Privacy Policy

This Privacy Policy explains how the Clear Water app (“the App”, “we”, “us”, or “our”) handles information. The App is published by D2X Enterprises LLC (“D2X”), the data controller. We have tried to write this in plain language.

In short: the App has no account and no sign-in, and everything you log (your pools, water tests, tasks, and equipment) stays only on your device — we never receive it. The App makes almost no network requests: the only data about you that is ever sent off your device is optional, anonymous usage analytics that are OFF unless you turn them on (and can be turned back off at any time). Separately, the optional “Where to purchase” supplier pages load a business’s image from our content host when you open one — which, like loading any image on the web, reveals your device’s IP address to that host; no account, identity, or pool data is attached. And if you buy the one-time Pro upgrade, your purchase is processed by Google and verified through our provider RevenueCat in the US (see Section 5).

1. Information We Do and Do Not Collect

Your pool data stays on your device. All of your pools, water tests, maintenance tasks, and equipment are stored only on your device. We do not receive, see, or store any of it.

We do not collect your name, email address, precise location, advertising identifiers, contacts, or photos, and we do not use third-party advertising trackers.

The only data we may collect is optional, anonymous product-usage analytics, and only if you opt in (see Section 3).

2. Network Use (Offline by Default)

The App is designed to run on your device. Apart from the two cases below, it makes no network requests and works fully offline:

• Optional analytics (Section 3) — off unless you turn them on.
• Supplier images. The optional “Where to purchase” feature shows a list of local pool-supply businesses; that list is built into the App. When you open a specific business’s page, the App downloads that business’s image from our content-delivery host. Like loading any image on the web, this request necessarily reveals your device’s IP address (and which image is requested) to that host. It carries no account, no analytics identifier, and none of your pool data, and it happens only when you open such a page. If you never open a supplier page, no such request is made.

3. Optional Usage Analytics (Off by Default)

To understand how the App is used and improve it, the App can send anonymous product-analytics events using PostHog, a third-party analytics provider acting as our processor.

• Opt-in and revocable. Analytics are disabled by default. Nothing is sent unless you explicitly turn analytics on. You can turn them off again at any time in Account › Usage analytics. Turning them off stops all further collection.
• What is collected. Only a small set of anonymous interaction events — for example, that a screen was viewed, that a water test was logged, that a pool was added, or that the upgrade screen was viewed. Events carry a random, app-generated identifier that is not linked to your name or identity, plus basic technical context (app version, device type, operating-system version).
• What is NOT collected. We do not send your readings, notes, pool names, volumes, location, contacts, email, or any of your on-device pool data. We instruct PostHog not to derive your location from your IP address (IP-based geolocation is disabled).
• Where it is processed. Analytics data is processed by PostHog in the United States. For users in the EEA, the UK, or other regions, this is an international transfer carried out under appropriate safeguards — see Section 8.
• Legal basis. Where the GDPR, UK GDPR, or similar laws apply, our legal basis for analytics is your consent (which you give by turning analytics on and may withdraw at any time).
• No advertising or sale. Analytics are used only to improve the App. We do not sell or share this data, and it is not used for advertising or cross-context behavioral tracking.

4. No Advertising

The App contains no advertisements and no advertising SDK. We do not collect an advertising identifier and do not use ad-based tracking.

5. Purchases

The App offers an optional one-time “Pro” purchase. Payment is processed by Google Play (and, on iOS, the Apple App Store) as merchant of record under their own terms; we never receive or store your payment-card details. To deliver and verify the purchase and to unlock Pro on your device, we use RevenueCat, Inc., a US purchase-management provider acting as our processor. RevenueCat receives the purchase/receipt data from the store and a stable, randomly generated app identifier that lets the App recognize and restore your Pro entitlement. This identifier is not your name, email, or an advertising ID, and it is not linked to your on-device pool data or to the analytics identifier described in Section 3. Google and RevenueCat process this data in the United States (see Section 8). We use it only to provide, verify, restore, and support your purchase — not for advertising — and we do not sell or share it.

6. Children’s Privacy

The App is intended for adults who own or maintain swimming pools and who handle pool chemicals. It is not directed to children under 13 (or the equivalent minimum age in your country) and does not knowingly collect personal information from children. Because the App involves handling hazardous chemicals, it is intended for users 18 and older.

7. Your Rights and Choices

Because your pool data lives only on your device:

• You can view and edit all of it directly in the App at any time.
• Using “Reset all data” in the App permanently wipes all of your pools, tests, tasks, and equipment from your device.
• Deleting the App removes its on-device data.
• You can enable or disable analytics at any time in Account › Usage analytics.

Depending on where you live, you may have rights under laws such as the GDPR (EEA/UK), CCPA/CPRA (California), and Middle-East data-protection laws (for example Saudi Arabia’s PDPL and the UAE PDPL), including the rights to access, correct, delete, or object to processing of your personal data, to withdraw consent, and not to be discriminated against for exercising these rights. Because we hold no account and the analytics we process are anonymous (not linked to your identity), we typically cannot identify a specific individual within that data. You can still exercise the practical equivalents above (resetting on-device data, disabling analytics), and you may contact us with any request (see Section 10). We do not sell or share your personal information for cross-context behavioral advertising or otherwise.

8. International Data Transfers

If you never enable analytics, no data leaves your device, so there is no international transfer. If you do enable analytics, the anonymous analytics data is processed by PostHog in the United States. Where required (for example for users in the EEA or UK), this transfer is carried out under appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and/or the EU-US Data Privacy Framework, together with PostHog’s data-processing commitments. Separately, supplier images (Section 2) are served from a content-delivery host in the United States; if you open a supplier page from the EEA or UK, that image request transmits your IP address to the US host. This is limited to the technical information needed to deliver an image and is not used to identify or profile you. Finally, if you make the one-time Pro purchase, the related purchase data is processed by Google and by RevenueCat in the United States (Section 5); for EEA or UK purchasers this transfer relies on the same safeguards (the Standard Contractual Clauses and/or the EU-US Data Privacy Framework) together with each provider’s data-processing commitments.

9. Security and Retention

Your on-device information is protected primarily by the fact that it never leaves your device. Any anonymous analytics you choose to enable are transmitted securely (encrypted in transit) to PostHog and retained only as long as needed for product analysis. No method of storage or transmission is completely secure, but because we hold no account and the analytics are anonymous, the risk surface on our side is minimal.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the Effective Date above and, where appropriate, provide additional notice in the App. Your continued use of the App after an update means you accept the revised policy.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise a privacy right, please contact us through our support page at https://d2xenterprises.com/support/, or by email at [email protected]:

D2X Enterprises LLC 30 S 15th St Ste 1550 PMB 852931 Philadelphia, Pennsylvania 19102-4806 US

This Privacy Policy is governed by the laws of the Commonwealth of Pennsylvania, USA, without regard to its conflict-of-laws rules.