Effective Date: July 1, 2026
Last Updated: July 1, 2026
Bukko Apps LLC, a California limited liability company located in Sacramento, California, United States, operates the mobile application known as Bukko, Bukko Tip Tracker, and related names, and the Bukko Apps website located at bukkoapps.com.
This Privacy Policy explains how Bukko Apps LLC collects, uses, stores, discloses, protects, and otherwise handles personal information in connection with:
- the Bukko mobile application for iPhone and iPad;
- the Bukko Apps website;
- Ghost-powered Website Accounts used only for newsletter subscription management;
- Bukko newsletters, promotional emails, and product communications;
- customer support communications;
- App Store purchases, in-app purchases, subscriptions, purchase restoration, refunds, and related Apple platform activity.
For purposes of this Privacy Policy:
“Company,” “we,” “us,” and “our” mean Bukko Apps LLC, a California limited liability company located in Sacramento, California, United States.
“App” means the mobile application known as Bukko, Bukko Tip Tracker, and related names.
“Website” means the Bukko Apps website located at bukkoapps.com.
“Website Account” means a Ghost-powered website member or subscriber account used only to manage newsletter subscriptions and related email preferences.
“You” and “user” mean a person who uses the App, visits the Website, creates or accesses a Website Account, subscribes to the newsletter, purchases or uses our products, or contacts us.
Privacy Contact:
Bukko Apps LLC
Attn: Privacy Officer
Sacramento, California, United States
Email: support@bukkoapps.com
1. Important Summary
The App is designed to be a private, local-first tip and income tracking app for tipped workers.
The App allows users to manually enter tip income, paycheck information, paystub information, work records, and related financial notes.
The App may generate totals, monthly summaries, charts, reports, exports, or PDFs from information the user enters into the App. These summaries, totals, charts, reports, exports, and PDFs are treated as App Content under this Privacy Policy.
The Company does not operate a backend server or database for App Content. The App does not transmit App Content to Company-operated servers, and the Company does not collect, receive, view, access, store, upload, sell, share, analyze, or monetize the tip, income, paycheck, paystub, summary, report, export, or PDF information that you enter, create, or generate inside the App.
Because the App does not transmit App Content to the Company, and because the Company does not maintain a server, database, account portal, admin dashboard, or backend system for App Content, the Company cannot see, access, retrieve, or use App Content under the current App architecture.
Your App Content is stored:
- locally on your iPhone or iPad; and
- if you use iCloud syncing, in your own private iCloud account using Apple’s native iCloud and CloudKit technology.
The App does not transmit your App Content to the Company, and the Company does not receive your App Content from the App.
The App does not use in-app Google Analytics, advertising SDKs, cross-app tracking SDKs, data broker integrations, behavioral advertising technology, or Company-operated analytics.
The App does not require an App account, user registration, username, password, login, or profile.
The Website may allow users to create or access a Ghost-powered Website Account. A Website Account is used only to manage newsletter subscriptions and related email preferences.
The Website and Website Account are completely separate from the App. The Website and Website Account cannot see, access, retrieve, receive, sync, store, display, modify, delete, analyze, sell, share, or monetize your App Content or App data in any way.
Creating, accessing, or managing a Website Account does not create an App account. It does not connect the Website to the App. It does not give the Company access to your App Content.
The Website does not currently use Google Analytics.
2. Scope of This Privacy Policy
This Privacy Policy applies to personal information processed in connection with:
- The App: Bukko / Bukko Tip Tracker on iOS and iPadOS.
- The Website: Bukko Apps website at bukkoapps.com.
- Website Accounts: Ghost-powered website member or subscriber accounts used only for newsletter subscription management and related email preferences.
- Newsletter and Marketing: Email signups, product updates, launch announcements, promotional emails, and advertisements.
- Support: Emails and communications sent to support@bukkoapps.com.
- Purchases: Apple App Store purchases, subscriptions, in-app purchases, receipts, refunds, purchase restoration, and related App Store Connect information.
This Privacy Policy does not apply to:
- Apple’s independent collection and processing of information through iOS, iPadOS, iCloud, the App Store, Apple ID, Apple payment systems, Apple diagnostics, App Store Connect, or related Apple services;
- Ghost’s independent processing of information through Ghost(Pro), Ghost.org, website hosting, email delivery, newsletter infrastructure, security, member/subscriber account functionality, or related services;
- third-party websites, services, or platforms that the Company does not control;
- information you choose to export, email, upload, print, save, or share outside the App.
3. Definitions
“App” means the mobile application known as Bukko, Bukko Tip Tracker, and related names.
“Company” means Bukko Apps LLC.
“Website” means the Bukko Apps website located at bukkoapps.com.
“Website Account” means a Ghost-powered website member or subscriber account used only to manage newsletter subscriptions and related email preferences on the Website. A Website Account is not an App account. A Website Account is not connected to the App.
“Website Separation” means that the Website and Website Account are completely separate from the App. The Website and Website Account cannot see, access, retrieve, receive, sync, store, display, modify, delete, analyze, sell, share, or monetize App Content or App data in any way. The Website Account is used only to manage newsletter subscriptions and related email preferences.
“App Content” means the information, records, files, reports, summaries, totals, charts, PDFs, notes, and other content that you manually enter, create, save, export, or generate inside the App. App Content includes tip records, income records, paycheck information, paystub information, employer information, shift information, pay periods, deductions, taxes, reimbursements, notes, monthly income summaries, total views, charts, reports, exports, and PDFs generated by the App from your entries.
“Personal Information” or “Personal Data” means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an identified or identifiable person or household.
