Privacy Policy

1. Who We Are

DuaScroll is published by Firswood Digital Services Limited ("we", "us", "our"), a company registered in England & Wales (company number 11608317), which is the data controller for the personal data described in this policy. Our registered office is 651a Mauldeth Road West, Chorlton Cum Hardy, Manchester, M21 7SA, United Kingdom. This policy is governed by the laws of England & Wales. Contact: duascroll@gmail.com

2. What Data We Collect

Names & email addresses: we collect a name and/or email address only in the limited cases shown above — when you sign up to our website newsletter, when you buy a gift or family plan on our website (the recipient's and the buyer's details), and when you choose to add your email to feedback you send from the app. The mobile app otherwise does not ask for your name or email. When you optionally Sign in with Apple to join the leaderboard, we explicitly request no scopes — we deliberately do not receive the name or email Apple offers; only the opaque per-app Apple user ID is stored.

We do NOT collect: phone numbers, photos, contacts, health data, card or bank details (all payments are handled entirely by Apple, our subscription & purchase provider, and our payment processor — we never see your card number), browsing history outside our own website, advertising identifiers (IDFA/GAID), or anything that identifies you by name, email or phone number.

3. Why We Process Data (Legal Bases)

EU GDPR (Art. 6)

• Core functionality (progress, prayer times, app locking) — Performance of a contract (Art. 6(1)(b))
• Subscription, gift & family purchases via our subscription & purchase provider / our payment processor — Performance of a contract (Art. 6(1)(b))
• Delivering a gift to its recipient (recipient email/name supplied by the buyer) — Legitimate interest (Art. 6(1)(f)); see Section 9 for the Art. 14 notice to recipients.
• Streak backup & trial-start records — Legitimate interest (Art. 6(1)(f)) in protecting your progress and preventing trial abuse.
• Usage & website analytics via our product-analytics provider (EU-hosted) — Legitimate interest (Art. 6(1)(f)) in the app; Consent (Art. 6(1)(a)) for website cookies. You may opt out (see Sections 5 and 10).
• Feedback you send from the app — Legitimate interest (Art. 6(1)(f)) in reading and answering it and improving the app.
• Notification reminders & push tokens — Consent (Art. 6(1)(a))
• Newsletter / marketing emails — Consent (Art. 6(1)(a)); withdraw any time via the unsubscribe link.
• Website advertising measurement via a third-party advertising-measurement provider — Consent (Art. 6(1)(a)), collected only after you accept cookies.

UK GDPR (post–Data (Use and Access) Act 2025)

The same legal bases apply. We do not rely on the new "recognised legitimate interests" basis (Art. 6(1)(ea), effective 5 February 2026) as our processing does not fall within the Annex 1 purposes. The UK digital age of consent is 13.

Legitimate Interest Assessment (Analytics)

We have conducted a three-part legitimate interest assessment:

1. Purpose: Genuine need to understand feature usage to prioritise development and fix issues.
2. Necessity: Anonymous, aggregated usage events are the least intrusive means. No personal identifiers collected in-app analytics. Screen recordings run only for a user's first 7 days, with everything typed and personal text hidden.
3. Balancing: Minimal impact on users — in-app events are anonymous, EU-hosted, and users can opt out at any time. Website analytics and advertising cookies fire only after consent.

4. Third-Party Services

• Our backend & database provider (EU-hosted) — Our database / backend host (EU). Stores the server-side records described in Section 2: device identity, streak backups, trial-start records, push tokens, Usrah groups, referral data, leaderboard entries, feature votes, newsletter signups, and gift/family purchase details.
• Our subscription & purchase provider — Subscription management, receipt validation, and web-billing purchase processing. Receives an anonymous user ID and purchase receipts.
• Our payment processor — Payment processing for donations and website purchases. Receives the payment details you enter at checkout; we never see your card number.
• Apple — Sign in with Apple (leaderboard opt-in), StoreKit purchases, and Apple Push Notification service (APNs) for reminders. Receives what is needed to authenticate, take payment, and deliver notifications.
• Our email-delivery provider — Transactional, gift and app-feedback email delivery. Receives the recipient/buyer email addresses and message content needed to send the email.
• Our creator-attribution provider — Credits the creator whose code you type (creators earn a share of referred subscriptions). Receives the code, your anonymous subscription ID and, like any internet request, your IP address. If you don't have an active subscription, the app also asks it whether a creator's free-access code applies to your anonymous subscription ID. We use this only to credit creators: never for advertising, and never sold. No device details, no advertising identifier, no name or email. Versions 1.89 and earlier of the app also send device model, OS version, screen size, time zone, language and a random per-install identifier when first opened, to match installs to taps on creators' links; version 1.90 stopped this.
• Our team chat provider — Receives the feedback you send from the app, so our team sees it.
• A prayer-time calculation API — Prayer time calculation. Receives latitude & longitude.
• Our product-analytics provider (EU-hosted) — Product analytics (app) and website analytics, including session replay on the website checkout funnel. Receives anonymous usage events; website tracking runs only after cookie consent. In the app, for your first 7 days, it also receives screen recordings with everything you type and your personal text hidden.
• A third-party advertising-measurement provider — Advertising measurement on our website only (not in the app). Fires only after you accept cookies. Receives website conversion events.
• Our crash & error-monitoring provider (EU-hosted) — Crash & error monitoring. Receives anonymous crash reports and technical diagnostics (device model, OS version, app build, stack traces). No personal info attached; covered by the analytics opt-out.
• Apple Speech Recognition — Optional, only used if you grant microphone & speech-recognition permissions and use voice tasbih or voice dhikr matching. Receives short audio clips of your spoken Arabic recitation. Apple processes the audio on-device or on Apple servers per Apple's defaults; we do not control this routing.
• A reverse-geocoding service — Reverse geocoding (city name lookup during onboarding). Receives latitude & longitude once. Stateless — no data retained.

