HOLDLEDGER PRIVACY

Privacy Policy

How HoldLedger processes, stores, and protects your information

HoldLedger App · Last updated: July 26, 2026

OVERVIEW

Introduction

HoldLedger is provided and operated by Wuhan Focus Creative Technology Co., Ltd. (the “Developer”). We value your privacy. This policy explains how HoldLedger processes, stores, and protects information when you use the App.

01

Scope

This policy applies to the HoldLedger iOS app, its widgets, and its optional iCloud backup feature.

HoldLedger does not require an account and does not operate a server for storing your personal data.

02

Information Processed by the App

Information You Enter

Depending on the features you use, the App may process the following information on your device:

This information is provided and managed by you. The Developer does not receive it through a Developer-operated server.

Device-Side Technical Information

The App may read device-side status needed to provide its functions, such as local preferences, file timestamps, system uptime, network availability, notification authorization status, and iCloud availability. This information is used only on your device and is not collected by the Developer for analytics or tracking.

03

Permissions and Their Uses

Camera

If you choose to scan a card, the App requests camera access to recognize card details. Recognition is performed on the device. HoldLedger configures the CardScan component not to send scan statistics. Recognized card information is not uploaded to a Developer-operated server.

You can deny or later revoke camera access in system settings and enter card information manually.

Face ID / Touch ID / Device Passcode

If you enable App Lock or edit protection, the App uses Apple LocalAuthentication to ask the system to verify your identity. Biometric templates and passcode information are handled by the operating system. HoldLedger and the Developer cannot read or store them.

You can disable App Lock in the App or manage biometric permissions in system settings.

Notifications

If you enable reminders, the App requests notification permission and schedules local notifications for card dates, subscriptions, and activities. Reminder content is generated and delivered by the operating system. The Developer does not receive your notification content.

You can revoke notification permission in system settings or disable reminders in the App.

04

Storage and Security

Local Storage

Your data is stored locally by default. HoldLedger encrypts its primary local data using AES-256-GCM, keeps encryption keys in the system Keychain, and applies iOS file protection.

Optional iCloud Backup

If you actively use iCloud backup, the App encrypts backup data before writing it to your personal iCloud container. The backup encryption key is stored through the synchronizable system Keychain. Apple provides the underlying iCloud and Keychain services. The Developer does not have access to your iCloud account, backup files, or encryption key.

Your use of iCloud is also governed by Apple’s terms and privacy policy.

05

Clipboard

When you use a copy action, selected card, ID card, subscription, or other text may be placed on the system clipboard. The clipboard is managed by the operating system and may participate in Universal Clipboard if you have enabled that Apple feature. Do not copy sensitive information on an untrusted device.

06

External Links and Third-Party Services

The App contains optional links that may open system services or third-party apps and websites, such as iCloud, Mail, bank apps, Weibo, Xiaohongshu, and Alipay. HoldLedger does not send your stored card, ID card, benefit, subscription, or activity data to these services merely because the links are displayed. If you choose to open a link or share content, the destination service may process device or usage information under its own privacy policy.

HoldLedger does not include advertising, cross-app tracking, or Developer-operated analytics. The Developer does not sell your personal data.

07

Data Retention and Deletion

Because HoldLedger has no account system and the Developer does not possess your App data, the Developer cannot remotely retrieve or delete it for you.

08

Children’s Privacy

HoldLedger is not designed specifically for children. The Developer does not knowingly collect personal information from children through a Developer-operated service. Minors should use the App with the guidance of a parent or guardian and should not enter sensitive financial or identity information without permission.

09

Changes to This Policy

We may update this policy when App features, data practices, or legal requirements change. The updated policy will be made available in the App and, where applicable, on the App Store or the Developer’s website. The date shown at the top indicates the latest revision.

10

Contact Us

If you have questions, requests, or complaints about this policy, contact: