1. Introduction

ActionSmartAI Ltd ("we", "us", or "our"), a company registered in England and Wales with company number 16429509, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the ActionSmartAI iOS application ("the App").

This policy complies with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable laws. By using the App, you agree to the practices described in this policy.

2. Data We Collect

We collect only the data necessary to provide and improve the App's functionality. The types of data collected include:

Personal Data

Information you voluntarily provide, such as:

• Name and email address (if provided for account creation or support purposes)
• Subscription-related data (e.g., payment status for premium features, processed via StoreKit)

App Usage Data

Information generated through your use of the App, including:

• Macro Goals, Micro Goals, Habits, Routines, and Journal/Reflection entries
• Achievement data (e.g., progress, streaks, and unlocked achievements)
• Notification and reminder settings

Technical Data

Automatically collected data to ensure the App functions correctly:

• Device information (e.g., device type, operating system version)
• Usage analytics (e.g., app interactions, feature usage, and performance metrics)
• Crash reports and diagnostic data to improve stability

3. How We Use Your Data

Your data is used solely to provide, maintain, and enhance the App's functionality. Specific uses include:

Service Delivery

• Managing and displaying your goals, habits, routines, and journal entries
• Generating AI-powered insights using AWS Bedrock (Claude 3 Sonnet model)
• Scheduling and delivering notifications via iOS UserNotifications framework
• Tracking achievements and progress metrics

App Improvement

• Analysing usage patterns to optimise performance and user experience
• Identifying and fixing bugs through crash reports and diagnostics

Subscription Management

• Processing subscription status and enabling premium features via StoreKit

4. Data Storage and Security

We take robust measures to protect your data:

Storage

• Data is stored locally on your device using UserDefaults for persistence
• Cloud-based data (for backup or sync via CloudKit) is encrypted both in transit and at rest

Security

• End-to-end encryption ensures data remains inaccessible to unauthorised parties
• Highly secure algorithms and protocols prevent data breaches
• AWS services (Lambda, API Gateway, Bedrock, CloudKit) are secured with AWS IAM
• Client-side caching reduces unnecessary API calls, minimising exposure

Retention

• Data is retained only for as long as necessary to provide the App's services
• You can delete your data at any time via the App's settings
• Upon deletion, data is permanently removed from our systems

5. Data Sharing and Third Parties

We do not sell, share, or disclose your personal data to third parties, except in the following limited circumstances:

Service Providers

We use AWS (Amazon Web Services) for backend infrastructure (Lambda, API Gateway, Bedrock, CloudKit). These services process data in accordance with our instructions and strict security standards, without human access.

Legal Obligations

We may disclose data if required by law, such as to comply with a court order or regulatory requirement, but only to the extent necessary.

6. Your Rights

Under the UK GDPR, you have the following rights regarding your personal data:

To exercise these rights, contact us at support@actionsmartai.com. We will respond within one month, as required by law.

7. Children's Privacy

The App is not intended for use by individuals under 16 years of age. We do not knowingly collect personal data from children. If you believe a child under 16 has provided data, please contact us to have it removed.

8. Cookies and Tracking

The App does not use cookies or third-party tracking technologies. Analytics are collected in an anonymised form to improve functionality, without identifying individual users.

9. International Data Transfers

As ActionSmartAI Ltd is based in the UK, data is primarily processed within the UK or the European Economic Area (EEA). Where data is processed by AWS in regions outside the UK/EEA, we ensure compliance with UK GDPR through appropriate safeguards, such as Standard Contractual Clauses.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via the App or by email (if provided). The latest version is always available at https://actionsmartai.com/legal.

These Terms and Conditions ("Terms") govern your use of the ActionSmartAI iOS application ("the App") provided by ActionSmartAI Ltd. ("we," "us," or "our"). By using the App, you agree to these Terms. If you do not agree, please do not use the App.

1. Use of the App

The App is a personal development tool for managing goals, habits, routines and journal entries, with AI-powered features. You may use the App for personal, non-commercial purposes in accordance with these Terms.