“Processing” means actions such as collecting, storing, using, disclosing, deleting, analyzing, or otherwise handling Personal Information.
“Sensitive Personal Information” means information that may receive special protection under applicable law, such as certain government identifiers, financial account information, precise location, health information, biometric information, protected-class information, and certain personal financial information.
4. App Privacy: What the Company Does Not Collect
The App is intentionally designed so that the Company does not collect your App Content.
The Company does not collect, receive, upload, view, access, sell, share, rent, license, disclose, mine, analyze, or monetize the following App Content:
- tip amounts;
- cash tips;
- credit card tips;
- tip-outs;
- tip pooling information;
- paycheck details;
- paystub details;
- wage or hourly-rate information;
- salary, income, earnings, or compensation information;
- employer or workplace records you enter;
- shift records;
- pay periods;
- deductions, taxes, reimbursements, or other paycheck details;
- notes, labels, tags, or comments entered in the App;
- financial summaries, monthly totals, charts, reports, exports, or PDFs generated locally by the App from your entries;
- any other manually entered, saved, exported, or locally generated App Content.
The Company does not have a backend server or database that stores App Content.
The Company does not have an App Content admin dashboard, employee portal, Website Account system, support system, or backend interface that allows the Company to see or retrieve App Content.
The Company does not use App Content for analytics, advertising, profiling, credit decisions, employment decisions, insurance decisions, tax reporting, payroll processing, marketing, or data brokerage. The Company cannot use App Content for those purposes under the current App architecture because the Company does not receive or have access to App Content.
The App does not require an App account, user registration, username, password, login, or profile.
Apple’s App Store privacy guidance defines “collect” as transmitting data off the device in a way that allows the developer or third-party partners to access it beyond real-time servicing; Apple also states that data processed only on-device and not sent to a server is not “collected” for App Store privacy answers. (Apple Developer)
5. No App Accounts or Logins; Separate Website Newsletter Accounts
The App does not require an App account.
The App does not require user registration.
The App does not require a username.
The App does not require a password.
The App does not require an App login.
The Company does not create or maintain App user accounts. The Company does not operate a backend account database for App users.
The App is designed so that your tip, income, paycheck, paystub, report, PDF, and related App records remain on your device and, if you use iCloud sync, in your private iCloud account.
The Website may allow you to create or access a Ghost-powered Website Account. A Website Account is used only for Website newsletter subscription management and related email preferences.
A Website Account is not connected to the App. A Website Account is not used to log in to the App, unlock App features, manage App Store purchases, restore App purchases, store App Content, sync App Content, retrieve App Content, display App Content, or access App Content.
The Website Separation applies at all times.
The Company does not link Website Account information with your tip records, income records, paycheck records, paystub records, monthly summaries, charts, reports, exports, PDFs, or other App Content.
Signing up for the newsletter, unsubscribing from the newsletter, or managing newsletter preferences through a Website Account does not create an App account and does not give the Company access to your App Content.
Ghost states that member sign-in is passwordless and that members can sign in using a secure magic link or one-time login code. (Ghost)
6. Local Storage and iCloud Sync
Your App Content is stored locally on your device.
If you use iCloud sync, your App Content may also be stored in your private iCloud account and synced across your Apple devices through Apple’s native iCloud and CloudKit technology.
The Company does not operate its own backend server or database for App Content. The Company does not receive, view, access, store, upload, analyze, sell, share, or monetize App Content.
Because the App does not transmit App Content to the Company, the Company cannot use App Content for its own purposes under the current App architecture. The Company cannot see App Content, cannot query it from a Company database, and cannot retrieve it through a Website Account.
Apple’s Developer Program License Agreement includes terms governing developer use of iCloud and CloudKit APIs, including the developer’s compliance responsibilities and Apple’s role for personal data stored through iCloud Storage APIs or CloudKit APIs. (Apple Developer)
Apple may process iCloud, Apple ID, device, diagnostic, technical, legal, security, and infrastructure information under Apple’s own terms and privacy policies.
The Company does not control your Apple ID, iCloud account, device settings, iCloud storage settings, Apple security settings, Apple payment settings, or Apple privacy settings.
You are responsible for maintaining the security of your device, Apple ID, iCloud account, device passcode, Face ID or Touch ID settings, Apple account recovery settings, and iCloud sharing settings.
To delete App Content, you should use the App’s available delete features, delete the relevant records, delete the App if appropriate, and manage or delete associated iCloud data through Apple’s iCloud settings.
Because the Company does not store App Content on Company servers, the Company generally cannot access, export, correct, or delete App Content for you.
The Website Separation applies.
7. Reports, Totals, Summaries, Charts, Exports, and PDFs
The App may generate totals, summaries, charts, reports, exports, or PDFs from information you enter into the App. These may include monthly income summaries, tip totals, paycheck summaries, earnings reports, tax-related summaries, or similar records.
These reports, totals, summaries, charts, exports, and PDFs are generated for your personal recordkeeping.
The Company does not receive, view, upload, access, store, analyze, sell, share, or monetize these reports, totals, summaries, charts, exports, or PDFs.
Because these reports, totals, summaries, charts, exports, and PDFs are generated locally from App Content that the Company does not receive or access, the Company cannot use them for its own purposes under the current App architecture.
The Website Separation applies.
If you choose to export, save, email, print, upload, or share a report or PDF outside the App, you control that action. Once you share App Content with another person, app, cloud service, email provider, employer, accountant, tax preparer, printer, or other third party, that third party’s privacy practices may apply. The Company is not responsible for how third parties handle information that you choose to export or share.
8. No In-App Analytics, Advertising, or Tracking
The App does not use Google Analytics.
