1) Information About The Collection Of Personal Data And Contact Details Of The Person Responsible
1.1 What This Policy Covers
This Privacy Policy explains how personal data is processed when you use the New Dawn Android application (the “App”) and the New Dawn website (the “Website”). Personal data means any information relating to an identified or identifiable individual, including information that can identify you directly or indirectly. This policy describes the types of information processed, the purposes and legal bases for processing, the services involved, retention periods, and the rights available to you.
New Dawn is not intended for children under the age of 13. Users aged 13 to 17 may use the App only with the consent of a parent or legal guardian. By using New Dawn, you acknowledge that you have read this Privacy Policy and understand how your personal data is handled.
1.2 Person Responsible For Data Processing
The person responsible for processing personal data in connection with New Dawn is Sai Vishnu Vikas Reddy Devireddi, Hyderabad, Telangana, India. You can contact this person at privacy@newdawnapp.dev. All personal data processed by New Dawn is handled under this person's responsibility. No representatives have been appointed.
2) Contact
You may contact the person responsible by email or submit a bug report directly through the App. A bug report may include the message you provide, the affected area and severity selected by you, up to three screenshots with metadata removed, the App version, device model, and Android version. Bug reports are stored using Supabase and are used exclusively to respond to your enquiry and investigate or resolve the reported problem. Processing is based on the legitimate interest in maintaining the functionality, reliability, and security of New Dawn, pursuant to Art. 6 (1) (f) GDPR. Bug reports are deleted after 24 months.
3) Data Processing In The App
New Dawn processes certain information locally on your Android device to provide its core features. This information is not transmitted to us. Screen time and application usage information are accessed through Android's Usage Access permission and retained on the device for up to 400 days. Notification counts for individual applications are obtained through Notification Access, without reading notification content, and retained for up to 92 days. The Accessibility service identifies websites and areas of applications that you choose to block and protects the App's settings while a blocking session is active. It is not used to read messages or capture what you type.
During workouts, camera images are analysed in real time to count repetitions. Images are neither saved nor transmitted to us. Other information kept locally includes blocking rules, schedules, usage limits, focus sessions, a PIN stored as a salted hash, App settings, and profile information such as your name, age, occupation, goals, and profile photo.
You can review or delete this locally stored information through the App. It is erased when you delete your account or uninstall the App. Android backups of this information to Google Drive are disabled. Information obtained through Usage Access, Notification Access, the Accessibility service, the camera, and Health Connect is never used for analytics or advertising.
New Dawn does not display advertisements within the App and does not contain crash-reporting tools. We do not sell personal data.
4) Data Processing For Contract Processing
4.1 Account Data
An account is required to use New Dawn. The account information processed includes your email address, sign-in and session records, IP address, and subscription plan, which may be Free or Premium. This information is necessary to create and maintain your account, authenticate you, manage access, and provide the features associated with your plan. The legal basis is the performance of a contract pursuant to Art. 6 (1) (b) GDPR. Account data is retained until you delete your account and is then deleted within 30 days, subject to any applicable legal obligations.
4.2 - Supabase
Supabase provides the backend infrastructure used by New Dawn to store account information and bug reports. The information processed includes the account data described in Section 4.1 and the contents and technical details of bug reports described in Section 2. Processing is necessary to provide account functionality and support services under Art. 6 (1) (b) GDPR, and to handle reported problems under Art. 6 (1) (f) GDPR. Account information is deleted within 30 days after account deletion, and bug reports are retained for 24 months. Further information is available in the Supabase Privacy Policy.
4.3 - Resend
Resend delivers the six-digit verification code required for email-based sign-in. Your email address and the information necessary to deliver the code are processed to authenticate you and enable access to your account. The legal basis is the performance of a contract under Art. 6 (1) (b) GDPR. No retention period beyond that necessary for delivery and operation of the sign-in process is specified here.
4.4 - Google Sign-In
Google Sign-In is an optional authentication method. If you choose it, New Dawn receives your Google account identifier, name, email address, and profile photo to authenticate you and associate your Google account with your New Dawn account. Processing is necessary to provide the sign-in method you selected and is based on Art. 6 (1) (b) GDPR. Account information is retained until your New Dawn account is deleted and then deleted within 30 days. Google's privacy practices are described in the Google Privacy Policy.
4.5 - Google Play
Premium subscriptions are purchased through Google Play. Google processes the payment and communicates whether your Premium purchase is active so that New Dawn can grant or remove access to the relevant features. New Dawn does not receive your payment card details. Processing necessary to provide the purchased subscription is based on Art. 6 (1) (b) GDPR. Purchase and payment information handled by Google is subject to Google's own retention practices. Further information is available in the Google Privacy Policy.
5) Additional Services
5.1 - Google ML Kit
Google ML Kit provides the pose-detection technology used during workouts. Pose detection runs on your device. ML Kit may nevertheless transmit limited technical information to Google, including device and App information, a per-installation identifier, and performance and error data. This processing supports the reliable operation and improvement of the workout feature and is based on the legitimate interest in providing a functional service, pursuant to Art. 6 (1) (f) GDPR. Further information is available in the Google ML Kit Android data disclosure.
