Privacy Policy

At a glance

This policy covers both the LessPuffs website and mobile app.
LessPuffs collects only what is needed to help you reduce vaping and track progress.
Health and wellness data you log is stored securely in the EU.
LessPuffs does not sell your personal information.
You can delete your account and all associated data at any time from within the app.
LessPuffs does not use your data for advertising, and no ads are shown in the app.
You must be at least 18 years old to use LessPuffs.
LessPuffs is not medical treatment, emergency response, or live counseling.

What information do we collect?
How do we process your information?
What legal bases do we rely on to process your personal information?
When and with whom do we share your personal information?
Do we use cookies and other tracking technologies?
How do we handle your social logins?
Is your information transferred internationally?
How long do we keep your information?
How do we keep your information safe?
Do we collect information from minors?
What are your privacy rights?
Controls for do-not-track features
Do United States residents have specific privacy rights?
Health and wellness data
Automated decision-making
Data breach notification
Third-party service providers
Do we make updates to this notice?
How can you contact us about this notice?
How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Account information. When you sign in with Google or Apple, we receive your email address, display name, and profile photo from the authentication provider. We do not receive or store your Google or Apple password.

Baseline and goals. During onboarding you enter your baseline daily puff count, nicotine strength (mg/mL), personal motivations for reducing (including any custom motivation text you write), your reduction goal (quit or reduce), and your preferred pace (quick, standard, or gentle).

Financial preferences. You may enter your weekly or monthly vaping spend, cost per pod, puffs per pod, your preferred cost input mode (weekly or monthly), a savings goal amount, target date, and preferred currency code. This information is used to calculate savings and is never shared with advertisers or data brokers.

Trusted contacts. You may add the name and phone number of people you trust for crisis support. This information is stored in your account and is only used when you choose to initiate a phone call to a contact from within the app. The call is placed through your device’s phone dialer — LessPuffs does not record or transmit call content.

Support messages. If you email contact@lesspuffs.app, we receive the information you choose to send, including your email address, name, and message contents.

The personal information we collect may include: names, phone numbers, email addresses, contact or authentication data, vaping habit data, reduction plan data, crisis intervention session data, and purchase history.

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

Health data — puff counts, craving intensity levels, trigger tags, nicotine strength, reduction goals, SOS session data (duration, tool used, outcome, craving intensity), and personal motivations for reducing.

Payment data

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by RevenueCat. LessPuffs does not receive or store your payment card details — all payment processing is handled by Apple or Google.

Information created through your use of the app

Puff logs. Each time you log puffs, we record the timestamp (including your device’s timezone offset), count, and any trigger tags you select (such as stress, social, routine, boredom, craving, or other).

SOS sessions. When you use the SOS feature, we record the session duration, the tool you used, the tool tier level, the outcome (resisted, puffed, or exited), craving intensity, and any feedback you provide. For specific premium tools, additional data is recorded, such as ride-the-wave completion data and reframe responses.

Daily aggregates. We calculate summary statistics from your puff logs, such as total daily puffs compared to your daily limit.

Plan history. When your reduction plan is recalculated (for example, after you adjust your goal or pace), we store a record of the recalculation including the date, previous and new parameters, and the reason for the change.

App preferences. Your theme choice, calendar week-start day, and notification settings are stored locally on your device.

Information collected automatically

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take), device event information (such as system activity, error reports, and hardware settings).
Device data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Application data

If you use our mobile application, we also collect the following information:

Mobile device data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
App analytics. We use Firebase Analytics to understand how the app is used. Examples of events tracked include: app open, onboarding step completion, feature screen views, SOS session starts, puff log submissions, plan adjustments, and subscription-related actions. Analytics data includes general usage patterns and feature engagement but does not include the content of your puff logs, SOS session details, or personal motivations.
Crash reports. We use Firebase Crashlytics to collect crash reports when the app encounters an error. These reports include device information, operating system version, and technical details about the crash.
Device identifiers. Firebase assigns a unique installation identifier to each app install for analytics and crash reporting purposes. This identifier is not linked to your personal identity and is reset when you reinstall the app.
App integrity. We use Firebase App Check to verify that requests come from a genuine LessPuffs app, helping protect against abuse.

This information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.

Information from third-party services

Authentication providers. Google or Apple provides a unique identifier, email address, display name, and profile photo when you sign in.

RevenueCat. Our subscription management provider shares your subscription status and billing platform identifier with us. LessPuffs does not receive or store your payment card details — all payment processing is handled by Apple or Google.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service — including generating your reduction plan, tracking your progress, calculating savings, and powering SOS sessions.
To respond to user inquiries and offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention, and verifying app authenticity through App Check.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
To communicate with you. We may process your information to send local notifications you have enabled and to respond to support inquiries.
To process payments. We may process your information to manage premium subscriptions through RevenueCat and Apple or Google billing.

