Privacy Policy

Who is responsible

The Dolce Way is the brand of DT Nova Tmi, a sole trader registered in Finland. For the purposes of the EU General Data Protection Regulation, DT Nova Tmi is the data controller for the processing described here.

Part 1

Our iOS apps

Our apps are built to work without an account. You do not sign up, you do not log in, and we do not run a server that stores what you do in them. What you create in an app is written to your own device.

Where an app can connect to Apple Health, that is always something you switch on yourself. It is off until you turn it on, and Health data stays inside Apple Health on your device.

Each app is documented individually so the description matches that specific binary rather than a generic statement. If a particular app's policy differs from the general description above, that app's policy is the one that applies.

Part 2

This website

thedolceway.com has no user accounts and no login. You can read every page on it without giving us anything. The processing below is everything the site does.

Hosting and security

The site runs on Cloudflare. As our hosting and network provider, Cloudflare processes technical connection data such as your IP address, browser user agent and the time of the request in order to deliver pages to you and to protect the site from attacks and abuse. The lawful basis is our legitimate interest under Article 6(1)(f) GDPR in running a working, secure website. Cloudflare acts as our processor for this.

Analytics and advertising on this site

Four third-party scripts run on the pages of this website. Two of them set cookies and can recognise you across websites. We would rather say this plainly than bury it:

• Google Analytics 4 (measurement ID G-CTVQH2Z7VG). It records page views, approximate location, device and browser details, and how you move through the site. It sets cookies and it is a Google product, so the data goes to Google.
• Google AdSense (publisher ID ca-pub-8302836534037419). This is what serves the ads you may see on this site. It sets cookies and Google may use them to personalise the ads you are shown, on this site and elsewhere.
• Cloudflare Web Analytics, which is cookieless, aggregate, and does not follow you between sites.
• Counterscale, an open-source analytics tool we run ourselves on our own Cloudflare account. It sets no cookies.

Where these tools set cookies or read information already on your device, they require your consent under the ePrivacy rules, and consent under Article 6(1)(a) GDPR is the lawful basis we rely on. The cookieless tools, Cloudflare Web Analytics and Counterscale, rely on our legitimate interest under Article 6(1)(f) GDPR in knowing whether anyone reads what we publish.

You can control what Google does with your data at Google My Ad Center and Google's partner sites policy. You can also block or delete cookies in your browser settings, which stops both of them.

None of this applies to our apps. Google Analytics and AdSense run on this website only. There is no Google Analytics, no AdSense, no ad network and no tracking of any kind inside our iOS apps.

Fonts

Page text is set in Inter, loaded from Google Fonts. Requesting the font file sends your IP address to Google. We use it for appearance only and get nothing back from it.

Newsletter and app waitlists

If you choose to subscribe to the newsletter or join a waitlist for an upcoming app, we collect your email address, and the name of the app if you are joining that app's waitlist. That is the whole form. We use it to send you the emails you asked for.

The lawful basis is your consent under Article 6(1)(a) GDPR. You can withdraw it at any time by using the unsubscribe link in any email or by writing to us, and we will remove your address. We keep it until you unsubscribe.

Two processors are involved. Cloudflare Turnstile checks that the form was submitted by a person and not a bot, which is our legitimate interest under Article 6(1)(f) GDPR in keeping spam out of the list. Resend stores the subscriber list and sends the emails on our behalf.

Cookies and browser storage

The cookies on this site are set by Google Analytics and Google AdSense, as described above. We do not set any advertising or tracking cookies of our own.

Separately, the site stores two small preferences in your browser's local storage: whether you chose light or dark mode, and whether you dismissed the announcement banner. Those stay on your device, are never sent to us, and are not used to identify or track you. Clearing your browser data removes all of it.

Part 3

Things that apply to both

What we never do

• We do not sell your personal data.
• We do not pass your email address to anyone except the provider that sends the emails you asked for.
• We do not put ads, ad networks, analytics or tracking of any kind inside our iOS apps.
• We do not combine anything from this website with anything from our apps, because our apps send us nothing to combine it with.

The one qualification, stated openly rather than hidden: this website shows Google AdSense ads and runs Google Analytics, so Google receives browsing data from these pages and may use it to personalise advertising. That is the website, and only the website.

We would disclose personal data only if we were legally required to, for example by a binding order from a competent authority. In practice we hold very little that could be disclosed.

If you email us

When you write to us we process your email address and your message so that we can answer. The lawful basis is our legitimate interest under Article 6(1)(f) GDPR in responding to people who contact us. We keep the correspondence only as long as we need it to deal with the matter.

Transfers outside the EU

Our providers, Cloudflare, Google, Resend and Apple, are international companies and may process data outside the European Economic Area. Where they do, the transfer relies on the safeguards set out in that provider's own data processing terms, such as the European Commission's Standard Contractual Clauses.

Your rights

Under the GDPR you have the right to:

• Ask what personal data we hold about you and get a copy (Article 15)
• Have inaccurate data corrected (Article 16)
• Have your data erased (Article 17)
• Restrict how we use it (Article 18)
• Receive it in a portable format (Article 20)
• Object to processing we base on legitimate interest (Article 21)
• Withdraw consent at any time, without affecting anything we did before you withdrew it (Article 7)

To exercise any of these, write to dt.nova369@gmail.com. We will answer within one month. You also have the right to complain to the Finnish Data Protection Ombudsman, Tietosuojavaltuutetun toimisto, at tietosuoja.fi, or to the supervisory authority in the EU country where you live.

One honest limitation: for data that never leaves your device, such as what you log in an app, we cannot access it, export it or delete it for you, because we do not have it. That data is under your control on your device.

Children

Our apps and this site are not directed at children. We do not knowingly collect personal data from children. If you believe a child has sent us personal data, write to us and we will delete it.

Changes to this policy

If what we do changes, this page changes with it, and it changes before the new behaviour ships. The date at the top shows when it was last updated.

Contact

dt.nova369@gmail.com

DT Nova Tmi, business ID 3595452-5, Finland. Trading as The Dolce Way, thedolceway.com.