You agree not to:

• Use the App for illegal or unauthorised purposes
• Attempt to reverse-engineer, decompile, or access the App's source code
• Interfere with the App's functionality or security
• Use the App to transmit harmful or offensive content

2. Account and Subscriptions

Account

You may need to create an account to access certain features. You are responsible for maintaining the confidentiality of your account credentials and all activities under your account.

Freemium Model

The App offers a free tier with limits and a premium subscription for unlimited access and advanced features.

3. AI Features

The App uses an advanced AI model which reaches back to a server for AI features like micro goal generation and journal insights. These features require data to be sent to our AWS-based servers.

4. Intellectual Property

The App, including its design, code and content (excluding user-generated content), is owned by ActionSmartAI Ltd. and protected by intellectual property laws.

You are granted a non-exclusive, non-transferable licence to use the App for personal purposes. You may not copy, modify, or distribute the App without our written consent.

5. User-Generated Content

Content you create (e.g., goals, journal entries) remains yours. By using AI features, you grant us a limited, non-exclusive licence to process your content solely to provide the App's services.

6. Termination

We may suspend or terminate your access to the App if you violate these Terms or for any reason at our discretion. You may stop using the App at any time by deleting your account and uninstalling the App.

Upon termination, your right to use the App ceases immediately and you must delete all copies of the App from your devices.

7. Limitation of Liability

The App is provided "as is" without warranties of any kind. We are not liable for:

• Errors, interruptions, or inaccuracies in the App or AI-generated content
• Loss of data or damages arising from your use of the App
• Indirect, incidental, or consequential damages
• Any damages resulting from reliance on AI-generated suggestions

Our total liability is limited to the amount you paid for the App, if any.

8. Governing Law

These Terms are governed by the laws of England and Wales. Any disputes will be resolved in the courts of England and Wales.

9. Changes to These Terms

We may update these Terms to reflect changes in our practices or legal requirements. We will notify you of significant changes via the App or email. Your continued use of the App after updates constitutes acceptance of the revised Terms.

The latest version is always available at https://actionsmartai.com/legal.

10. Contact Us

1. Acceptance of Terms

By downloading, installing, or using ActionSmartAI ("the App"), you agree to be bound by this End User License Agreement (EULA). If you do not agree to these terms, please do not use the App.

2. App Description

ActionSmartAI is a goal-tracking and habit-building application that uses artificial intelligence to help users achieve their personal and professional objectives through smart insights, routine management, and progress tracking.

3. License Grant

Subject to your compliance with this EULA and all applicable laws, ActionSmartAI Ltd. grants you a limited, non-exclusive, non-transferable, revocable licence to download and use the App on Apple devices that you own or control and as permitted by the Apple App Store Terms of Service.

Permitted Uses

You may:

• Download and install the App on your personal Apple devices
• Use the App for personal, non-commercial purposes
• Use the AI-powered features to generate goals, insights, and recommendations for your personal use

Restricted Uses

You may not:

• Copy, modify, adapt, translate, or create derivative works of the App
• Reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code of the App
• Remove or alter any proprietary notices, labels, or marks on the App
• Rent, lease, lend, sell, redistribute, or sublicense the App
• Use the App to develop competing products or services
• Use the App for any illegal purpose or in violation of any applicable laws
• Use the App in any way that could damage, disable, or impair the service

4. Subscription Plans and Pricing

Plan	Features	Price	Billing Cycle
Free Tier	3 macro goals, 10 micro goals per day, 2 habits, 3 reminders	Free	-
Premium Monthly	Unlimited goals, habits, AI insights, routines, journal	£4.99/month	Auto-renewable monthly
Premium Yearly	Unlimited goals, habits, AI insights, routines, journal	£39.99/year	Auto-renewable yearly

5. Payment and Billing

Payment Processing

All payments are processed through Apple's App Store. Charges will appear on your Apple ID account.

Auto-Renewal

Premium subscriptions automatically renew for the same duration unless auto-renewal is turned off at least 24 hours before the current period ends. Renewal charges occur within 24 hours prior to the end of the current period.

