ExPouch

Privacy Policy

Last updated:

This Privacy Policy explains how ExPouch (“we”, “us”, or “our”) handles information through the ExPouch mobile app (the “App”) and expouch.com (the “Site”). You can contact us about this policy or your data at hello@expouch.com.

Information We Handle

Depending on how you use the App or Site, we may handle:

  • Information you provide: information about your nicotine pouch use and quitting goals, preferences and responses you provide during onboarding, information used to estimate your pouch spending, and information you send when contacting us.
  • App and subscription information: app activity, diagnostic information, and purchase or subscription status. Purchases made through Apple's App Store are handled by Apple; we do not receive your full payment card details.
  • Site and technical information: pages viewed, interactions, approximate country, IP address, browser and device information, identifiers, referring pages, and advertising campaign or click information.

Some information may be stored only on your device. Certain sensitive assessment information, including symptom responses and dependence-related assessments, is processed and stored only on your device and is not sent to us or our analytics or advertising providers.

How We Use Information

We use information to provide and personalize App features, track progress, manage subscriptions, respond to requests, maintain security, diagnose problems, understand how the App and Site are used, improve our services, and measure visits and advertising performance.

If you ask to receive updates or other communications, we may also use your contact information for that purpose.

Sharing and Third-Party Services

We use service providers for analytics, diagnostics, subscriptions, app delivery, hosting, and advertising attribution. Depending on the service, they may receive app activity, identifiers, device or technical information, subscription information, and other information needed to provide their services.

The App may use services including Expo, Sentry, AppsFlyer, Mixpanel, and RevenueCat.

We do not send symptom responses, dependence assessments, or other sensitive health-related assessment information to analytics or advertising providers.

We require service providers that process information on our behalf to protect it consistently with this policy and applicable law. We may also disclose information when required by law, to protect users or the service, or in connection with a transfer, acquisition, or reorganization of the service, subject to applicable law.

Cookies, SDKs, and Tracking

The Site may use cookies, browser storage, and similar technologies for functionality, analytics, and campaign attribution. The App and its service providers may use SDKs and device or app identifiers for similar purposes.

On iOS, where required, the App asks for permission through Apple's App Tracking Transparency framework before using information to track you across other companies' apps or websites or accessing the device advertising identifier. You can change this permission in iOS Settings.

You can manage browser cookies through your browser and device permissions through your device settings. Uninstalling the App stops future collection from that installation but does not delete information already sent to us or a service provider.

Where GDPR or similar laws apply, we process information as necessary to provide the App and requested services, for our legitimate interests in maintaining, securing, understanding, and improving the App and Site, to comply with legal obligations, and based on consent where required, including for certain tracking and optional communications.

Where processing is based on consent, you may withdraw that consent at any time.

Our service providers may process information outside your country, including outside the European Economic Area. Where required, international transfers rely on an applicable legal mechanism, such as an adequacy decision or Standard Contractual Clauses. You may contact us for more information about a particular transfer.

How Long We Keep Information

We keep information for as long as reasonably necessary for the purposes described in this policy, including providing the service, maintaining security, resolving requests, and meeting legal obligations.

Information stored only on your device remains there until you remove it or delete the App. If you ask us to delete personal information we hold, we will delete or de-identify it unless we need to retain some information for a lawful reason. Service providers may maintain information according to their own applicable retention periods.

Your Choices and Rights

Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of your personal information, object to or restrict certain processing, and withdraw consent where applicable. You may also have the right to complain to a relevant data protection authority.

To make a privacy request, email hello@expouch.com. We may need to verify your request before acting on it.

Age Requirements

ExPouch is intended for people who are at least 18 and have reached the age of majority where they live, whichever is higher.

We do not knowingly collect personal information from anyone below that age. If you believe an ineligible person has provided us with information, contact us so we can take appropriate action.

Security and Changes

We use reasonable administrative and technical measures to protect information we handle, although no method of storage or transmission is completely secure.

We may update this Privacy Policy when our practices or legal requirements change. We will post the updated version with a new “Last updated” date and provide additional notice where required.

Contact

For privacy questions or requests, email hello@expouch.com.