PRIVACY POLICY

Refuse: Habit Changer

Web Application and Mobile Application

Date: June 02, 2026

1. Introduction and Scope

Milky Way Entertainment LLC ("we," "us," or "our"), a company registered at 30 N Gould St Ste R Sheridan, WY 82801 USA, a subscription-based web and mobile application designed to help adults manage and change harmful habits, including alcohol use, other substance-related habits, and related behavioral patterns through neuroscience-based content, personalized plans, progress tracking, mindfulness exercises, and community support.

This Privacy Policy explains what personal data we collect when you use the Service, how we use it, with whom we share it, and what rights you have. It applies to the website at https://refuses.online/refuse/ and any associated mobile applications (collectively, the "Service").

By accessing or using the Service you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please do not use the Service.

2. Important Notice: No Clinical or Medical Services

Refuse: Habit Changer is an informational and self-help tool. The Service does not provide, facilitate, or refer users to any clinical care, telehealth services, prescriptions, or licensed medical or mental health professional services. All content is provided for informational and motivational purposes only and is not a substitute for professional medical advice, diagnosis, or treatment. Users with medical concerns related to substance use or addiction should consult a qualified healthcare professional.

3. Who This Policy Applies To

This Privacy Policy applies to all visitors, registered users, and subscribers of the Service, including individuals who access the Service through our website or mobile applications. The Service is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18.

4. Personal Data We Collect

4.1 Data You Provide Directly

  1. Account registration information: email address and password.
  2. Subscription and billing information: subscription plan selection and billing cycle. Payment transactions are processed directly by our third-party payment processors; we do not collect or store payment card numbers or full financial account details.
  3. Habit and progress data: information you enter about your habits, goals, and progress within the app.
  4. Customer support communications: messages you send to our support team.
  5. Community content: messages, posts, or other content you choose to share within community features of the Service. See Section 4.4 below.

4.2 Data We Collect Automatically

When you use the Service we automatically collect:

  1. Device and technical data: device make, model, and operating system; screen size and orientation; device settings (including accessibility features); hardware identifiers (Device ID, Vendor ID / IDFV); advertising identifiers (IDFA/GAID) where applicable and subject to your device privacy settings; IP address; browser user-agent; network connection type and speed; carrier; country, time zone, and language settings.
  2. Usage and event data: pages or screens viewed; session length and frequency; in-app interactions and feature use; push notification token; crash reports and diagnostic logs.
  3. Cookies and similar technologies: see Section 8 below.

4.3 Data from Third Parties

We may receive limited data from analytics and advertising partners where you have interacted with their services. We do not purchase personal data from data brokers.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

  1. Service delivery: to create and manage your account, provide access to subscription content, authenticate users, and process subscription payments.
  2. Product improvement: to analyse usage patterns, diagnose bugs, fix errors, and develop new features.
  3. Personalisation: to tailor content recommendations, habit plans, and in-app messaging to your goals and preferences.
  4. Sensitive data commitment: information you provide about your habits, sobriety journey, and progress is treated as sensitive. It is used exclusively to deliver and improve the Service. We do not use this data for advertising targeting, profile it for third-party advertising purposes, or share it with ad networks.
  5. Communications: to send transactional emails (subscription confirmations, renewal notices, billing receipts, cancellation confirmations), service announcements, and, where you have consented, marketing messages. You can unsubscribe from marketing emails at any time using the unsubscribe link included in every marketing message.
  6. Security and fraud prevention: to detect and prevent fraudulent activity, enforce our Terms of Use, and protect the rights and safety of our users.
  7. Legal compliance: to comply with applicable laws and respond to lawful requests from courts, regulators, or law-enforcement authorities.
  8. Business operations: for quality assurance, staff training, and internal analytics.

6. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) applies, we process your personal data on the following legal bases:

  1. Contractual necessity: to provide the Service you have subscribed to.
  2. Legal obligation: to comply with applicable laws and regulatory requirements.
  3. Legitimate interests: for analytics, security, fraud prevention, and improving the Service, where such interests are not overridden by your fundamental rights.
  4. Consent: for certain marketing communications and the placement of non-essential cookies, which you may withdraw at any time.

7. How We Share Your Personal Data

We do not sell or rent your personal data. We share data only as described below:

7.1 Service Processors

We share data with the following third-party service providers, which process data on our behalf under data processing agreements and applicable privacy regulations:

  1. Firebase Analytics – app analytics and event tracking (Google LLC, https://firebase.google.com/support/privacy)
  2. Firebase Firestore / Realtime Database – user progress and content storage (Google LLC)
  3. Firebase Crashlytics – crash reporting and diagnostics (Google LLC)
  4. Firebase Remote Config – feature flag and configuration delivery (Google LLC)
  5. Google Analytics – web analytics (Google LLC, https://policies.google.com/privacy)
  6. Google Cloud Platform – cloud infrastructure and hosting (Google LLC)
  7. Meta (Facebook) SDK – campaign attribution and install measurement only (Meta Platforms, Inc., https://www.facebook.com/privacy/policy/). We transmit only anonymised, aggregated attribution signals (such as install and campaign performance events) to Meta. We do not share your habit data, sobriety progress, or any health-related behavioural data with Meta.
  8. Recurly – subscription management and recurring billing (Recurly, Inc., https://recurly.com/legal/privacy/)
  9. Stripe – payment processing for direct purchases (Stripe, Inc., https://stripe.com/privacy)
  10. Amazon Web Services (AWS) – cloud infrastructure (Amazon.com, Inc., https://aws.amazon.com/privacy/)

7.2 Platform Providers

If you subscribe through Apple App Store (Apple Inc.) or Google Play (Google LLC), your payment and subscription are managed by those platforms under their own privacy policies.

