Last Updated: December 30, 2025

Privacy Policy

Privacy Policy

Effective Date: December 30, 2025 Last Updated: December 30, 2025

1. Introduction

This Privacy Policy explains how Mooncake Investments Ltd (trading as “Desk Jockey”) (“we,” “our,” or “us”) handles information when you use the Desk Jockey iOS application (the “App”).

Our Contact Details

Company Name: Mooncake Investments Ltd Trading As: Desk Jockey Company Number: 14548002 Registered Office: 71-75 Shelton St, London, England, WC2H 9JQ, United Kingdom Email: support@deskjockey.app Registered in: England and Wales

2. Our Commitment to Privacy

We do not collect, store, or transmit your personal data to any servers.

All your exercise data, preferences, and settings remain exclusively:

  • On your device (stored locally using iOS UserDefaults), and/or
  • In your personal iCloud account (if you enable iCloud sync in iOS Settings)

We have no servers, no databases, and no ability to access your data.

3. Information Processing

3.1 Data Stored Locally on Your Device

The App stores the following information locally on your device:

Exercise Data:

  • Number of squats completed per exercise session
  • Date and time of exercise completion
  • Daily exercise count
  • Streak information (consecutive days of exercise)
  • Weekly and monthly statistics

App Preferences:

  • Notification settings (enabled/disabled, frequency)
  • Work hours preferences (Premium users only)
  • Premium subscription status

Important: This data is stored using iOS UserDefaults and remains on your device. We cannot access it.

3.2 Optional iCloud Sync

If you have iCloud enabled on your device, the App uses Apple’s CloudKit framework to sync your exercise data across your Apple devices (iPhone, iPad, etc.).

Key Points:

  • Data is stored in your personal iCloud account, not our servers
  • We have no access to your iCloud data
  • iCloud sync is optional and controlled by your iOS Settings
  • This data is protected by Apple’s encryption and security measures
  • Apple’s Privacy Policy governs iCloud data storage

To disable iCloud sync: Go to iOS Settings → [Your Name] → iCloud → Toggle off Desk Jockey

3.3 Premium Subscription Data

When you purchase a Premium subscription:

What Apple Collects:

  • Apple processes your payment information through the App Store
  • Apple collects your Apple ID, payment method, and transaction details
  • This is governed by Apple’s Privacy Policy

What We Receive:

  • A subscription receipt validation token (anonymous identifier)
  • Subscription status (active/expired)
  • Subscription tier (monthly/yearly)

What We Do NOT Receive:

  • Your name
  • Your email address
  • Your payment card details
  • Your Apple ID
  • Any personally identifiable information

The receipt validation happens locally on your device using Apple’s StoreKit framework.

3.4 Push Notifications

The App uses iOS UserNotifications framework to send you local workout reminders.

Important: These are local notifications scheduled on your device. They do not involve:

  • Sending data to our servers
  • Tracking your location
  • Collecting any information
  • Transmitting data over the internet

You can enable/disable notifications in iOS Settings → Notifications → Desk Jockey.

4. Data We Do NOT Collect

We do NOT collect, store, or process:

  • ❌ Your name
  • ❌ Your email address
  • ❌ Your phone number
  • ❌ Your location data
  • ❌ Your IP address
  • ❌ Device identifiers (beyond what iOS requires for app functionality)
  • ❌ Analytics or usage tracking data
  • ❌ Advertising identifiers
  • ❌ Biometric data
  • ❌ Health data (beyond basic squat counts)
  • ❌ Any sensitive personal data

5. Third-Party Services

5.1 Apple Services

The App uses the following Apple frameworks, all governed by Apple’s Privacy Policy:

CloudKit (Optional):

  • Purpose: Sync your data across your Apple devices
  • Data Location: Your personal iCloud account
  • Our Access: None

StoreKit:

  • Purpose: Process in-app purchases and validate subscriptions
  • Data Shared with Us: Anonymous receipt validation token only
  • Payment Processing: Handled entirely by Apple

UserNotifications:

  • Purpose: Schedule local workout reminders
  • Data Transmission: None (notifications are local)

Apple’s Privacy Policy: https://www.apple.com/legal/privacy/

5.2 No Analytics or Tracking

We do NOT use:

  • ❌ Google Analytics or similar services
  • ❌ Crash reporting tools (e.g., Firebase, Crashlytics)
  • ❌ Advertising networks
  • ❌ Social media tracking pixels
  • ❌ Any third-party SDKs that collect data

6. How We Use Your Information

Since we don’t collect your data, we don’t “use” it in the traditional sense.

