Privacy Policy

1. Data Controller

The data controller responsible for your personal data is: Alexander Alber Tömlingerstr. 21 81375 Munich, Germany Email: info@inzpyre.me

2. What Data We Collect

2.1 Account Data

When you create an account using Apple Sign-In or email-based authentication (magic link), we receive:

• Your Apple ID user identifier (a unique, anonymous token) — Apple Sign-In only
• Your name (if you choose to share it) — Apple Sign-In only
• Your email address (directly provided, or an Apple-generated relay address if you choose "Hide My Email")

2.2 Onboarding & Profile Data — Stored on your device only

During the onboarding questionnaire, you provide information such as age, fitness level, health goals, work schedule, dietary preferences, sleep habits, available fitness equipment, focus areas, priority ranking across 6 life categories, and wellbeing, energy, and concentration baselines.

Your full questionnaire response is stored exclusively in SwiftData on your iPhone and is never transmitted to our servers. When you use AI-powered plan generation, the relevant subset is sent ad hoc to Anthropic (Claude) via our Edge Function and not persisted server-side — see section 6.

2.3 Health Data (Apple HealthKit)

If you choose to connect Apple Health, Dopafy reads the following data from your device: daily step count, sleep analysis, workouts, nutrition data, mindful minutes, resting heart rate and HRV, weight and body fat percentage.

HealthKit data is read locally on your device. It is only transmitted to our servers if you explicitly grant consent for AI-powered health analysis (see section 6).

2.4 Usage Data on Our Servers

The following operational data is stored on our servers (Supabase, Ireland):

• Routine completion status and streaks
• Dopamine score history (aggregated daily numeric)
• Achievement unlocks
• Energy-driver entries (category + intensity)
• Weekly/daily plan structure
• Anonymized weekly usage snapshots — see 2.15

2.5 Bad-Habit Check-ins — Stored on your device only (GDPR Art. 9)

Bad-habit check-ins capture sensitive health information (smoking, alcohol, drugs, pornography, social media excess, etc.) and are explicitly classified as special category data under GDPR Article 9. Stored exclusively in SwiftData on your iPhone — never transmitted to our servers.

Free-text notes, daily wins, daily learnings, and tomorrow's priority remain on-device permanently. Detailed per-day entries are kept for 90 days, then automatically rolled up into weekly category counts (kept for 12 months) and finally monthly aggregates (kept indefinitely at low resolution). Only the category counts ever flow into AI pattern analysis — never the free-text fields.

2.6 Weekly Reflections — Stored on your device only

Weekly reflections capture wellbeing, concentration, and energy scores (1–10) plus free-text energizers and drains. All of it stays on your iPhone. Free-text fields are automatically erased after 90 days; numeric scores remain so long-term trend analysis still works. When you use AI pattern analysis, only the numeric scores are sent to Anthropic.

2.7 Career Check-ins — Stored on your device only

If you use the Career Check-in feature, we capture satisfaction, fun, learning curve, and stress scores (1–10) plus free-text problem descriptions and reflection notes. All on-device only. Numeric scores retained; free-text fields auto-erased after 90 days. Never transmitted to Anthropic or any third party.

2.8 Goals — Stored on your device only

If you use the Goals module, goal titles, descriptions, and types, milestones and progress entries, deadlines and completion status stay in SwiftData on your iPhone. Goal titles and notes can be highly personal, so we keep them entirely off our servers.

2.9 Calendar Integration (Local Only)

Dopafy can write your routines as events to your iOS Calendar via EventKit. This data stays entirely on your device and is never transmitted to our servers.

2.10 Technical Data

We automatically collect minimal technical data required to operate the service: device type and OS version, app version, preferred language.

2.11 Diagnostic Data (MetricKit)

Apple's MetricKit framework provides crash reports and performance metrics from iOS to the app. We store these locally in the App Group container for in-app diagnostics. We do not transmit MetricKit data to our servers, Supabase, or Anthropic. iOS independently sends crash reports to Apple via the standard system mechanism. The data is not linked to your account.

