Privacy Policy

Last updated: 19 June 2026  ·  Effective: 19 June 2026

1. Who we are

Refrain ("the app", "we", "us", "our") is developed and published by Subverting Complexity, based in South Africa. This Privacy Policy explains how the app handles information when you use it on iOS, iPadOS, Android, or the web.

This policy is published in accordance with the requirements of the Apple App Store and Google Play, and with the Protection of Personal Information Act, 2013 (POPIA) of South Africa.

2. Information we do not collect

Refrain is designed to be private by default. We do not collect any of the following:

• Personal information such as your name, email address, phone number, or postal address.
• Account credentials — Refrain has no accounts, no sign-up, and no login.
• Usage analytics, telemetry, or crash-reporting data.
• Advertising identifiers, cookies, or tracking technologies.
• Location data.
• Contacts, photos, calendars, or other personal libraries.
• Microphone or camera input — Refrain does not request microphone or camera access.

3. Data stored on your device

Refrain stores the content you create so the app is useful between sessions. This data is held locally on your device only, inside the app's private storage area. It is never transmitted to us or to any third party. This includes:

• Audio files you import into the app for looping and practice.
• Loop markers and segment profiles (your saved A/B points and named segments).
• App settings such as playback volume, skip interval, and countdown preferences.

Because this data never leaves your device, we have no ability to access, recover, or restore it. You can remove all of it at any time by deleting the relevant tracks within the app, or by uninstalling the app — which permanently erases all associated local data.

4. No network transmission

Refrain does not send your data to any server. The app has no backend, makes no analytics or advertising network calls, and does not include third-party tracking SDKs. Audio you import is read locally and never uploaded.

5. Permissions

To let you bring your own audio into the app, Refrain uses your operating system's file picker so you can select audio files to import. This is initiated by you and used solely to copy the selected file into the app's private storage. Refrain does not scan, index, or upload your wider file library.

6. Children's privacy

Refrain does not collect personal information from anyone, including children. The app contains no advertising, no in-app purchases, no chat, and no user-generated content sharing.

7. Third-party platforms

Refrain is distributed through the Apple App Store and Google Play. When you download or use apps, those platforms may collect information under their own policies (for example, download counts, device type, and purchase records). That collection is governed by Apple and Google, not by Refrain. Please review the Apple Privacy Policy and the Google Privacy Policy for details.

8. Your rights under POPIA

Because Refrain does not collect or process your personal information, there is no personal data held by us to access, correct, or delete. Nonetheless, under POPIA you have the right to:

• Be notified about whether your personal information is being processed.
• Request access to any personal information held about you.
• Request correction or deletion of your personal information.
• Object to processing and to lodge a complaint with the Information Regulator.

If you believe we hold any personal information about you, you may contact us using the details below, and you may also contact South Africa's Information Regulator (inforegulator.org.za).

9. Security

Your data resides within the sandboxed, private storage that iOS and Android provide to each app, protected by your device's own security model. We recommend keeping your operating system up to date and securing your device with a passcode or biometric lock.

10. Changes to this policy

We may update this Privacy Policy from time to time — for example, to reflect new features or legal requirements. When we do, we will revise the "Last updated" date above. If a future version of the app ever begins to collect data, we will update this policy and request consent where required before doing so.

11. Contact us

For any questions about this Privacy Policy or your privacy, contact our Information Officer at:

Subverting Complexity
Email: [email protected]
Web: subvertingcomplexity.com