Each of these providers processes data under its own privacy policy and a data-processing agreement with us.

We do not sell, rent, or trade your personal data for money. The only third-party "sharing" in the CPRA sense is website advertising measurement via a third-party advertising-measurement provider, which is consent-gated and which you can decline via the cookie banner (see Section 5).

5. Cookies & Website Tracking

Our website (duascroll.app) uses a cookie-consent banner. Strictly-necessary cookies (needed for the site and checkout to work) are always on. Analytics and advertising cookies — our product-analytics provider (EU-hosted) product analytics and session replay, and a third-party advertising-measurement provider — fire only after you accept them via the banner. You can decline or change your choice at any time. The mobile app does not use web cookies.

6. Data Retention

• On-device data: persists until you uninstall the app or clear app data.
• Our subscription & purchase provider / our payment processor: retain subscription and payment records per their retention policies and applicable tax/accounting law.
• Our product-analytics provider (EU-hosted): event data retained for 12 months, then automatically deleted. App screen recordings are kept for 30 days, then automatically deleted.
• Feedback you send from the app: kept in our team inbox and team chat for as long as we need it to answer you and improve the app. Ask us and we will delete it.
• A third-party advertising-measurement provider: advertising-measurement data retained per its policies; only collected after consent.
• Our crash & error-monitoring provider (EU-hosted): crash & error events retained per their default retention (90 days), then automatically deleted.
• Our backend & database provider (EU-hosted): device identity, streak backups, trial-start records, push tokens, Usrah groups, referral data, leaderboard entries, feature votes, newsletter signups, and gift/family purchase details are retained until you request deletion (or, for newsletter, until you unsubscribe).
• A prayer-time calculation API / a reverse-geocoding service: stateless APIs — no data is retained.

7. International Transfers

• Our product-analytics provider (EU-hosted) — the EU. No transfer outside EEA. For UK users, mutual adequacy applies.
• Our crash & error-monitoring provider (EU-hosted) — EU region. No transfer outside EEA. For UK users, mutual adequacy applies.
• Our backend & database provider (EU-hosted) — the EU. No transfer outside EEA. For UK users, mutual adequacy applies.
• Some providers (payment, email delivery, team chat, and advertising measurement) process data in the United States under EU Standard Contractual Clauses (2021 module) and the UK International Data Transfer Addendum (IDTA).
• A prayer-time calculation API — Stateless; no personal data retained. Transfer risk negligible.

Transfer Risk Assessment (Schrems II): For US transfers, we have assessed the risk of government access and applied supplementary measures (TLS 1.2+ encryption, data minimisation, and contractual safeguards). The data transferred to our subscription & purchase provider contains no names, emails, or IP addresses. Where a US processor necessarily receives an email address (our payment processor, our email-delivery provider, our team chat provider, a third-party advertising-measurement provider), it is limited to what is required to take payment, send the requested email, show us your feedback, or measure an ad you consented to.

8. Your Rights

UK GDPR & EU GDPR

• Access — request a copy of your data
• Rectification — correct inaccurate data
• Erasure ("right to be forgotten") — request deletion
• Restriction — limit how we process your data
• Portability — receive your data in a portable format
• Object — object to processing based on legitimate interest
• Withdraw consent — at any time, without affecting prior processing

To exercise these rights, email duascroll@gmail.com. We will respond within 30 days.

You may lodge a complaint with the ICO (UK) or your local EU supervisory authority.