All data processing happens locally on your device to:

  • Track your exercise completion and display your statistics
  • Calculate your daily/weekly streaks
  • Send you scheduled workout reminders (if you enable notifications)
  • Sync your data across your devices via your iCloud account (if enabled)
  • Verify your Premium subscription status using Apple’s receipt validation

While we don’t operate as a traditional “data controller” (we have no servers and cannot access your data), for transparency:

Contractual Necessity (GDPR Article 6(1)(b)):

  • Processing necessary to provide the App’s core functionality (tracking exercises, sending reminders)

Legitimate Interests (GDPR Article 6(1)(f)):

  • Verifying Premium subscription status to provide paid features

Consent (GDPR Article 6(1)(a)):

  • Optional iCloud sync (you control this in iOS Settings)
  • Push notifications (you grant permission via iOS)

8. Data Retention

Local Device Storage:

  • Data is retained on your device until you:
    • Delete the App (permanently removes all local data)
    • Manually clear data in App Settings (if we implement this feature)
    • Reset your device

iCloud Storage:

  • Data is retained in your iCloud account according to:
    • Your iCloud storage settings
    • Apple’s iCloud retention policies
    • Your choice to disable iCloud sync (data remains on device)

Our Servers:

  • We have no servers, therefore we retain no data.

9. Data Sharing and Disclosure

9.1 We Do NOT Share Your Data

We do not sell, rent, trade, or share your data with third parties because:

  • We don’t collect your data
  • We have no access to your data
  • We have no servers storing your data

In the unlikely event we are legally compelled to provide information:

  • We would inform the requesting party that we do not collect or store user data
  • We cannot comply with data requests because we don’t have access to your data
  • We would direct them to Apple if the request relates to iCloud data or payment information

10. Your Rights

10.1 UK GDPR Rights

Under UK GDPR, you have the following rights:

Right of Access (Article 15):

  • You can view all your data within the App (exercise history, settings, statistics)

Right to Rectification (Article 16):

  • You can edit or correct your data within the App settings

Right to Erasure (Article 17):

  • Delete the App to permanently remove all local data
  • Disable iCloud sync and delete iCloud data via iOS Settings
  • We cannot delete your data because we don’t store it

Right to Restriction (Article 18):

  • Stop using the App to cease all processing

Right to Data Portability (Article 20):

  • Your data is stored in standard iOS formats (UserDefaults, CloudKit)
  • You control this data via iOS/iCloud

Right to Object (Article 21):

  • You can object to processing by deleting the App

Right to Complain:

10.2 Exercising Your Rights

To exercise your rights:

  • Access your data: Open the App and view your statistics
  • Delete your data: Delete the App or disable iCloud sync
  • Contact us: Email support@deskjockey.app

Response Time: We will respond to requests within 30 days.

11. Data Security

11.1 Device Security

Your data security depends on your device security:

  • iOS Security: Face ID, Touch ID, device passcode
  • iCloud Security: Apple’s encryption (AES 256-bit)
  • Our Security: We cannot access your data (additional security by design)

11.2 Our Security Measures

Since we have no servers:

  • ✅ No risk of data breaches on our end
  • ✅ No centralized database to hack
  • ✅ No employee access to user data
  • ✅ Privacy by design and default

Your Responsibility:

  • Keep your device secure (use passcode/biometric authentication)
  • Keep your Apple ID secure (strong password, two-factor authentication)
  • Keep iOS updated to latest security patches

12. Children’s Privacy

The App is designed for working adults aged 18 and over. We do not knowingly collect information from children under 13 (or 16 in the EEA).

If you are under 18:

  • Consult a parent or guardian before using the App
  • Consult a doctor before starting any exercise program

If you believe a child has used the App:

  • Contact us at support@deskjockey.app
  • Note: We cannot access or delete data as it’s stored locally on the device

13. Health and Medical Disclaimers

13.1 Not Medical Advice

IMPORTANT: Desk Jockey is for general fitness purposes only and is NOT:

  • Medical advice, diagnosis, or treatment
  • A substitute for professional medical advice
  • Intended to diagnose, treat, cure, or prevent any medical condition
  • Supervised exercise instruction from a qualified professional

Always consult a qualified healthcare professional before starting any exercise program.

