Privacy Policy
Effective Date: 7 February 2026 | Last Updated: 7 February 2026
1. Data Controller
Data Controller: George Parker (sole developer, acting as a sole trader)
Email: support@closerapp.co.uk
Jurisdiction: England and Wales, United Kingdom
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the Data Controller is George Parker. This means George Parker determines the purposes and means of processing your personal data in connection with the App.
2. Scope of This Policy
This Privacy Policy applies to the Closer mobile application ("App"), including all associated services such as widgets, Apple Watch companions, complications, and optional iCloud synchronisation features (collectively, the "Service"). By downloading, installing, or using the Service, you acknowledge that you have read and understood this Privacy Policy.
3. Information We Collect
We collect only the minimum data necessary to provide the Service. All data categories are listed below:
| Data Category | Examples | Storage |
|---|---|---|
| Financial Data | Asset names, values, categories, debt amounts | On-device only |
| Goal Data | Target amounts, deadlines, milestones achieved | On-device only |
| Preferences | Currency, display settings, notification preferences | On-device only |
| Anonymous Analytics | Feature usage counts, app opens (no personal identifiers) | TelemetryDeck (EU servers) |
| Purchase Data | Pro upgrade status | Apple (App Store) |
4. Information We Do Not Collect
We explicitly do NOT collect, store, or process any of the following:
- Your real name, email address, phone number, or physical address
- Bank account numbers, sort codes, credit/debit card details, or any payment credentials
- Login credentials for any financial institution
- Location data (GPS, IP-based geolocation, or similar)
- Device identifiers (IDFA, IDFV) for tracking or advertising purposes
- Browsing history, contacts, photos, or any data outside the App
- Biometric data (Face ID / Touch ID processing is handled entirely by Apple's Secure Enclave)
The App does not connect to your bank, building society, or any financial institution. All financial data within the App is manually entered by you.
5. Legal Basis for Processing (UK GDPR, Article 6)
We process your data under the following lawful bases:
| Purpose | Legal Basis |
|---|---|
| Providing core App functionality | Contract performance — necessary to deliver the Service you requested (Art. 6(1)(b)) |
| iCloud Sync (optional) | Consent — you explicitly enable this feature (Art. 6(1)(a)) |
| Anonymous analytics | Legitimate interest — to improve the App, with minimal privacy impact (Art. 6(1)(f)) |
| Processing in-app purchases | Contract performance — necessary to fulfil the purchase (Art. 6(1)(b)) |
6. How Your Data Is Stored
6.1 Local Storage (Default)
All financial data you enter is stored exclusively on your device using Apple's secure storage frameworks (UserDefaults with App Group containers, and Keychain Services for sensitive data such as API keys). We have no access to this data — it never leaves your device unless you explicitly enable iCloud Sync.
6.2 Optional iCloud Sync (Pro Feature)
If you enable iCloud Sync, your data is transmitted to and stored in your personal Apple iCloud account via Apple's CloudKit framework. Key points:
- Data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
- Data resides in your iCloud account — we have no server-side access
- iCloud Sync is governed by Apple's Privacy Policy
- You can disable sync or delete synced data at any time from iOS Settings
- No personal identifiers (names, emails) are stored alongside your financial data
6.3 Keychain & Secure Storage
Sensitive application data (e.g., API key obfuscation seeds) is stored using Apple's Keychain Services, which provides hardware-backed encryption via the device's Secure Enclave where available.
7. Data Sharing & Disclosure
We do not sell, rent, trade, or otherwise share your personal data with any third party for marketing, advertising, or data-brokering purposes. Full stop.
Your data may only be disclosed in these strictly limited circumstances:
- At your direction: If you use the App's Share feature to voluntarily share a progress card
- Legal obligation: If required by law, court order, regulatory authority, or to protect our legal rights under applicable law
- Vital interests: To protect someone's life in an emergency (Art. 6(1)(d) UK GDPR)
8. Third-Party Services
The App integrates with the following third-party services. Each operates independently under its own privacy policy:
8.1 Apple Platform Services
| Service | Purpose | Data Shared |
|---|---|---|
| App Store / StoreKit | In-app purchase processing | Transaction receipts (handled by Apple) |
| CloudKit (optional) | Cross-device data sync | Your financial data (stored in your iCloud) |
| WidgetKit | Home/Lock screen widgets | Display data (on-device only) |
| WatchKit | Apple Watch app & complications | Display data (on-device only) |
All Apple services are governed by Apple's Privacy Policy.
8.2 TelemetryDeck (Analytics)
We use TelemetryDeck for privacy-respecting, anonymous analytics. TelemetryDeck:
- Collects no personal data — no names, emails, IPs, or device identifiers
- Uses no cookies and does not track users across apps or websites
- Processes data on EU-based servers (GDPR-compliant)
- Provides only aggregate, anonymous statistics (e.g., "feature X was used 100 times this week")
- Is certified GDPR-compliant by design
See: TelemetryDeck Privacy Policy
8.3 Market Data APIs
| Provider | Purpose | Data Sent |
|---|---|---|
| Finnhub | Stock/equity price lookup | Stock ticker symbols only |
| CoinGecko | Cryptocurrency price lookup | Cryptocurrency identifiers only |
No personal data, device identifiers, or user information is sent to these services. Only the specific asset symbols you search for are transmitted via HTTPS.
