Privacy Policy

Last updated: February 2026

1. Introduction

ChotkiSol ("the App") is an Orthodox Christian prayer rope (chotki) companion application for Android devices. The App provides guided prayer rope sessions, Orthodox Christian prayers, meditation reflections, Desert Father wisdom, and devotional tools to support Orthodox Christian prayer life. ChotkiSol also offers optional Solana wallet connection for Saga Genesis Token (SGT) verification via the Sign In With Solana (SIWS) protocol.

This Privacy Policy explains how ChotkiSol handles information when you use our App. We are committed to protecting your privacy and being transparent about our data practices. As you will read below, ChotkiSol is designed with a privacy-first architecture: we do not collect, store, transmit, or process any personal data.

This policy applies to all users of the ChotkiSol application, regardless of location or jurisdiction.

2. Data Controller

The data controller responsible for the App is:

MidMightBit Games
Melbourne, VIC, Australia
Email: aardappvark@proton.me

For all privacy-related enquiries, requests, or complaints, please contact us at the email address above.

3. Data We Collect

ChotkiSol collects no personal data whatsoever.

We do not collect, store, transmit, or process any of the following:

Names, email addresses, phone numbers, or any personally identifiable information (PII)
Device identifiers, advertising IDs, or hardware identifiers
IP addresses or network information
Location data (coordinates, GPS, or geolocation)
Usage analytics, behavioural data, or interaction logs
Browsing history or app usage patterns
Crash reports or diagnostic data
Financial information, wallet balances, or transaction history
Biometric data of any kind
Contacts, calendar data, photos, or any other on-device data

We have no servers, databases, or cloud infrastructure that receive data from the App. There is no backend service, no user accounts, and no data pipeline of any kind.

4. Local Storage

ChotkiSol stores a limited amount of functional data locally on your device using Android's SharedPreferences and EncryptedSharedPreferences mechanisms. This data never leaves your device.

4.1 Data Stored Locally

Data Type	Purpose	Storage Method
App settings and preferences	Remember your chosen settings (e.g., prayer speed, haptic feedback, notification preferences)	SharedPreferences
Prayer progress	Track your position within a prayer rope session so you can resume	SharedPreferences
Favourite prayers and meditations	Save your preferred selections for quick access	SharedPreferences
Wallet verification status	Remember whether SGT verification was completed (optional feature)	EncryptedSharedPreferences
Notification schedules	Store prayer reminder times set by you	SharedPreferences

4.2 No Synchronisation

Local data is not synchronised to any server, cloud service, or third-party platform. It exists solely on your device and is fully removed when you uninstall the App or clear its data through your device settings.

5. Network Requests & Third-Party APIs

ChotkiSol makes minimal network requests, limited to the following:

5.1 Solana RPC (Wallet Verification Only)

Endpoint: api.mainnet-beta.solana.com
Purpose: Verify Saga Genesis Token (SGT) ownership when you optionally connect a Solana wallet
Data sent: Wallet public address only (no PII)
When: Only when you explicitly initiate wallet connection via SIWS

A Solana wallet public address is a pseudonymous blockchain identifier. It is not linked to your real-world identity within our App. We do not store, log, or transmit this address to any server we control. The RPC request is made directly from your device to the Solana network.

5.2 Solana Mobile Wallet Adapter (MWA)

Wallet connection uses the Solana Mobile Wallet Adapter protocol with Sign In With Solana (SIWS). This communication occurs locally between the App and your installed wallet app (e.g., Solflare, Phantom) via Android intents. No data is sent to MidMightBit Games servers.

5.3 No Other Network Requests

ChotkiSol does not make any other network requests. There are no analytics endpoints, advertising networks, crash reporting services, remote configuration servers, or any other external connections.

6. No Accounts, No Analytics, No Advertising, No Tracking

No Accounts: ChotkiSol does not require or offer user account creation. There is no registration, login, or authentication system (apart from optional wallet verification via SIWS).
No Analytics: We do not use Google Analytics, Firebase Analytics, Mixpanel, Amplitude, or any other analytics platform. We do not collect usage statistics, session data, screen views, or interaction events.
No Advertising: ChotkiSol contains no advertisements. We do not integrate any advertising SDKs, ad networks, or mediation platforms. There are no ad identifiers collected or shared.
No Tracking: We do not use cookies, tracking pixels, fingerprinting, or any other tracking technology. We do not build user profiles or track behaviour across apps or websites.