The App does not use Company-operated analytics.
The App does not use third-party analytics SDKs.
The App does not use third-party advertising networks.
The App does not use cross-app tracking technologies.
The App does not use behavioral advertising technologies.
The App does not sell or share App Content.
The App does not use App Content for targeted advertising or behavioral advertising.
The App does not combine App Content with data from other apps, websites, data brokers, advertising networks, third-party marketing databases, the Website, Website Accounts, or newsletter records.
The App does not profile users based on tips, income, paychecks, paystubs, reports, summaries, PDFs, or work records.
Because the Company does not receive or access App Content, the Company cannot use App Content for analytics, advertising, tracking, or profiling under the current App architecture.
Apple’s App Store guidance describes “tracking” as linking app-collected user or device data with third-party data for targeted advertising or advertising measurement, or sharing app-collected user or device data with a data broker. (Apple Developer) The App does not engage in that activity.
9. Information the Company May Collect Outside App Content
Although the Company does not collect App Content, the Company may collect or receive limited information in other contexts.
9.1 Support Communications
If you contact the Company by email or another support channel, the Company may collect:
- your email address;
- your name, if you provide it;
- the content of your message;
- any screenshots, attachments, documents, or files you choose to send;
- information needed to respond to your request;
- date and time of communication;
- support history.
The Company uses support information to respond to you, troubleshoot issues, improve products, maintain records of support requests, protect rights, prevent abuse, and comply with legal obligations.
If you send App Content to Company support yourself, the Company may receive that specific information because you chose to send it. That does not mean the Company can access other App Content, your device, your iCloud account, or the App data stored locally on your device.
9.2 Newsletter, Website Account, and Marketing Information
If you subscribe to the Bukko newsletter, create or access a Website Account, or manage newsletter preferences through the Website, the Company and Ghost may collect or process limited Website-related information, such as:
- your email address;
- your name, if you provide it;
- Website Account or Ghost subscriber status;
- newsletter subscription status;
- unsubscribe status;
- email preference settings;
- marketing preferences;
- date and time of signup;
- source of signup;
- confirmation or consent records;
- email delivery information;
- email open or click information, if newsletter analytics are enabled;
- login or authentication information used for Website Account access, such as magic links or one-time login codes;
- communications you send in response to newsletters.
The Company uses this information to:
- operate Website newsletter subscriptions;
- allow you to manage newsletter preferences;
- send product updates, promotional messages, advertisements, announcements, launch information, feature updates, and other marketing communications;
- process unsubscribe requests;
- maintain suppression lists so the Company does not continue sending marketing emails after you unsubscribe;
- prevent spam, abuse, or unauthorized access to Website newsletter features;
- comply with applicable law.
Website Account information is separate from App Content. The Website Separation applies.
The Company does not use Website Account information to access, store, sync, analyze, sell, share, or monetize App Content. The Company also cannot use Website Account information to access App Content, because Website Accounts have no connection to App Content under the current App architecture.
You can unsubscribe from marketing emails by using the unsubscribe link in the email or by contacting support@bukkoapps.com.
Ghost’s member management documentation describes member dashboard fields and filters such as email subscription status, member status, newsletter subscription status, unsubscribed status, email disabled status, emails opened, emails sent, open rates, and related engagement metrics. (Ghost)
9.3 Website Technical and Security Information
The Website does not currently use Google Analytics.
The Website does not currently use third-party advertising cookies, third-party analytics cookies, remarketing cookies, behavioral advertising cookies, affiliate tracking cookies, or cross-site tracking pixels.
The Company may process limited technical information necessary to operate, secure, deliver, and maintain the Website. This may include information such as:
- IP address;
- browser type;
- device type;
- operating system;
- referring URL;
- pages requested;
- timestamps;
- basic server logs;
- security logs;
- spam-prevention or abuse-prevention information.
This information may be processed by the Company, Ghost(Pro), hosting providers, security providers, email providers, or infrastructure providers for Website operation, security, troubleshooting, spam prevention, abuse prevention, legal compliance, and service maintenance.
9.4 Ghost(Pro) Website, Newsletter, and Website Account Hosting
The Website is hosted using Ghost(Pro) or Ghost.org services.
Ghost may process personal information in connection with website hosting, newsletter subscriptions, Website Accounts, email delivery, member or subscriber features, website security, spam prevention, service operations, and related services.
The Website may use Ghost-powered member or subscriber accounts. These Website Accounts are used only for newsletter subscription management and related Website email preferences.
Website Accounts are not connected to the App. The Website Separation applies.
The Company does not use Ghost Website Accounts to access App Content, link Website visitors or newsletter subscribers to App records, analyze App usage, store App data, retrieve App data from your device, or retrieve App data from your iCloud account.
If Ghost native analytics are enabled, the Company may receive first-party, cookie-free Website analytics information from Ghost, such as page views, traffic sources, general location, newsletter performance, member sources, or similar Website/newsletter metrics. Ghost describes its native analytics as first-party and cookie-free, and states that its web analytics do not use cookies or persistent browser storage to identify visitors across sessions, browsers, or devices. (Ghost)
If Ghost analytics features are disabled, the Company will not intentionally use Ghost’s native analytics features.
9.5 Apple App Store Purchases and App Store Connect Information
Purchases, subscriptions, in-app purchases, refunds, and purchase restoration are processed through Apple.
The Company does not receive your full payment card number, bank account number, or complete Apple billing credentials from Apple. Apple’s App Store privacy guidance states that if payment information is entered outside the app through a payment service and the developer never has access to that payment information, it is not collected and does not need to be disclosed by the developer for App Store privacy answers. (Apple Developer)
Apple may process your Apple Account information, payment information, purchase history, tax information, device information, billing information, and related App Store information under Apple’s own privacy policies and terms.
