LEGAL

Privacy Policy

Effective Date: September 2026

Welcome to When. Your privacy is paramount. This Privacy Policy explains how When handles information across our offline-first mobile application, website, and advertiser platform ("When Studio").
1.

Information We Collect

When App Users: When App does not require user account registration, phone numbers, contact lists, photos, messages, or cloud profile creation. Your personal timeline items, expiry reminders, warranties, subscriptions, documents, and Vault files are stored locally on your device.

Advertisers (When Studio): When businesses or individuals register for an advertiser account to run campaigns, we collect account credentials including business email address, company name, and authentication tokens via Firebase Authentication to manage account access and support.

2.

Local Data Storage & User Privacy

All user data created inside When App—including timeline dates, categories, reminders, custom notes, warranty records, document attachments, and Vault items—is stored exclusively in local database storage on your device. This information never leaves your device unless you manually choose to export an offline backup file.

3.

No Cloud Storage for User Content

When does not operate remote cloud storage or centralized syncing databases for your personal timeline records. Because your personal entries remain on your hardware, you retain direct control over your locally stored timeline data.

4.

Contextual Ad Delivery & On-Device Matching

When operates a privacy-first contextual advertising platform. Approved, active campaign catalog metadata (such as general product categories, broad trigger windows, and creative assets) is synchronized to the mobile application. All contextual eligibility evaluation and ad matching occurs strictly on the user's device. Your personal timeline items, exact dates, reminder notes, and Vault contents are never sent to When servers or shared with advertisers to target ads.

5.

Advertiser Platform & Advertising Data

When offers an advertising management platform ("When Studio") where verified advertisers can create, schedule, fund, and monitor contextual campaigns.

When an advertisement is displayed or engaged with in the application, the advertising system automatically generates event-level delivery and measurement records. This data is utilized solely for campaign delivery validation, performance reporting, billing calculation, fraud prevention, and platform integrity.

6.

Advertising Measurement & Aggregated Reporting

When users interact with advertisements delivered through the platform, the system may automatically record technical measurement events, specifically:

  • Eligible ad impressions;
  • Eligible ad clicks and call-to-action interactions;
  • Campaign delivery timestamps and ad placement types (e.g., Home, Timeline);
  • Aggregated performance metrics (Click-Through Rate, Daily Spend, Remaining Budget).

Advertisers receive campaign measurement and performance information in aggregated or non-personally identifying form and are not provided with the personal identity of individual When users through the advertising measurement system.

7.

Technical Data & Fraud Prevention

When client devices connect to our backend to synchronize public campaign catalogs or transmit batch measurement events, technical request data (such as network IP addresses) may be processed automatically and transiently for security, rate limiting, and click-fraud prevention. Technical identifiers are converted into temporary cryptographic hashes (SHA-256 session keys) in memory to detect anomalous click bursts and are not stored in campaign reporting databases or disclosed to advertisers.

8.

Payment Processing & Advertiser Billing Information

Advertiser billing and wallet funding transactions are processed through our third-party payment provider, PayPal.

All financial transactions are denominated and processed in United States Dollars (USD). When stores administrative transaction ledger records (such as PayPal Order IDs, PayPal Capture IDs, credited amounts, transaction timestamps, and wallet balances). When does not collect, process, or store full credit card numbers, debit card details, or banking credentials; all payment submissions are governed directly by PayPal's Privacy Statement and security controls.

9.

No Personal User Identity Shared With Advertisers

Campaign reporting is designed to provide advertising performance information without disclosing the personal identity of individual When users to advertisers. Advertisers do not receive users' private reminder content, Vault data, Borrowed data, private notes, exact personal dates, contact details, or personal device identifiers through campaign reporting.

10.

Data Sharing & Third Parties

We do not sell, rent, or trade your personal information. Information is only processed by essential infrastructure providers (such as Google Firebase for advertiser account authentication and PayPal for secure payment processing) solely to operate and secure platform functionality.

11.

Permissions Required

When App requests only device permissions that are strictly necessary for core application capabilities (such as camera access for local optical character recognition / scanning, or system notification alerts for scheduled reminders). Any granted permission operates exclusively on your device and is never used to transmit personal files or photos to remote servers.

12.

Data Security

For app users, your data security is rooted in your physical device controls. We recommend enabling device encryption, biometrics, and secure screen locks. For advertisers, account credentials and server communications are protected using industry-standard encryption, secure session authentication, and transactional ledger protections.

13.

Children's Privacy

When App and the When Studio advertiser platform do not knowingly collect personal information from children under the age of 13 (or applicable legal age). The advertiser platform is intended strictly for commercial and business entities.

14.

Your Control & Data Retention

App users can edit or delete their timeline data, custom categories, and reminder records at any time. Uninstalling the app permanently erases all locally stored database records unless an offline backup has been exported. Advertisers may manage, pause, or request deletion of their account and campaigns subject to statutory accounting and fraud-prevention recordkeeping requirements.

15.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or platform updates. Any changes will become effective upon publication with an updated Effective Date at the top of this page.

16.

Contact Us

If you have any questions, privacy inquiries, or feedback regarding this Privacy Policy, please contact our privacy and support team at:

support@netraksha.com