7. Permissions

ChotkiSol requests the following Android permissions, each for a specific and limited purpose:

Permission	Purpose	Details
`INTERNET`	Solana RPC access	Required to communicate with the Solana blockchain for optional wallet/SGT verification. No personal data is transmitted.
`ACCESS_COARSE_LOCATION`	Sanctions screening only	Used exclusively to determine whether the device is located in a sanctioned region. Location data is checked locally on-device against a list of sanctioned jurisdictions. Location is never stored, logged, recorded, or transmitted to any server. The check is performed once and the result (permitted/blocked) is retained locally as a boolean value only.
`POST_NOTIFICATIONS`	Prayer reminders	Allows the App to send local notifications for prayer reminders that you configure. Notifications are generated entirely on-device. No notification data is sent externally.
`VIBRATE`	Haptic feedback	Provides tactile feedback during prayer bead progression. Purely a local device function.
`RECEIVE_BOOT_COMPLETED`	Notification rescheduling	Allows the App to re-register your prayer reminder notifications after your device restarts. Without this permission, scheduled reminders would be lost on reboot.

No permission is used to collect, store, or transmit personal data. Each permission serves a specific functional purpose as described above.

8. Automated Decision-Making

ChotkiSol performs one form of automated decision-making: sanctions compliance screening.

8.1 How Sanctions Screening Works

When the App starts, it may check your device's SIM card country, mobile carrier information, and/or system locale settings to determine whether you are located in or associated with a sanctioned jurisdiction. This check is:

Performed entirely on-device — no data is sent to any external server
Privacy-preserving — the raw location/carrier/locale data is compared locally against a static list of sanctioned regions and immediately discarded
Non-identifying — only a boolean result (permitted or blocked) is retained

If the screening determines that you are in a sanctioned region, access to the App will be restricted. This is required for compliance with Australian sanctions law, US OFAC regulations, and EU restrictive measures.

8.2 No Profiling

ChotkiSol does not engage in any profiling, behavioural analysis, automated scoring, or algorithmic decision-making beyond the sanctions screening described above.

9. Children's Privacy

ChotkiSol is not directed at children under the age of 13. We do not knowingly collect any information from children under 13. Since the App collects no personal data from any user, there is no risk of inadvertent collection of children's data.

If you believe a child under 13 is using the App in a manner that concerns you, please contact us at aardappvark@proton.me. However, since we collect no data, there is no data to delete.

The App complies with the US Children's Online Privacy Protection Act (COPPA), the EU General Data Protection Regulation (GDPR) provisions on children's consent (Article 8), and the Australian Privacy Act 1988 as it applies to minors.

10. International Data Transfers

No personal data leaves your device. Therefore, there are no international data transfers.

Since ChotkiSol does not collect, process, or store personal data on any server, the question of international data transfers does not arise. There is no data to transfer between jurisdictions. Your locally stored preferences remain on your device in your jurisdiction at all times.

The only network communication (Solana RPC requests) involves a pseudonymous wallet public address sent directly from your device to the decentralised Solana network. This is not a transfer of personal data as defined by the GDPR, CCPA, or equivalent regulations.

11. Data Security

Although ChotkiSol does not transmit personal data, we take reasonable measures to protect locally stored information:

Encrypted wallet data: Any wallet verification status is stored using Android's EncryptedSharedPreferences, which employs AES-256 encryption via the Android Keystore system.
Standard local storage: Non-sensitive preferences (prayer progress, settings) use Android's standard SharedPreferences, protected by the Android application sandbox which prevents other apps from accessing this data.
No remote attack surface: Because we have no servers, there is no remote database to breach, no API to exploit, and no cloud storage to compromise.
Minimal data principle: We store only what is functionally necessary for the App to operate as expected.

12. Your Rights

Depending on your jurisdiction, you may have various rights concerning your personal data. Since ChotkiSol collects no personal data, most of these rights are automatically satisfied. We set out below how each major privacy framework applies:

12.1 European Union — General Data Protection Regulation (GDPR)

Under the GDPR, you have the right to access, rectify, erase, restrict processing, data portability, and object to processing of your personal data. Since ChotkiSol collects and processes no personal data:

Right of access (Art. 15): There is no personal data held about you to access.
Right to rectification (Art. 16): There is no personal data to correct.
Right to erasure (Art. 17): No personal data exists on our systems. Local data on your device can be erased by uninstalling the App or clearing its data.
Right to restriction of processing (Art. 18): No processing of personal data occurs.
Right to data portability (Art. 20): There is no personal data to port.
Right to object (Art. 21): There is no data processing to object to.
Rights related to automated decision-making (Art. 22): The only automated decision (sanctions screening) is necessary for compliance with legal obligations and does not process personal data.

Legal basis for any processing: Legitimate interest (Art. 6(1)(f)) for sanctions compliance.

