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Privacy Policy

"Countdown" app and countdown.interrupt.fr website

Last updated: 16 August 2026

This is an English translation provided for convenience. The French version is the reference text.

This policy explains what personal data is — and is not — processed when you use the Countdown iOS app and when you visit countdown.interrupt.fr.

It is written pursuant to Articles 12 to 14 of Regulation (EU) 2016/679 ("GDPR"), the French loi n° 78-17 du 6 janvier 1978 modifiée (the French Data Protection Act, known as "loi Informatique et Libertés"), and Article 82 of that Act (which implements Directive 2002/58/EC, the "ePrivacy" Directive, in France).

In short — the rest of this document only spells it out: the app collects no personal data, makes no network connections, and transmits nothing to Interrupt. The website sets no cookies and uses no analytics.

1. Who is the data controller?

The controller, within the meaning of Article 4(7) GDPR, is:

Interrupt — Camille Terol, sole trader (entrepreneur individuel), trading under the business name "Interrupt"
37 Allée Guy de la Brosse, 76230 Isneauville, France
SIREN 514 308 808 — RCS Rouen 514 308 808

Contact for any question or request concerning personal data:
[email protected]

Interrupt has not appointed a Data Protection Officer (DPO). This is not required under Article 37 GDPR: Interrupt is not a public authority, does not carry out regular and systematic monitoring of individuals on a large scale, and does not process special categories of data on a large scale. All requests are handled at the address above.

2. The Countdown app

2.1 No personal data is collected

Countdown is a timer app that runs entirely on your device. Specifically:

  • No account, no sign-up, no authentication. You are never asked for a name, an email address or any identifier.
  • No analytics or audience-measurement tool (no Google Analytics, Firebase, Amplitude, Mixpanel or equivalent).
  • No crash-reporting SDK (no Crashlytics, Sentry, Bugsnag or equivalent).
  • No advertising, no ad trackers, no advertising identifier (the IDFA is neither read nor used; the app never displays the App Tracking Transparency prompt, because it performs no tracking).
  • No third-party SDKs of any kind.
  • No network calls. The app opens no connection to any Interrupt server or third-party server. It works entirely offline.

As a result, Interrupt receives no data about you from your use of the app — neither directly nor indirectly.

2.2 Data stored locally on your device

The app saves the following in its app container on your device (iOS UserDefaults):

  • your timer settings (durations, configured quick actions);
  • your chosen display theme.

This information never leaves the device. It is not read, collected or transmitted by Interrupt. It may be included in your iCloud or iTunes/Finder backups if you have enabled app backup: that backup is an Apple service, governed by Apple's terms and privacy policy, and Interrupt has no access to it.

Deletion: uninstalling the app removes these settings from the device. No request to Interrupt is needed — or even possible — since we hold no copy of them.

Legal basis for local storage (Article 82, loi Informatique et Libertés): writing and reading this information on your terminal equipment is strictly necessary for the provision of a service you have expressly requested — a timer that remembers your settings. It therefore falls within the consent exemption set out in that same article. No information is stored or read for analytics, advertising or tracking purposes.

2.3 Live Activity (Lock Screen and Dynamic Island)

The app uses ActivityKit, Apple's feature for displaying the running countdown on the Lock Screen and in the Dynamic Island.

This activity is updated locally by the app and rendered by iOS on your device. Countdown does not use remote updates: it sends no push notifications and sends no data to any server to drive the Live Activity.

For the sake of accuracy: Apple's Live Activities mechanism can, in principle, rely on Apple's push notification infrastructure (APNs) when an app chooses to update its activity remotely. That is not the case here. The operation of the iOS platform itself is Apple's responsibility and is governed by Apple's own privacy policy.

2.4 Purchasing the app: Apple's role

Countdown is sold for €0.99 as a one-time purchase (it is not a subscription), exclusively through the Apple App Store.

The seller of the app is Apple, not Interrupt. Apple, acting as an independent data controller, collects and processes the data relating to your purchase: App Store account identifier, payment method and payment data, purchase history and billing. That processing is governed by Apple's privacy policy (https://www.apple.com/legal/privacy/) and by the Apple Media Services Terms and Conditions. Interrupt is neither a joint controller nor a processor for that processing, and has no ability to act on it.