The Company may receive or access limited purchase-related and App Store information, such as:
- purchase status;
- subscription or entitlement status;
- transaction identifiers;
- receipt or verification information;
- refund status;
- product purchased;
- purchase date;
- territory or region;
- sales, proceeds, and App Store performance metrics;
- device category, such as iPhone or iPad;
- platform version or operating system version;
- app version;
- aggregated download, engagement, retention, or conversion information;
- crash or diagnostic information if Apple provides it and the user has opted in to share diagnostics with Apple.
The Company uses this limited Apple-related information to provide purchased features, restore purchases, respond to purchase-related support requests, prevent fraud, understand aggregate App Store performance, maintain business records, and comply with legal obligations.
Apple’s App Store Connect help says that if the developer and its third-party partners do not collect data from the app, the developer can select “No, we do not collect data from this app.” (Apple Developer)
10. Categories of Personal Information
The following chart explains categories of information the Company may process. This chart excludes App Content that remains local to your device or private iCloud account and is not collected by the Company.
| Category | Examples | Source | Purpose | Shared With | Sold or Shared for Cross-Context Behavioral Advertising |
|---|---|---|---|---|---|
| Identifiers | Email address, name if provided, support contact details, newsletter subscription information, Apple transaction/order identifiers if available or provided | You, Apple, Ghost, support communications | Support, newsletter, purchase support, service administration | Ghost, email service providers, Apple, legal/compliance providers | No |
| Commercial information | App purchase status, subscription status, entitlement status, refund status, product purchased | Apple, App Store Connect, StoreKit | Provide paid features, restore purchases, process refunds/support, maintain business records | Apple, payment/platform providers, legal/accounting providers | No |
| Website technical and security information | IP address, browser type, device type, operating system, requested pages, timestamps, basic server logs, security logs | Website, Ghost(Pro), hosting/security infrastructure | Operate the Website, deliver pages, prevent abuse, troubleshoot errors, maintain security, comply with law | Ghost(Pro), hosting providers, infrastructure providers, security providers | No |
| Device and platform information | Device category, platform version, app version, App Store territory, crash or diagnostics data if provided by Apple | Apple, App Store Connect | App Store analytics, troubleshooting, aggregate business metrics | Apple | No |
| Customer support information | Email content, screenshots, attachments, voluntary documents | You | Respond to support requests, troubleshoot, maintain records | Email/support service providers | No |
| Newsletter, Website Account, and marketing information | Email address, name if provided, Website Account/subscriber status, newsletter subscription status, unsubscribe status, email preferences, consent records, magic-link or one-time-code authentication information, email engagement if enabled | You, Ghost, email service providers | Operate Website newsletter subscriptions, allow users to manage email preferences, send promotions and product updates, process unsubscribe requests, maintain compliance records | Ghost, email delivery providers, support providers, legal/compliance providers | No |
| Sensitive information voluntarily sent to support | Pay information, employment details, financial details, tax-related details, or other sensitive information if you choose to send it | You | Respond to your support request only | Email/support service providers, legal providers if necessary | No |
| Legal and compliance information | Records needed for legal claims, tax, accounting, fraud prevention, compliance | You, Apple, vendors, legal sources | Comply with law, protect rights, maintain business records | Legal, accounting, compliance providers | No |
For avoidance of doubt, the Company does not collect App Content. Because the Company does not receive or access App Content, the Company cannot use App Content for its own purposes under the current App architecture.
The Website Separation applies.
11. Purposes for Processing Personal Information
The Company may use Personal Information that the Company actually collects or receives for the following purposes:
- to operate the App;
- to allow users to maintain their own local and iCloud-synced App records;
- to provide purchased features;
- to restore purchases;
- to process purchase-related support requests;
- to respond to support emails;
- to troubleshoot bugs or technical issues;
- to operate and maintain the Website;
- to secure the Website;
- to prevent spam, abuse, fraud, or security incidents;
- to operate Website Accounts used only for newsletter subscription management;
- to allow Website users to manage newsletter subscriptions and email preferences;
- to send newsletters and promotional emails;
- to manage subscriptions and unsubscribe requests;
- to maintain suppression lists so the Company does not continue sending marketing emails after an unsubscribe request;
- to keep Website Account information separate from App Content;
- to prevent Website Account information from being used to access, sync, retrieve, store, display, modify, delete, analyze, or use App Content;
- to protect against fraud, abuse, spam, or security threats;
- to comply with applicable laws;
- to maintain accounting, tax, and business records;
- to enforce legal rights and agreements;
- to respond to lawful requests from courts, regulators, or government authorities.
The Company does not use App Content for advertising, analytics, profiling, data brokerage, sale, sharing, marketing, employment decisions, payroll decisions, tax reporting, credit decisions, or insurance decisions.
The Company cannot use App Content for its own purposes under the current App architecture because the Company does not receive, see, access, or store App Content.
The Website Separation applies.
12. Data Controller and Privacy Roles
For purposes of the GDPR, UK GDPR, Swiss FADP, and similar privacy laws, Bukko Apps LLC is the Data Controller for Personal Data that the Company actually collects and uses, as described in this Privacy Policy. This includes, for example, Website Account information, newsletter subscription information, support communications, and limited App Store purchase, entitlement, or transaction information that the Company receives or accesses through Apple developer tools.
The Company does not collect, receive, view, access, upload, analyze, sell, share, monetize, or otherwise use App Content for its own purposes. App Content remains on your device and, if you use iCloud sync, in your private iCloud account.