12.2 United States — California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA)

Under the CCPA/CPRA, California residents have rights regarding personal information. Since ChotkiSol does not collect, sell, or share personal information:

Right to know: We collect no personal information.
Right to delete: No personal information is held. Uninstall the App to remove all local data.
Right to opt-out of sale/sharing: We do not sell or share personal information with third parties.
Right to non-discrimination: We do not discriminate against users exercising their privacy rights.
Right to correct: There is no personal information to correct.
Right to limit use of sensitive personal information: We do not collect sensitive personal information.

ChotkiSol does not constitute a "business" under the CCPA as we do not meet the applicable thresholds, but we voluntarily respect these rights for all users.

12.3 Australia — Privacy Act 1988

Under the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs), you have rights regarding your personal information. As ChotkiSol collects no personal information:

APP 12 (Access): There is no personal information to access.
APP 13 (Correction): There is no personal information to correct.
APP 5 (Notification): This Privacy Policy serves as notification of our practices.
APP 8 (Cross-border disclosure): No personal information is disclosed to overseas recipients.

Complaints may be directed to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

12.4 Brazil — Lei Geral de Proteção de Dados (LGPD)

Under Brazil's LGPD, data subjects have rights including confirmation of processing, access, correction, anonymisation, portability, deletion, and information about sharing. Since ChotkiSol collects no personal data, all of these rights are inherently satisfied. You may contact us or Brazil's National Data Protection Authority (ANPD) with any enquiries.

12.5 Japan — Act on the Protection of Personal Information (APPI)

Under Japan's APPI, individuals have the right to request disclosure, correction, suspension of use, and deletion of personal data. ChotkiSol holds no personal data, and thus these rights are automatically fulfilled. Enquiries may be directed to us or the Personal Information Protection Commission (PPC).

12.6 South Korea — Personal Information Protection Act (PIPA)

Under South Korea's PIPA, data subjects have rights including access, correction, deletion, and suspension of processing. Since we collect no personal information, these rights are inherently satisfied. The Personal Information Protection Commission (PIPC) oversees PIPA compliance.

12.7 Thailand — Personal Data Protection Act (PDPA)

Under Thailand's PDPA, data subjects have rights of access, rectification, erasure, restriction, portability, and objection. ChotkiSol collects no personal data, so these rights are automatically met.

12.8 Singapore — Personal Data Protection Act (PDPA)

Under Singapore's PDPA, individuals have rights of access and correction regarding personal data held by organisations. ChotkiSol holds no personal data. Enquiries may be directed to us or the Personal Data Protection Commission (PDPC).

13. Data Retention

ChotkiSol does not retain any personal data on any server or cloud service. All App data is stored locally on your device.

Local data persistence: Settings, prayer progress, and preferences persist on your device for as long as the App is installed.
Deletion: You can delete all App data at any time by uninstalling ChotkiSol or clearing the App's data through your device's Settings > Apps > ChotkiSol > Clear Data.
No backups: We do not back up your data. If your device's system backup includes App data, that is governed by your device manufacturer's and/or Google's backup policies, not ours.

14. Do Not Track

ChotkiSol honours Do Not Track (DNT) browser signals and similar privacy preferences. In practice, this is inherently satisfied because we do not track users in any way, regardless of whether a DNT signal is present. There is no tracking to disable.

15. Local Storage Disclosure (ePrivacy Directive)

In compliance with the EU ePrivacy Directive (2002/58/EC as amended by 2009/136/EC), we disclose that ChotkiSol stores data locally on your device using Android's SharedPreferences and EncryptedSharedPreferences mechanisms.

This local storage is used exclusively for:

Functional purposes essential to providing the service you requested (prayer progress, settings, preferences)
Security purposes (encrypted wallet verification status)

This storage falls under the "strictly necessary" exemption of Article 5(3) of the ePrivacy Directive, as it is required for the App to function as expected by the user. No consent is required for this functional storage.

No cookies, web storage, or tracking technologies are used.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes:

The "Last updated" date at the top of this policy will be revised.
Material changes will be communicated through the App or on our website.
Your continued use of the App after changes are posted constitutes acceptance of the revised policy.

We encourage you to review this policy periodically. Given that ChotkiSol collects no personal data, substantive changes to this policy are unlikely.

17. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Commonwealth of Australia and the State of New South Wales. Any disputes arising from or relating to this policy shall be subject to the exclusive jurisdiction of the courts of New South Wales, Australia.

This choice of law does not deprive you of any mandatory consumer protections available under the laws of your country of residence, where those protections cannot be excluded by contract.

18. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

MidMightBit Games
Email: aardappvark@proton.me

We will endeavour to respond to all enquiries within 30 days.