places and world clocks, countdown and “days since” dates.
• Your settings — units, preferred theme, refresh preferences.
• Your widget diagnostics — the Widget Health screen keeps a capped local log of when your widgets reloaded. It exists so you can see your widgets are updating. It is never transmitted.

Device permissions we ask for, and why

We only ask when a feature needs it, and the app works without any of them.

You can withdraw any of these at any time in iOS Settings. The affected widget will say what it is missing rather than failing silently.

4. The few things that leave your device

Elements makes a small number of network requests. None of them carry your name, your account, an advertising identifier, or a profile of you, because the app holds none of those.

4.1 Weather

Weather comes from Apple Weather (WeatherKit). Your coordinates — or the place you pinned — are sent to Apple to get a forecast. Apple’s handling of that request is governed by Apple’s own privacy policy.

Optionally, you may enter your own OpenWeather API key in Settings to get air quality, which Apple does not publish. If you do, coordinates go to OpenWeather under your own key and their terms. Your key is stored in your device’s Keychain, is never shared with the widget extension, and is never sent to us.

4.2 Public content feeds

These requests fetch public content. Each carries only what it needs, and nothing about you:

For news, note that you choose the publishers. When your device requests a feed, that publisher’s server can see your device’s IP address, exactly as it would if you opened the page in a browser. Elements downloads no images from feeds and stores only the headline, the name you gave the feed, and the time.

4.3 Purchases

Purchases are processed by Apple and managed through RevenueCat, Inc., which we use to validate subscriptions and restore them across your devices.

RevenueCat receives purchase history — what was bought, when, and whether it is still active — associated with an anonymous identifier that RevenueCat generates. We do not send RevenueCat your name, your email, or any custom user ID, and RevenueCat does not use this data for tracking.

Your payment details go to Apple and are never seen by us or by RevenueCat.

RevenueCat’s privacy policy: revenuecat.com/privacy

4.4 When you contact us

If you email support, we receive your email address and whatever you choose to write. We use it only to answer you, and we do not add you to any mailing list.

5. Legal bases for processing (UK/EU GDPR)

Most of what Elements does involves no processing by us at all, because the data never reaches us. Where it does:

• Purchase data (via RevenueCat) — processed for the performance of a contract (giving you what you paid for) and our legitimate interest in preventing fraudulent entitlements.
• Support email — processed on the basis of your consent, given by choosing to write to us, and our legitimate interest in supporting the app.
• On-device permissions (Calendar, Reminders, Health, Location, Photos, Notifications) — you grant these to the app on your own device through iOS. We never receive that data, so we do not process it.

6. Retention

• On-device data is kept until you delete it in the app, or until you delete the app. We cannot delete it for you, because we cannot reach it.
• Purchase records are retained by RevenueCat and Apple for as long as needed to manage your subscription and to meet tax and accounting obligations.
• Support email is kept only as long as needed to resolve your question.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, port or restrict processing of your personal data, to object to processing, and to lodge a complaint with your data protection authority. Residents of California have rights of access, deletion, correction and portability, and the right not to be discriminated against for exercising them.

In practice, for Elements:

• Access and deletion of your app data is immediate and in your hands: it is all on your device, visible in the app, and removed entirely when you delete the app.
• For purchase records, write to us at the address in section 1 and we will action the request with RevenueCat.

We do not charge for these requests and will respond within the period required by applicable law.

8. Children

Elements is not directed at children under 13, and we do not knowingly collect personal information from them. The app has no account system, no social features, no chat and no user-to-user content of any kind.

9. International transfers

The publisher is established in Pakistan, and RevenueCat, Inc. is established in the United States. Neither is covered by a UK or EU adequacy decision.

In practice the only personal data that reaches the publisher is the content of an email you choose to send us (section 4.4). Purchase data is held by RevenueCat and by Apple, not by us. Where purchase data is transferred out of the UK or EEA, that transfer relies on the safeguards offered by the processor, including Standard Contractual Clauses where applicable.

Your on-device data — designs, habits, counters, renewals, readings, health figures, calendar and reminders — is never transferred anywhere, because it never leaves your device.

10. Security

Your data stays inside the app’s sandboxed container, protected by iOS file protection and your device passcode. Your optional OpenWeather API key is held in the iOS Keychain. All network requests the app makes use HTTPS; the news feature refuses plain-http URLs both when you enter one and again when fetching, so a feed cannot be downgraded later.

11. Changes to this policy

If this policy changes materially, we will update the date at the top and note the change in the app’s release notes. Continuing to use Elements after a change means you accept the updated policy.

12. Contact

THE SOLANA LABS (PRIVATE) LIMITED · CUIN 0347376
Registered office: Minhaj Chowk, Saghar, Talagang 48150, Pakistan
Office: Street No 7, Shah Khalid Colony, Rawalpindi 46200, Pakistan
Email: [email protected]