Last updated: June 19, 2026
Pennen is a private, handwritten journal for iPad. This Privacy Policy explains what information the Pennen app ("Pennen", the "App") handles, how it is used, and the choices and rights you have. We built Pennen to collect as little as possible: we do not run our own servers for your content, we do not sell your data, we do not show ads, and we do not use third-party tracking or analytics software.
Pennen is operated by Ishaan Rawat, a sole proprietor established in India ("we", "us", "our"), who is the data controller for the limited processing described in this policy. You can reach us at ishaan@ishaanrawat.com.
This policy applies to the Pennen iPad app distributed through the Apple App Store. It does not apply to Apple's own services (such as iCloud, the App Store, or your Apple Account), which are governed by Apple's Privacy Policy. Because Pennen relies on Apple's iCloud and CloudKit to store and sync your content, your use of those features is also subject to Apple's terms and privacy practices. Your use of Pennen is additionally governed by the Apple Standard Licensed Application End User License Agreement (the "EULA"), available here.
The following stays on your device and, if you are signed in to iCloud, syncs through your own iCloud account using Apple's CloudKit private database. It is not transmitted to us, and we have no ability to read it:
The statement "we cannot read it" refers to your journal pages and passcode. The separate pseudonymous activity records described in Section 2.2 are stored in a shared area we can read, but they contain no journal content.
Pennen shows a live counter of how many people are writing now and have written today. When you write, the App records the following in a shared (public) area of our CloudKit container hosted on Apple's servers:
This information is used only to calculate and display aggregate counts. It is not linked to your real-world identity. Because the identifier is persistent on your device and stored on our behalf, we treat it as pseudonymous personal data and protect it accordingly, rather than calling it anonymous. The records are designed to be short-lived (see Data retention), and you have choices about this processing (see Your privacy rights).
If you enable daily reminders, they are scheduled and delivered locally by iOS on your device. The reminder content and schedule do not leave your device and are not sent to us. You can turn reminders on or off at any time within the App or in iOS Settings › Notifications › Pennen; the notification permission is granted and revoked through iOS.
Subscriptions and one-time purchases are processed entirely by Apple through the App Store using your Apple Account. We do not receive or store your name, payment card, or billing details. Pennen offers auto-renewable subscriptions; a subscription renews automatically unless cancelled at least 24 hours before the end of the current period, and you can manage or cancel it in your Apple Account settings. Subscription terms are governed by the EULA linked in Section 1.
When you view the subscription offer, purchase, or restore, Apple's App Store and StoreKit generate standard product-interaction data. This usage data is processed by Apple to operate the App's purchase features; it is not used to track you across other companies' apps or websites, is not linked to your identity by us, and is not sold or shared. Apple provides us only with anonymized, aggregate sales and subscription reports through App Store Connect, which we cannot use to identify you.
Pennen does not collect, request, or have access to: your name, email address, phone number, mailing address, contacts, photos, precise or coarse location, health data, your Apple Account credentials or the identity behind it (Apple handles all sign-in, iCloud, and payment; we never receive it), your device's advertising identifier (IDFA), or any cross-app or cross-site browsing activity. Pennen contains no advertising, no analytics or attribution SDKs, and — as of this version — no third-party software development kits of any kind. If this ever changes, we will update this policy before doing so.
We use the limited information described above only to:
Automated decision-making and profiling. We do not use your information for advertising or to build a profile about you, and we do not carry out profiling or any automated decision-making that produces legal or similarly significant effects within the meaning of Article 22 of the GDPR or applicable U.S. state privacy laws.
If you are in the European Economic Area or the United Kingdom, the following applies under the GDPR / UK GDPR. Your journal pages, passcode, preferences, and reminders are processed by you on your own device and in your personal iCloud; we do not receive or process them, so no legal basis on our part is required. For the limited information we do process, we rely on:
Your journal pages and passcode are stored on your device and, where applicable, in your personal iCloud (Apple's CloudKit private database and iCloud Keychain). The pseudonymous activity records described in Section 2.2 are stored in our app's public CloudKit database on Apple's servers. We do not operate our own application servers and do not maintain a separate copy of your content. Apple acts as our infrastructure provider for these features.
We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising. We disclose information only as follows:
Our only service provider is Apple Inc., which provides:
Apple's handling of this data is governed by Apple's Privacy Policy.
Information handled through Apple's iCloud and CloudKit may be stored and processed on Apple's infrastructure in countries other than your own. The pseudonymous community activity records we control are stored on Apple's CloudKit infrastructure, which may be located outside the EEA/UK; for these transfers we rely on Apple acting as our processor under appropriate safeguards (such as standard contractual clauses) as described in Apple's Privacy Policy. We do not independently transfer your private journal content, because it remains in your own iCloud and we never receive it.
Pennen relies on Apple's platform security. Content stored in iCloud/CloudKit is encrypted in transit and at rest by Apple. Your journal pages reside in your private iCloud database and your passcode in the encrypted iCloud Keychain; the in-app passcode adds a lock on top of the App itself. The pseudonymous activity records (Section 2.2) are stored in a shared, readable area by design so the counter can be computed, and contain no journal content. No method of storage or transmission is completely secure, and we cannot guarantee absolute security; however, we minimize risk by collecting almost no data and by not operating our own servers.
