CTM Labs LLC: Privacy Policy

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Last Updated: May 3, 2026

This Privacy Policy is provided by CTM Labs LLC (doing business as Cognition Through Motion). CTM Labs LLC (we, our, or us) operates the website https://cognitiontm.com and various mobile applications, including Habitz On Track! and InneRConnect (collectively, the Service).

1. Information Collection and Use

A. Mobile Application Architecture

Our Applications are built with a Privacy-First architecture. We do not require account creation, nor do we collect personal identifiers such as names, email addresses, or phone numbers.

App-Specific Permissions:

InneRConnect: This application is designed for a fully offline experience. It may request permission for Local Notifications to facilitate optional meditation reminders. We do not access location services, camera, microphone, or health data.

Habitz On Track!: This application may request permission for Local Notifications to facilitate habit reminders and App Tracking Transparency (ATT) to support ad-funded features.

Local Data Storage:

All user-generated content, including habit schedules and completion history for Habitz or session preferences and unlocked packs for InneRConnect, is stored locally on your device via UserDefaults and the secure iOS Keychain.

No External Transmission:

All data remains on your device. Data synced between your primary device and companion devices (e.g., Apple Watch) is transmitted peer-to-peer via local frameworks; no data is sent to CTM Labs LLC or any external server during this sync.

B. Health, Wellness and Audio Data (InneRConnect Specific)

Intended Use: InneRConnect utilizes binaural beats and specific sound frequencies intended to support a deeper meditative state and enhance your relaxation experience.

Data Processing: The application does not collect, process, or transmit medical information, biometric data, or brainwave states.

Medical Disclaimer: InneRConnect is a tool for wellness and meditation; it is not a medical device and is not intended to diagnose, treat, cure, or prevent any disease.

2. Third-Party Service Providers

Advertising (Habitz On Track! Only):

For our ad-supported Service (Habitz On Track!), we integrate the Google AdMob SDK. AdMob may use your device's Advertising Identifier (IDFA) to show personalized ads only if you grant explicit permission via the ATT prompt. InneRConnect contains no advertising SDKs, analytics, or third-party trackers.

Transaction Processing:

All in-app purchases are processed entirely by Apple. We do not collect or store your credit card information or Apple ID.

3. Regional Rights and Compliance

Strict-Region Consent (GDPR / UK / Brazil):

Users in the EU, EEA, UK, and Brazil are presented with a mandatory consent screen in Habitz On Track! before any advertising SDK is initialized. Declining consent results in non-personalized ads only.

California Privacy Rights (CCPA):

We do not sell or share your personal information. Users may opt out of personalized advertising at any time via the Personalized Ads toggle in the app settings.

Philippines Privacy Rights (Data Privacy Act of 2012):

In compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), users in the Philippines have the right to be informed, object, access, rectify, erase or block, data portability, and file a complaint with the National Privacy Commission (NPC). Because our Service processes and stores all user-generated data locally on your device without transmitting personal information to our servers, you retain full and direct control over your data. You may exercise your right to erasure by utilizing the "Delete All Data" (or Hard Reset) feature within the app settings. If you have any inquiries regarding your privacy rights, please contact our support team using the information provided below.

Right to Erasure:

You may permanently delete all locally stored data at any time via the Delete All Data (or Hard Reset) feature in the settings of either application.

4. Children's Privacy

Our Service does not address anyone under the age of 13. Users of Habitz On Track! are required to self-declare they are 13 or older during the onboarding process via a mandatory confirmation checkbox.

5. Contact Us

If you have questions regarding this policy, please contact us:

By Email: support@cognitiontm.com

By Mail: CTM Labs, PO Box 35, Grand Blanc, MI 48480-9998