Privacy Policy

PNL — Profit and Loss is operated by Highglossy FZE, a company registered in the United Arab Emirates, with its registered office at Al Shmookh Business Center, One UAQ, UAQ Free Trade Zone, Umm Al Quwain, U.A.E. (“we”, “us”). For the purposes of the UK and EU General Data Protection Regulation, we are the data controller for the personal data described here.

Questions, requests and complaints: privacy@highglossy.com.

• No account, no server. Your sheets are stored on your iPad; we never receive them.
• Sync is yours. iCloud and Dropbox sync, if you turn them on, use your own accounts under Apple's and Dropbox's policies.
• We do see: the record of your in-app purchase, through Apple.
• No analytics SDK, no ads, no selling of personal data.

• Sheets and calculations. Stored in the app's local storage on the device.
• Passcode, Touch ID and Face ID. The passcode is kept on the device; biometrics are checked by the operating system and never leave it.
• iCloud and Dropbox. Optional; the app writes your sheets to your own storage. We have no access to either account.
• Excel export. The .xls file is handed to the mail app you choose; we are not part of that transfer.

Every category we hold, why we hold it, the lawful basis and how long we keep it:

• Purchase record: the App Store receipt that unlocks the full version — To unlock what you paid for and restore it on a new device. We never see your payment details. Basis: Contract (Art. 6(1)(b) GDPR). Kept: life of the installation; Apple keeps its own record.
• Support correspondence: your email address and what you write to us — To answer you. Basis: Legitimate interests (Art. 6(1)(f) GDPR). Kept: 24 months.

We do not sell personal data and we do not use it for advertising or profiling.

We use a small number of processors. Each is bound by a data processing agreement and may use the data only to provide the service to us.

• Apple — payment processing for in-app purchases. Apple takes the payment; we never see your card number or billing address. Your relationship for the payment itself is with the App Store, under Apple's own privacy policy.
• Apple iCloud and Dropbox — only if you turn sync on, and under your own accounts. They store your sheets for you, not for us.

We also disclose data where we are legally compelled to: to comply with a legal obligation, to protect our rights or property, to investigate possible wrongdoing in connection with the app, or to protect the safety of users or the public.

We do not sell personal data, and we do not share it for cross-context behavioural advertising.

The section above gives the retention period for each category. PNL has no account to delete: uninstalling the app removes everything it stored on the device, and sheets in your iCloud or Dropbox are yours to delete there.

PNL has no servers of its own. Apple, and Dropbox if you use it, process data under their own policies in their own regions. Where personal data leaves the UK or the EEA, the transfer relies on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum or an adequacy decision, as applicable.

Wherever you live, you can ask us to:

• Give you a copy of the personal data we hold about you, in a portable format.
• Correct anything inaccurate.
• Delete your data.
• Restrict or object to processing we carry out on the basis of legitimate interests.
• Withdraw consent, for example for notifications by turning them off in your device settings, without affecting what we did before you withdrew it.

Write to privacy@highglossy.com. We respond within 30 days.

Since we hold no personal data about PNL users beyond support correspondence, a request will usually concern that correspondence only.

If you are in the UK or the EEA, you may also complain to your data protection authority: in the UK the Information Commissioner's Office, in the EEA the supervisory authority where you live.

Under the CCPA as amended by the CPRA, in the last 12 months we collected the categories described above for the business purposes stated there, from you and from your device. We have not sold personal information and we have not shared it for cross-context behavioural advertising. We have no actual knowledge of selling the personal information of consumers under 16.

You have the right to know, delete, correct, and to be free from discrimination for exercising those rights. Exercise them at privacy@highglossy.com.

PNL — Profit and Loss is not directed to children and is not intended for anyone under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with data, write to privacy@highglossy.com and we will delete it.

Data in transit is protected with TLS. Access to our systems is limited to the people who need it to run the service and is logged. No system is perfectly secure, and we will not claim otherwise; if a breach affects your personal data, we will notify you and the competent authority as the law requires.

We will update this policy when what we do changes. The date at the top always reflects the current version. If a change materially reduces your rights or widens what we collect, we will tell you in the app before it takes effect.

Highglossy FZE, Al Shmookh Business Center, One UAQ, UAQ Free Trade Zone, Umm Al Quwain, U.A.E.

Support: support@highglossy.com · Privacy: privacy@highglossy.com