Shortfall Privacy Policy

1. Overview

Shortfall is an iOS app that audits car-purchase contracts against per-state doc-fee rules, credit-tier APR bands, and F&I add-on price ranges. This policy explains exactly what data the app processes, where it lives, and who has access to it. The short answer is: everything stays on your iPhone.

Shortfall has no backend. We run no servers, operate no databases, and maintain no user accounts. Kynoss Studios, the developer of Shortfall, has no way to retrieve your data from your device because there is no data-retrieval path in the app.

2. Contract Documents & Extracted Fields

When you import a PDF or photograph a contract, Shortfall uses Apple's on-device frameworks (PDFKit, VisionKit, Vision) to read the document and extract fields such as sale price, doc fee, APR, loan term, monthly payment, GAP insurance charge, and vehicle service contract charge.

The contract file and all extracted fields never leave your device. They are not uploaded to any server (including Apple's), not transmitted to Kynoss Studios, and not shared with any third party.

If you save an audit, the extracted fields and resulting verdict are stored locally using Apple's SwiftData framework in your app's sandbox. This storage is subject to iOS's standard application-data protection and is automatically removed by iOS when you uninstall the app.

3. On-Device AI (Apple Foundation Models)

Part of Shortfall's extraction pipeline uses Apple's Foundation Models framework — an on-device large language model built into iOS 26 and later. Foundation Models runs entirely on your iPhone. Prompts and responses do not leave the device.

Shortfall does not use any third-party AI service. Specifically: no OpenAI, no Anthropic, no Google Gemini, no server-side machine learning of any kind. We do not "train" or "improve" any model using your data.

Shortfall requires an Apple Intelligence-capable iPhone (iPhone 15 Pro, iPhone 15 Pro Max, or any iPhone 16 or iPhone 17 model) specifically because Foundation Models is the on-device privacy-preserving alternative to uploading your data to a cloud AI service.

4. Benchmark Data

Shortfall compares your contract against per-state doc-fee rules, credit-tier APR bands, and F&I add-on price ranges. These benchmarks are bundled with the app at install time as a static JSON file shipped inside the app bundle. Shortfall does not call any server to fetch them.

The effective date of the bundled benchmarks and the source of each benchmark type are displayed in the app's verdict detail and on every shared Walkaway Card. Benchmark updates ship as part of normal app updates via the App Store. Updated benchmarks never reveal your data to the source; they flow one-way, from us to the app, at install or update time.

5. Purchases (StoreKit)

Shortfall offers a one-time $4.99 in-app purchase to unlock unlimited audits and multi-purchase history. The transaction is processed by Apple through StoreKit 2. Apple handles:

• The payment transaction itself
• Billing, receipts, refunds, and Family Sharing
• Any tax reporting required by your jurisdiction

Shortfall receives only a local receipt indicating whether your unlock is active. We never see your payment method, Apple ID, billing address, or any other personal identifier from the purchase flow.

Apple's handling of your purchase data is governed by Apple's own privacy policy.

6. Data Storage

All Shortfall data is stored on your device using Apple's SwiftData framework within your app's sandbox directory. This includes:

• Each audit's extracted field values
• The verdict generated for each audit
• The state, credit tier, and new/used context you selected
• A serialized copy of the Walkaway Card's contents (so the card can be re-rendered later)

iOS applies its standard file-system protection to this storage. It is not synced to iCloud (Shortfall does not enable iCloud sync), is not backed up to any cloud, and is not accessible to any other app on your device.

7. Data Retention & Deletion

Audit history persists on your device until:

• You delete individual audits via swipe-to-delete in the History view, or
• You uninstall Shortfall, in which case iOS removes the app's entire sandbox, including all audit data.

Because Shortfall never transmits your data anywhere, there is no cloud copy of your data for us to retain or delete. Deletion is immediate and total on your device.

8. Data Sharing & Third Parties

Shortfall does not share your data with any third party. There is no third party to share with — no analytics provider, no ad network, no lead-generation partner, no cloud-AI vendor.

When you tap "Share walkaway card," the rendered image is passed to iOS's system share sheet. What happens next depends on which destination you choose (Messages, Mail, Save to Photos, etc.). That interaction is governed by the destination app's privacy policy, not Shortfall's. Shortfall itself never transmits the image; it hands the image to iOS, and iOS hands it to whichever app you pick.

9. Data Security

Shortfall relies entirely on iOS's built-in security model:

• App sandboxing prevents other apps from accessing Shortfall's data.
• File-system encryption on iOS protects local storage at rest.
• No network transmission means no transport-layer attack surface for your contract data.

Because Shortfall does not operate a server, there is no server-side infrastructure that could be breached, no database that could be exfiltrated, and no cloud backup that could be compromised. The "security" of your data is bounded by the security of your own iPhone.