5.2 - Cloudflare Family DNS
If you enable the adult content filter, New Dawn uses Cloudflare's Family DNS service to check websites opened in supported browsers, but only while a blocking session is active. The information checked is the bare website name, such as example.com, and not the complete web address or page path. The result is stored locally on your device for up to 24 hours and is not associated with your account. Processing is necessary to provide the filtering feature you have chosen and is based on Art. 6 (1) (b) GDPR. Further information is available in the Cloudflare Privacy Policy.
5.3 - Health Connect
Health Connect is an optional, read-only integration. If you grant permission, New Dawn reads step counts to calculate screen time earned by walking and active calorie information to display on the workout screen. This information remains on your device. New Dawn does not write information to Health Connect, use this data for analytics or advertising, or sell or transfer it. Access is used solely to provide the features you request. You can revoke Health Connect permissions through your device settings.
5.4 - Google Analytics For Firebase
Google provides Google Analytics for Firebase, which New Dawn uses only if you give consent within the App. You can withdraw that consent at any time through app privacy setting. If enabled, the service processes an App instance identifier, the Android advertising ID if permitted by your device, device model, Android version, App version, approximate location at country or regional level, and events such as first open, sessions, screens viewed, sign-up, trial start, and Premium purchase. These records are pseudonymous: your name, email address, and account data are not sent to the analytics service. This information is never combined with data from Usage Access, Notification Access, the Accessibility service, the camera, or Health Connect.
The purposes are to measure which advertising campaigns for New Dawn result in installations and purchases and to enable New Dawn advertisements through Google Ads to people who have previously used the App. The legal basis is your consent under Art. 6 (1) (a) GDPR. Data is retained for analytics retention period. Further information is available in the Google Privacy Policy and Google's information about partner sites and services.
6) Website
6.1 Hosting - Cloudflare Pages
The New Dawn Website is hosted using Cloudflare Pages. To deliver pages and protect the Website against misuse, Cloudflare processes visitors' IP addresses and request details. This processing is based on the legitimate interest in operating a secure and accessible website, pursuant to Art. 6 (1) (f) GDPR. Hosting logs are retained for website hosting retention period. Further information is available in the Cloudflare Privacy Policy.
6.2 - Google Analytics
Google Analytics is used on the Website only when you accept analytics and advertising cookies through the cookie banner. You can change your choice at any time using the cookie settings link in the Website footer. If you consent, Google Analytics sets cookies and processes information including pages visited, the referring website, browser and device type, approximate location at country or regional level, and clicks on links to app stores. The service does not store IP addresses. The resulting information is pseudonymous and is used to measure which advertising campaigns generate Website visits and App installations and to show New Dawn advertisements through Google Ads to people who have visited the Website.
The legal basis for this processing is your consent under Art. 6 (1) (a) GDPR. Data is retained for analytics retention period. The Website does not respond to Do Not Track signals; you may instead decline the relevant cookies through the cookie banner or cookie settings. Further information is available in the Google Privacy Policy.
7) Rights Of The Data Subject
7.1 Your Rights
New Dawn complies with the data protection laws applicable in every country where the App is available, including the GDPR, the UK GDPR, US state privacy laws such as the CCPA, and India's Digital Personal Data Protection Act, 2023.
Subject to the conditions and limitations of applicable law, you may exercise the following rights:
- Right of access (Art. 15 GDPR): to obtain confirmation of whether your personal data is being processed and access to that data.
- Right to rectification (Art. 16 GDPR): to request correction of inaccurate or incomplete personal data.
- Right to erasure (Art. 17 GDPR): to request deletion of personal data where the applicable conditions are met.
- Right to restriction of processing (Art. 18 GDPR): to request that the processing of your personal data be restricted in circumstances provided by law.
- Right to data portability (Art. 20 GDPR): to receive qualifying personal data in a structured, commonly used, machine-readable format and, where applicable, transmit it to another controller.
- Right to withdraw consent (Art. 7 (3) GDPR): to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal. You may also opt out of the use of data for advertising at any time through app privacy setting or the Website's cookie settings.
- Right to lodge a complaint (Art. 77 GDPR): to submit a complaint to a competent data protection supervisory authority if you believe that the processing of your personal data infringes applicable data protection law.
You can delete your account directly in the App by navigating to Profile › Account › Delete my account. This action deletes your account data from our servers and erases the App's data stored on your device. For any other privacy-related request, please contact privacy@newdawnapp.dev.
7.2 RIGHT TO OBJECT (Art. 21 GDPR)
WHERE THE PROCESSING OF YOUR PERSONAL DATA IS BASED ON LEGITIMATE INTERESTS UNDER ART. 6 (1) (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION. FOLLOWING AN OBJECTION, THE PROCESSING WILL CEASE UNLESS COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS.