PRIVACY POLICY
Last updated August 18, 2025
This Privacy Policy explains how Oleksandr Romaniuk PE (“we,” “us,” “our”) collects, uses, and protects information when you use our mobile application TorrinPass (the “App”) and related services (collectively, the “Services”). If you do not agree with this policy, please do not use the Services.
SUMMARY
• We do not track you across apps or websites for advertising; we do not sell or share personal information for targeted ads.
• We use your account details to authenticate you and use purchase information to manage your subscription entitlements.
• Your vault contents are end-to-end encrypted (E2EE). We cannot read your saved passwords or secure items.
• Biometrics (Face ID/Touch ID) are checked on your device by Apple; we do not collect biometric data.
• You can delete your account in the App at Settings → Account Deletion.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. LEGAL BASES (EU/UK)
4. WHEN DO WE SHARE INFORMATION?
5. COOKIES, ANALYTICS & TRACKING
6. HOW LONG DO WE KEEP INFORMATION?
7. HOW DO WE KEEP INFORMATION SAFE?
8. YOUR RIGHTS & CHOICES
9. UNITED STATES PRIVACY DISCLOSURES
10. CHANGES TO THIS POLICY
11. CONTACT US
1. WHAT INFORMATION DO WE COLLECT?
Account & Profile
• Email address and a unique user identifier. If you use Sign in with Apple, we may receive your Apple-provided email (which may be private relay) and, if you allow, your name.
• We do not collect or store your plaintext password. Email/password auth is handled by our authentication provider.
Subscription & Purchase Information
• Product identifiers, receipt/transaction identifiers, and entitlement status needed to deliver premium features.
• Payments are processed by Apple In-App Purchase. We do not receive your full payment card details.
• We use RevenueCat as a processor to validate purchases and manage entitlements.
Vault Content (End-to-End Encrypted)
• Your saved passwords and secure items are encrypted on your device before syncing. We cannot decrypt or read them.
• Encryption keys are managed on your device/Keychain and are not sent to us in plaintext.
Device & Diagnostics (Minimal)
• App version, OS version, and basic diagnostics (e.g., error codes) to keep the App secure and reliable.
• We do not collect precise location.
Biometrics
• Face ID/Touch ID checks are performed by Apple on your device. We do not collect, store, or receive biometric templates or images.
2. HOW DO WE USE YOUR INFORMATION?
We use information to:
• Authenticate you and operate the App (contract).
• Provide premium features and manage entitlements (contract).
• Secure the App, prevent fraud/abuse, and fix issues (legitimate interests; legal obligations).
• Communicate service updates and transactional messages (contract/legitimate interests).
We do not use your information for third-party advertising or cross-app tracking.
3. LEGAL BASES (EU/UK)
• Contract (provide the App and features you request).
• Legitimate interests (security, diagnostics, improving reliability).
• Legal obligations (tax/accounting for purchases, responding to lawful requests).
Where we rely on consent, you can withdraw it at any time.
4. WHEN DO WE SHARE INFORMATION?
We share only with service providers acting on our behalf to operate the Services:
• Apple (In-App Purchase).
• RevenueCat (purchase validation & entitlements): Privacy.
• Cloud hosting/authentication providers to run the Service reliably and securely.
We do not sell or share personal information for targeted advertising and we do not have third-party advertising SDKs.
5. COOKIES, ANALYTICS & TRACKING
The mobile App does not use cookies and does not include third-party analytics or advertising SDKs. We do not track you across apps or websites for advertising purposes and therefore we do not display the AppTrackingTransparency (ATT) prompt.
Our public website may use strictly necessary cookies to operate; no third-party advertising cookies.
6. HOW LONG DO WE KEEP INFORMATION?
We keep personal information only as long as needed to provide the Services and comply with legal obligations. When you delete your account (see below), we delete your account data and encrypted content from our systems, and we retain only what is legally required (e.g., purchase records/receipts for accounting).
7. HOW DO WE KEEP INFORMATION SAFE?
We use administrative, technical, and organizational safeguards. Your vault is end-to-end encrypted so we cannot read its contents. No method of transmission or storage is 100% secure, but we work to protect your information.
8. YOUR RIGHTS & CHOICES
Access/Correction/Deletion. You can review or update account details in the App. To delete your account and associated data, open the App and go to Settings → Account Deletion, then follow the prompts. If we cannot verify your identity or there is a legal requirement to retain some records, we will inform you.
Communications. We may send transactional/service messages. We do not send advertising in the App.
9. UNITED STATES PRIVACY DISCLOSURES
We disclose below the categories of personal information we collect/process, as defined by certain US state laws. This reflects what we use to provide the Services.
Category Examples (as applicable to our Services) Collected
A. Identifiers Email address, user ID, Sign in with Apple relay email (if used) YES
B. Customer Records (CA Civ. Code 1798.80) Basic contact (email) and account information YES
C. Protected classifications Demographics such as race, gender, etc. NO
D. Commercial information Subscription/purchase history and entitlement status (no full card data) YES
E. Biometric information Face ID/Touch ID checks are device-only; we receive no biometric templates NO
F. Internet/network activity Browsing history, cross-site tracking, ad interactions NO
G. Geolocation data Precise location NO
H. Audio/visual data Images, recordings NO
I. Professional information Work history, qualifications NO
J. Education information Student records NO
K. Inferences Profiles about preferences/characteristics NO
L. Sensitive personal information Account log-in (email). Passwords handled by auth provider; no biometrics collected by us. YES (limited)
Sale/Sharing for targeted advertising: No — we do not sell or share personal information for cross-context behavioral advertising.
Use of sensitive information: limited to providing the Services (e.g., authentication).
Do Not Track (DNT): Industry standards are not finalized; we do not respond to DNT signals.
10. CHANGES TO THIS POLICY
We may update this policy. We will post the updated version and change the “Last updated” date above.
11. CONTACT US
If you have questions or want to exercise your rights, contact us at support@torrinpass.com. Related document: Terms of Use (EULA).