10. Children's Privacy (COPPA)

Shortfall is rated 4+ on the App Store but is targeted at adult car buyers. Because Shortfall does not collect any data from any user regardless of age, the Children's Online Privacy Protection Act (COPPA) is not applicable in the traditional sense — we have no data collection practices to constrain for children.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights.

Information We Process

Under CCPA/CPRA definitions, Shortfall processes the following categories of information on your device only:

• Contract document images and PDFs that you choose to import
• Financial information extracted from those documents (sale price, APR, fees, etc.)
• Your self-reported credit tier, state, and new/used selection

Because all processing occurs on your device and we never collect, receive, or access this information, Kynoss Studios does not "collect" personal information as defined by the CCPA/CPRA.

Your Rights

• Right to know: This Privacy Policy describes everything the app processes. We do not collect additional data beyond what is described here.
• Right to delete: Delete the app, or use in-app swipe-to-delete on any audit row, to remove data.
• Right to opt out of sale: We do not sell your personal information. We never have and never will.
• Right to opt out of sharing: We do not share your personal information with third parties for cross-context behavioral advertising or any other purpose.
• Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.
• Right to limit use of sensitive personal information: Financial information is considered sensitive under CPRA. Shortfall accesses the content of financial documents only on your device and only at your explicit instruction (by importing a contract).

"Do Not Sell or Share My Personal Information"

Shortfall does not sell or share personal information. Because no data is transmitted from your device to us or any third party, there is no sale or sharing to opt out of. We fully comply with the CCPA/CPRA without requiring any user action.

12. Apple Platform Disclosures

In compliance with Apple's App Store Review Guidelines and platform requirements:

AI Service Disclosure (Guidelines 5.1.1(i) / 5.1.2(i))

• Shortfall uses Apple's on-device Foundation Models framework for parts of the contract-field extraction pipeline.
• Shortfall does not use any third-party AI service (OpenAI, Anthropic, Google, etc.).
• AI inference happens entirely on the user's iPhone; no prompts or model responses are transmitted anywhere.
• User data is never used to train or improve any model, internally or externally.

Required Reason APIs

Shortfall uses only Apple's first-party frameworks (PDFKit, VisionKit, Vision, Foundation Models, SwiftData, StoreKit 2) and does not access any APIs that require declared reasons beyond those already disclosed in this policy and in the app's App Store privacy nutrition label.

App Tracking Transparency

Shortfall does not track users across apps or websites owned by other companies. The App Tracking Transparency framework is not used because no tracking occurs. Shortfall does not access the user's IDFA.

App Privacy Nutrition Label

Shortfall's App Store privacy nutrition label accurately reflects that the app does not collect data linked to user identity and does not track users. All three privacy-label sections — "Data Used to Track You," "Data Linked to You," and "Data Not Linked to You" — show as None.

Apple-Native Diagnostic Signposts (OSLog & MetricKit)

Shortfall emits Apple-native diagnostic signposts using OSLog and MetricKit (via os_signpost on the PointsOfInterest log) so we can learn what's working in the audit and paywall flows over time. These signposts:

• Stay on your device by default. They are written to the system log and to MetricKit's daily diagnostic payload, both of which Apple stores locally.
• Are not sent to Kynoss Studios — we run no servers and have no analytics endpoint to receive them.
• May be sampled into Apple's anonymized, aggregate diagnostic stream only if you have opted into Apple's system-wide "Share with App Developers" diagnostics setting (off by default). Even then, what Kynoss Studios receives is anonymized and aggregated by Apple, not raw events tied to you.
• Contain no contract data, no extracted fields, no audit history, no Apple-ID, and no IDFA — only event labels like paywall_view and per-trigger funnel markers.

Per Apple's classifier, these are not "Usage Data Collected" because they don't leave the device under default settings.

Financial Advice Framing (Guideline 5.1.1)

Shortfall reports factual deltas against publicly available benchmark data. It does not provide legal or financial advice, does not name individual dealers, and does not characterize charges as fraud or scams. Every verdict includes source attribution and an effective date. The user remains the decision-maker.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in the app's functionality or legal requirements. When we make changes:

• The "Last Updated" date at the top of this page will be revised.
• Material changes (e.g., if we ever added an opt-in iCloud sync feature) would be communicated in the app before the change takes effect and would require your explicit consent.
• Continued use of Shortfall after non-material changes constitutes acceptance of the updated policy.

We encourage you to review this policy periodically. This policy will be reviewed at least annually.

14. Contact Us

If you have questions about this Privacy Policy, your privacy rights, or Shortfall's data practices, please contact us:

• Email: kynossstudios@gmail.com
• Developer: Kynoss Studios
• Support Page: Shortfall Support

We will respond to privacy inquiries within 30 days.