Privacy Policy

1. Information We Collect

To provide accountability and parental control services, RootLock processes the following minimal data strictly within the Apple ecosystem:

• Identifiers: Apple iCloud user record IDs (e.g., CKCurrentUserDefaultName). We do NOT collect your actual Apple ID email address; we only process anonymized iCloud record IDs assigned by Apple to link partnerships and child records.
• Product Interaction (Usage Data): When a monitored user attempts to access a restricted application or website, an event record is created. This includes a timestamp, the type of attempt, whether it was blocked, and an anonymized application token. (Apple's Family Controls framework returns opaque tokens, meaning RootLock cannot read the actual app name outside of Apple's protected Shield extension context).
• Other Usage Data:
  • Tamper Events: Generated when the device fails to send a heartbeat ping, signs out of iCloud, revokes Family Controls authorization, or uninstalls the app.
  • Unlock Requests: Generated when a user requests temporary access to a blocked app (includes an optional short text message).
  • Configuration Metadata: Allowlist configurations (categories of allowed apps), accountability partner relationships, 8-character invite codes, and monitored user/device mapping.

2. What We Do NOT Collect

RootLock's architecture is uniquely private. We strictly DO NOT collect, access, or transmit:

• Names (display names entered during onboarding remain securely local on your device)
• Email addresses or Phone numbers
• Physical addresses or precise/coarse location data
• Health, medical, or biometric data
• Financial information (all payments are handled entirely by Apple In-App Purchase)
• Contacts list, Calendar, or Reminder data
• Photos, videos, audio recordings, or file contents
• Browsing History: The web filter blocks restricted content locally but NEVER logs URLs visited.
• Search history or queries
• Crash analytics, performance telemetry, or sensor data

3. No Tracking and No Advertising (ATT Compliance)

In accordance with Apple's App Tracking Transparency (ATT) framework and Guideline 5.1.2: RootLock does not track you. We do not collect advertising identifiers (IDFA/IDFV). We do not engage in device fingerprinting. We do not link user or device data with third-party data for targeted advertising or advertising measurement purposes. Because no tracking occurs, you will not see an App Tracking Transparency prompt within RootLock.

4. Where Your Data is Stored

NO RootLock-owned servers exist. Apexium Marketing LLC operates absolutely no backend infrastructure, databases, or analytics dashboards.

All data is stored exclusively in Apple CloudKit within YOUR own iCloud account (specifically in the container iCloud.com.rootlock.app) and locally on your device in secure App Group UserDefaults.

Because your data is stored in your personal iCloud, Apexium Marketing LLC has absolutely no access to it. Your records are protected by Apple's encryption standards at rest and in transit. Apple's standard CloudKit security and privacy policies apply.

5. Data Sharing — Who Can See What

Your monitored data is shared ONLY with your explicitly designated Accountability Partner (or Parent, in the child-monitoring case) utilizing Apple's CKShare mechanism.

• The designated Partner/Parent can see: bypass attempts, tamper events, unlock requests, and allowlist configuration metadata (counts of allowed items, not specific app names).
• The CKShare utilizes bidirectional sharing with a .none public permission—meaning there is zero public discovery and zero anonymous access. Establishing a partnership requires strict, bilateral explicit consent via an 8-character code and iCloud share acceptance.

Because we do not use third-party analytics or external APIs, we can definitively confirm that no third parties receive your data, meaning there is zero risk of third parties offering lesser protections than stated here.

6. Push Notifications

RootLock utilizes the Apple Push Notification service (APNs) to deliver silent push notifications alerting partners of bypass or tamper events. The notification payload itself contains minimal metadata (a CloudKit subscription identifier). The actual human-readable notification text is constructed securely and locally on the receiving device. Notification contents are never stored on any external servers.

7. Apple's Role in Data Processing

Because RootLock operates serverlessly, Apple Inc. acts as the data processor for:

• iCloud & CloudKit: Storage, encryption, replication, and account-level access control.
• APNs: Routing silent push notifications.
• StoreKit: Processing all subscriptions, financial transactions, and refunds.
• Family Controls: Enforcing app/category blocking at the OS level and returning anonymized, opaque tokens to RootLock.

8. Children's Privacy (COPPA Compliance)

RootLock's parental control functionality is designed for the supervision of minor children utilizing Apple's Family Controls framework (using the .child authorization scope). RootLock complies with COPPA through an "in-person setup model." Verifiable parental consent is achieved because the parent must be physically present to configure the child's device, grant OS-level Family Controls authorization, and set up the parent passcode. Data collected from monitored children is strictly scoped to the parental control function and stored only within the parent's Family Sharing ecosystem. Parents may delete the app from the child's device at any time to immediately cease monitoring.

9. User Rights and Data Deletion

• Revoke Consent & Delete App: Deleting RootLock removes all local App Group data immediately. In "Adult" mode, you can revoke consent to be monitored by ending the partnership in the app's Settings, which instantly revokes the CKShare.
• Request Deletion of Data (Manage iCloud): Because we have no servers, you control your data directly. Users can manually purge their entire CloudKit data container by navigating to iOS Settings → Apple ID → iCloud → Manage Storage → RootLock → Delete Data.
• Cancel Subscription: Manageable solely through Apple Subscriptions in iOS Settings.

10. International Users & State Privacy Laws

California Residents (CCPA/CPRA): Apexium Marketing LLC explicitly DOES NOT SELL OR SHARE your personal information. RootLock engages in no cross-context behavioral advertising.

European Union (GDPR): Apexium Marketing LLC serves as the data controller, while Apple acts as the data processor. Our lawful basis for processing is contractual necessity (providing the app's core function) and legitimate interest (facilitating partner accountability). You maintain rights to access, rectification, erasure, and portability of your data (manageable via iCloud). We respond to privacy inquiries within 30 days.

11. Data Retention

Your data is retained in your personal Apple iCloud account for as long as you maintain your iCloud account and the RootLock container within it. Upon app deletion, all local device data is destroyed. CloudKit data remains in your iCloud until you manually delete it or purge the iCloud container via iOS Settings. Apexium Marketing LLC retains no data whatsoever.

12. Security Measures

All data is encrypted in transit (Apple HTTPS/TLS) and at rest (Apple iCloud/CloudKit encryption). By utilizing zero third-party SDKs, RootLock possesses an exceptionally small attack surface. The app requires no separate passwords, relying entirely on secure Apple Sign-in. The partner accountability model requires explicit bilateral consent, ensuring robust privacy protection.

13. Changes to This Privacy Policy

We may update this policy periodically. Updates will be posted at https://rootlock.app/privacy, with the "Last Updated" date revised accordingly. Material changes will be communicated via in-app notices. Continued use of the app constitutes acceptance of any updates.

14. Contact Information

For privacy-related requests or inquiries, please contact the Data Controller:

Email: hello@rootlock.app
Company: Apexium Marketing LLC
Address: 8206 Louisiana Blvd NE, Ste A #7450, Albuquerque, NM 87113, United States