Privacy Policy

Effective date: 2 October 2026

This Privacy Policy explains how DACCAA Ltd ("we", "us", "our") collects, uses and shares information when you use the Rotely app ("Rotely", the "App") on iPhone, iPad and Mac. DACCAA Ltd is the data controller for the personal data described in this policy.

Summary

• Rotely does not require an account.
• Your packs and cards stay on your device and, if you use iCloud sync, in your own iCloud account. We cannot see them.
• Rotely does not use advertising, tracking or third-party analytics.
• If you contact us through the App, we receive your name, email address, message and basic device and app information so we can reply.
• If you use Rotely Pro, RevenueCat processes your purchase information on our behalf to manage your subscription.
• AI features are provided by Apple Intelligence, on your device or through Apple’s Private Cloud Compute. Your content is not sent to us.

Information We Collect

Your Packs and Cards

The packs, cards, images, video and other content you create are stored on your device. If iCloud is turned on for Rotely on your device, which it is by default, this content is also stored in your private iCloud account using Apple’s CloudKit and synced between your devices. We do not have access to content stored in your iCloud account. Apple’s handling of iCloud data is covered by Apple’s privacy policy.

Sharing Packs

You can export and share packs as .rotely files. These files contain your pack data and are shared directly by you, using the method you choose (for example AirDrop, Messages or email). They are not uploaded to us.

In-App Contact Page

If you send us a message using the contact page in the App, we collect:

• your name
• your email address
• your message
• device and app information, such as your app version, operating system version and device model

Your message is sent securely to a server operated by us and forwarded to our support inbox by email using Amazon Web Services (AWS) Simple Email Service. We use this information only to respond to you and to help resolve any problem you report.

Rotely Pro Subscriptions

Purchases are made through the App Store and processed by Apple. We do not receive your payment card details. We use RevenueCat to manage subscriptions. RevenueCat receives an anonymous app user identifier, your purchase and subscription history, and basic device information so it can confirm which features you have access to. RevenueCat does not receive your packs or cards. You can read RevenueCat’s privacy policy at revenuecat.com/privacy.

AI Features

Rotely Pro’s AI features, including pack generation, answer completion and translation, use Apple Intelligence. Requests are processed on your device or, where needed, by Apple’s Private Cloud Compute, which Apple designs so that your data is not stored or made accessible to Apple. The content you use with AI features is not sent to us or to any other third-party AI provider.

Streak Reminders

Streak reminders are scheduled as local notifications on your device. No push notification tokens or reminder data are sent to us.

Optional Apple Diagnostics

If you choose to share diagnostics with developers in your device settings, Apple may provide us with crash reports or performance data. This information is provided by Apple and is not used to identify you. You can control this sharing in your Apple device settings at any time.

How We Use Information and Our Legal Basis

Under UK data protection law, we rely on the following legal bases:

• Responding to messages: our legitimate interests in providing support and answering your questions.
• Managing subscriptions: to perform our contract with you and give you access to the Rotely Pro features you have paid for.
• Diagnostics: our legitimate interests in keeping the App stable and working well.

We do not use your information for advertising, and we do not sell it.

Who We Share Information With

We only share information with service providers who help us run Rotely, and only as needed:

• Apple, for App Store purchases, iCloud sync, Apple Intelligence and optional diagnostics.
• RevenueCat, to manage Rotely Pro subscriptions.
• Amazon Web Services, to deliver contact page messages to our support inbox.
• Our hosting provider, which hosts the server that receives contact page messages.

We may also disclose information if we are required to by law.

International Transfers

DACCAA Ltd is based in England. Some of our service providers, including RevenueCat and Amazon Web Services, may process information outside the UK, including in the United States. Where this happens, we rely on appropriate safeguards recognised under UK data protection law, such as the UK International Data Transfer Addendum or the UK-US data bridge.

Data Retention

• Contact page messages are kept in our support inbox for as long as needed to resolve your query, and then deleted when no longer needed.
• Subscription records are kept by RevenueCat and Apple for as long as needed to manage your subscription and meet legal and accounting requirements.
• Apple diagnostics are kept within Apple’s systems and our developer tools for as long as needed to address stability issues.
• Your packs and cards stay on your device and in your iCloud account until you delete them.

Your Rights

Under UK data protection law, you have the right to access, correct or delete the personal data we hold about you, to object to or restrict how we use it, and to ask for a copy of it in a portable format. To use any of these rights, email us at hello@daccaa.com.

If you are unhappy with how we have handled your data, you can complain to the Information Commissioner’s Office (ICO) at ico.org.uk. We would appreciate the chance to help first, so please contact us.

Your Choices

• iCloud sync is on by default. You can turn it off for Rotely in your device’s iCloud settings.
• You can turn streak reminders on or off in the App or in your device’s notification settings.
• You can control whether Apple shares diagnostics with us in your device settings.
• Using the contact page is optional. Rotely works without it.

Children’s Privacy

Rotely is not directed to children. We do not knowingly collect personal information from children. If you believe a child has sent us personal information, contact us and we will take appropriate steps.

Changes to This Policy

We may update this Privacy Policy from time to time. If we make changes, we will update the effective date at the top of this page.

Contact Us

If you have questions about this Privacy Policy, use the contact page in the App or email us at hello@daccaa.com.

DACCAA Ltd, 11 Othello Close, Stafford, ST17 9ZN, England.

DACCAA Ltd is a registered company in England and Wales (company number: 14639674).