9. Tracking & Cookies
The App does not use cookies, tracking pixels, advertising SDKs, fingerprinting, or any form of cross-app or cross-site tracking technology.
We do not participate in any advertising networks. The App contains no advertisements whatsoever.
10. International Data Transfers
Your financial data is stored locally on your device and, if iCloud Sync is enabled, within Apple's iCloud infrastructure. Apple may process iCloud data in data centres globally. Such transfers are covered by Apple's compliance with standard contractual clauses and applicable data protection frameworks.
Anonymous analytics data processed by TelemetryDeck is stored on EU-based servers. No international transfers of personal data occur as TelemetryDeck does not collect personal data.
11. Data Retention
| Data Type | Retention Period | Deletion Method |
|---|---|---|
| On-device financial data | Until you delete it or uninstall the App | Delete in-app or uninstall |
| iCloud synced data | Until you delete it from iCloud | iOS Settings → iCloud → Manage Storage |
| Net worth history | Rolling 90-day window | Automatically purged |
| Anonymous analytics | Aggregated, no personal data retained | N/A (no personal data) |
| Purchase records | Managed by Apple | Contact Apple Support |
12. Your Rights Under UK GDPR
Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights. Since we store your data locally on your device and do not maintain a central database, most of these rights are inherently satisfied:
| Right | How It Applies |
|---|---|
| Access (Art. 15) | All your data is visible directly in the App at all times |
| Rectification (Art. 16) | You can edit any data directly in the App |
| Erasure (Art. 17) | Delete data in-app, or uninstall to remove all local data |
| Restriction (Art. 18) | You can disable features (e.g., iCloud Sync) at any time |
| Portability (Art. 20) | Export your data via the App's export feature (Pro) |
| Objection (Art. 21) | Contact us to object to any processing based on legitimate interest |
| Withdraw Consent | Disable iCloud Sync at any time; this does not affect prior processing |
To exercise any of these rights, or if you have concerns about how your data is processed, contact us at support@closerapp.co.uk. We will respond within 30 days as required by law.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection.
13. Children's Privacy
The App is not directed at children under the age of 13 (or under 16 in the UK/EEA for GDPR purposes). We do not knowingly collect personal information from children. If you believe a child has provided data through the App, please contact us immediately and we will take appropriate steps.
14. Security Measures
We implement industry-standard technical and organisational measures to protect your data:
- Encryption at rest: Sensitive data stored using Apple's Keychain Services with hardware-backed encryption
- Encryption in transit: All network requests use HTTPS (TLS 1.2 or later)
- API key protection: API keys are obfuscated using XOR encryption and stored in the Keychain, never in plain text
- Biometric protection: Optional Face ID / Touch ID lock (processing handled by Apple's Secure Enclave — biometric data never leaves your device)
- Privacy screen: App content is automatically hidden in the iOS app switcher to prevent shoulder-surfing
- No remote servers: We do not operate servers that store your data, eliminating server-side breach risk
- Debug safeguards: All diagnostic logging is disabled in production builds
15. Financial Disclaimer
⚠️ Closer is NOT a regulated financial service.
The App is not authorised or regulated by the Financial Conduct Authority (FCA) or any other financial regulatory body. It is a personal tracking tool only and does not constitute:
- Financial, investment, tax, legal, or accounting advice
- A recommendation to buy, sell, or hold any security, cryptocurrency, or other financial instrument
- A substitute for professional financial planning or advice
All financial data displayed — including stock and cryptocurrency prices — is provided by third-party APIs for informational purposes only, may be delayed, and may contain inaccuracies. You should always consult a qualified, FCA-regulated financial adviser before making financial decisions.
Use of this App is entirely at your own risk.
16. Limitation of Liability
To the maximum extent permitted by applicable law (including the Consumer Rights Act 2015 where applicable), George Parker shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenues, data, use, goodwill, or other intangible losses resulting from:
- Your use of, or inability to use, the App
- Any errors, inaccuracies, or omissions in App content or calculations
- Third-party API data (including stock and cryptocurrency prices)
- Unauthorised access to or alteration of your data
- Any financial decisions made based on information displayed in the App
- Interruption or cessation of the Service
Nothing in this Privacy Policy excludes or limits liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be excluded by law.
17. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or App functionality. We will indicate changes by updating the "Last Updated" date at the top of this document. Material changes may also be communicated through an in-app notification. Your continued use of the App after any changes constitutes acceptance of the updated Privacy Policy.
18. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:
By using the Service, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information in accordance with it.