Privacy Policy

Last updated: May 10, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

How Refrain Handles Your Data

Refrain is a fully on-device app. We do not run servers and do not transmit Your data anywhere. The general clauses below describe rights and processes that apply by law (GDPR, CCPA), but most do not apply in practice because We do not collect, transmit, or store Your data on any server We control.

Refrain does not use analytics, advertising, tracking SDKs, or remote backends.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Affiliate means an entity that controls, is controlled by, or is under common control with a party.
• Application refers to Refrain: Screen Time Control, the software program provided by the Company.
• Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information.
• CCPA and/or CPRA refers to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020.
• Company (referred to as "We", "Us" or "Our") refers to Mojo Apps, the developer of the Application. For the purposes of the GDPR, the Company is the Data Controller.
• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.
• Country refers to: United States
• Data Controller, for the purposes of the GDPR, refers to the Company.
• Device means any device that can access the Service such as a cell phone or a digital tablet.
• GDPR refers to EU General Data Protection Regulation.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes data on behalf of the Company. For Refrain this means Google Play Billing only.
• You means the individual accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

The Application itself does not collect Personal Data on a server. The only Personal Data associated with Your use of the Service is Your Google account email, which is held by Google Play when You purchase a Pro subscription. We do not directly receive or store this email — it is used by Google Play to associate Your purchase with Your Google account so that Pro entitlement can be restored across reinstalls.

On-Device Data (Not Transmitted)

Refrain processes the following data locally on Your device only:

• The package names of apps You add to the controlled list.
• Your daily usage minutes per controlled app, queried from Android's Usage Stats API.
• Counts of intervention events (opens, walk-aways) and your daily limit settings.

This data is stored in the app's local storage on Your device. It is never transmitted to Us or any third party. Uninstalling the app removes all of it.

Use of Your Personal Data

The Company may use any Personal Data associated with the Service for the following purposes:

• To provide and maintain the Service, including processing Pro entitlements via Google Play Billing.
• For business transfers, in connection with any merger, sale of Company assets, or acquisition.
• To comply with legal obligations, including responding to lawful requests from public authorities.

We do not use Personal Data for marketing, analytics, or profiling.

We may share Personal Data only in the following situations:

• With Google Play, as the payment processor for Pro purchases. Google Play's handling of this data is governed by Google's Privacy Policy.
• For business transfers, as described above.
• With Your consent, for any other purpose.

Retention of Your Personal Data

Because Refrain does not transmit Personal Data to a server We control, retention applies primarily to data held by Google Play in connection with purchases. Google Play retains transaction and account data according to its own retention schedule, which You can review in Google's Privacy Policy.

On-device data (controlled app list, usage stats, intervention counters) is retained on Your device until You uninstall the application or clear the app's data through Android Settings.

Transfer of Your Personal Data

Personal Data You provide to Google Play may be processed in the United States and other countries in which Google operates. We do not transfer Personal Data internationally because We do not collect Personal Data on a server.

Delete Your Personal Data

To delete the on-device data Refrain stores, uninstall the application or clear its data via Android Settings → Apps → Refrain → Storage → Clear Data.

To delete or modify Personal Data held by Google Play (including Your purchase history), contact Google Play support directly at https://support.google.com/googleplay.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, any Personal Data may be transferred. We will provide notice before any transfer becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities.

Other legal requirements

The Company may disclose Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

Because Refrain does not transmit data to a server, the security of on-device data is governed by the security features of Your Android device. Data held by Google Play in connection with Your purchase is secured according to Google's security standards.

Detailed Information on the Processing of Your Personal Data

Payments

Pro subscriptions and lifetime upgrades are processed exclusively by Google Play.

• Google Play In-App Payments — Their Privacy Policy can be viewed at https://policies.google.com/privacy

We do not store or have access to Your payment card details, billing address, or other financial information. All such data is provided directly to Google and governed by Google's Privacy Policy.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You (e.g., a Pro subscription).
• Legal obligations: Processing is necessary for compliance with a legal obligation.
• Legitimate interests: Processing is necessary for the legitimate interests pursued by the Company.