13.2 Health Data

Squat Counts Are NOT Health Data:

  • We track exercise repetitions (counts)
  • This is basic activity data, similar to a step counter
  • We do NOT collect medical information, diagnoses, or biometric data

Future HealthKit Integration:

  • If we add Apple HealthKit integration in the future, we will update this Privacy Policy
  • HealthKit data would remain in your Apple Health app
  • We would not have access to your HealthKit data

14. International Data Transfers

No International Transfers:

  • We do not transfer your data internationally because we don’t collect it
  • Your data stays on your device (wherever you are located)
  • iCloud data may be stored in Apple’s data centers (governed by Apple’s policies)

UK GDPR Compliance:

  • We are based in the United Kingdom
  • We comply with UK GDPR requirements
  • We do not transfer data outside the UK/EEA

15. Cookies and Website Tracking

Our Website (deskjockey.app):

  • We do not use cookies for tracking or analytics
  • No third-party tracking scripts
  • No advertising cookies

If we add analytics in the future:

  • We will update this Privacy Policy
  • We will use privacy-respecting analytics (e.g., Plausible, no personal data)
  • We will provide opt-out mechanisms

16. Changes to This Privacy Policy

16.1 Notification of Changes

We may update this Privacy Policy from time to time. We will notify you of material changes by:

  • Posting the updated Privacy Policy in the App
  • Updating the “Last Updated” date above
  • Providing an in-app notification for significant changes
  • Posting on our website

16.2 Your Acceptance

Continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

If you do not agree to changes:

  • Stop using the App
  • Delete the App to remove all data

17. Contact Us

17.1 Privacy Questions

If you have questions about this Privacy Policy or our privacy practices:

Email: support@deskjockey.app Postal Address: Mooncake Investments Ltd 71-75 Shelton St London, England WC2H 9JQ United Kingdom

Response Time: We aim to respond within 7 business days.

17.2 Data Protection Officer

As a small company processing minimal data, we are not required to appoint a Data Protection Officer under UK GDPR. Privacy inquiries should be directed to support@deskjockey.app.

17.3 Supervisory Authority

You have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO) Website: https://ico.org.uk/make-a-complaint/ Telephone: 0303 123 1113 Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

18. California Privacy Rights (CCPA)

For California Residents:

While we don’t collect personal information in the traditional sense, under the California Consumer Privacy Act (CCPA):

Right to Know: You can access all your data within the App Right to Delete: Delete the App to remove all data Right to Opt-Out of Sale: We do not sell personal information Non-Discrimination: We do not discriminate based on privacy rights

Contact for California Privacy Requests: support@deskjockey.app

19. Transparency Statement

What Makes Us Different

Most apps collect extensive data about you. We don’t. Here’s our commitment:

✅ No data collection - We don’t collect your personal information ✅ No servers - We have no backend infrastructure to store data ✅ No tracking - No analytics, no advertising networks, no third-party SDKs ✅ Local-only - All your data stays on your device or in your iCloud ✅ No access - We cannot access your data even if we wanted to ✅ Privacy by design - Built from the ground up to respect your privacy

Our Business Model: We make money from Premium subscriptions (processed by Apple), not from your data.

20. Summary (Plain English)

What we know about you: Nothing. We don’t collect your data. Where your data is stored: On your device and optionally in your iCloud. Who can access your data: Only you. What we do with your data: Nothing. We can’t access it. Can you delete your data: Yes, by deleting the App. Do we sell your data: No. We don’t have your data to sell. Do we use tracking/analytics: No.

Bottom line: Your privacy is protected because we simply don’t collect, store, or process your personal data. Everything stays on your device.

This Privacy Policy complies with:

  • ✅ UK General Data Protection Regulation (UK GDPR)
  • ✅ Data Protection Act 2018
  • ✅ Privacy and Electronic Communications Regulations (PECR)
  • ✅ Apple App Store Guidelines
  • ✅ Consumer Contracts Regulations 2013
  • ✅ Electronic Commerce Regulations 2002

By using Desk Jockey, you acknowledge that you have read, understood, and agree to this Privacy Policy.

Last Updated: December 30, 2025 Version: 2.0

© 2025 Mooncake Investments Ltd. All rights reserved.