Privacy Policy
Comma Labs Yazılım Anonim Şirketi ("Comma Labs," "we," "us," "our") makes the why? application ("App"). This Privacy Policy explains what data the App handles, where it is stored, and what rights you have. In short: nothing about what you do on your phone leaves it. There is no account, no advertising and no tracking. The App does not send us your activity, and it cannot read which apps you chose. The single exception is purchases, which are handled for us by RevenueCat and described in section 4.
Data controller. Comma Labs Yazılım Anonim Şirketi, TOBB ETÜ TTO Garaj, Söğütözü, Ankara, Türkiye. Contact: hello@commalabs.co
1. Data We Collect
Nothing about your use of the App. We do not receive, transmit or store any record of which apps you chose, what you answered, when you opened anything, or how often you changed your mind. There are no analytics, attribution, advertising or crash-reporting services in the App.
The one thing that does leave your device is your purchase history, and only if you buy why? Pro. That is described in section 4. It is not linked to your identity, it is used only to know whether Pro is active, and it is never used for tracking or advertising.
We hold no profile of you. There is nothing to build one from: the App never learns your name, your email, or which apps are on your phone.
1.1 What the App stores on your own device
The App keeps the following locally, in a container that only the App and its own Screen Time extensions can read:
- The sealed identifiers Apple provides for the apps you selected (see section 3)
- The three purposes configured for each selected app, whether written by you or left as the defaults
- A record of each time the question appeared and how you answered it: the timestamp, which selected app it concerned, whether you chose a purpose or went back, and which purpose you chose
- The expiry times of temporary access windows currently in progress
- Your settings: whether the App is paused, and whether setup is complete
This information never leaves your device. It is not backed up to our systems, because we have none.
1.2 What the App does not access
- No location, contacts, photos, camera, microphone or health data
- No advertising identifier (IDFA), and no App Tracking Transparency prompt, because nothing is tracked
- No browsing history, message content or activity inside any other app
- No Apple Screen Time reports or usage statistics
2. How the App Works Without Collecting Data
Every number the App shows you, including today's opens, changed minds, the seven-day figures and the purposes you chose, is computed on your device from the local records described in section 1.1. Nothing is calculated remotely and nothing is uploaded to produce them.
The App functions identically with no internet connection.
3. Screen Time and Family Controls
The App uses Apple's Family Controls, ManagedSettings and DeviceActivity frameworks, with your explicit authorization, to show a question before a selected app opens.
These frameworks are designed by Apple so that an app cannot learn which applications you selected. Apple provides opaque tokens rather than names or bundle identifiers, and we cannot read their contents. The names and icons you see in the App's own list are drawn by iOS on our behalf; the App itself cannot read them.
An app's display name is visible only to the extension that draws the question, at the moment it draws it, so the question can name the app you tapped. That name is written to the same local container described in section 1.1 and is never transmitted.
Authorization can be withdrawn at any time in Settings › Screen Time. Withdrawing it stops the App from asking anything.
4. Purchases
why? Pro is sold through Apple's In-App Purchase system using StoreKit. Apple processes the transaction. We never see, receive or store your payment card details, billing address or Apple Account credentials.
The only thing the App needs to know is whether the Apple Account signed in on the device holds a valid why? Pro entitlement. No account creation, email address or sign-up is required at any point. Apple's handling of your purchase is governed by Apple's Privacy Policy.
That entitlement is checked for us by RevenueCat, Inc. (United States), acting as our data processor. RevenueCat receives the purchase and transaction records Apple issues, together with an anonymous identifier the App generates on your device. It does not receive your name, your email address, or anything at all about which apps you chose or what you answered.
RevenueCat's own privacy manifest declares exactly one category of data: purchase history, not linked to your identity, used for app functionality, and not used for tracking. We use it to know whether Pro is active and to see how many people buy which plan. Their handling is governed by RevenueCat's Privacy Policy.
5. Data Sharing
RevenueCat, Inc. is our only data processor, and purchase history is the only thing it processes. There are no advertising partners, no analytics vendors and no data brokers involved in the App, and nothing about your activity is shared with anyone.
We do not sell or share personal information as those terms are defined under the California Consumer Privacy Act, and we have never done so.
6. Data Retention and Deletion
Records of the question being answered are pruned automatically after seven days by the App itself.
Everything else persists on your device until you change or remove it. Deleting the App removes all of it. There is no separate deletion request to make and no account to close, because nothing exists outside your device.
7. Your Rights
Under the Turkish Personal Data Protection Law No. 6698 (KVKK), the EU and UK General Data Protection Regulation (GDPR), and comparable laws including the CCPA, you have rights of access, rectification, erasure, restriction, portability and objection in relation to personal data a company holds about you.
Comma Labs holds no profile of you. The purchase records described in section 4 are not linked to your identity, so we cannot connect them to a person on request. Everything described in section 1.1 is under your direct control on your own device at all times, and deleting the App removes it.
If you would like your purchase records erased, write to us with the approximate date and plan of your purchase and we will ask RevenueCat to delete them.
You may still contact us at hello@commalabs.co with any question, and you have the right to lodge a complaint with your local supervisory authority. In Türkiye that is the Personal Data Protection Authority (KVKK Kurumu).
8. Children's Privacy
The App is not directed to children and we do not knowingly collect information from anyone, including children under 13 (or the equivalent age under COPPA, GDPR Article 8 and local law).
In addition, Apple requires an adult Apple Account to grant Family Controls authorization. Managed and child accounts cannot authorize the App, so it cannot function on them.
9. International Data Transfers
Purchase records are processed by RevenueCat, Inc. in the United States. That transfer is covered by the data processing terms we have agreed with them, which incorporate the European Commission's Standard Contractual Clauses.
Nothing else is transferred anywhere, because nothing else leaves your device. Purchase transactions themselves are carried out by Apple under Apple's own terms and transfer arrangements.
10. Data Security
Local data is held in the App's sandboxed App Group container and protected by iOS file-level encryption, which is active whenever your device is locked with a passcode, Face ID or Touch ID.
Everything the App records about your use of your phone stays in that container and is never transmitted, so there is no server of ours that could be breached and expose it. The most effective protection you can apply is a device passcode.
11. Apple Privacy Disclosures
The App's App Store privacy label declares one item: purchase history, used for app functionality, not linked to you and not used for tracking. That is RevenueCat, and nothing else. The App ships a privacy manifest declaring its use of the User Defaults API, whose only purpose is to store the App's own settings and the records described in section 1.1 on your device.
12. Changes
If this policy changes, this page is updated and the date at the top changes with it. Any material change, in particular the App beginning to collect any data, would also be disclosed clearly inside the App before it took effect.
13. Contact
Comma Labs Yazılım Anonim Şirketi
TOBB ETÜ TTO Garaj, Söğütözü, Ankara, Türkiye
hello@commalabs.co