Because App Content is not transmitted to the Company and the Company does not maintain a server, database, account system, admin dashboard, or backend tool for App Content, the Company cannot use App Content for its own purposes under the current App architecture. The Company cannot see App Content in the first place.
You determine what App Content to enter, create, save, edit, export, or delete. You also determine whether to use the App for personal recordkeeping, income tracking, paycheck tracking, tax preparation support, employment recordkeeping, or any other lawful purpose.
To the extent applicable privacy law treats the Company as having any controller role for any processing of App Content because the Company provides the App and chooses the App’s local-storage and iCloud-sync functionality, the Company’s role is limited to providing user-directed App functionality. The Company does not collect, receive, view, access, analyze, sell, share, monetize, or use App Content for advertising, analytics, profiling, marketing, employment decisions, payroll decisions, tax reporting, credit decisions, insurance decisions, or data brokerage.
Apple provides iCloud, CloudKit, Apple ID, App Store, payment, diagnostic, device, and platform services under Apple’s own terms and privacy policies. Apple’s role may differ depending on the Apple service involved. Apple’s Developer Program License Agreement includes provisions governing developer use of iCloud and CloudKit APIs, including developer compliance responsibilities and Apple’s processing, storage, and handling of personal data stored through those APIs. (Apple Developer)
Where a user processes their own App Content for purely personal or household purposes, the GDPR or similar laws may not apply to that user’s own personal processing. However, this depends on the user’s circumstances and may not apply where processing is connected to a professional, commercial, or other non-personal activity. The European Commission explains that the GDPR does not apply to data processed by an individual for purely personal reasons or home activities where there is no connection to a professional or commercial activity. (European Commission)
13. Legal Bases for Processing Under GDPR, UK GDPR, Swiss FADP, and Similar Laws
Where the GDPR, UK GDPR, Swiss FADP, or similar laws apply, the Company relies on one or more of the following legal bases:
| Processing Activity | Legal Basis |
|---|---|
| Providing the App and paid features | Performance of a contract; legitimate interests |
| Local App functionality that allows users to create, edit, store, export, and delete their own App Content | Performance of a contract; legitimate interests; user-directed processing |
| iCloud sync functionality, if used by the user | Performance of a contract; legitimate interests; user-directed processing |
| Purchase restoration and entitlement verification | Performance of a contract; legitimate interests; legal obligations |
| Support communications | Performance of a contract; legitimate interests; consent where you voluntarily provide information |
| Website Account functionality for newsletter subscription management | Performance of a contract; consent; legitimate interests |
| Newsletter and promotional emails | Consent, or legitimate interests where permitted by law |
| Website operation and security | Legitimate interests; legal obligations |
| Spam, abuse, and fraud prevention | Legitimate interests; legal obligations |
| Tax, accounting, and legal compliance | Legal obligations; legitimate interests |
| Legal claims and rights enforcement | Legitimate interests; legal obligations |
The Company does not use App Content for advertising, analytics, profiling, data brokerage, sale, sharing, marketing, employment decisions, payroll decisions, tax reporting, credit decisions, or insurance decisions.
The Company cannot use App Content for those purposes under the current App architecture because the Company does not receive or access App Content.
The European Commission describes GDPR rights as including rights to information, access, rectification, erasure, restriction, portability, objection, and rights related to automated decision-making and profiling. (European Commission) Switzerland’s revised Federal Act on Data Protection is intended to protect the personality and fundamental rights of natural persons whose personal data is processed, and Swiss government materials describe the revised law as granting new rights to individuals. (Fedlex)
14. How the Company Shares Personal Information
The Company does not sell App Content.
The Company does not share App Content with advertisers, analytics providers, data brokers, employers, payroll companies, tax authorities, or other third parties.
The Company may disclose limited Personal Information that the Company actually collects or receives in the following circumstances.
14.1 Apple
Apple processes App Store purchases, in-app purchases, subscriptions, purchase restoration, refunds, Apple ID, iCloud, App Store, Apple diagnostics, and related Apple services.
Apple may provide the Company with limited purchase, entitlement, sales, analytics, device category, territory, platform version, and performance information through Apple developer tools.
Apple does not provide the Company with App Content.
14.2 Ghost(Pro)
Ghost may host the Website, manage newsletter features, process subscriber information, operate Website Account functionality, provide email features, provide Website infrastructure, prevent spam or abuse, and deliver Website or newsletter services.
Website Account information may be processed by Ghost for Website newsletter and subscriber-account functionality.
Website Account information is not shared with the App.
Website Account information is not used to create an App account.
Website Account information is not used to access App Content.
Ghost does not receive App Content from the Company.
The Website Separation applies.
14.3 Email and Support Providers
The Company may use email hosting, email delivery, support, or business communication providers to receive and respond to messages and send newsletters.
14.4 Legal, Accounting, Tax, and Compliance Providers
The Company may disclose information to attorneys, accountants, tax professionals, auditors, consultants, insurers, or compliance providers where reasonably necessary.
14.5 Business Transfers
If the Company is involved in a merger, acquisition, financing, sale of assets, reorganization, bankruptcy, or similar transaction, limited business, Website, Website Account, newsletter, support, or purchase-related information may be transferred as part of that transaction.
App Content stored only on your device or private iCloud account would not be available for transfer by the Company.
14.6 Legal Requirements and Protection
The Company may disclose information if required by law, subpoena, court order, legal process, regulator request, or government request, or where necessary to protect rights, safety, security, or property.
Because the Company does not possess App Content, the Company generally cannot disclose App Content in response to legal requests.