3. What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. In particular, we rely on your explicit consent under Article 9(2)(a) to process health-related data (puff counts, craving intensity, trigger tags, nicotine strength, reduction goals, SOS session outcomes, and motivations). The app requests your explicit consent to process health-related data during onboarding, before any such data is collected. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to:
- Analyze how our Services are used so we can improve them to engage and retain users
- Diagnose problems and/or prevent fraudulent activities
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We do not sell your personal information.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. See Third-party service providers for details and links to their privacy policies.

We may also need to share your personal information in the following situations:

Service providers. Google Cloud and Firebase (data hosting, authentication, analytics, crash reporting), RevenueCat (subscription management), and Apple or Google (authentication and payment processing).
Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Legal requirements. When required by applicable law, regulation, legal process, or governmental request.
Safety. To protect the rights, safety, or property of LessPuffs or its users.
Trusted contacts. Your trusted contacts receive a phone call only when you initiate it from within the app. We do not share their information with anyone.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/“sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “Do United States residents have specific privacy rights?”

Website. The LessPuffs website may use cookies for site functionality and traffic analysis. You can control cookie preferences through your browser settings. The site remains functional without non-essential cookies.

App. The app uses Firebase Analytics to collect usage data. You can limit analytics collection through your device privacy settings (such as limiting ad tracking on iOS or opting out of personalized ads on Android). The app does not use browser cookies.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party account details (Google or Apple). Where you choose to do this, we will receive certain profile information about you from your provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Your data is primarily stored in the EU (Google Cloud region europe-west1). Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “When and with whom do we share your personal information?” above), including facilities in the United States and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission’s Standard Contractual Clauses

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Google Cloud and Firebase. Some processing may occur outside the EU through Google Cloud infrastructure. Google has entered into Standard Contractual Clauses (SCCs) approved by the European Commission and maintains additional transfer safeguards as described in their Data Processing Terms.

RevenueCat. Subscription data is processed by RevenueCat in the United States. RevenueCat maintains a Data Processing Agreement (DPA) with Standard Contractual Clauses for international transfers. See RevenueCat’s Privacy Policy for details.

Your authentication provider. When you sign in with Google or Apple, authentication data is processed by those providers under their own data transfer mechanisms and privacy policies.

Where data is transferred outside the EU/EEA, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses and, where applicable, reliance on adequacy decisions by the European Commission.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

Account and usage data (profile, puff logs, SOS sessions, plans, savings goals, trusted contacts): retained while your account is active. Deleted when you delete your account.
Firebase Analytics data: retained according to Firebase default settings (user-level data retained for up to 14 months).
Crash reports: retained according to Firebase Crashlytics default settings.
Website technical logs: retained only as long as reasonably needed for security and site operations.
Support email correspondence: retained as long as needed to respond, maintain records, or handle follow-up.

Account deletion. When you delete your account through the app, a Cloud Function permanently removes all your data from Firestore, revokes your Apple authentication token (if applicable), and deletes your Firebase Authentication record. This process is irreversible.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Specifically:

Your cloud data is stored in Google Cloud (Firebase Firestore) in the EU region (europe-west1) and is encrypted at rest and in transit.
Local data on your device (preferences, theme, notification settings) is stored in encrypted SharedPreferences.
Authentication is handled through industry-standard OAuth 2.0 with Google and Apple.
App Check verifies that requests originate from a genuine LessPuffs app.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at contact@lesspuffs.app.

11. What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information.

Under the General Data Protection Regulation, you have the right to:

Access the personal data we hold about you.
Rectify inaccurate or incomplete data.
Erase your data (right to be forgotten).
Restrict processing of your data in certain circumstances.
Data portability — receive your data in a structured, commonly used format. To request a portable copy of your data, email contact@lesspuffs.app. We will provide your data in JSON format within 30 days.
Object to processing based on legitimate interest.
Withdraw consent at any time where processing is based on consent.
Lodge a complaint with your local data protection supervisory authority.

You can make such a request by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below, or by deleting your account in the app.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at contact@lesspuffs.app.

12. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control

Some browsers send a Global Privacy Control (GPC) signal. If we detect a GPC signal, we treat it as a valid opt-out of any sale or sharing of personal information, consistent with applicable law. Since LessPuffs does not sell or share personal information for advertising, the practical effect is the same regardless of the signal.

13. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

The following describes the categories of personal information we have collected in the past twelve (12) months.