California (CCPA / CPRA — January 2026 amendments)

California residents have the right to:

• Know what personal information we collect, its sources, purposes, and who we share it with
• Delete personal information we hold
• Correct inaccurate personal information
• Opt out of sale or sharing — we do not sell personal information. We "share" only for website advertising measurement (a third-party advertising-measurement provider), which is consent-gated and can be declined via the cookie banner.
• Limit use of sensitive personal information — we do not collect sensitive personal information
• Non-discrimination — exercising your rights will not affect your access to the App

Personal information collected (prior 12 months):

We do not use automated decision-making technology (ADMT). To make a verifiable consumer request, email duascroll@gmail.com. We will respond within 45 days.

9. Data We Received About You From Someone Else (GDPR Art. 14)

If someone buys you a DuaScroll gift or adds you to a family plan on our website, the person who bought it provides us with your name and email address so we can email you the gift. In that case we did not collect your data from you directly — we received it from the gift purchaser. We use it only to deliver the gift and any related email, on the basis of our legitimate interest in fulfilling a purchase the buyer made.

If you have received a gift email and would rather not hear from us, you can unsubscribe using the link in that email, or email duascroll@gmail.com to request access to, or deletion of, the data we hold about you. We will action the request within 30 days.

10. Opting Out of Analytics

You can disable analytics in the app: Settings → About → Anonymous Analytics → toggle off. This immediately stops all usage data from being sent to our product-analytics provider (EU-hosted). Screen recordings stop too. Your existing data will be deleted within 30 days of opting out. On the website, decline analytics and advertising cookies in the cookie banner.

11. Children's Privacy

DuaScroll is intended for a general adult audience and is not directed at children. We still take children's privacy seriously and do not knowingly collect personal data from anyone under the applicable minimum age.

COPPA (US — under 13)

We do not knowingly collect personal information from children under 13. The App requires no registration to use core features and does not ask for a name; it asks for an email only if you choose to add one to feedback. Website newsletter signup and gift/family purchases are directed at adults and collect a name/email only from the person who submits the form. The optional Sign in with Apple flow used to join the public leaderboard is gated by Apple's own age policies and is not surfaced to a child by default. If we learn that a child under 13 has provided personal data, we will delete it within 72 hours.

EU GDPR Art. 8 (under 16) & UK GDPR (under 13)

Core functionality does not rely on consent-based processing. Analytics operate under legitimate interest with anonymous data only. No parental consent mechanism is required because we do not process children's personal data for profiling, marketing, or behavioural targeting.

Privacy-protective design

DuaScroll is aimed at adults, so the Children's Code's child-specific obligations are not the basis of our design. Even so, our defaults are privacy-protective as a matter of good practice:

• Privacy-high defaults — no public profile is created by default; the optional public leaderboard is strictly opt-in via Sign in with Apple, with no real name or email collected
• No profiling, behavioural advertising, or nudge techniques that exploit children (a third-party advertising-measurement provider runs on the website only, after adult cookie consent)
• Data minimisation — in the app, only location (prayer times) and anonymous events are collected by default
• Social features are opt-in, not default: the public leaderboard exposes only a user-chosen display name and public adhkar score (no real-identity linkage); Usrah groups are user-created and shared only with members you join; gifting is a website purchase flow. None create a public profile automatically.
• The app-locking feature is entirely user-initiated and serves a self-improvement purpose

If you believe a child's personal data has been collected, contact duascroll@gmail.com and we will investigate and delete it within 72 hours.

12. Referral Programme

DuaScroll offers an optional invite/referral programme. When you share your unique invite code with a friend and they redeem it, a referral relationship is recorded.

What is collected

• An anonymous device identifier (randomly generated, not linked to your Apple ID, email, or name)
• Your unique invite code
• The referral relationship (which anonymous ID invited which anonymous ID)
• Aggregate hasanat credits earned through referrals

What is NOT shared between users

• The inviter cannot see the invitee's individual adhkar data, progress, or streak
• The inviter can only see an aggregate number of referral hasanat earned — not individual block completions
• Neither party can identify the other — all identifiers are anonymous

Legal basis

Performance of a contract (Art. 6(1)(b)) — the referral programme is a feature of the App that users opt into by sharing or redeeming an invite code.

Deletion

To delete your referral data, email duascroll@gmail.com. We will remove your anonymous ID, invite code, and all referral relationships within 30 days.

13. Gifting & Family Plans

On our website you can buy a DuaScroll subscription as a gift, or set up a family plan. To do that we collect and store, in our backend provider (EU):

• The recipient's email address and name
• Your (the gifter's) name and email address
• An optional free-text gift message you write
• The buyer's email address (for the receipt and account)

We use our payment processor / our subscription & purchase provider to take payment and our email-delivery provider to email the gift to the recipient. See Section 9 for the notice we give to gift recipients whose details were provided by the buyer.