Because the Website and Website Account cannot access App Content, the Website and Website Account cannot retrieve App Content from your device or iCloud account in response to legal requests.
15. No Sale of Personal Information
The Company does not sell Personal Information.
The Company does not sell App Content.
The Company does not sell Website Account information.
The Company does not sell newsletter lists.
The Company does not sell support emails.
The Company does not sell purchase information.
The Company does not sell Website technical information.
16. No Sharing for Cross-Context Behavioral Advertising
The Company does not share App Content for cross-context behavioral advertising.
The App does not use targeted advertising.
The App does not track you across apps or websites owned by other companies.
The Company does not use Website Accounts for cross-context behavioral advertising.
The Website does not currently use advertising pixels, remarketing pixels, behavioral advertising cookies, affiliate tracking cookies, or third-party analytics cookies.
If the Company later enables Google Analytics, third-party analytics, Google Signals, Meta Pixel, TikTok Pixel, remarketing, targeted advertising, affiliate tracking, or similar advertising or analytics features, the Company will update this Privacy Policy and provide any required cookie notice, consent, opt-out, “Do Not Sell or Share,” or Global Privacy Control mechanisms before using those technologies.
17. Cookies and Similar Technologies
The Website is hosted using Ghost(Pro).
The Website does not currently use Google Analytics or third-party advertising cookies.
The Website does not currently use third-party analytics cookies, remarketing cookies, behavioral advertising cookies, affiliate tracking cookies, or cross-site tracking pixels.
The Website may use cookies or similar technologies that are strictly necessary or technically required to operate the Website, provide security, support Website Account login or session functionality, maintain newsletter subscription functionality, prevent abuse, remember necessary service settings, or provide features requested by users.
The Company does not currently use cookies for behavioral advertising, cross-site tracking, remarketing, or targeted advertising.
Ghost states that its native web analytics are cookie-free and first-party by design. Ghost also states that its web analytics do not use cookies or persistent browser storage to identify visitors across sessions, browsers, or devices. (Ghost) If the Company enables Ghost native analytics, those analytics may process first-party Website usage information as described in this Privacy Policy.
If the Company later uses non-essential cookies or similar technologies, including third-party analytics, advertising, remarketing, or affiliate-tracking technologies, the Company will update this Privacy Policy and provide any cookie notice, consent, and opt-out controls required by applicable law.
18. Do Not Track and Global Privacy Control
Some browsers offer “Do Not Track” signals. There is no universally accepted technical or legal standard for responding to Do Not Track signals, and the Website may not respond to Do Not Track signals.
Some browsers or extensions support Global Privacy Control or similar opt-out preference signals. To the extent required by applicable law, and to the extent the Company engages in activity covered by such opt-out rights, the Company will treat applicable recognized opt-out preference signals as requests to opt out of sale or sharing.
Because the Company does not sell Personal Information or share Personal Information for cross-context behavioral advertising, such signals generally do not change the Company’s current practices.
California’s privacy agency explains that California residents have rights including the right to opt out of sale or sharing, the right to know, the right to delete, the right to correct, the right to limit certain uses of sensitive personal information, and the right to equal treatment for exercising CCPA rights. (California Privacy Protection Agency)
19. Data Retention
The Company retains Personal Information only as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
19.1 App Content
The Company does not store App Content on Company servers.
App Content remains on your device and, if you use iCloud sync, in your private iCloud account.
Retention of App Content is controlled by you, your device settings, your iCloud settings, and Apple.
Because the Company does not receive or access App Content, the Company cannot retain App Content for its own purposes under the current App architecture.
The Website Separation applies.
19.2 Support Emails
Support emails may be retained as long as necessary to respond to you, maintain records, troubleshoot issues, resolve disputes, comply with law, and protect the Company’s rights.
19.3 Newsletter and Website Account Information
Newsletter subscription information and Website Account information may be retained until you unsubscribe, request deletion, delete or modify your Website Account where available, or the Company no longer needs the information for newsletter, compliance, security, fraud-prevention, or recordkeeping purposes.
The Company may retain unsubscribe or suppression records to ensure the Company does not send marketing emails after you opt out.
Deleting App Content does not automatically delete Website Account or newsletter subscription information because the App and Website are separate systems.
Deleting Website Account or newsletter subscription information does not automatically delete App Content because the Company does not store App Content and the Website cannot access App Content.
19.4 Website Technical and Security Information
Website technical, hosting, server, and security records may be retained as long as reasonably necessary for Website operation, security, troubleshooting, abuse prevention, legal compliance, and service maintenance.
19.5 Purchase and Business Records
Purchase, entitlement, accounting, tax, and legal records may be retained as needed for legal, accounting, tax, audit, refund, fraud prevention, and compliance purposes.
20. Security
The Company uses reasonable administrative, technical, and organizational measures designed to protect Personal Information that the Company actually collects.
Because App Content is stored locally and in your private iCloud account, its security depends significantly on your device security, iCloud security, Apple ID security, password practices, device passcode, Face ID or Touch ID settings, and account recovery settings.
You should:
- use a strong device passcode;
- enable Face ID or Touch ID where available;
- use a strong Apple ID password;
- enable two-factor authentication for your Apple ID;
- keep iOS or iPadOS updated;
- avoid sharing your device with untrusted persons;
- review your iCloud settings;
- avoid emailing sensitive financial, paycheck, tax, or employment documents unless necessary.
No method of electronic storage or transmission is completely secure. The Company cannot guarantee absolute security.
The Website Separation applies.
