Effective date: To be set at publication Last updated: To be set at publication

This Privacy Policy explains how Ironwood Technology Group LLC, a Colorado limited liability company (“BitClock,” “we,” “us,” or “our”) collects, uses, and shares information in connection with the BitClock mobile apps, widgets, and website (collectively, the “Service”).

BitClock displays a proprietary market-pressure metric derived from public Bitcoin order-book data. It is an informational tool, not a financial service — the Service does not execute trades, does not hold funds, and does not require or process brokerage or trading account information. That scope shapes what data we do and don’t collect, described below.

1. Summary (plain language)

• BitClock’s free experience — the live ratio, live BTC price, and 24h stats (volume, % change, high/low) — can be used without creating an account, and we do not collect financial or trading data of any kind.
• Threshold alerts are also free, but require an account: we collect the minimum information needed to run them — an email address or an OAuth identity token (Google/Apple sign-in), and a device push-notification token if you enable alerts.
• Subscriber-only features (the ratio’s daily extremes, R-HOD and R-LOD; live bid/ask depth; and, coming soon, ratio history) additionally involve a subscription status record, provided to us by the payment platforms described below.
• We do not sell your data. We do not use third-party advertising trackers. We do not embed general-purpose analytics SDKs that harvest behavioral data beyond what is necessary to keep the Service running and to honestly complete app-store “data safety” disclosures as minimal.
• Payment card and billing details are handled entirely by Google Play Billing, Apple’s App Store In-App Purchase system, or Stripe (for web subscriptions) — BitClock never receives or stores your full card number.
• The market data displayed in BitClock is sourced from Coinbase’s public market-data feeds. BitClock is an independent product. It is not affiliated with, endorsed by, or sponsored by Coinbase, Inc., and does not use Coinbase’s name or marks as part of its own branding.

The sections below give the full detail.

2. Information We Collect

2.1 Information you provide directly

• Account identifiers: an email address, or an identity token from Google Sign-In or Sign in with Apple, used to create and authenticate your BitClock account.
• Subscription status: whether you have an active subscription, its tier, and renewal date — provided to us by Google Play, the App Store, or Stripe as part of purchase/entitlement validation (see §2.4).
• Alert configuration: any price/ratio thresholds you configure, and your alert history. Alerts are evaluated only on our servers, not on your device, so this data must be stored for alerts to work at all.

2.2 Device and usage data

• Push notification tokens: a device-specific token issued by Firebase Cloud Messaging (Android) or Apple Push Notification service (iOS), used solely to deliver alerts you’ve opted into. Uninstalling the app or disabling notifications invalidates this token.
• Minimal technical/diagnostic data: basic operational data needed to keep the Service reliable (e.g., app version, OS version, crash reports) may be collected. We do not use this data for advertising, profiling, or cross-app tracking, and we do not install general-purpose analytics SDKs beyond what is necessary for this minimal operational purpose.
• [OPEN QUESTION]: the exact diagnostic/crash-reporting tool has not yet been selected. This section should be updated to name the specific vendor once chosen, since that vendor’s own data handling becomes part of this policy (see §4).

2.3 What we do NOT collect

• We do not collect brokerage, exchange-account, wallet, or trading credentials. BitClock does not connect to your exchange or brokerage account, does not execute trades, and does not hold or transmit funds of any kind — it only displays a computed market metric.
• We do not collect precise device location.
• We do not use third-party behavioral-advertising trackers or sell personal information to data brokers.
• We do not store your full payment card number, bank account, or other raw payment credentials (see §2.4).

2.4 Payment information

Subscription payments are processed entirely by:

• Google Play Billing (Android in-app subscriptions),
• Apple’s App Store In-App Purchase / StoreKit (iOS subscriptions), or
• Stripe (web-only subscriptions purchased directly on BitClock’s website).

These providers handle your payment method directly under their own privacy policies. BitClock receives only a purchase/subscription status token (e.g., “active,” “expired,” tier) from these providers to unlock features — we never receive or store your card number, bank details, or other raw payment credentials.

3. Third-Party Data Sources

BitClock’s core metric is computed from public Bitcoin order-book market data made available via Coinbase’s public market-data APIs. This is market data about the Bitcoin order book — it is not personal information about BitClock’s users, and no information about you or your BitClock usage is sent to Coinbase.

To be clear about the nature of this relationship: BitClock is an independent product built by Ironwood Technology Group LLC. It is not affiliated with, endorsed by, sponsored by, or operated in partnership with Coinbase, Inc. or any Coinbase affiliate. Any references to Coinbase in this policy or elsewhere in the Service describe the public data source only, not a business relationship.

