❄️ Winter ArcOpen app ›

Privacy Policy

Last updated: 1 October 2026

This policy explains how Steffin Xavier L S, trading as Winter Arc, London, UK (the “controller”), uses your personal data, in line with the UK GDPR and the Data Protection Act 2018. Contact: support@winterarc.life.

What we collect

Why we use it, and our lawful basis

We don't sell your data, show ads, or use tracking or analytics cookies. Only we can read usage data, support messages and cancellation reasons.

Cookies and storage

We only use storage that is strictly necessary for the app to work: keeping you signed in and a copy of your data on your device so it works offline. These need no consent banner. Paddle sets its own cookies when you open checkout. See Paddle's privacy policy.

Who processes it for us

Where a provider processes data outside the UK, it is protected by UK-approved safeguards such as the International Data Transfer Addendum.

How long we keep it

We keep your data while your account exists. When you delete your account, your profile and tracker data are erased straight away. Records of payments are kept for 6 years, as HMRC requires.

Your rights

You can access, correct, export or delete your data, object to or restrict how we use it, and withdraw consent at any time. You can export from Me → Export backup, edit in the app, and delete from Me → Account → Delete account. For anything else, email support@winterarc.life; we reply within one month. You can also complain to the Information Commissioner's Office.

Children

The Service is for people aged 18 and over.

Changes

We'll post updates here and tell you about material changes.