21. Your Privacy Choices
21.1 App Content Choices
Because App Content is stored locally and, if you use iCloud sync, in your private iCloud account, you can manage App Content by:
- editing or deleting records in the App;
- deleting generated reports or PDFs;
- deleting the App from your device;
- managing iCloud sync settings;
- deleting relevant iCloud data through Apple’s settings;
- managing device backups and iCloud backups.
The Company generally cannot access, export, correct, or delete App Content because the Company does not store it on Company servers.
Because the Company does not receive or access App Content, the Company cannot manage App Content for you through support, the Website, or a Website Account.
The Website Separation applies.
21.2 Newsletter Choices
You may unsubscribe from marketing emails at any time by using the unsubscribe link in the email or by contacting support@bukkoapps.com.
21.3 Website Cookie Choices
You may control cookies through your browser settings. Where required, the Company will provide Website cookie controls or consent options.
21.4 Support Communications
You may request deletion of support communications by contacting support@bukkoapps.com.
The Company may retain certain records where necessary for legal, security, accounting, dispute-resolution, abuse-prevention, or compliance purposes.
21.5 Website Account and Newsletter Choices
You may use the Website Account features provided through Ghost to manage newsletter subscriptions and related email preferences.
You may unsubscribe from Bukko marketing emails by using the unsubscribe link in the email or by contacting support@bukkoapps.com.
Managing or deleting Website Account information does not affect App Content stored on your device or in your private iCloud account. App Content must be managed through the App, your device settings, and your iCloud settings.
Deleting App Content does not automatically delete Website Account or newsletter subscription information because the Website and App are separate systems.
Unsubscribing from the newsletter does not delete App Content because the Company does not store App Content.
22. California Privacy Notice
This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to the Company.
The California Privacy Protection Agency states that the CCPA applies to for-profit businesses doing business in California that collect consumers’ personal information, determine why and how that information is processed, and meet specified thresholds, including the gross annual revenue threshold, 100,000-consumer/household threshold, or 50%-of-revenue-from-selling-or-sharing threshold. (California Privacy Protection Agency) Even if the Company is not legally required to comply with the CCPA because it does not meet those thresholds, the Company provides this section for transparency.
22.1 Categories Collected
In the past 12 months, the Company may have collected the categories described in Section 10 above, including identifiers, commercial information, Website technical and security information, device/platform information, support information, newsletter information, Website Account information, and limited sensitive information voluntarily sent to support.
The Company does not collect App Content.
Because the Company does not receive or access App Content, the Company cannot use App Content for its own purposes under the current App architecture.
The Website Separation applies.
22.2 Sources
The Company may receive Personal Information from:
- you;
- Apple;
- Ghost;
- email and support providers;
- service providers;
- business, legal, accounting, and compliance sources.
22.3 Business or Commercial Purposes
The Company processes Personal Information for the purposes listed in Section 11.
22.4 Disclosure to Third Parties
The Company may disclose Personal Information to the categories of recipients listed in Section 14.
22.5 Sale or Sharing
The Company does not sell Personal Information.
The Company does not share Personal Information for cross-context behavioral advertising.
The Company does not knowingly sell or share Personal Information of persons under 16.
22.6 Sensitive Personal Information
The Company does not use or disclose Sensitive Personal Information for purposes that require a “Limit the Use of My Sensitive Personal Information” right under California law.
If you voluntarily send sensitive documents or sensitive information to support, the Company uses them only to respond to your support request, comply with law, protect rights, prevent abuse, or as otherwise permitted by applicable law.
22.7 California Rights Requests
California residents may request to:
- know what Personal Information the Company has collected;
- access Personal Information;
- delete Personal Information;
- correct inaccurate Personal Information;
- opt out of sale or sharing;
- limit certain uses of Sensitive Personal Information, if applicable;
- receive non-discriminatory treatment for exercising privacy rights.
To exercise rights, contact support@bukkoapps.com with the subject line “California Privacy Request.”
Because the Company does not collect App Content, requests to access, correct, or delete App Content must generally be handled by you through the App, your device, or your iCloud account.
A California request submitted through the Website or Website Account cannot be used to access App Content because the Website Separation applies.
The Company may verify your request by asking for information reasonably necessary to confirm your identity and request. The Company will not use verification information for unrelated purposes.
22.8 Authorized Agents
California residents may use an authorized agent to submit a request. The Company may require proof that the agent is authorized and may require the user to verify their identity directly.
22.9 No Discrimination
The Company will not discriminate against you for exercising privacy rights.
22.10 Financial Incentives
The Company does not offer financial incentives or price/service differences in exchange for the sale, sharing, or retention of Personal Information.
23. U.S. State Privacy Rights
Residents of certain U.S. states may have rights to access, correct, delete, obtain a copy of, or opt out of certain processing of Personal Information, depending on applicable law and whether the Company is subject to that law.
The Company does not sell Personal Information.
The Company does not use App Content for targeted advertising.
The Company does not use App Content for profiling in furtherance of decisions that produce legal or similarly significant effects.
Because the Company does not receive or access App Content, the Company cannot use App Content for its own purposes under the current App architecture.
The Website Separation applies.
To submit a U.S. state privacy request, contact support@bukkoapps.com with the subject line “Privacy Rights Request.”
If your request is denied and applicable law gives you a right to appeal, you may appeal by emailing support@bukkoapps.com with the subject line “Privacy Appeal.”
24. Canada Privacy Rights
If Canadian privacy laws apply, including PIPEDA or substantially similar provincial laws, the Company will process Personal Information in accordance with applicable Canadian privacy principles, including accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, and challenging compliance.
Canadian users may request access to or correction of Personal Information that the Company controls by contacting support@bukkoapps.com.