Legal basis

Performance of a contract (Art. 6(1)(b)) for the buyer, and legitimate interest (Art. 6(1)(f)) in delivering the gift to the recipient.

Deletion

To delete gift or family data we hold about you, email duascroll@gmail.com. We will action the request within 30 days, subject to any records we must keep for tax/accounting law.

14. Newsletter & Marketing Emails

If you enter your email address into the newsletter form on our website, we store it in our backend provider (EU) and use our email-delivery provider to send you occasional updates about DuaScroll. This is based on your consent. You can unsubscribe at any time via the link in any email, or by emailing duascroll@gmail.com. Unsubscribing removes your address from the mailing list.

15. Notifications & Push Tokens

If you allow notifications, we store an Apple Push Notification (APNs) device token and your device locale in our backend provider (EU) so we can send you dhikr reminders in the right language. This is based on your consent (the iOS notification permission). Revoke it any time in iOS Settings → DuaScroll → Notifications, which stops the reminders.

16. Optional Sign in with Apple, Public Leaderboard & Usrah Groups

DuaScroll offers an optional public leaderboard and optional Usrah (group) features. These are strictly opt-in: the core functionality of the App — adhkar progress, streaks, and app locking — works fully without signing in or joining a group.

What is collected when you join the leaderboard

• The opaque Apple user ID returned by Sign in with Apple — a per-app identifier issued by Apple, not your Apple Account email or name
• An autogenerated friendly display name (e.g. "eggly638"), which you may rename to anything you choose
• Your dhikr level and tasbih/rep counts — i.e. your public adhkar score / hasanat totals as displayed on the leaderboard

What is NOT collected from Sign in with Apple

• Your real name — we explicitly request no scopes from Apple
• Your Apple Account email
• Any other identifier that ties the leaderboard entry back to your real identity

Usrah groups

If you create or join an Usrah group, we store the group name (chosen by whoever created it) and your membership of that group in our backend provider (EU). Your membership and the group name are visible to the other members of that group. Groups are opt-in and are not created by default.

Public visibility

Your chosen display name and your leaderboard score are visible to other DuaScroll users on the leaderboard screen. Choose a display name you are comfortable being public.

Where it is stored

Leaderboard and Usrah data are stored on our backend provider (EU). The same backend provider (EU) also stores anonymous referral data and anonymous feature-voting data.

Legal basis

Performance of a contract (Art. 6(1)(b)) — the leaderboard and Usrah groups are features of the App that you opt into.

Deletion

"Leave leaderboard" on the app’s Leaderboard screen stops your score updating. To remove your entry, email duascroll@gmail.com to request full deletion of your Apple user ID, display name, score, and Usrah memberships from our database. We will action requests within 30 days.

17. Voice Recognition (Optional)

DuaScroll offers an optional voice mode for two features: the standalone tasbih counter and per-rep voice matching on dhikr cards. Voice mode requires you to grant Microphone and Speech Recognition permissions; it is strictly opt-in and the App functions fully without it.

How it works

• While voice mode is active, your microphone captures short audio clips of your spoken Arabic recitation
• The audio is passed to Apple's Speech Recognition framework (SFSpeechRecognizer) for transcription
• The transcript is matched against the expected dhikr text to count reps
• Audio and transcripts are never stored, never sent to our servers, and discarded immediately after each rep is counted

On-device vs Apple servers

Apple's Speech Recognition framework processes audio either on-device or on Apple servers depending on locale, device capability, and Apple's defaults. We do not control or override this routing. Apple's own privacy policy governs that processing. Apple Privacy Policy

Legal basis

Consent (Art. 6(1)(a)) — granted explicitly via the iOS Microphone and Speech Recognition permission prompts. Withdraw consent at any time by revoking either permission in iOS Settings → DuaScroll.

Opting out

Deny or revoke Microphone or Speech Recognition permission in iOS Settings → DuaScroll. Voice features will be unavailable but every other feature continues to work normally.

18. Security

All on-device data is stored in encrypted MMKV storage. The personal data we hold server-side is stored in our backend & database provider (EU-hosted), protected by row-level security and encrypted in transit and at rest. Communications with all third-party services use HTTPS/TLS 1.2+.

19. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via an in-app notice. The "Last updated" date at the top reflects the most recent revision.

20. Contact Us

Firswood Digital Services Limited (registered in England & Wales, company number 11608317)
651a Mauldeth Road West, Chorlton Cum Hardy, Manchester, M21 7SA, United Kingdom
Email: duascroll@gmail.com