Cancellation

You may cancel your subscription at any time through your Apple ID account settings. Cancellation takes effect at the end of the current billing period. No refunds are provided for unused portions of the subscription period.

Refunds

Refund requests must be made through Apple's App Store refund process. We do not process direct refunds. Apple's refund policies apply to all purchases made through the App Store.

6. User Account and Data

Account Responsibility

You are responsible for maintaining the security of your account and all activities that occur under your account. You agree to provide accurate and complete information when creating your account.

Data Storage

Your personal data, including goals, habits, and progress information, is stored locally on your device and may be synchronised with iCloud if enabled.

7. Intellectual Property Rights

The App and all related content, features, and functionality (excluding user-generated content) are owned by ActionSmartAI Ltd. and are protected by copyright, trademark, and other intellectual property laws.

You are granted a limited, non-exclusive, non-transferable, revocable licence to use the App. All rights not expressly granted to you are retained by ActionSmartAI Ltd.

8. User-Generated Content

You retain all ownership rights to content you create within the App (e.g., goals, habits, journal entries). By using AI features, you grant ActionSmartAI Ltd. a limited, non-exclusive licence to process your content solely to provide the App's services.

We do not claim ownership of your content. Your goals, habits and personal data remain private and under your control.

9. Privacy and Data Protection

Your use of the App is subject to our Privacy Policy, which is incorporated into this EULA by reference. Please review our Privacy Policy to understand our practices regarding the collection and use of your personal data.

10. AI-Generated Content

The App uses artificial intelligence to generate suggestions, insights, and recommendations based on your input. Please note that:

• AI-generated content is for informational purposes only
• We do not guarantee the accuracy or suitability of AI-generated recommendations
• You should evaluate AI suggestions carefully before implementing them
• AI-generated content should not replace professional advice from qualified experts

11. Disclaimers

Service Availability

We strive to maintain continuous service availability but cannot guarantee uninterrupted access. The App may be temporarily unavailable for maintenance, updates, or due to technical issues beyond our control.

Warranty Disclaimer

The App is provided "as is" and "as available" without any warranties of any kind, either express or implied. We disclaim all warranties including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

12. Limitation of Liability

To the maximum extent permitted by applicable law, in no event shall ActionSmartAI Ltd. be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to damages for loss of profits, data, or other intangible losses, arising from:

• Your use or inability to use the App
• Errors, interruptions, or inaccuracies in the App or AI-generated content
• Loss of data or damages arising from your use of the App
• Any damages resulting from reliance on AI-generated suggestions
• Unauthorised access to or alteration of your transmissions or data

Our total liability is limited to the amount you paid for the App in the 12 months preceding the claim, if any.

13. Termination

We may terminate or suspend your access to the App at any time, with or without cause, with or without notice. Upon termination, your right to use the App ceases immediately and you must delete all copies of the App from your devices.

14. Updates and Modifications

We reserve the right to modify this EULA at any time. Material changes will be communicated through the App or via email. Continued use of the App after changes constitutes acceptance of the new terms.

We may also update or modify the App's features, functionality, or services at any time without notice.

15. Governing Law and Jurisdiction

This EULA is governed by the laws of England and Wales, without regard to its conflict of law provisions. Any disputes arising from or relating to this EULA shall be subject to the exclusive jurisdiction of the courts of England and Wales.

16. Apple-Specific Terms

This App is available through the Apple App Store. Apple is not a party to this EULA and has no responsibility for the App or its content. Apple's terms and conditions (including the Apple App Store Terms of Service) also apply to your use of the App.

You acknowledge that this licence is limited to a non-transferable licence to use the App on an Apple device that you own or control and as permitted by Apple's App Store Terms of Service.

17. Entire Agreement

This EULA, together with our Privacy Policy, constitutes the entire agreement between you and ActionSmartAI Ltd. regarding your use of the App and supersedes all prior and contemporaneous agreements, understandings, and negotiations, whether written or oral.

18. Severability

If any provision of this EULA is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

19. Contact Information