Because the Company does not collect App Content, requests involving App Content should generally be handled through the App, device, and iCloud settings.
Because the Company does not receive or access App Content, the Company cannot use App Content for its own purposes under the current App architecture.
The Website Separation applies.
Commercial electronic messages sent to Canadian recipients may be subject to Canada’s Anti-Spam Legislation. The Company will use consent where required, identify itself in commercial electronic messages, and include an unsubscribe mechanism. Canada’s CRTC states that commercial electronic messages require prior consent, identification/contact information, and a working unsubscribe mechanism. (CRTC)
25. GDPR, UK GDPR, EEA, UK, and Switzerland Rights
Where the GDPR, UK GDPR, Swiss FADP, or similar laws apply, you may have rights to:
- access your Personal Data;
- correct inaccurate Personal Data;
- delete Personal Data;
- restrict processing;
- object to processing;
- withdraw consent;
- receive data portability;
- object to direct marketing;
- lodge a complaint with a supervisory authority;
- request information about automated decision-making and profiling, if applicable.
To exercise rights, contact support@bukkoapps.com with the subject line “GDPR/Swiss Privacy Request.”
The Company will respond as required by applicable law.
Because the Company does not collect App Content, the Company generally cannot access, correct, export, or delete App Content for you. You can manage App Content through the App, device settings, iCloud settings, and Apple tools.
Because the Company does not receive or access App Content, the Company cannot use App Content for its own purposes under the current App architecture.
The Website Separation applies. Therefore, a GDPR, UK GDPR, or Swiss privacy request submitted through the Website or Website Account cannot be used to retrieve App Content from the App, your device, or your private iCloud account.
If the Company actively offers goods or services to individuals in the EU/EEA, UK, or Switzerland, or monitors behavior in those jurisdictions, the Company may need to assess additional requirements, such as whether an EU or UK representative is required, whether a data protection representative is required under Swiss law, and whether a Data Protection Officer is required. The European Commission explains that GDPR can apply to companies outside the EU when they offer goods or services to individuals in the EU or monitor their behavior. (European Commission)
26. International Data Transfers
The Company is based in the United States.
If you use the Website, create or access a Website Account, subscribe to the newsletter, contact support, or purchase through the App Store, information may be processed in the United States or other countries where the Company, Apple, Ghost, email providers, support providers, or other service providers operate.
These countries may have data protection laws different from those in your jurisdiction.
Where required, the Company will take steps intended to support lawful international transfers, such as using appropriate contractual protections, relying on vendor data transfer terms, limiting the data collected, and using privacy-protective configurations.
App Content stored only on your device or in your private iCloud account is not transferred to the Company by the App.
Because the Company does not receive or access App Content, the Company cannot transfer App Content internationally for its own purposes under the current App architecture.
27. Children’s Privacy
The App is intended for workers and is not directed to children under 13.
The Company does not knowingly collect Personal Information from children under 13.
If you believe a child under 13 has provided Personal Information to the Company through the Website, Website Account, newsletter, or support email, contact support@bukkoapps.com and the Company will take appropriate steps to delete the information.
The App does not require an App account and does not transmit App Content to the Company.
The Website Separation applies.
28. Automated Decision-Making and Profiling
The Company does not use App Content for automated decision-making, profiling, credit decisions, employment decisions, housing decisions, insurance decisions, lending decisions, payroll decisions, tax decisions, or decisions that produce legal or similarly significant effects.
The Company does not use App Content to infer your financial condition, work performance, reliability, employment status, tax status, or eligibility for benefits.
The Company does not use Website Accounts to profile App users.
The Company does not connect Website Account information to App Content.
Because the Company does not receive or access App Content, the Company cannot use App Content for automated decision-making or profiling under the current App architecture.
The Website Separation applies.
29. Employment, Payroll, Tax, and Financial Disclaimer
The App is a recordkeeping tool.
The Company is not your employer, payroll provider, accountant, tax preparer, bank, lender, financial institution, insurance provider, consumer reporting agency, or legal advisor.
The Company does not report your income to employers, payroll companies, tax authorities, credit bureaus, lenders, or government agencies.
You are responsible for determining how to use your records for tax, payroll, employment, accounting, legal, or financial purposes.
Because the Company does not receive or access your App records, the Company cannot report your App Content to third parties under the current App architecture.
The Website Separation applies.
30. Third-Party Links and Services
The App or Website may link to third-party websites, platforms, services, or resources.
The Company is not responsible for the privacy practices of third parties.
Your use of Apple, iCloud, App Store, Ghost, email providers, and other third-party services is subject to those third parties’ privacy policies, terms, and settings.
If you export, email, upload, print, save, or share App Content outside the App, the privacy practices of the destination you choose may apply.
31. Changes to This Privacy Policy
The Company may update this Privacy Policy from time to time.
When the Company updates this Privacy Policy, the Company will update the “Last Updated” date. If changes are material, the Company may provide additional notice, such as through the Website, App, email, or App Store listing where appropriate.
Your continued use of the App, Website, Website Account, newsletter, or services after an updated Privacy Policy is posted means you acknowledge the updated Privacy Policy.
If the Company materially changes the App architecture so that the App begins transmitting App Content to the Company, or the Company begins collecting, receiving, accessing, viewing, uploading, analyzing, selling, sharing, or monetizing App Content, the Company will update this Privacy Policy and any required App Store privacy disclosures before or at the time required by applicable law and platform rules.
32. Contact Us
For questions, privacy requests, or support, contact:
Bukko Apps LLC
Attn: Privacy Officer
Sacramento, California, United States
Email: support@bukkoapps.com