4. How We Share Information

We do not sell personal information. We share information only as necessary to operate the Service:

• Service providers: cloud hosting and infrastructure (Hetzner), push notification delivery (Firebase Cloud Messaging, Apple Push Notification service), and payment processing (Google, Apple, Stripe) as described in §2.4.
• Legal purposes: if required to comply with a legal obligation, enforce our Terms of Service, or protect the rights, property, or safety of BitClock, our users, or others.
• Business transfers: if BitClock is involved in a merger, acquisition, or asset sale, user information may be transferred as part of that transaction, subject to this Policy’s protections continuing to apply (or you being notified of a materially different policy).

We do not use general-purpose third-party analytics or advertising SDKs that harvest data beyond the minimal operational scope described in §2.2.

5. Data Retention & Deletion

• Account data: retained for as long as your account is active, plus a limited period after closure for legal, tax, and dispute-resolution purposes. [OPEN QUESTION]: the exact post-closure retention period has not yet been decided — commonly 30-90 days for this category of app, but this is a product/legal decision that will be settled before publication.
• Alert history: retained per user; exact retention window [OPEN QUESTION — not yet specified].
• Ratio/market-data history: the underlying market-pressure dataset is aggregate market data, not personal information about any individual user, and is retained indefinitely as BitClock’s core dataset asset — this does not implicate user privacy rights.
• Account deletion: you can request deletion of your account and associated personal data through the app or by contacting us at the support address in §11 (also see the Account Deletion page). We will delete or anonymize your personal data within a reasonable period after a verified request, except where retention is required by law.

6. Your Rights and Choices

Depending on your location, you may have rights to access, correct, delete, or export your personal data, or to object to certain processing. We provide account deletion through the app and the Account Deletion page; for other requests, contact us using the information in §11.

[OPEN QUESTION]: whether BitClock will publish region-specific rights language (e.g., a GDPR-specific section for EU/UK users naming a legal basis for processing and a right to lodge a complaint with a supervisory authority; a CCPA/CPRA-specific section for California users) depends on the markets BitClock operates in. Counsel should add the applicable regional sections before publication.

You can also control push notifications at any time through your device’s operating-system settings, and disable specific alerts within the app.

7. Children’s Privacy

BitClock is a market-data information tool intended for a general adult audience and is not directed to children. We do not knowingly collect personal information from children under 13 (or under 16, in jurisdictions that set a higher age threshold for consent to data processing, e.g. under GDPR-adjacent regimes). If we learn that we have collected personal information from a child under the applicable age without appropriate consent, we will delete it. If you believe a child has provided us information, contact us using the details in §11.

[OPEN QUESTION]: final age threshold language (13 vs. 16, or a jurisdiction-dependent split) should be confirmed with counsel based on BitClock’s actual target markets, per §6 above.

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information we hold. TLS is used for all client-server connections; no cleartext endpoints are shipped in any client. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. International Data Transfers

BitClock’s infrastructure is hosted with Hetzner. [OPEN QUESTION]: whether BitClock’s users and infrastructure span countries/regions in a way that requires cross-border data-transfer language (e.g., Standard Contractual Clauses for EU data) depends on the markets BitClock launches into. Counsel should add this section once those facts are settled.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the app, by email (if we have one on file), or by posting a notice on our website prior to the change taking effect. The “Last updated” date at the top of this Policy reflects the most recent revision.

11. Contact Us

If you have questions about this Privacy Policy or want to exercise a privacy right described above, contact us at:

support@getbitclock.com

Ironwood Technology Group LLC [MAILING ADDRESS — to be added at publication]

Appendix: Open-Question Index

For the reviewer’s convenience, every item in this draft that still requires a decision (and eventually attorney review) before publication:

1. Mailing address for the entity (§11).
2. Effective date / last-updated date (set at actual publication).
3. Diagnostic/crash-reporting vendor not yet selected (§2.2).
4. Post-account-closure data retention period (§5) — not yet decided.
5. Alert-history retention window (§5) — not yet specified.
6. Region-specific rights language (GDPR/CCPA sections) (§6) — depends on target markets.
7. Final children’s-privacy age threshold (13 vs. 16 or jurisdictional split) (§7).
8. International data transfer language (§9) — depends on launch markets.

This document should not be treated as final, linked publicly as a final policy, or submitted in any app store listing until (a) the open items above are resolved, and (b) a licensed attorney has reviewed the final text.