Privacy policy
Last updated: 1 October 2026 (draft v0.1)
1. Who we are
This privacy policy explains how [COMPANY NAME] ("Pact", "we", "us"), [address], Chamber of Commerce number [KvK number], handles personal data when you visit this website, create a Pact account, join challenges or use the Pact browser extension. We are the controller for the personal data described here. Contact: [privacy email]. [State whether a data protection officer has been appointed, or that none is required]
2. In short
- The Pact extension stores your rules, waitlist and decisions locally in your browser. We do not receive them. Only if you switch on the optional anonymous counters in the extension settings, we receive a small set of numbers (see section 5).
- This website uses no tracking cookies, no advertising trackers and no external fonts. After you sign in, your login is kept in your browser storage. We count visits and sign-up steps with privacy-friendly analytics that sets no cookie and stores no identifier on your device.
- With an account we store your email address, your settings and your challenge progress.
- Challenges are private by default. Only if you choose public do we show a display name, your days kept and your rank on the public challenges page.
- We do not sell personal data and we do not use it for advertising.
- You can download or delete your data yourself at any time in your portal.
3. What we collect, why, and on what basis
| Situation | Data | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account and sign-in | Email address, first name (optional), a one-way hash of your password (or the identifier of your Google or Apple account), plan and plan status, sign-in times, consent records (which versions you accepted and when) | Create and secure your account, provide the service | Contract (Art. 6(1)(b)) and your consent (Art. 6(1)(a)) |
| Join form answers | Your answers about shopping frequency, regretted purchases, product categories, preferred cooling-off period, amount threshold, currency, optional goal text, browser, device of your last unplanned purchase and optional shops | Set up Pact for you, understand whether Pact works, decide how to improve it | Your consent (Art. 6(1)(a)). You can withdraw it at any time. |
| Portal settings | Websites you add, cooling-off period, amount, currency, goal text | Let you manage your rules in one place | Contract (Art. 6(1)(b)) |
| Challenges | Challenges you joined, the days you checked in, whether you take part privately or publicly and, if public, the display name you chose | Show your progress and, if you choose, a public ranking | Contract (Art. 6(1)(b)). The public ranking: your consent (Art. 6(1)(a)), which you can withdraw by switching to private. |
| Optional emails | Your email address and your choice about product news | Tell you about new features and offers | Your consent (Art. 6(1)(a)) |
| Contact and privacy requests | Email address, your message, our reply | Answer you and handle your request | Legitimate interest in answering enquiries (Art. 6(1)(f)) and legal obligation for privacy requests (Art. 6(1)(c)) |
| Website analytics | Page address (without search terms), a few events such as "join form started" and "sign-up submitted", browser language and country. No cookie, no stored identifier, no email address, no session recordings. We ask the analytics provider not to store IP addresses. We do not measure if your browser sends a Do Not Track or Global Privacy Control signal. | Understand how the website is used and improve it | Legitimate interest (Art. 6(1)(f)) [lawyer to confirm the legal basis and whether consent is needed] |
| Extension counters (optional, off by default) | Once a week and only if you switch it on: a random install id and numbers such as how many shops you added, how many times Pact stepped in, and how many purchase intents you bought, released or let expire. No web addresses, shop names, product names, prices, goal text, name or email. Not linked to an account. | Learn whether Pact works and where to improve it | Your consent (Art. 6(1)(a)), which you can withdraw at any time. [Lawyer: confirm whether these numbers are personal data given the random install id] |
| Server security | Our hosting and database providers may keep short-term technical logs (for example IP address and time of a request). [Describe the providers' logs and their retention here] | Keep the service secure and available | Legitimate interest (Art. 6(1)(f)) |
| Paid plans (when offered) | Name, email, billing details, payment status. Card numbers are handled by our payment provider [payment provider] and never reach us. | Provide the plan, invoicing, tax and accounting duties | Contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)) |
The join form includes a wellbeing question. We ask it only to check that Pact is suitable for you. We do not store your answer. If you answer that your spending causes serious worries or that you cannot control it, the form stops and nothing is submitted.
We do not ask for special category data (for example health data) and ask you not to enter any in free-text fields such as your goal or display name.
Challenge check-ins are confirmed by you. We do not watch your browsing to score you. A public ranking never shows money, products or shops.
4. Signing in with Google or Apple
If you choose to sign in with Google or Apple, that provider tells us your verified email address and, when available, your first name. We do not receive your password. Each provider processes your data under its own privacy policy. We only use the provider to sign you in.
5. The Pact extension
The extension keeps the following on your device only: your settings, shops, waitlist (product page address, title and price you saved), decisions and milestones. It adds site access only for the shops you choose, using the permission prompt of your browser. We have no access to this data. It stays until you delete it in the extension settings ("Delete all my data") or remove the extension.
Optional anonymous counters. In the extension settings you can switch on "Share anonymous counters". It is off by default and nothing is sent before you switch it on. The settings page shows exactly what would be sent. Pact then sends a random install id and numbers once a week (see the table in section 3). You can switch it off at any time, which stops all sending, and you can delete what was already shared with "Delete what I shared" (also done by "Delete all my data"). [If you later add sync to the extension, update this section and the store listing before release]
6. Who receives your data
Only people at Pact who need it, and the service providers that process data on our behalf under a data processing agreement: Supabase (database and sign-in, region [EU, Frankfurt: confirm]), Vercel (website hosting), PostHog (website analytics, EU cloud), Resend (sign-up and password emails), [newsletter provider, if used] and [payment provider, when paid plans start]. Public challenge entries are visible to every visitor of the challenges page. We do not sell your data and we do not share it with advertisers.
7. Transfers outside the EEA
We aim to store personal data within the European Economic Area. [If any provider is outside the EEA, name it and state the safeguard, for example standard contractual clauses]
8. How long we keep it
| Data | Retention |
|---|---|
| Account, settings and challenge data | Until you delete your account, or until [24] months after your last sign-in. Then we delete it. |
| Join form answers | Until you delete your account, or until [12] months after you joined, whichever is first. Afterwards we delete them or reduce them to anonymous statistics that cannot identify you. |
| Sign-in session (browser storage) | Until you log out; the session token renews while you use Pact [confirm session length in Supabase settings] |
| Website analytics events | [12] months, then deleted automatically |
| Privacy requests | [3] years, as proof that we handled the request |
| Invoices and payment records (when offered) | As long as tax and accounting law requires [confirm period] |
9. Your rights
You have the right to access your data, correct it, have it erased, restrict or object to its use, receive it in a portable format, and withdraw consent at any time (this does not affect processing before the withdrawal). The fastest way: log in and use Account in your portal to download your data, change it or delete your account. If you cannot log in, send a request on the data page. We verify your identity and respond within one month. You may also contact [privacy email].
You can complain to the supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). [Adjust if your establishment is in another country]
10. Security
We use encrypted connections (HTTPS), collect as little data as possible, limit access to the people who need it, and store passwords only as a salted one-way hash. Admin access requires an admin account. No system is perfectly secure. If a personal data breach occurs we will act as the law requires.
11. Cookies and similar technologies
This website sets no cookies. After you sign in, a login token is kept in your browser's local storage so you stay logged in. It is strictly necessary and is removed when you log out. Our analytics sets no cookie and stores nothing on your device. We do not use advertising or tracking cookies. If we ever add them we will ask for your consent first and update this policy.
12. Age
Pact is for people aged 18 and over. We do not knowingly collect data from minors.
13. Changes
We may update this policy. We record the version you accepted when you join. For material changes we will tell you before they apply to you.