Privacy Policy

Kapua256 Limited  ·  Last Updated: 19 March 2026

1. Introduction

Kapua256 Limited ("Kapua256", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you:

• Visit our website at kapua256.com
• Use our mobile application Avgora (available on iOS, iPadOS, and watchOS)
• Engage our consulting services

By using our website or app, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use.

2. Who We Are

Company: Kapua256 Limited
Location: Auckland, New Zealand
Website: https://kapua256.com
Contact: Via the contact form at kapua256.com

3. App Tracking Transparency (ATT)

When you first open Avgora on iOS 14.5 or later, you will see an App Tracking Transparency (ATT) permission prompt from Apple. This is a system-level popup asking whether you allow the app to track your activity across other companies' apps and websites.

What "tracking" means: It refers to linking your device's advertising identifier (IDFA) with data from other apps or websites for the purpose of showing you personalised advertisements via Google AdMob.

• If you tap "Allow": Google AdMob may serve personalised ads based on your interests and activity across other apps.
• If you tap "Ask App Not to Track": You will still see ads, but they will be non-personalised (context-based only).

Your choice does not affect the core functionality of Avgora in any way.

4. Google AdMob — Advertising

Avgora uses Google AdMob to display advertisements. AdMob is operated by Google LLC. Depending on your ATT choice, AdMob may collect and use the following data:

• Device Identifier (IDFA): Apple's Identifier for Advertisers, used to serve and measure personalised ads
• IP address: Used for approximate location and fraud prevention
• Device information: Device type, operating system version, and app version
• Ad interaction data: Whether you viewed or tapped an ad
• Coarse location: Country or region level only

Google AdMob's data collection is governed by Google's Privacy Policy at policies.google.com/privacy.

To opt out of personalised advertising by Google, visit adssettings.google.com.

5. Device Identifier (IDFA)

Your device's IDFA (Identifier for Advertisers) is a unique, resettable identifier assigned by Apple. It is used solely for advertising purposes through Google AdMob.

• We do not use your IDFA for any purpose other than advertising
• We do not share your IDFA with any party other than Google AdMob
• You can reset your IDFA at any time: Settings → Privacy & Security → Tracking
• You can disable personalised ads: Settings → Privacy & Security → Apple Advertising → Personalised Ads (off)

6. In-App Purchases

Avgora may offer in-app purchases processed exclusively through Apple's StoreKit framework. We do not collect, store, or have access to your payment information.

When you make a purchase, Apple collects and processes:

• Payment method details (handled entirely by Apple)
• Purchase history (accessible to you via your Apple ID)
• Transaction identifiers (used to verify purchases within the app)

All payment data is governed by Apple's Privacy Policy at apple.com/legal/privacy. We only receive confirmation that a purchase was completed — we never see your payment details.

7. Data We Collect in the App

7.1 Data You Provide

• Rowing session data you enter (distance, time, stroke rate, etc.)
• Any preferences or settings you configure within the app

7.2 Local Storage Only

All data you enter in Avgora is stored locally on your device only. We do not sync, upload, or transmit your personal rowing data to any server or cloud service. Your data stays on your iPhone, iPad, or Apple Watch.

• No account or login required
• No cloud backup by us (you may back up via iCloud as part of your normal Apple device backup)
• Deleting the app removes all locally stored app data from your device

8. Website Information We Collect

8.1 Information You Provide Directly

• Name and contact details submitted via contact forms
• Email address
• Project or enquiry details you choose to share

8.2 Information Collected Automatically

• IP address and browser or device type
• Pages visited and time spent on our website
• Operating system and browser version
• General location data (country/region level)

9. How We Use Your Information

We use the information we collect to:

• Respond to your enquiries and provide requested services
• Display advertisements within Avgora via Google AdMob
• Process and verify in-app purchases via Apple StoreKit
• Improve our website and app functionality
• Comply with legal obligations
• Protect against fraudulent or unauthorised activity

10. How We Share Your Information

We do not sell or rent your personal information. We may share data with:

• Google AdMob: For serving advertisements in Avgora (subject to your ATT choice)
• Apple StoreKit: For processing in-app purchases
• Formspree: For processing website contact form submissions
• Cloudflare: For website hosting and delivery
• Legal Authorities: If required by law, regulation, or legal process
• Business Transfers: In connection with a merger, acquisition, or sale of assets

11. Children's Privacy (COPPA Compliance)

Avgora is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 years of age.

• The app is rated for ages 13+ on the Apple App Store
• We do not knowingly display targeted advertising to children under 13
• If you are a parent or guardian and believe your child under 13 has used the app, please contact us via the form at kapua256.com and we will take appropriate action
• Google AdMob is configured to serve non-personalised ads only in the event that a user's age cannot be verified

For users in the EU/EEA aged under 16, personalised advertising is disabled in compliance with GDPR requirements for minors.

12. Your Rights and Opt-Out Options

12.1 Advertising Opt-Out

• Deny ATT prompt: Tap "Ask App Not to Track" when prompted on first launch
• Disable tracking after install: Settings → Privacy & Security → Tracking → toggle off Avgora
• Reset your IDFA: Settings → Privacy & Security → Tracking → Reset Advertising Identifier
• Google Ad Settings: adssettings.google.com

12.2 Your Data Rights by Region

• NZ Privacy Act 2020: Access, correct, or request deletion of your personal information
• GDPR (EU/EEA): Access, rectification, erasure, restriction, portability, and right to object
• CCPA (California): Know what data is collected, opt out of sale, and request deletion

To exercise any of these rights, contact us via the form at kapua256.com.

13. Data Storage and Security

App data is stored locally on your device and never transmitted to our servers. Website enquiry data may be stored and processed in New Zealand or other countries where our service providers operate. We implement reasonable technical and organisational measures to protect your information.

14. Third-Party Links

Our website and app may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last Updated" date at the top of this page. Continued use of our website or app after changes constitutes acceptance of the updated policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us via the contact form at kapua256.com.