2.12 Data We Do Not Collect

• No third-party analytics or tracking SDKs (no Mixpanel, PostHog, Google Analytics, Firebase Analytics, Amplitude, etc.)
• No location data
• No payment information (handled entirely by Apple)
• No advertising SDKs or data sharing with advertisers
• No transmission of screen time duration, app usage statistics, or the names of apps you select for blocking — all Screen Time data stays on your device

2.13 External Links

The app references the Arthur Brooks Happiness Scale (learn.arthurbrooks.com) as an educational resource within the Weekly Reflection feature. This link opens in Safari; we do not share any data with this website.

2.14 Screen Time & Digital Wellness Data (Local Only)

If you enable the Screen Time management features, the following data is stored locally on your device in the App Group container: opaque app and category tokens from Apple's Family Controls framework, Digital Sunset schedule settings, daily screen time limit settings and threshold data, temporary unlock override status and expiry timestamps, unlock wait-timer configuration.

All Screen Time data remains entirely local in the App Group container shared between the main app and its on-device extensions. No Screen Time data is transmitted to our servers, Supabase, or Anthropic. The opaque tokens cannot be used to determine the names of your apps.

Dopafy uses four on-device App Extensions: DeviceActivityMonitor (monitors thresholds and sunset schedules), DeviceActivityReport (generates usage reports shown in the app), ShieldConfiguration (customizes blocking-screen appearance), ShieldAction (handles interactions with blocking screens, e.g. unlock requests).

2.15 Anonymized Weekly Usage Snapshots — Opt-out available

Once per ISO week, the app posts one bucketed summary to our backend to help us understand macro-level retention and feature impact. The snapshot contains only the following bucketed values:

• Routines completed this week (none / 1–5 / 6–15 / 16–30 / 31+)
• Current longest streak (none / 1–7 / 8–30 / 31+ days)
• Wellbeing, energy, and concentration self-rating averages over the last four weekly reflections, each as low/mid/high — never the raw 1–10 scores
• Whether you have ever filled in a weekly reflection (yes/no)
• Whether Digital Sunset and Screen Time features are active (yes/no each)
• ISO week and year of the snapshot
• App version, iOS major version, language code, country code from device locale

What is deliberately not in the snapshot: your user ID, email, Apple ID, device ID, IP address, free text, exact scores, exact dates, routine titles, goal contents.

Where it lives: the analytics_snapshots table on Supabase (Ireland, eu-west-1), with Row-Level Security enabled — only a server-side function with the service role can write, and it discards the authenticated user identity before inserting.

Legal basis: GDPR Art. 6(1)(f) — legitimate interest in macro-level product improvement. Because the snapshot is anonymous and cannot be traced back to you, it is technically not personal data under GDPR Art. 4(1); we describe it here for transparency.

Opt-out: open the app → Profile → Privacy and toggle "Share anonymized usage data" off. From the next snapshot interval onward, no further data is sent.

3. How We Use Your Data

We use your personal data for the following purposes:

• Providing the service: generating personalized daily and weekly routines, meal suggestions, and workout plans based on your questionnaire responses
• AI plan generation: your onboarding data is sent to Anthropic (Claude AI) via a Supabase Edge Function to create personalized plans
• AI health analysis (with consent): health summaries, scores, habit entries, weekly reflections, and career baselines sent to Anthropic for personalized insights (see section 6)
• AI meal suggestions: your dietary preferences sent to Anthropic to generate personalized meal recommendations
• Progress tracking: calculating your score, maintaining streaks, tracking goal progress, and providing statistics
• Calendar integration: writing routine events to your local iOS Calendar (data stays on device)
• Notifications: sending routine reminders, check-in notifications, and goal reminders (only with your permission)
• Digital wellness: managing app blocking schedules, screen time limits, and temporary unlock flows (processed locally on your device)
• Service improvement: understanding usage patterns to improve the app's features
• Anonymized usage statistics: see section 2.15, opt-out in Profile → Privacy
• Account management: managing your subscription and providing customer support

