# Privacy Policy — The Jimmy Handbook
Effective date: 0
Publisher: Locstat Consulting (“**we**”, “**us**”, “**our**”)
This Privacy Policy describes how we handle information in connection with the iOS application The Jimmy Handbook (the “**App**”) and, where relevant, web pages you open from the App (for example Terms of Use, Privacy Policy, and contact pages on our site).
If you do not agree with this Policy, please do not use the App or our linked web pages.
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## 1. Summary
- The App is designed to work primarily on your device with bundled reference content.
- We do not operate user accounts inside the App in the current design.
- We do not integrate third-party advertising or analytics SDKs in the App as of the version described by this Policy (if we add them later, we will update this Policy).
- We store minimal settings (such as light/dark theme) on your device only.
- When you open external websites (including our Terms, Privacy, or Contact pages, or links inside reference documents), those sites’ or browsers’ practices apply to that activity.
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## 2. Information the App processes on your device
### 2.1 App settings
The App may store preferences on your device using UserDefaults (or equivalent Apple APIs), such as:
- Display theme (e.g. light or dark mode).
These values are stored locally on your device. We do not sync them to our servers through the App’s core reading features as currently implemented.
### 2.2 Reference content and derived presentation
Reference materials are bundled with the App. The App renders markdown and related assets on device (for example by converting content to HTML and displaying it in a web view). Reading history is not uploaded to us as part of that core on-device behaviour.
### 2.3 Printing and PDF export
If you use print or export to PDF, output is handled by Apple’s system services on your device (and any printer or app you choose). We do not receive the content of those exports unless you separately send it to us (for example by email).
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## 3. Information we do not intentionally collect through the App
Based on the current App design, we do not intentionally collect through the App:
- your name, email, or account credentials (the App does not provide a login);
- precise location;
- contacts, photos, microphone, or camera data;
- health data;
- analytics about which sections you read (no such SDK is integrated in the described version).
If future versions add features that collect personal information, we will update this Policy and, where required, obtain consent or provide notice.
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## 4. When information may leave your device
### 4.1 Links you choose to open
The App may open http or https links in your system browser or an in-app browser (for example Safari or SFSafariViewController), including:
- links from Help & About (Terms of Use, Privacy Policy, Contact);
- links that may appear inside reference documents.
When you visit a website:
- the site operator may process technical data such as IP address, user agent, date/time, and referrer according to that site’s privacy policy;
- Apple or your network provider may also process data in the ordinary course of providing connectivity.
We encourage you to read the privacy policy of any site you visit.
### 4.2 Email or other messages you send us
If you contact us by email or a web form, we receive whatever information you choose to provide (for example your name, email address, and message content). We use that information to respond and to operate our business, subject to applicable law.
### 4.3 App Store and Apple
Apple processes information related to app download, updates, payments (if any), and fraud prevention in accordance with Apple’s privacy policy. We may receive limited aggregate or transactional information from Apple as a developer where Apple provides it.
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## 5. Legal bases (if GDPR or similar applies)
If the EU/UK General Data Protection Regulation or similar law applies to our processing:
- On-device settings that do not identify you may not constitute personal data; where they do, we rely on performance of a contract (providing the App) or legitimate interests (basic app functionality).
- Support communications rely on legitimate interests and/or your consent when you contact us.
- We do not intend to sell personal information as defined under U.S. state privacy laws; if our practices change, we will update this Policy.
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## 6. Retention
- Local App settings: remain on your device until you clear app data or uninstall the App.
- Support emails: retained as long as needed to respond and for legitimate business and legal purposes (records, disputes), unless a shorter period is required by law.
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## 7. Security
We use reasonable measures to protect information we hold on our systems. No method of transmission or storage is 100% secure. You are responsible for device security (passcode, updates) and for what you share when you open external links or send us messages.
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## 8. Children’s privacy
The App is not directed at children under 13 (or the age required by your jurisdiction) for the collection of personal information. We do not knowingly collect personal information from children through the App. If you believe we have collected information from a child in error, contact us and we will take appropriate steps.
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## 9. International users
If you use the App outside Canada, your information may be processed in Canada or other countries where we or our service providers operate, which may have different data protection laws. Where required, we use appropriate safeguards or rely on permitted legal mechanisms.
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## 10. Your rights
Depending on where you live, you may have rights to access, correct, delete, or restrict processing of personal information, or to object or port data. To exercise rights against us, contact us below. We may need to verify your request. You may also have the right to complain to a supervisory authority.
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## 11. Changes to this Policy
We may update this Policy from time to time. The effective date at the top will change, and we will post the updated Policy at the URL linked from the App (**Help & About → Privacy Policy**). Continued use of the App after an update may constitute acceptance where permitted by law.
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## 12. Contact
Privacy questions or requests:
https://www.locstatconsulting.com/contact
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## 13. Not legal advice
This Policy is intended to describe our practices in plain language. It is not legal advice. Consult qualified counsel for organisation-specific compliance (including military, government employer, or classification rules).