Sapling ("we", "us", the "app") is a six-week civic climate journey. It is designed to be local-first: personal progress lives on your device. A separate, optional collective can contribute limited anonymous activity counts. This policy explains the intended pilot design under the EU General Data Protection Regulation (GDPR).
On this page
1. What we process 2. Optional collective 3. Legal bases (GDPR) 4. Your rights 5. Retention & deletion 6. Children 7. International transfers 8. Changes & contact1.What we process
- On-device personal data. Your garden, rhythm, completed activities, impact commitments, field notes, chosen country, language and settings are stored locally using Apple's on-device database. There is no Sapling account or personal server profile.
- Notifications. If you allow them, reminders are scheduled locally on your device. We do not operate a push server and do not receive delivery information.
- Support email. If you email us, we process the contents of your message and your email address solely to respond and provide support.
- Commercial data. Sapling contains no advertising, tracking prompt, purchase, paywall or paid gameplay reward.
2.Optional collective
Collective participation is off until you choose to join it. An eligible contribution contains only the local day, your manually selected country or “EU”, the campaign, activity kind, weekly theme and a rotating daily token. It contains no name, account, exact location, free text, quiz answer, impact value, advertising identifier or contact detail.
- At most one accepted contribution per activity kind and device-day is intended.
- Country results remain hidden below 25 contributing device-days in the rolling seven-day window.
- Turning participation off clears anything still waiting on your device. Offline contributions expire after seven days.
- Separate pilot research is off by default and requires its own consent.
3.Legal bases (GDPR)
- Consent — for optional collective participation and any separately offered pilot research (Art. 6(1)(a)). You may withdraw future participation at any time.
- Legitimate interests — for basic service security, aggregate operation and responding to support requests (Art. 6(1)(f)), subject to the final professional review.
4.Your rights
Under the GDPR you may have rights to access, rectify, erase, restrict or object to processing, to portability, and to withdraw consent. The app's Transparency screen lets you leave the collective and delete all local progress. Accepted aggregate counts are not designed to be linkable back to an installation. You may also lodge a complaint with your national Data Protection Authority.
5.Retention & deletion
On-device data remains until you delete it in Transparency or uninstall the app. The pilot service is designed to keep raw contribution receipts for no more than eight days, security/network logs for 24 hours, separately consented raw research events for 90 days, and anonymous aggregate counts without device tokens. These periods must be operationally verified before launch.
6.Children
Sapling's pilot audience is EU residents aged 16 and over. It has no child account or age-profiling feature. If you believe a child has submitted pilot data, contact us.
7.International transfers
The planned collective pilot is intended for an Amsterdam-region EU host and managed PostgreSQL service under an appropriate data-processing agreement. Apple provides app distribution and device services under its own terms. Confirm final processors, sub-processors and transfer safeguards before launch.
8.Changes & contact
We may update this policy as the app evolves; material changes will be reflected by the "last updated" date above. Questions or requests: support@codingascreating.com.