International Transfer of Personal Data

We do not transfer Personal Data internationally because We do not collect it on a server. Personal Data held by Google Play in connection with Your purchase may be transferred internationally per Google's standard data transfer practices, governed by Google's Privacy Policy.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right to:

• Request access to Your Personal Data. Because Refrain does not collect Personal Data on a server, We have no Personal Data to provide. You can review and modify on-device data through the app itself or Android Settings.
• Request correction. Same as above — on-device data can be modified directly.
• Request restriction of processing.
• Object to processing of Your Personal Data.
• Request erasure of Your Personal Data. Uninstalling the app removes all on-device data.
• Request the transfer of Your Personal Data. No server-side data is held; on-device data is exportable through Android backup if enabled.
• Withdraw Your consent.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights by contacting Us. We may ask You to verify Your identity before responding. We will respond within one month and may extend by two further months where necessary.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

The following is a list of CCPA/CPRA categories and our actual collection status. Refrain is an on-device application; the only Personal Information indirectly associated with use is Your Google account email, used by Google Play for purchase verification.

• Category A: Identifiers. Examples: name, postal address, IP address, email address, account name. Collected: Limited — Google account email is associated with Pro purchases via Google Play; We do not directly receive it.
• Category B: California Customer Records statute. Collected: Limited — only as part of Google Play purchase records.
• Category C: Protected classification characteristics. Collected: No.
• Category D: Commercial information. Examples: records of products or services purchased. Collected: Limited — Pro purchase history via Google Play.
• Category E: Biometric information. Collected: No.
• Category F: Internet or other similar network activity. Collected: No. Refrain does not collect browsing history, search history, or website interactions.
• Category G: Geolocation data. Collected: No.
• Category H: Sensory data. Collected: No.
• Category I: Professional or employment information. Collected: No.
• Category J: Non-public education information. Collected: No.
• Category K: Inferences drawn from other personal information. Collected: No.
• Category L: Sensitive personal information. Collected: No.

Sources of Personal Information

We obtain the limited Personal Information described above only:

• From Google Play when You make a Pro purchase.

We do not collect Personal Information directly from You, automatically through cookies, or from third-party data brokers.

Use of Personal Information

We may use Personal Information collected for these business purposes:

• To verify and maintain Your Pro entitlement.
• To respond to lawful requests from public authorities.
• To support business transfers (mergers, acquisitions).

Disclosure of Personal Information

We may have disclosed in the last twelve (12) months the following categories of personal information for business purposes:

• Category A: Identifiers (Google account email — to Google Play, as the payment processor)
• Category D: Commercial information (Pro purchase history — to Google Play)

Sale or Sharing of Personal Information

We do not "sell" or "share" Your Personal Information as those terms are defined under CCPA/CPRA. We do not exchange Personal Information for monetary or other valuable consideration.

Retention of Personal Information

We retain on-device data only until You uninstall the app or clear its data. Personal Information held by Google Play in connection with Your purchase is retained per Google's policies.

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the Personal Information of any users, including minors. We do not knowingly collect Personal Information from minors under 16.

Your Rights under the CCPA/CPRA

If You are a California resident, You have the following rights:

• The right to notice.
• The right to know/access.
• The right to say no to the sale or sharing of Personal Information. We do not sell or share Personal Information.
• The right to correct Personal Information.
• The right to limit use and disclosure of sensitive Personal Information.
• The right to delete Personal Information.
• The right not to be discriminated against.

Exercising Your CCPA/CPRA Data Protection Rights

To exercise Your rights, You can contact Us:

• By email: mojo.apps.support@gmail.com

We will respond within 45 days. The time period may be extended once by an additional 45 days when reasonably necessary.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals. Refrain does not track Your behavior across websites or applications.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798, California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. We do not share Personal Data for direct marketing.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under 18 who are registered users of online services to request and obtain removal of content or information they have publicly posted. Refrain does not allow public posting; uninstalling removes all on-device content.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us:

• By email: mojo.apps.support@gmail.com