TraceYourTime
What we do with your data, in short: almost nothing.
Privacy Policy
Effective date: [05.10.2026] · Version 1.1
Document information
Entity name: K4M OÜ
Contact email: info@traceyourtime.com
Document type: Privacy Policy
Applies to: TraceYourTime for iPhone, iPad, Mac and Apple Watch, and traceyourtime.com.
Governing law: Laws of the Republic of Estonia
Privacy Policy
1. Summary: the short version
TraceYourTime is built to give you insight into how you spend your time without taking a copy of your life. The app reads events from your Apple Calendar directly on your device. Your calendar data, your activities, your notes, your favorites and your goals stay on your devices and, when iCloud is turned on, in your own iCloud account. The app does not send any of your data to servers run by us; we do not run such servers. We do not sell your data. We do not share it with advertisers. We do not use it to train AI models.
In plain English: We can’t see your calendar, your activities, or your goals. Our business model is selling software, not data. If you delete the app, there is nothing for you to delete on our servers, because there is nothing there.
2. Who we are
This Privacy Policy is issued by K4M OÜ (“we”, “us”, “our”), the publisher of the TraceYourTime application and the associated website traceyourtime.com (together, the “Service”). K4M OÜ is the controller of personal data processed in connection with the Service, where “controller” has the meaning given in Article 4(7) of the EU General Data Protection Regulation (“GDPR”).
Contact for data-protection matters
Email: info@traceyourtime.com
We have not appointed a statutory Data Protection Officer because we do not meet the thresholds in GDPR Article 37. For any privacy-related question, write to the email above and we will reply within the timelines required by applicable law.
3. Scope of this Policy
This Policy applies to (a) your use of the TraceYourTime application on iPhone, iPad, Mac and Apple Watch; (b) your visits to traceyourtime.com; and (c) any email correspondence you have with us. It does not apply to third-party services you may choose to use alongside TraceYourTime, including Apple iCloud, Siri, Apple Calendar accounts provided by Google, Microsoft, or others, and any external calendars you have linked at the operating-system level. Those services are governed by their own privacy policies.
4. What data the app processes and where it goes
The list below is the core of this Policy. It covers every category of data TraceYourTime processes, where the processing happens, and why.
Apple Calendar events
Examples: event titles, times, calendar names, notes, attendees if present.
Where processed: on your device only.
Purpose: to build your summaries, goals and views.
Completed timer and Pomodoro sessions
Examples: sessions you start in the app, by Siri or Shortcuts, or through a Focus filter.
Where processed: written to a calendar you select, via Apple EventKit. Sessions started by a Focus filter carry a small marker so the app can show your Time in Focus.
Purpose: because you asked the app to log them.
Your app content and settings
Examples: favorites, goals, streaks, achievements, selected calendars, preferences.
Where processed: on your device and, when iCloud is turned on, in iCloud key-value storage in your own iCloud account, so they are available on all your devices.
Purpose: to operate the app across your devices.
Apple Health data
Examples: workouts, sleep and mindful minutes read from Apple Health; completed Pomodoro sessions written to Apple Health as mindful minutes.
Where processed: on your device only. Only if you turn these options on in the app and allow access in the Health permissions.
Purpose: to add health context to your summaries and to record your focus time in Apple Health.
Data shared between your iPhone and Apple Watch
Examples: favorites, the running session, goal progress, your plan level.
Where processed: sent directly between your paired devices by Apple’s Watch Connectivity.
Purpose: to show and control tracking on your watch.
Focus filters, Siri and Shortcuts
Examples: the favorite or Pomodoro a Focus should start; your Siri questions such as “How much time did I spend on Work this week?” and the answer.
Where processed: Focus filters and Shortcuts actions run on your device. When you use Siri, your request and the spoken answer (for example a calendar name and a number of hours) are handled by Siri under Apple’s privacy terms.
Purpose: to start, stop and report on tracking the way you set it up.
Notifications
Examples: goal reminders, streak reminders, Pomodoro alerts.
Where processed: scheduled on your device. The app does not use push notifications.
Purpose: to remind you, if you allow notifications.
Exports and share cards
Examples: CSV files, PDF reports, JSON backups, share card images.
Where processed: created on your device. They leave your device only when you choose where to send them.
Purpose: because you asked for them.
App Store analytics
Examples: aggregate download and crash metrics provided by Apple.
Where processed: on Apple’s infrastructure.
Purpose: to see whether the app is working and being used, at an aggregate level.
Subscription status
Examples: whether you have Pro or Expert, and when it renews or ends.
Where processed: Apple handles billing; the app checks your entitlement on your device through Apple’s StoreKit.
Purpose: to unlock TraceYourTime Pro and Expert features.
Email correspondence
Examples: what you send us at info@traceyourtime.com.
Where processed: our email provider.
Purpose: to respond to you.
We do not receive a copy of your calendar events, your health data, your notes, your goals, or any other personal content you interact with inside the app. These remain on your devices or, where applicable, in your iCloud account, which is under your Apple Account.
5. Data we deliberately do not collect
To make it unambiguous, we do not collect:
Your calendar events or their content.
Your Apple Health or Apple Fitness data.
Your location. The app does not request access to your location. If you set a Focus to turn on at a place, iOS handles that, and the app only learns that the Focus turned on.
Device identifiers used for tracking, or advertising identifiers.
Your contacts or address book.
Your photos.
Your IP address at the application layer. The app makes no network requests to us; your device only exchanges data with Apple’s services such as the App Store and iCloud.
Any data for advertising, profiling, or AI-model training.
6. Legal bases we rely on (for users in the EU / UK)
Where we do process personal data, we rely on the following GDPR / UK GDPR Article 6 legal bases:
Performance of a contract (Art. 6(1)(b)): to provide the Service you have installed and, if applicable, paid for.
Legitimate interest (Art. 6(1)(f)): for aggregate App Store analytics, crash monitoring, and responding to your email. We have assessed that these interests do not override your fundamental rights because the processing is minimal, aggregated, and does not allow us to identify you.
Consent (Art. 6(1)(a)): for optional features such as Apple Health integration and notifications. You can withdraw consent at any time in the app’s Settings or in your device’s Settings.
Legal obligation (Art. 6(1)(c)): to comply with requests from regulators and tax authorities.
7. How long we keep data
Because we do not receive your calendar or activity data, there is nothing for us to retain about your day-to-day use of the Service. We retain the following:
Email correspondence: up to 24 months after the conversation closes, unless a longer period is required (for example, for a dispute or legal claim).
Purchase and subscription records: kept by Apple for the period Apple requires, including for tax purposes and to process refunds. We only receive aggregate sales reports from Apple.
Aggregate App Store metrics: for as long as Apple makes them available; these are not attributable to you.
The data that remains on your devices (favorites, goals, preferences, notes) stays until you delete it in the app, use “Delete All App Data” in Settings, or uninstall the app. Data in your iCloud account is managed through your Apple Account. Calendar events created by the app stay in your calendar until you delete them there.
8. Who we share data with
We share personal data only with the following parties, where strictly necessary to operate the Service:
Apple Inc. and its subsidiaries: for App Store distribution, App Store Connect analytics, in-app purchases through StoreKit, iCloud storage of your app settings in your own iCloud account, and Siri. Apple acts as an independent controller for payments, and Apple’s processing of your iCloud and Siri data is governed by your agreement with Apple and Apple’s Privacy Policy.
Our email provider: Hostinger, which hosts the info@traceyourtime.com mailbox.
Our website host: Hostinger, which serves traceyourtime.com.
Professional advisors: our accountants and lawyers, under duty of confidentiality, where necessary.
We do not sell personal information to any third party. We do not share personal information for cross-context behavioral advertising. We do not share personal information with advertisers.
9. International transfers
Because your calendar and activity data never leaves your devices except into your own iCloud account, no transfer of that data to us occurs as a result of using TraceYourTime. Where limited data (email, website data) is processed outside the European Economic Area, the following safeguards apply:
Apple relies on Standard Contractual Clauses and other transfer mechanisms for transfers outside the EEA. See Apple’s Privacy Policy at apple.com/legal/privacy.
Our email provider and website host process data under Standard Contractual Clauses and, where relevant, the EU-U.S. Data Privacy Framework.
You can request a copy of the relevant safeguards by writing to the contact email above.
10. Your rights
Depending on where you live, you have the following rights. We honor these rights globally as a matter of policy, even where local law does not require us to.
Rights under EU / UK GDPR
Right of access to your personal data.
Right to rectification of inaccurate data.
Right to erasure (“right to be forgotten”).
Right to restriction of processing.
Right to data portability.
Right to object to processing based on legitimate interest.
Right not to be subject to decisions based solely on automated processing (we do not make such decisions).
Right to withdraw consent at any time where processing is based on consent.
Right to lodge a complaint with your local data-protection authority. In Estonia this is the Andmekaitse Inspektsioon (aki.ee).
Rights under California law (CCPA / CPRA)
California residents have the right to know what personal information we collect, the right to delete it, the right to correct it, and the right to opt out of sale or sharing. We do not sell or share personal information within the meaning of the CCPA. We treat all our users in accordance with the stricter of the standards described in this Policy.