7.3 Legal and Regulatory Disclosures

We may disclose your data to courts, law-enforcement agencies, regulators, or other public authorities where required by law or to protect the legal rights, safety, or property of Milky Way Entertainment LLC, our users, or third parties.

7.4 Business Transfers

In the event of a merger, acquisition, sale of assets, or similar transaction, your personal data may be transferred to the successor entity. We will notify users via a notice on the Service if such a transfer occurs.

7.5 Authorised Disclosure

We may share your data with professional advisors (lawyers, accountants, auditors) and other parties you have expressly authorised.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve the Service. Categories include:

  1. Essential cookies: required for the Service to function (authentication, session management).
  2. Functional cookies: remember your preferences and login details.
  3. Analytics cookies: help us understand how users interact with the Service (e.g., Google Analytics). These collect aggregated, non-personally-identifying data.
  4. Marketing/attribution cookies: used to measure the effectiveness of our marketing campaigns. These are used only where you have provided consent or where permitted by law.

You can manage or disable non-essential cookies through your browser settings or via the consent mechanisms within the Service. Opting out of certain analytics tracking may reduce personalisation. For more information on managing cookies, visit www.allaboutcookies.org.

To opt out of Google Analytics tracking, you may install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

To opt out of interest-based advertising on mobile, enable 'Limit Ad Tracking' in iOS Settings > Privacy > Advertising, or 'Opt out of Ads Personalisation' in Android Settings > Google > Ads. You may also opt out via the Digital Advertising Alliance at https://optout.aboutads.info/ or the Network Advertising Initiative at https://optout.networkadvertising.org/

9. Payment Processing

All subscription purchases made directly on our platform are processed by Recurly and Stripe. Purchases made through mobile platforms are processed by Apple (App Store) or Google (Google Play). We do not collect, process, or store payment card numbers, bank account details, or other sensitive financial information. All payment data is handled exclusively by these PCI-DSS-compliant processors.

10. Data Retention

We retain your personal data for as long as you have an active account and for 24 months after you cease using the Service, unless a longer retention period is required by applicable law (for example, for financial records). After the applicable retention period, your data is securely deleted or anonymised. We may retain de-identified, aggregated data indefinitely for analytical purposes.

Closed or terminated accounts are retained for a minimum of two years for fraud-prevention and regulatory purposes.

11. Children’s Privacy

The Service is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. In compliance with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect information from children under the age of 13. If you believe we have inadvertently collected data from a minor, please contact us immediately at support@refuses.online with the subject line “COPPA Concern” and we will promptly delete such data.

12. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

  1. Encryption of data in transit (TLS/HTTPS) and at rest.
  2. Password protection and multi-factor authentication for system access.
  3. Regular security assessments and monitoring.
  4. Restricted staff access to personal data on a need-to-know basis.
  5. Confidentiality obligations for all personnel with access to personal data.

Despite these safeguards, no internet-based service can be guaranteed 100% secure. We cannot warrant the absolute security of data transmitted over the internet or wireless networks. If you believe your data has been compromised, please contact us immediately at support@refuses.online 

13. International Data Transfers

Milky Way Entertainment LLC is incorporated in the United States. Your data may be processed by us and our service providers in the United States and other countries that may have different data protection laws than your home jurisdiction. Where we transfer personal data from the European Economic Area (EEA) or the United Kingdom, we rely on appropriate safeguards, including European Commission-approved Standard Contractual Clauses. For further information, please contact us using the details in Section 17.

14. Your Privacy Rights

14.1 General Rights

Subject to applicable law, you have the right to:

  1. Access: request a copy of the personal data we hold about you.
  2. Correction: ask us to correct inaccurate or incomplete data.
  3. Erasure: request deletion of your personal data, subject to legal retention obligations.
  4. Restriction: ask us to limit how we use your data in certain circumstances.
  5. Portability: receive your personal data in a structured, machine-readable format.
  6. Objection: object to processing based on legitimate interests or for direct marketing.
  7. Withdraw consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email support@refuses.online with the subject line 'Privacy Request'. Please include your full name, the email address associated with your account, and a brief description of the right you wish to exercise. To protect your privacy, we will ask you to verify your identity before fulfilling the request typically by confirming your account email address or a recent transaction reference. We will respond within 30 days of receiving a complete request.

14.2 EEA and UK Residents

If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority. We encourage you to contact us first so we can try to resolve your concern directly.

14.3 California Residents (CCPA/CPRA)

California residents may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information is collected and disclosed, the right to delete personal information, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your California rights, contact us at support@refuses.online 

15. Automated Decision-Making and Profiling

We use automated processing to personalise in-app content recommendations and marketing communications based on your usage behaviour. This processing does not produce legal or similarly significant effects on you. If you have concerns about any such processing, you may object by contacting us at support@refuses.online.

16. Third-Party Websites and Services

The Service may contain links to external websites and services not operated by us. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party site you visit.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting a prominent notice on the Service or by sending an email to your registered address. The “Effective Date” at the top of this policy reflects the date of the most recent revision. Your continued use of the Service after such notification constitutes acceptance of the updated policy.

18. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact:

Milky Way Entertainment LLC

30 N Gould St Ste R

Sheridan, WY 82801, USA

Phone: +1 877 237 0608

Email: support@refuses.online

Website: https://refuses.online/refuse/