Privacy Policy

1. Who we are

This website and waitlist are currently operated by Fabrice Pittet, trading as OFF/ON® and Master Your Digital Habits®.

For privacy-related questions, you can contact us at:

OFF/ON Labs SA may become the operator and data controller of the Service once incorporated in Switzerland. If this happens, OFF/ON Labs SA will continue operating the Service under this Privacy Policy, unless we notify you of material changes.

No new consent or action will be required from you unless the change materially affects how your personal data is processed.

2. What this Privacy Policy covers

This Privacy Policy applies to:

• the OFF/ON landing page;
• the OFF/ON waitlist;
• the phone habit quiz;
• the phone habit profile;
• the 7-day starter plan;
• early-access emails about the OFF/ON app.

It does not yet cover the future OFF/ON mobile app. A separate or updated privacy policy will be provided before the app launches.

We keep your quiz answers and phone habit profile so that, if you choose to join the OFF/ON app, your setup can be prepared and you do not have to answer the same questions again. Nothing is transferred to an app account unless you use your personal access link and create an account yourself. If you never join, your data stays under this Privacy Policy and is deleted as described in section 10.

3. What data we collect

When you submit the waitlist form or take the phone habit quiz, we may collect:

Email address — used to send your phone habit profile, 7-day starter plan, and early-access emails.

Quiz answers — the answers you provide in the phone habit quiz, used to generate your phone habit profile and starter plan.

Phone habit profile — one of four descriptive profiles, derived automatically from your quiz answers by a fixed set of rules. It is used to personalize your profile email and starter plan, and to prepare your app setup if you join. It is not a medical or psychological assessment, and it does not produce any legal or similarly significant effect for you.

Device information — approximate device type, such as iOS, Android, desktop Mac, desktop Windows, or unknown. This is detected automatically from your browser and used to understand demand and prioritize launch access.

Marketing attribution data — such as UTM parameters, referrer information, campaign source, campaign medium, campaign name, ad identifiers such as fbclid or gclid, and similar information passed through the URL.

Consent record — the consent text version, timestamp, page URL, and form source at the time you submit the form.

Technical logs — standard server logs, such as IP address, browser type, timestamp, and security events, kept temporarily for security and abuse prevention.

Advertising and measurement data — where applicable, we may use event data and hashed email matching to measure and improve OFF/ON advertising campaigns and to show more relevant OFF/ON ads.

We do not collect on this website:

• your name, unless you choose to provide it later;
• your phone number;
• your exact phone usage data;
• your Screen Time data;
• biometric data;
• health data;
• medical or therapeutic records.

4. Why we collect data and legal basis

We process personal data under the UK GDPR, EU GDPR, and Swiss Federal Act on Data Protection where applicable.

You can withdraw your email consent at any time by clicking "Unsubscribe" in any OFF/ON email or by contacting us directly.

You can object at any time to the use of your personal data for advertising audience matching by contacting us directly.

5. Email communications

When you submit the form, you request your OFF/ON profile, 7-day starter plan, and launch invite. We send these by email as part of the service you asked for, together with a small number of service updates directly related to your plan and to the launch you are waiting for.

We keep a record of your submission, including the version of the on-page text, timestamp, page URL, and source form.

Every email includes an unsubscribe option. If you unsubscribe, we will stop sending you emails.

6. Advertising tools and Meta

We may use advertising tools to measure and improve OFF/ON campaigns.

This may include Meta tools operated by Meta Platforms Ireland Ltd.

We may send Meta limited event data, such as a lead or quiz completion event, to help us understand whether our campaigns are working.

We may also use your email address in hashed form to create OFF/ON advertising audiences on Meta platforms. Hashing means the email is transformed before being sent to Meta. However, hashed email matching may still involve personal data because it can be used to match you to a Meta account.

We use this only for OFF/ON advertising purposes, such as:

• showing relevant OFF/ON ads;
• avoiding irrelevant or repeated ads;
• measuring campaign performance;
• improving our launch campaigns.

We do not sell your data. We do not share your data for other companies' marketing purposes.

You can opt out of OFF/ON advertising audience matching at any time by contacting us at info@masteryourdigitalhabits.com. If you opt out, we will remove you from OFF/ON Custom Audiences within 30 days where technically possible.

Meta may also process data under its own terms and privacy policies when you use Meta platforms.

7. Cookies and tracking technologies

At launch, this landing page does not use Google Analytics, Meta Pixel, or browser-based advertising cookies.

If we introduce cookies, Meta Pixel, analytics tags, retargeting pixels, or similar browser-based technologies in the future, we will update this Privacy Policy and use a cookie banner where required before non-essential technologies are activated.

Server-side measurement tools, such as Meta Conversions API, may be used without setting cookies on your device. Where such tools involve personal data, they are described in this Privacy Policy.

8. Who we share data with

We share only the data needed to operate the Service with selected providers:

MailerLite — email delivery, list management, unsubscribe management, and consent records.

Meta Platforms Ireland Ltd — advertising measurement and, where used, hashed email audience matching for OFF/ON ads.

Amazon Web Services — hosting and storage of quiz answers and generated profiles.

Rocketech PTE. LTD. — technology partner supporting development of the quiz application and technical infrastructure.

These providers may process data only for the purposes described in this Privacy Policy and under appropriate contractual safeguards.

We may also disclose data if required by law, regulation, court order, or competent authority.

9. International transfers

Some providers may be located outside the United Kingdom, the European Economic Area, or Switzerland.

Where personal data is transferred internationally, we use appropriate safeguards where required, such as adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or equivalent safeguards.

10. How long we keep data

Email address — kept while you remain subscribed or on the waitlist.

Quiz answers and phone habit profile — kept while you remain subscribed or on the waitlist. If you unsubscribe or request deletion, we delete quiz answers and profile data within 30 days, unless we need to keep limited records for legal reasons.

If you never join the OFF/ON app — we delete your quiz answers and phone habit profile within [RETENTION_PERIOD] after the OFF/ON app becomes publicly available in your market, or sooner if you ask us to.

Consent record — kept for up to 3 years after your last interaction, to demonstrate consent and compliance.

Suppression record — if you unsubscribe, we may keep a limited record of your email address to make sure we do not email you again.

Server logs — kept for up to 90 days, unless longer retention is necessary for security, fraud prevention, or legal reasons.

Advertising audience data — if used, removed from OFF/ON-managed Meta audiences within 30 days after you opt out or unsubscribe, where technically possible.

11. Your rights

Depending on where you live, you may have the right to:

• access your personal data;
• correct inaccurate data;
• request deletion;
• restrict processing;
• object to processing based on legitimate interest;
• object to direct marketing;
• withdraw consent;
• request data portability;
• lodge a complaint with a data protection authority.

To exercise your rights, contact us at info@masteryourdigitalhabits.com. We aim to respond within 30 days.

If you are in the United Kingdom, you may complain to the Information Commissioner's Office. If you are in the European Union, you may complain to your local data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

12. Children

The Service is intended for adults aged 18 and over.

We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data through the Service, contact us and we will delete it promptly.

13. Security

We use reasonable technical and organizational measures to protect personal data, including:

• HTTPS/TLS encryption in transit;
• access controls;
• limited provider access;
• secure hosting;
• contractual confidentiality obligations with providers.

No system is completely secure. If we become aware of a personal data breach that is likely to affect your rights, we will take appropriate action and notify the relevant authority and affected users where required by law.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The current version will be available on the OFF/ON website. If we make material changes to how we process personal data, we will notify subscribed users where appropriate.

15. Contact

OFF/ON® and Master Your Digital Habits® are registered trademarks of Fabrice Pittet.