Rights under Brazilian law (LGPD)
Residents of Brazil have the rights listed in Article 18 of the Lei Geral de Proteção de Dados, including confirmation of processing, access, correction, anonymization, portability, deletion, and information about sharing.
Rights under Canadian law (PIPEDA / Québec Law 25)
Canadian residents have the rights to access and correct their personal information, to withdraw consent, and, in Québec, additional rights including data portability and an explicit right to request deletion.
How to exercise your rights
Most of your data is under your own control: you can view, export and delete it in the app and in your Apple Account. For anything we hold (mainly email correspondence), write to info@traceyourtime.com. We reply within 30 days for EU / UK requests and within the applicable timelines for other jurisdictions. We may ask you to verify your identity before acting on the request.
11. Children and young people
TraceYourTime is not directed at children under the age of 13 and is not intended for use by children under that age. If you are in the EU, the local minimum age for consent to information-society services is either 13, 14, 15, or 16, depending on the country; you must be at least the locally applicable age to use the app on your own. If we learn that we have inadvertently received personal data from a person below the applicable age, we will delete it.
12. Security
We take security seriously:
Your calendar and activity data never reaches us. This is the strongest security measure we can offer, because data we never receive cannot be breached on our side.
Data synced through iCloud is stored in your own iCloud account and protected by Apple’s iCloud security under your Apple Account.
We follow Apple’s platform security requirements, and the app makes no network connections of its own.
We will notify you and, where required, the competent supervisory authority of any personal-data breach within the timelines required by applicable law (72 hours under GDPR).
13. Artificial intelligence features
TraceYourTime does not currently include AI or machine-learning features. If we add them in the future, our approach will be:
Where technically feasible, models run on-device, using Apple Intelligence, Apple’s Foundation Models framework, or Core ML.
If any feature requires processing by a cloud model, it will be (i) opt-in, (ii) clearly labeled at the moment of use, and (iii) disclosed in this Policy before launch, with information about the processor.
We will not use your personal data to train our own or any third-party AI models.
14. Cookies and website analytics
The traceyourtime.com website is a static marketing page. It does not set tracking cookies and does not use cross-site analytics by default. If we add basic, privacy-preserving server-side analytics (for example Plausible or simple log analysis), we will update this Policy to describe what is collected, and we will not require consent for analytics that is genuinely aggregate and non-identifying, consistent with the ePrivacy Directive as implemented in your country.
15. Automated decision-making
We do not make decisions that produce legal or similarly significant effects on you using solely automated means. Suggestions and reminders in the app are advisory; any action you take is yours.
16. Changes to this Policy
When we make material changes to this Policy, we will (a) update the version number and effective date at the top of this document, (b) publish the new version at traceyourtime.com/privacy, and (c) mention the change in the app’s release notes in the App Store. Non-material changes (typographical corrections, clarifications) may be made without notice.
17. Contact
Questions or complaints about this Policy, or requests to exercise your rights:
Email: info@traceyourtime.com
Appendix A: Regional addendum for California
This addendum applies to consumers who are California residents, as additional disclosures required by the California Consumer Privacy Act as amended by the CPRA.
Categories of personal information
In the preceding 12 months we have processed the following categories of personal information as described in this Policy:
Identifiers (email address, if you write to us).
Commercial information (subscription and purchase records, held by Apple; we receive aggregate sales reports).
Internet or other electronic network activity information (aggregate App Store metrics).
Sources
Directly from you; from Apple in aggregate form.
Business purposes
To provide the Service, to operate subscriptions, to communicate with you.
Sale and sharing
We do not sell personal information and do not share it for cross-context behavioral advertising. We therefore do not offer a “Do Not Sell or Share My Personal Information” link because there is nothing to opt out of.
Right to limit use of sensitive personal information
We do not collect or use sensitive personal information for purposes that trigger the right to limit under the CPRA.
Non-discrimination
We do not discriminate against you for exercising any CCPA right.
Appendix B: Apple-specific disclosures
For clarity and to align with Apple’s App Store Privacy policy and App Privacy (“nutrition label”) requirements:
Data Linked to You: None.
Data Used to Track You: None. We do not use the App Tracking Transparency framework because we do not track.
Data collected by Apple: aggregate usage and crash metrics are collected by Apple at the App Store level, not by us.
Third-party SDKs: None. The app uses only Apple’s own frameworks (such as EventKit, HealthKit, StoreKit and App Intents). If we ever add a third-party SDK, we will update this Policy and the App Privacy label before doing so.