If we ever become aware of a personal-data breach affecting the limited information we control (the public activity records), we will assess it and, where legally required, notify the relevant supervisory authority without undue delay — and, in the EEA/UK, within 72 hours where feasible — and notify affected individuals where required, consistent with applicable breach-notification laws.
Depending on where you live, you may have some or all of the following rights regarding personal information: to access it, correct it, delete it, restrict or object to its processing, port it, and (where we rely on consent) withdraw consent. EEA/UK users also have the right to lodge a complaint with their local data protection authority — you can find yours via the European Data Protection Board or, in the UK, the Information Commissioner's Office.
Because most of your information never leaves your device or your personal iCloud, you can exercise the most important controls directly: delete individual pages or the App to remove your content. For the community activity signal, the App does not currently include an in-app switch to turn it off; to object to or stop this processing, you can (a) delete the App, which stops all activity records and removes the local identifier, or (b) email us. We do not hold information that lets us identify you from the community activity records (Article 11 GDPR); if you can provide details that let us locate specific records, we will act on your request, and in any event those records age out of all counts within about two days. To make a request or ask a question, email ishaan@ishaanrawat.com. We will not discriminate against you for exercising your rights.
This section provides additional information for California residents under the California Consumer Privacy Act, as amended (CCPA/CPRA).
We do not sell your personal information and do not share it for cross-context behavioral advertising. We have not done so in the preceding 12 months, and we do not knowingly sell or share the personal information of consumers under 16.
In the preceding 12 months, the categories of personal information we have collected are:
| Category | Examples (as used in Pennen) | Collected? | Sold/Shared? |
|---|---|---|---|
| Identifiers | A random, app-generated device identifier (no name, email, or Apple Account) | Yes | No |
| Internet or other electronic network activity | Pseudonymous "writing activity" timestamps for the community counter | Yes | No |
| All other categories (e.g. real name, contact details, geolocation, biometric, financial) | — | No | No |
We collect this information directly from your device. The business purpose is to operate and secure the community activity counter (performing services, debugging, and security). The only recipient is Apple Inc., as our service provider for CloudKit hosting; no category is disclosed to any third party for any commercial purpose, sold, or shared. We retain these records as described in Section 10 (the pseudonymous records are deleted after approximately two days; the random identifier persists locally until you delete the App). We retain no other categories of personal information.
Sensitive personal information. Pennen does not collect or process sensitive personal information as defined by the CCPA. Your journal writing — which may be personal or intimate — never leaves your device or your personal iCloud account and is never received by us, so we do not collect it. Because we do not collect sensitive personal information, the right to limit its use and disclosure does not apply.
As a California resident you have the right to: know/access the categories and specific pieces of personal information we have collected; delete it; correct inaccurate information; opt out of the sale or sharing of personal information; limit the use of sensitive personal information; and not be discriminated against for exercising these rights. To exercise a right, email ishaan@ishaanrawat.com; we will respond within 45 days (extendable once where permitted). We may need to take reasonable steps to verify your request; you may also use an authorized agent. Because we do not sell or share personal information, no "Do Not Sell or Share My Personal Information" link is required.
If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or another state with a comprehensive consumer privacy law, you may have rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling. Pennen does not engage in targeted advertising, does not sell personal data, and does not profile you. To exercise any of these rights, email ishaan@ishaanrawat.com. If we decline a request, you may appeal by replying to our response; if your appeal is denied, you may contact your state attorney general.
Pennen is a general-audience app intended for adults and is not directed to children. You must be at least the minimum age required in your country (16 in the EEA/UK unless a lower age is permitted, 13 in the United States) to use Pennen, consistent with the App Store age rating. The App has no account and asks for no age, name, or contact information, so we do not knowingly collect personal information from children. If you believe a child has provided us with information, contact us and we will take appropriate steps.
Pennen does not track you across apps or websites owned by other companies and does not use Apple's App Tracking Transparency framework, because it performs no such tracking. We do not sell or share your personal information, so there is nothing to opt out of in that respect. Pennen does not respond to browser "Do Not Track" signals because it is not a website and collects no browsing activity.
We may update this policy from time to time. When we make material changes, we will revise the "Last updated" date above and, where appropriate, provide notice within the App. Where a change requires your consent under applicable law (for example, any new sale or sharing of personal information, or processing of sensitive personal information), we will obtain that consent before it takes effect.
If you have questions, requests, or complaints about this policy or your information, contact:
Ishaan Rawat
Email: ishaan@ishaanrawat.com
Postal address: 41, Rawat Palace, Jaipur 302002, India
EEA/UK representative: we have assessed Article 27(2) of the GDPR / UK GDPR and consider our processing of EEA/UK personal data occasional, low-risk, and not involving special categories of data, so we do not consider a representative to be required. You may contact us directly using the details above.