For its part, Interrupt receives from App Store Connect only aggregated, anonymised sales reports: number of downloads and purchases, breakdown by country and period, and amounts paid out. These reports cannot identify a purchaser in any way, directly or indirectly. They are therefore not personal data within the meaning of Article 4(1) GDPR.

For anything relating to your purchase (invoice, refund, exercising your rights over payment data), you must contact Apple. Interrupt cannot help, because it does not hold that information.

3. The countdown.interrupt.fr website

3.1 A strictly static site

The site consists of static pages. It contains:

  • no forms (no contact form, no sign-up, no newsletter);
  • no cookies, no local storage (localStorage, sessionStorage), no trackers;
  • no analytics or audience-measurement tool;
  • no tracking pixels, no social network widgets loaded from a third party;
  • no fonts or assets loaded from a third party: fonts are self-hosted on our own server, and no asset is loaded from a third-party domain.

No request is therefore made to any third-party domain when you visit, and no data is shared with a third party as a result. The site is, however, served behind the content delivery network (CDN) of Cloudflare, Inc., acting as a processor: your requests to countdown.interrupt.fr pass through its infrastructure before reaching our server (see §5).

3.2 Server access logs

Like any web server, the site's hosting layer may generate technical logs containing:

  • the connecting IP address,
  • the date and time of the request,
  • the requested URL and the response code,
  • the user agent (the browser and operating system it reports).

Purposes: keeping the site technically operational, diagnosing incidents, and detecting and preventing abuse and attacks (information-system security).

Legal basis: Interrupt's legitimate interest in ensuring the security and availability of its service, under Article 6(1)(f) GDPR, in connection with the security obligation in Article 32 GDPR. Interrupt has verified that this interest does not disproportionately affect your rights: the logs are not used to profile you, are not cross-referenced with any other source, and serve no commercial purpose.

Retention: these logs are kept for a maximum of six months on a rolling basis, in line with the CNIL's recommended practice for technical logs (six months to one year), and are then deleted.

Recipients: these logs are accessible only to the people responsible for technical operations at Interrupt and, where applicable, at our hosting provider acting as a processor within the meaning of Article 28 GDPR (Camille Terol / Interrupt — self-hosted, 37 Allée Guy de la Brosse, 76230 Isneauville, France; and Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, United States, as content delivery network and protection provider). They are not sold, assigned or passed on to third parties, except upon a valid request from a competent judicial or administrative authority.

3.3 Cookies and trackers: why there is no consent banner

Article 82 of the loi Informatique et Libertés requires prior user consent before writing information to, or accessing information already stored on, the user's terminal equipment, unless the operation is strictly necessary to provide a service expressly requested by the user, or is solely for the purpose of enabling or facilitating electronic communication.

The countdown.interrupt.fr site writes and reads nothing on your device: no cookie, no pixel, no browser fingerprinting, no local storage — including for analytics purposes.

The Article 82 consent requirement is therefore not triggered, and no cookie banner is required. A banner here would be meaningless: there is no choice to offer you, because there is nothing to accept or refuse.

The server logs described in section 3.2 do not fall under Article 82: they are generated server-side by the HTTP protocol itself and involve no reading from or writing to your device. They fall under the GDPR only, on the legal basis set out above.

If this changes — for example if an analytics tool is added — this policy will be updated and, if the tool did not meet the exemption conditions set by the CNIL, a consent mechanism would be put in place before anything is stored.

4. Processing at a glance

Processing Data Purpose Legal basis (Art. 6 GDPR) Retention
Countdown app No personal data processed by Interrupt — Not applicable Not applicable
In-app settings Timer settings and theme, stored locally Provide the requested service Not applicable (no processing by Interrupt); Art. 82 exemption for the local storage Until uninstall, on your device
App Store purchase App Store account, payment Sale of the app Processing by Apple, independent controller See Apple's policy
Sales reports Aggregated, anonymised data Business monitoring Outside the GDPR (not personal data) —
Website server logs IP, timestamp, URL, user agent Security and technical operations Legitimate interest — Art. 6(1)(f) 6 months maximum

5. Recipients and transfers outside the European Union

From the app: no data is collected, so no data is disclosed to any recipient, and no transfer outside the European Union takes place.

