Log Off Club Privacy

Legal · Document 01

Privacy Policy

Version 2.1.0 · Last updated: 2026-05-06

This Privacy Policy explains how Log Off Club ("we," "us," "our") collects, uses, and shares your personal data when you use our mobile application and website (collectively, the "Service"). We are the data controller for the personal data we process about you.

1. Who we are

Data controller: Log Off Club. Contact: logoffclubcontact@gmail.com.

Privacy contact: logoffclubcontact@gmail.com.

EU representative (GDPR Art. 27): not currently appointed. The Service does not regularly target users in the European Economic Area or United Kingdom. If our user base in those regions grows beyond occasional processing, we will appoint a representative and update this policy.

Data Protection Officer: not appointed — exemptions in GDPR Art. 37 apply (we are not a public authority and do not engage in large-scale processing of special-category data or large-scale systematic monitoring).

2. Personal data we process

2.1 Information you provide

2.2 Information collected automatically

2.3 Biometric verification result

The Service requires you to authenticate via Face ID, Touch ID, or fingerprint before posting, commenting, liking, following, sharing, or sending direct messages. The biometric data itself is processed entirely on your device by the operating system's secure enclave. We receive only a pass/fail signal — never the biometric template, raw camera input, or any cryptographic material derived from it. We do not process biometric data within the meaning of GDPR Art. 9 or BIPA (740 ILCS 14). For details see our Data Protection Impact Assessment.

2.4 Things we do not collect

3. Lawful basis for processing (GDPR Art. 6)

PurposeLawful basis
Provide the Service (account, posts, messaging, calls)Contract performance — Art. 6(1)(b)
Verify you are 18+Legal obligation + contract performance
Detect abuse, prevent fraud, securityLegitimate interest — Art. 6(1)(f)
Crash reporting (Sentry)Legitimate interest — opt-out in Settings
Product analytics (PostHog)Consent — Art. 6(1)(a) — opt-in only
Marketing emails (future)Consent — opt-in only

You can change your consent choices at any time in Settings → Privacy & Data, or by emailing us. Withdrawing consent does not affect lawful processing that took place before withdrawal.

4. How we share your information

We do not sell your personal data, do not share it with data brokers, and do not use it for cross-context behavioural advertising.

5. International transfers

Our database runs on servers in Beauharnois, Québec, Canada (OVH BHS datacenter). Canada is recognised by the European Commission as providing an adequate level of personal-data protection (commercial-sector adequacy decision, 2024 review upheld), so transfers from the EEA into Canada do not require additional safeguards.

Some sub-processors (Sentry, PostHog, Stripe, Cloudflare, Apple, Google) are based in the United States. Where applicable, transfers from the EEA / UK to those processors are protected by Standard Contractual Clauses (SCCs) and, where the processor is certified, the EU–U.S. Data Privacy Framework.

6. Sub-processors

We share data with the following sub-processors. The full list with DPA links is maintained at docs/SUB_PROCESSORS.md and is also surfaced in-app at Settings → Privacy → Sub-processors. We will notify you in-app and bump the privacy-policy version when we add or remove a sub-processor.

VendorPurposeRegion
Supabase (self-hosted on OVH)Database, auth, storage, realtimeCanada (OVH BHS)
OVHcloudVPS infrastructureCanada (OVH BHS)
CloudflareCDN, DNS, TLS, DDoSGlobal
PostHog (US Cloud)Product analytics — opt-inUnited States
SentryCrash reporting — opt-outUnited States
StripePayment processingUnited States, Ireland
OpenRouterAI safety classifierUnited States
Apple App Store / Google PlayDistribution + IAPUnited States

7. Retention

Data categoryHow long
Account dataWhile your account is active
Content (posts, comments, messages)Until you delete it; 30-day grace after account deactivation, then permanently deleted
Crash diagnostics (Sentry)90 days
Analytics events (PostHog, with consent)365 days
Audit + security logs365 days
Backups30 days rolling

8. Security

We use industry-standard safeguards: TLS 1.3 in transit, AES-256 at rest, bcrypt password hashing, row-level security in the database, biometric verification of every interaction to deter automated abuse, and SSH-key-only administrative access. No system is 100% secure; we cannot guarantee absolute security.

In the event of a personal-data breach likely to result in a risk to your rights and freedoms, we will notify our supervisory authority within 72 hours where required by GDPR Art. 33 and notify affected users without undue delay where required by Art. 34 — see our breach response runbook.

9. Your rights

9.1 GDPR / UK GDPR (Art. 15–22)

There is no automated decision-making producing legal or similarly significant effects (GDPR Art. 22) in the Service.

We respond to requests within 30 days. Email logoffclubcontact@gmail.com with the subject "Data rights request".

9.2 Canada — PIPEDA

If you reside in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies. We adhere to the ten fair information principles (accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, challenging compliance). You have the right to access and correct your personal information and to challenge our compliance with these principles. To do so, contact logoffclubcontact@gmail.com. If you are not satisfied with our response, you can file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

9.3 California — CCPA / CPRA

The categories of personal information we have collected in the past 12 months, the sources, and the purposes are summarised below. We do not sell personal information and do not share it for cross-context behavioural advertising.

Category (Cal. Civ. Code §1798.140)Collected?Source
Identifiers (email, username, IP)YesDirectly from you, automatically
Customer records (name, phone — optional)Yes (if provided)Directly from you
Internet/network activity (in-app events)With consent onlyAutomatically
Geolocation (precise)No
Audio / electronic / visual (calls, photos, videos you create)YesDirectly from you
Sensitive PI: account login + passwordYesDirectly from you
Sensitive PI: precise geo / racial / religious / health / genetic / biometric for IDNo
Inferences / profilesNo

Sensitive PI we do collect (login + password) is used only to authenticate you, not for inference, profiling, or any other purpose. As a result the §1798.121 right to limit use is not separately required, but you can still request limitation by emailing us.

California rights: right to know, right to delete, right to correct, right to opt out of sale/sharing (we do not sell or share — this is honoured by default), right to limit use of sensitive PI, right to non-discrimination. To exercise these rights, email logoffclubcontact@gmail.com with subject "California rights request". You may designate an authorized agent to make a request on your behalf; we will require written, signed proof of authorization. We will not discriminate against you for exercising any right.

Do Not Sell or Share My Personal Information — even though we do not sell or share, you can confirm this election by emailing us.

9.4 Other regions

If you are in Brazil (LGPD), Australia (Privacy Act), India (DPDP Act), or another jurisdiction with comparable rights, you may exercise equivalent rights by contacting us at the email above. We will respond within the statutory timeframe applicable to you.

10. Children

The Service is not for anyone under 18. We require date-of-birth verification at signup and do not knowingly process personal data of anyone under 18. If you believe a person under 18 has created an account, please contact us and we will delete the account.

Because we do not knowingly process personal information of anyone under 13, we are not subject to the U.S. Children's Online Privacy Protection Act (COPPA).

11. Cookies and trackers (web)

This website (thelogoffclub.com) does not set advertising or analytics cookies. We load Google Fonts, which may set cookies on the fonts.googleapis.com / fonts.gstatic.com domains under Google's own privacy policy. We do not pass identifiers to Google. The Log Off Club mobile application does not use third-party advertising or analytics SDKs without your in-app consent (see §3 and §6).

12. Changes to this policy

We will update this policy when we make material changes. On any material change, we will re-prompt you in-app to accept the new version. The version number and last-updated date are shown at the top of this document.

13. Contact

Postal address available on written request to the privacy contact email above.