Privacy Policy

This Privacy Policy explains how Level 19 Enterprises, LLC (“Level 19,” “we,” “us,” or “our”) handles personal information. It covers two things:

1. This website, https://l19.ltd.
2. The apps we publish, including web apps and mobile apps distributed through the Apple App Store and other app stores.

This policy is the default privacy policy for our apps. If an app has its own privacy policy or an app-specific privacy section, that app-specific document takes precedence for that app wherever the two differ.

This website

This website is a static site. It has no user accounts, sets no cookies, and does not use analytics tools, advertising trackers, or tracking pixels.

Our hosting provider, Cloudflare, processes standard server log data when you visit, such as your IP address, browser user agent, the page requested, and the time of the request. Cloudflare uses this data to deliver the site and protect it against abuse and attacks. We do not use it to identify or profile visitors.

If you email us, we receive your email address, your name if you include it, and whatever you write. We use it only to respond to you and keep a record of the conversation. We do not add you to a mailing list.

Information our apps may collect

Each app collects only what it needs to work. Many of our apps collect little or no personal information. Depending on the app, we may collect:

• Account information, such as your name, email address, and password (or a sign-in token if you use a service like Sign in with Apple). Passwords are stored in hashed form, never in plain text.
• Content you create, such as notes, entries, files, photos, or settings you save in the app.
• Device and diagnostic data, such as device model, operating system version, app version, language, and basic performance information.
• Crash reports, which describe what the app was doing when it crashed so we can fix the problem.
• Support messages you send us from inside the app or by email.

If an app needs access to something on your device, such as your camera, photos, location, or contacts, it will ask for your permission first. You can change these permissions at any time in your device settings.

For apps on the App Store, the app’s privacy label on its App Store page lists the categories of data that app collects.

How we use information

We use the information our apps collect to:

• provide the app and its features, including syncing your content across devices;
• respond to support requests and other messages;
• keep the app and its users secure, and prevent fraud and abuse;
• diagnose bugs and crashes and improve how the app works; and
• comply with legal obligations.

We do not sell personal information.

Advertising and tracking

We do not sell or rent personal data, and we do not share it with third parties for their own marketing.

Our apps do not use third-party advertising or cross-app tracking unless that app’s App Store privacy label discloses it. If an app ever does, it will ask for your permission where Apple’s App Tracking Transparency rules or other laws require it.

Service providers

We use a small number of service providers to run our website and apps, such as providers for hosting, databases, email delivery, and crash reporting. They process data only on our behalf, under contracts that limit their use of it to providing services to us and that require them to protect it.

If you download an app from the App Store, Apple handles the download and any payment. Apple’s handling of that information is covered by Apple’s own privacy policy. We do not receive your payment card details.

We may also disclose information if the law requires it, to protect the rights, safety, or property of our users or others, or as part of a merger, acquisition, or sale of assets, in which case this policy will continue to apply to the transferred information.

How long we keep information

We keep personal information only as long as we need it to provide the service to you. When you delete your account, or when we no longer need the information, we delete it or make it anonymous. Some information may remain in backups for a limited period until those backups are overwritten, and we may keep certain records longer if the law requires it.

Emails sent to us are kept only as long as needed to handle your request.

Deleting your account and data

If an app lets you create an account, it also lets you delete that account from inside the app, as Apple requires. Deleting your account deletes the personal information and content associated with it, subject to the backup and legal exceptions described above.

You can also ask us to delete your data at any time by emailing privacy@l19.ltd. Tell us which app you use and the email address on your account so we can find it.

Security

We use reasonable technical and organizational measures to protect personal information, including encryption in transit (HTTPS), access controls that limit who can see your data, and keeping our systems up to date. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we learn of a breach that affects your personal information, we will notify you as the law requires.

Children

Our website and apps are not directed at children under 13, and we do not knowingly collect personal information from children under 13, consistent with the U.S. Children’s Online Privacy Protection Act (COPPA). If you believe a child under 13 has given us personal information, contact us at privacy@l19.ltd and we will delete it.

International users

We are based in the United States, and our service providers may process information in the United States and other countries. Data protection laws in those countries may differ from the laws where you live. Where the law requires it, we take steps to put appropriate safeguards in place for transfers of personal information.

Your rights

Depending on where you live, you may have the right to:

• access the personal information we hold about you;
• correct information that is inaccurate;
• delete your information;
• receive a copy of your information in a portable format; and
• object to or limit certain uses of your information.

To make a request, email privacy@l19.ltd. We may need to verify your identity before we act on it. We will not treat you differently for exercising your rights.

California residents

If you live in California, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), may give you the rights to know what personal information we collect, use, and disclose; to request deletion or correction; and to opt out of the sale or sharing of personal information. We do not sell personal information, and we do not share it for cross-context behavioral advertising. We do not use sensitive personal information for purposes that would require offering a right to limit its use. You may use an authorized agent to make a request on your behalf.

EEA and UK residents

If you live in the European Economic Area or the United Kingdom, the GDPR or UK GDPR applies to our processing of your personal information, and Level 19 Enterprises, LLC is the controller. We rely on these legal bases:

• Contract: to provide an app or service you have asked for.
• Legitimate interests: to keep our services secure, fix bugs, and respond to messages, where those interests are not overridden by your rights.
• Consent: where we ask for it, such as for certain device permissions. You can withdraw consent at any time.
• Legal obligation: where the law requires us to process or keep information.

In addition to the rights listed above, you may restrict certain processing and lodge a complaint with your local data protection authority. We would appreciate the chance to address your concern first, so please contact us at privacy@l19.ltd.

Changes to this policy

We may update this policy from time to time. When we do, we will change the “Last updated” date at the top of this page. If we make a significant change to how we handle personal information, we will give notice in the affected app or on this website before the change takes effect.

Contact us

If you have questions about this policy or how we handle your information, email us at privacy@l19.ltd.

Level 19 Enterprises, LLC