Draft · 17 October 2026

Privacy Notice

pause.

1. Who is responsible for your data

This Privacy Notice applies to the pause. application, website and related services (Service). In this draft, ‘pause.’, ‘we’, ‘us’ and ‘our’ identify the operator provisionally by its trading name; the operator’s legal name, address and contact details must be inserted before this Notice is adopted. The operator is the data controller: it decides why and how your personal data is processed.

Payments for pause Plus are processed by Paddle.com as our reseller and Merchant of Record. Paddle is a separate controller of the purchase, billing, tax and payment data it collects at checkout; Paddle’s own privacy terms govern that processing. This Notice covers the data pause. itself collects.

2. What we collect

Account and profile data: email address, sign-in credentials (held by our authentication provider, never visible to us in plain text), display name, phone number, profile photo and default shipping details you choose to save.

Shopping and reflection data: product links and stores you capture, item names and prices, pause lengths and choices, post-pause decisions, diary entries, reward points, referral activity, budget settings and discount-code interactions.

Technical data: device and browser type, approximate identifiers such as IP address, notification subscription tokens, error logs and usage events generated when you use the Service.

We do not collect real payment-card numbers. The simulated checkout uses a practice card only; any real payment details you enter at an actual Paddle checkout go to Paddle, not to us.

3. Why we use it and our legal bases

To provide the Service — creating your account, syncing your basket and diary across devices, running the simulated checkout, sending pause-end notifications you switch on, and applying your plan limits. Legal basis: performance of our contract with you.

To keep the Service secure and prevent fraud, abuse and manipulation of rewards or referrals. Legal basis: our legitimate interests in security and integrity, balanced against your rights.

To understand and improve the Service — aggregated usage analytics, sector classification of captured items, and owner reporting on how users decide. Legal basis: our legitimate interests in product improvement; where required, consent.

To provide customer support and communicate important service or policy changes. Legal basis: contract performance and legitimate interests.

Optional marketing or promotional messages, only where you have agreed or where the law permits. Legal basis: consent, which you may withdraw at any time.

4. Commercial use of data

pause. may develop and sell or license shopping-trend reports, sector analyses and similar insights to retailers, brands, researchers and commercial partners. These products use genuinely anonymised or aggregated information from which no individual can reasonably be identified.

We do not sell identifiable personal data — such as your name, contact details, diary entries or linkable shopping history — without first giving you a clear, separate disclosure of the data categories, recipients and purposes, establishing a valid legal basis, and obtaining your separate affirmative consent where the law requires it. Accepting our Terms of Service or this Notice is not that consent.

Where you have a legal right to opt out of, or object to, the sale or sharing of your personal data, we honour it. Declining optional commercial-data consent never reduces your access to the core Service, and silence or inactivity is never treated as consent.

5. Who receives your data

Service providers acting on our instructions: hosting and database infrastructure, authentication, push-notification delivery, product-information retrieval and AI classification providers. They may process data only for the services they provide to us, under contractual confidentiality and security obligations.

Paddle, as Merchant of Record, for the sale of Plus subscriptions, payment processing, subscription management, tax compliance and invoicing.

Professional advisers (legal, accounting) where reasonably necessary, and courts, regulators or law-enforcement authorities where the law requires disclosure.

A successor entity in a genuine merger, acquisition or restructuring, subject to the protections in this Notice and applicable law. We do not otherwise share your personal data with third parties for their own marketing.

6. International transfers

Our service providers may process data in countries other than your own, including countries whose data-protection laws differ. Where the law requires safeguards for such transfers — such as adequacy decisions or standard contractual clauses — we rely on them. You may request information about the safeguards applicable to your data through the contact channel below once published.

7. How long we keep it

We keep personal data only for as long as reasonably necessary for the purposes above or as the law requires. Account and app-state data is kept while your account is active. Transaction and tax records are kept for the periods required by applicable financial law. Notification tokens are kept until you switch alerts off or they expire.

After a valid deletion request, we erase or irreversibly anonymise your identifiable data, except where a specific legal obligation or a lawful, necessary exception applies — for example keeping transaction evidence, investigating fraud, or establishing, exercising or defending legal claims. Copies made before your request are not exempt merely because they predate it; any permitted retention is purpose-limited and access-restricted.

Backup copies may remain temporarily until the documented backup rotation expires. While retained, deleted records are not restored to active use or repurposed for marketing or sale, and if a recovery restores them, deletion is reapplied. Genuinely anonymised statistics may be kept after account deletion where no person can reasonably be identified.

8. Your rights and choices

Subject to applicable law, you may have the right to access your personal data, correct inaccuracies, receive a copy in a portable format, object to or restrict certain processing, withdraw consent, and request erasure. The Account tab currently offers an app-state export and a ‘Delete my data’ option; that option clears app-state items, credits and points and is not a full account-erasure request. A dedicated contact channel for broader requests must be published before this Notice is adopted.

You can switch push notifications off at any time in the Account tab or in your device settings, and you can decline optional commercial-data consent without losing core features. We respond to rights requests within the time limits applicable law sets, and we explain any lawful refusal or limitation.

If you believe your data has been handled unlawfully, you may complain to the data-protection authority competent where you live or work, in addition to contacting us.

9. Security

We apply appropriate technical and organisational measures, including encrypted transport, access controls that limit account data to its owner, and separation of administrative access. No method of transmission or storage is perfectly secure; if a breach affects your rights, we will notify you and the authorities where the law requires.

10. Cookies and local storage

The Service uses essential browser storage to keep you signed in, remember your preferences and operate core features. We do not currently use advertising or cross-site tracking cookies. If analytics or marketing cookies are introduced, this Notice will be updated and any required consent obtained first. You can clear site data through your browser settings, which signs you out.

11. Children

The Service is not directed at children below the age at which they can lawfully consent to data processing in their country, and we do not knowingly collect their data. If you believe a child has provided us personal data, contact us so we can delete it.

12. Changes and contact

We may update this Notice to reflect changes in the Service or the law. Material changes will be communicated in-app or to your account email before taking effect where required. New purposes for your personal data require fresh disclosure and any necessary consent.

The operator’s verified legal identity, postal address and a dedicated privacy contact channel remain outstanding before this Notice is adopted. Until then, this page is a draft and does not by itself enable any data sale or collect consent.