4. Legal Basis for Processing (GDPR Art. 6)

• Contract performance (Art. 6(1)(b) GDPR): necessary to provide the app's services as outlined in our Terms of Service, including AI-generated plan creation and the Screen Time features you actively configure
• Consent (Art. 6(1)(a) GDPR): for push notifications, optional data sharing during onboarding, and AI-powered health data analysis — withdrawable at any time
• Legitimate interest (Art. 6(1)(f) GDPR): for service improvement, security, and fraud prevention

5. Data Storage & Security

Server-stored data (account, plan structure, routine completions, streaks, score history, achievements, energy-driver entries, anonymized weekly snapshots) is hosted by Supabase Inc. on AWS infrastructure in Ireland (eu-west-1) — entirely within the European Union.

Local-only data (questionnaire response, bad-habit check-ins, weekly reflections, career check-ins, goals, wellness configuration, all free-text reflections) is stored exclusively in SwiftData on your iPhone with complete-until-first-user-authentication file protection. iOS automatically backs up this store via iCloud (encrypted by Apple).

• Encryption of data in transit (TLS/SSL via Apple App Transport Security)
• Encryption at rest, both on Supabase's Postgres infrastructure and on your iOS device
• Row-level security policies on every server table
• Secure authentication via Apple Sign-In and email magic link
• JWT-based authentication on all Edge Functions
• Sensitive identifiers (auth tokens) stored in the iOS Keychain with accessibleWhenUnlockedThisDeviceOnly protection
• Input sanitization on all AI-powered Edge Functions to prevent prompt-injection
• Rate limiting on AI and destructive endpoints
• Service-role and AI API keys held only in Edge Function environment variables, never in the iOS app bundle
• Automatic 90-day redaction of free-text fields in local weekly reflections and career check-ins

6. AI-Powered Analysis & Consent

6.1 Plan Generation

During onboarding, your questionnaire responses are sent to Anthropic (Claude AI) via a Supabase Edge Function to generate your personalized routine plan. This processing is covered by the legal basis of contract performance. No HealthKit data is included in this step.

6.2 Meal Suggestions

Your dietary preferences and restrictions are sent to Anthropic (Claude AI) to generate personalized meal recommendations. Legal basis: contract performance.

6.3 Health & Behavioral Data Analysis (Requires Explicit Consent)

If you choose to use the AI health analysis feature, the following aggregated, anonymized data is sent to Anthropic (Claude AI): health summaries (steps, sleep, workouts), nutrition summaries, vitals (resting heart rate, HRV), body metrics (weight, body fat), scores, bad-habit category counts (never the free-text fields), routine completion data, weekly reflection numeric scores (never the free-text notes), energy-driver entries, and your priority rankings.

What is never sent to Anthropic: your name, email, Apple ID, any free-text from weekly reflections, bad-habit free-text (notes, daily wins, daily learnings, tomorrow's priority), career check-in problem text, goal progress notes.

Before the first AI analysis, you will see an explicit consent dialog explaining exactly this. You must actively agree before any data is transmitted. You can withdraw consent at any time in Settings → Apple Health → "AI Data Analysis Consent".

6.4 How Anthropic Processes Your Data

• Data is processed per request; per Anthropic's API policy it is retained for at most 30 days for trust & safety monitoring, then deleted
• No personally identifiable information is sent to Anthropic
• Anthropic does not use API inputs for model training (default API settings)
• Data is transmitted via TLS-encrypted connections
• Transfers to the USA are covered by Standard Contractual Clauses and the EU-US Data Privacy Framework
• We have a Data Processing Agreement (DPA) with Anthropic Inc.