A. Identifiers — contact details such as real name, email address, unique personal identifier, online identifier, Internet Protocol address, and account name. Collected: Yes
B. Personal information (California Customer Records statute) — name, contact information, and financial information. Collected: Yes
C. Protected classification characteristics — gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data. Collected: No
D. Commercial information — transaction information, purchase history, financial details, and payment information. Collected: Yes
E. Biometric information — fingerprints and voiceprints. Collected: No
F. Internet or other similar network activity — browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. Collected: Yes
G. Geolocation data — device location. Collected: No
H. Audio, electronic, sensory, or similar information — images and audio, video or call recordings created in connection with our business activities. Collected: No
I. Professional or employment-related information — business contact details, job title, work history, and professional qualifications. Collected: No
J. Education information — student records and directory information. Collected: No
K. Inferences drawn from collected personal information — inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. Collected: Yes
L. Sensitive personal information — health data (vaping habit data, craving intensity, reduction plans, SOS session outcomes). Collected: Yes

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels
Participation in customer surveys or contests
Facilitation in the delivery of our Services and to respond to your inquiries

Sources of personal information

Learn more about the sources of personal information we collect in “What information do we collect?”

Learn more about how we use your personal information in the section “How do we process your information?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section “When and with whom do we share your personal information?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Categories of personal information disclosed for business purposes in the last 12 months:

Category	Disclosed to	Purpose
Identifiers (email, name, user ID)	Google Cloud/Firebase, RevenueCat	Account management, subscription processing
Internet activity (analytics events, crash data)	Google Cloud/Firebase	Service improvement, bug fixing
Health-related information	Google Cloud/Firebase (hosting only)	Service delivery (stored, not shared)

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

Washington My Health My Data Act

For consumers in Washington State, the following additional disclosures apply:

Categories of health data collected: puff counts, craving intensity levels, trigger tags, nicotine strength, reduction goals, SOS session data (duration, tool used, outcome, craving intensity), and personal motivations for reducing.

Purposes: to generate and maintain your personalized reduction plan, track your progress, power SOS crisis-support sessions, and calculate savings estimates.

Third parties receiving health data: none. Health data is stored in Google Cloud (Firebase) in the EU for hosting purposes only. It is not shared with third parties for their independent use.

Your rights: you may request access to, deletion of, or withdrawal of consent for your health data by emailing contact@lesspuffs.app or by deleting your account in the app.

How to exercise your rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at contact@lesspuffs.app, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at contact@lesspuffs.app. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How can you contact us about this notice?“

14. Health and wellness data

Puff counts, craving intensity, trigger tags, nicotine strength, reduction goals, SOS session outcomes, and motivations relate to your health and wellbeing. Under the EU General Data Protection Regulation (GDPR), this information is classified as “special category data” (Article 9).

We process this data under Article 9(2)(a) — your explicit consent. The app requests your explicit consent to process health-related data during onboarding, before any such data is collected. You may withdraw this consent at any time by deleting your account.

How we protect wellness data

Wellness data is used solely to provide and improve LessPuffs features for you.
We do not use wellness data for advertising, profiling, or marketing purposes.
We do not share wellness data with advertisers, data brokers, or any third parties for their own purposes.
We do not access Apple HealthKit, Google Health Connect, or any device health sensors.
LessPuffs is a habit-tracking and reduction tool, not a medical device or health platform.

15. Automated decision-making

LessPuffs uses your baseline puff count, nicotine strength, reduction goal, and preferred pace to automatically generate a personalized reduction plan. This plan sets daily puff targets that gradually decrease over time.

This process is automated but is not the sole basis for decisions with legal or similarly significant effects. You can view, adjust, or recalculate your plan at any time within the app. If you have questions about how your plan was generated, contact us at contact@lesspuffs.app.

16. Data breach notification

In the event of a data breach involving your personal information, we will:

Notify affected users by email (to the address associated with your account) and, where appropriate, through an in-app notification.
Provide notification within 60 days of discovering the breach, as required by the FTC Health Breach Notification Rule. Where applicable, we will also comply with the GDPR 72-hour supervisory authority notification requirement and other state-specific timeframes.
Include in the notification: a description of the breach, the types of information involved, the steps we are taking in response, steps you can take to protect yourself, and how to contact us for further information.
Notify the FTC and applicable regulators as required by law.

17. Third-party service providers

LessPuffs relies on the following third-party services to operate. Each service processes data as described in this policy and is subject to its own privacy practices:

Google Cloud and Firebase (data hosting, authentication, analytics, crash reporting, app integrity): Google Privacy Policy, Firebase Data Processing Terms, Privacy and Security in Firebase
RevenueCat (subscription and billing management): RevenueCat Privacy Policy

18. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

19. How can you contact us about this notice?

If you have questions or comments about this notice, you may contact us by post at:

Marcin Stramowski Jana Henryka Dąbrowskiego 89/62 Poznań, Wielkopolskie 60-574 Poland

Email: contact@lesspuffs.app

20. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request, or contact us at contact@lesspuffs.app.

You can also delete your account and all associated data at any time from within the app (Settings > Delete Account).

Product boundary

LessPuffs supports reduction and habit awareness. It is not medical treatment, emergency response, or live counseling.

Do not use this site, the app, or the support inbox for urgent or clinical needs.