From the website: the server logs are not disclosed to any third party, other than the hosting provider acting as a processor and other than on valid legal request. The site is self-hosted in France, on our own servers located at the registered office address given in §1: server logs are therefore stored and processed within the European Union.

Cloudflare: the site is served behind the CDN and protection service of Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, United States), acting as a processor within the meaning of Article 28 GDPR. Your requests are handled by the nearest Cloudflare point of presence, which may serve cached content from a country outside the European Union. This processing may therefore involve a transfer outside the EU within the meaning of Chapter V GDPR, framed by the European Commission's standard contractual clauses (Implementing Decision (EU) 2021/914) set out in Cloudflare's data processing addendum, together with Cloudflare's technical measures (encryption in transit). The only data concerned is the technical connection data described in §3.2; no data from the app is concerned, since the app collects nothing.

Apple: the processing carried out by Apple in connection with the sale may involve transfers outside the European Union, which Apple frames under its own responsibility (see Apple's privacy policy).

6. Automated decision-making and profiling

None of the processing described in this policy involves automated decision-making producing legal effects or similarly significantly affecting you within the meaning of Article 22 GDPR. No profiling is carried out.

7. Your rights

The GDPR grants you the following rights over personal data concerning you:

  • Right of access (Art. 15): to obtain confirmation as to whether data concerning you is processed, and a copy of it.
  • Right to rectification (Art. 16): to have inaccurate or incomplete data corrected.
  • Right to erasure (Art. 17), the "right to be forgotten".
  • Right to restriction of processing (Art. 18).
  • Right to data portability (Art. 20): where processing is based on consent or a contract and is carried out by automated means.
  • Right to object (Art. 21): you may object, on grounds relating to your particular situation, to processing based on legitimate interest — which here means the server logs.
  • Right to give directions as to what happens to your data after your death (Art. 85 of the loi Informatique et Libertés — a right specific to French law).

How to exercise them: write to [email protected]. We respond within one month of receiving the request, extendable by two months where the request is complex or where we receive a high number of requests, in which case we will inform you (Art. 12(3) GDPR). We may ask for proof of identity where we have reasonable doubts as to the identity of the person making the request (Art. 12(6) GDPR).

In practice, and in full transparency: as regards the app, we hold no data about you. An access or erasure request concerning your use of the app can therefore only result in a reasoned negative answer: we have nothing to give you and nothing to erase. As regards the website logs, identifying a person from an IP address alone requires you to supply the necessary details (IP address and precise time window). Failing that, Article 11 GDPR allows us not to retain or obtain additional information for the sole purpose of identifying you.

Complaint to the CNIL: if, after contacting us, you believe your rights are not being respected, you may lodge a complaint with the French supervisory authority (Art. 77 GDPR):

Commission Nationale de l'Informatique et des Libertés (CNIL) — the French data protection authority
Service des plaintes (Complaints Department)
3 place de Fontenoy — TSA 80715
75334 PARIS CEDEX 07, France
Telephone: +33 1 53 73 22 22
Online complaint: https://www.cnil.fr/fr/plaintes

If you reside in another EU Member State, you may also lodge a complaint with your local supervisory authority.

8. Security

The site is served exclusively over HTTPS (TLS encryption). Access to server logs is restricted to those who need it for technical operations. Since the app opens no network connection and stores no data off-device, it exposes no data to interception or to a server-side breach.

9. Children

Countdown is a general-purpose timer app, with no content aimed specifically at children, no user account and no data collection. It therefore collects no data about a minor — or about anyone. No age verification is necessary, and none is performed. The app's age rating is the one shown on its App Store listing.

10. Changes to this policy

This policy may be updated, in particular if the app, the site or the applicable law changes. The date of the latest update appears at the top of this document. Any material change — in particular the introduction of data collection, an analytics tool or a tracker — will be flagged prominently on the site and, where relevant, in the app, before it takes effect.

11. Contact

[email protected]

For written requests: Camille Terol / Interrupt, 37 Allée Guy de la Brosse, 76230 Isneauville, France.