7. Data Sharing & Subprocessors

We do not sell, rent, or trade your personal data. We share data only with the following subprocessors, strictly for operating the app:

• Supabase Inc. — Backend infrastructure, Postgres database, authentication, and Edge Functions. Hosting on AWS Ireland (eu-west-1), fully within the EU. DPA in place.
• Apple Inc. — Authentication via Apple Sign-In, email magic link, payment processing via the App Store, push notifications via APNs, HealthKit data access on device, Family Controls framework for on-device Screen Time management, iCloud Backup of the local SwiftData store. DPA via App Store agreement.
• Anthropic PBC — AI-powered plan generation, meal suggestions, and pattern analysis (consent-only for the latter). Transmitted via Supabase Edge Functions; payloads are not persisted by us. Retains inputs at most 30 days for trust & safety, does not train on inputs, bound by a DPA. US transfer covered by SCCs and the EU-US Data Privacy Framework.
• Netlify Inc. — Static hosting for our landing page and privacy policy. No user data is transmitted to Netlify.

We do not share your personal data with any other third parties or advertisers. We do not use any third-party analytics SDKs. The anonymized weekly snapshots described in section 2.15 are stored on our own Supabase instance and never shared with anyone.

9. Data Retention

Retention differs by category and storage location. Server-side data persists for the lifetime of your account; local-only data follows a tiered retention model:

• Account data (server): retained until you request account deletion
• Routines, completions, streaks, scores (server): retained for the duration of your account
• Questionnaire response (local-only): retained until account deletion
• Goals + progress (local-only): retained until you delete the goal or your account
• Bad-habit check-ins (local-only, GDPR Art. 9): per-day detail kept 90 days, then rolled up to weekly category counts (12 months), then monthly totals (indefinitely, low resolution)
• Weekly reflections (local-only): numeric scores kept indefinitely; free-text auto-deleted after 90 days
• Career check-ins (local-only): numeric scores kept indefinitely; free-text auto-deleted after 90 days
• AI analysis results: stored locally on your device; not retained on our servers; Anthropic retains inputs for at most 30 days
• Screen Time data: stored locally only; automatically cleared when you disable the feature, revoke Family Controls authorization, or delete your account
• Anonymized weekly snapshots (server): retained indefinitely for longitudinal trend analysis; unaffected by account deletion — stop new snapshots via the opt-out in section 2.15

When you delete your account through the app, all your server-side data is permanently removed. A 30-day grace period applies for accidental deletions, after which the server records are unrecoverable. Local-only data is removed immediately and cannot be recovered. Statutory retention obligations take precedence where applicable.

10. Your Rights Under GDPR

As a data subject in the European Union, you have the following rights:

• Right of access (Art. 15 GDPR): request a copy of your personal data at any time
• Right to rectification (Art. 16 GDPR): request correction of inaccurate data
• Right to erasure (Art. 17 GDPR): request deletion of your personal data
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR): export your data directly from the app in a structured, machine-readable JSON format via Settings, or request it by contacting us
• Right to object (Art. 21 GDPR) to processing based on legitimate interests
• Right to withdraw consent (Art. 7(3) GDPR), where processing is based on consent

To exercise any of these rights, please contact us at info@inzpyre.me. We will respond within 30 days.

Note on anonymized snapshots: the rights of access, rectification, and erasure (Art. 15–17 GDPR) apply to personal data that can be linked to you. The anonymized weekly snapshots described in section 2.15 contain no identifier and cannot be tied to your account, so technically these rights do not apply to them. The effective control is the opt-out toggle in Settings.

You also have the right to lodge a complaint with a supervisory authority: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) Promenade 18, 91522 Ansbach, Germany www.lda.bayern.de

11. Children's Privacy

Dopafy is not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe that a child under 16 has provided us with personal data, please contact us immediately at info@inzpyre.me, and we will take steps to delete such data.

12. Push Notifications

Dopafy may send push notifications for routine reminders, check-in prompts, goal reminders, and motivational messages. You can enable or disable notifications at any time through your device settings. We use Apple Push Notification service (APNs) to deliver these notifications.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last updated" date at the top of this page
• Notify you through the app where appropriate
• Provide a reasonable notice period before changes take effect

14. Contact

If you have any questions about this Privacy Policy or your personal data, please contact us:

Alexander Alber (sole proprietor) Tömlingerstr. 21 81375 Munich, Germany Email: info@inzpyre.me Website: www.dopafy.app