Privacy Policy — Holdtotal

Effective date: [DATE]

1. Introduction

Holdtotal ("the app") is a cryptocurrency portfolio tracker for iOS and Android, published by SMARTNESS HOME ("we", "us"). This policy explains what happens to information when you use the app.

There are two very different things described in this policy, and the difference matters:

• Your portfolio — the coins you enter and the amounts you hold. This stays on your device. We never receive it.
• Advertising data — information the Google AdMob advertising SDK collects from your device in order to show ads. Google receives this; we do not.

We have tried to keep these two apart throughout the document, because collapsing them together is how privacy policies end up misleading people.

2. Summary in plain English

• There are no user accounts. You never give us a name, an email, or a password.
• We operate no server. There is nowhere for us to store your portfolio, even if we wanted to.
• Your holdings are saved locally on your device. Deleting the app deletes them.
• The app is free because it shows ads. Ads come from Google AdMob, which does collect information from your device.
• We do not claim to collect no data. The app contains an advertising SDK, and that SDK collects information. What we can accurately say is that your portfolio is not part of it.
• Your holdings are never used to target ads and are never passed to any advertiser.

3. Data stored only on your device

When you add a holding, the app stores the coin identifier, its symbol and name, and the amount you entered. It also stores your settings (display currency, appearance) and a cached copy of recently fetched prices.

All of this is written to your device's local app storage. It is not transmitted to us, to Google, or to anyone else.

You can remove it at any time:

• Settings → Clear all data deletes every holding, with a double confirmation.
• Deleting the app removes all of it, along with the app itself.

We cannot recover this data for you, because we never had it. There is no cloud backup.

4. Information collected through advertising

Holdtotal is free and is supported by ads served by Google AdMob. To show those ads, the Google Mobile Ads SDK — software provided by Google that runs inside the app — collects information from your device. This may include:

• your IP address, which Google may use to estimate your approximate location;
• your advertising identifier (IDFA on iOS, Advertising ID on Android);
• ad interaction data — which ads were shown to you, whether you viewed or tapped them;
• app activity related to ads, such as when an ad was requested;
• diagnostic and crash information about the SDK itself.

Google processes this information as an independent controller under its own policies, including for personalized advertising where you have consented.

We do not receive this information. Our access to AdMob is limited to aggregate revenue reporting — figures such as total impressions and earnings. We cannot identify you from it.

For more detail, see:

• Google's Privacy Policy: https://policies.google.com/privacy
• How Google uses information from sites or apps that use our services: https://policies.google.com/technologies/partner-sites

Google AdMob is the only advertising or third-party data SDK in the app. There is no analytics SDK, no attribution SDK, no crash-reporting SDK, and no ad mediation partner.

Your portfolio is never involved. Your coins, amounts, and totals are not sent to the advertising SDK in any form — not as ad request parameters, not as keywords, and not as custom targeting values.

5. Third-party price data

The app fetches cryptocurrency prices from CoinGecko, a public market data provider. This is the only source of price data the app uses.

As with any request over the internet, CoinGecko receives the IP address your request comes from. We do not receive it, and we do not store it. The app sends CoinGecko only the list of coin identifiers it needs prices for — never the amounts you hold.

CoinGecko's privacy policy: https://www.coingecko.com/en/privacy

6. Your choices and controls

iOS — App Tracking Transparency. On first use, after you dismiss the introductory notice, iOS asks whether the app may track you across other companies' apps and websites. If you decline, the app serves non-personalized ads instead. Everything in the app works exactly the same either way. You can change this later in iOS Settings → Privacy & Security → Tracking.

Consent form. The app uses Google's User Messaging Platform to gather consent where it is required. If you decline, or if consent cannot be obtained, non-personalized ads are served.

Privacy options. Settings → Privacy options inside the app reopens the consent form so you can change your choice at any time.

Reset your advertising identifier. You can reset or limit it in your device settings:

• iOS: Settings → Privacy & Security → Tracking / Apple Advertising
• Android: Settings → Privacy → Ads

7. Your US state privacy rights

Depending on where you live, state law may give you rights over personal information — for example the California Consumer Privacy Act as amended by the CPRA, and comparable laws in Colorado, Connecticut, Texas, Virginia and other states.

What this means here. We do not sell personal information for money and we hold no personal information about you. However, sharing data with an advertising network for personalized advertising can qualify as a "sale" or as "sharing" for cross-context behavioral advertising under those laws. Because the app serves ads through Google AdMob, you should assume that definition may apply to the advertising data described in Section 4.

How to opt out. Use the in-app controls:

• Settings → Privacy options — change your advertising consent choice.
• On iOS, decline the App Tracking Transparency prompt (or turn tracking off in iOS Settings).
• Reset or limit your advertising identifier in your device settings.

Together these are the mechanisms by which you can opt out of personalized advertising in this app.

Other rights. Rights to access, correct, delete, or port personal information generally apply to information a business holds about you. We hold none: there is no account and no server-side record. Your portfolio is on your device and is under your control — Settings → Clear all data deletes it immediately. For information held by Google, please use Google's own privacy controls at https://myaccount.google.com/data-and-privacy.

You may contact us at [SUPPORT EMAIL] with any privacy question, and you will not be treated differently for exercising a privacy right.

8. Permissions

The app requests no device permissions beyond network access, which is required to fetch prices and ads. It does not request access to your contacts, camera, microphone, photos, files, or precise location.

On iOS you will see the App Tracking Transparency prompt. Declining it does not limit any feature of the app.

9. Children's privacy

Holdtotal is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information through the app, contact us at [SUPPORT EMAIL] and we will address it.

10. Security

Your portfolio is stored in your device's app storage and is protected by your device's own security — your passcode, biometric lock, and the operating system's app sandbox. Keeping your device updated and locked is the most effective protection.

The app makes network requests over HTTPS. No method of storage or transmission is completely secure, and we cannot guarantee absolute security.

Because we hold no copy of your data, losing or resetting your device means losing your entered holdings. There is no backup on our side.

11. Changes to this policy

We may update this policy from time to time. When we do, we will change the effective date at the top. Material changes will be reflected in the app or on our website. Continuing to use the app after a change means you accept the updated policy.

12. Contact and publisher

Questions about this policy: [SUPPORT EMAIL]

Holdtotal is published by:

The app is offered to users in the United States. Because the publisher is established in France, it is also subject to French and EU data protection law for any personal data it processes. In practice the publisher processes none: there is no account, no server, and no copy of your portfolio. The advertising data described in Section 4 is collected and controlled by Google, not by the publisher.