Privacy policy
PLACEHOLDER, not for release.
Who we are
The provider of Ease My Mind (the app) is the person named in the Impressum: [PLACEHOLDER NAME, PLACEHOLDER ADDRESS, placeholder@example.invalid]. We have no data protection officer. [TO DECIDE: confirm with a lawyer.]
In short
What you tell the app stays on your iPhone. If you switch on cloud AI, a check-in is sent to get a suggestion, and it is not stored on the way. The app has no accounts, no tracking and no advertising. The app is for people aged 16 and over.
What stays on your phone
Your check-ins, sessions, reflections, favorites, preferences, parked thoughts and your consent record stay on this device. So does a copy of the last request that was sent, so you can see it under "What was shared?". Deleting the app removes all of it. A "Delete everything" option and an export of your data are planned and not built yet. [TO DECIDE: update this once they exist.]
What is sent when cloud AI is on
Only if you switch on cloud AI, and only with your explicit consent, the app sends a request to get a suggestion. It holds your check-in (chips, strength and optional text, exactly as you wrote it), a short summary of your history and your preferences. It also carries your installation key and proof of your subscription. The request is answered and not stored. The answer is text generated by an AI. With cloud AI off, nothing like this leaves your phone, and the app suggests practices on the device.
If a check-in shows signs of a crisis, the app shows care and local help instead of a practice. Nothing of that request is kept.
Who receives data
Apple: Private Cloud Compute may answer a request on supported devices; Apple also runs the App Store, your purchases and the check that the app is genuine. Mistral, in the EU, answers requests that go through our relay; we agree with Mistral that it keeps nothing and does not train on them. [TO DECIDE: confirm once the data processing agreement with Mistral is signed.] Scaleway, in Paris, hosts our relay and its key store. If you contact support, Crisp would handle the message you send. [TO DECIDE: Crisp's role, data location, agreement and the form of contact (Q-048).] [TO DECIDE: status of the data processing agreements with Mistral, our hosting and Crisp.] Website hosting: statichost.eu, in Sweden, serves these legal pages; its access logs may hold your IP address when you visit them. [TO DECIDE: read statichost.eu's log content, retention and data processing agreement before release.]
We do not sell data and we share it with no one else.
What our relay keeps
A random key for your installation and a few counters, so the relay can recognize genuine apps and apply a daily limit. We don't link it to you. Like any server, the relay sees your IP address while the connection is open; we don't store it. It expires 30 days after last use. Logs hold counts of status codes, timings and tokens, never your text or your IP address, and are kept for 7 days. [TO DECIDE: confirm these numbers before release.]
Why we may process it
Your explicit consent for check-in content sent to the cloud (GDPR Art. 9(2)(a) and 6(1)(a)). Our legitimate interest in keeping the relay safe and affordable (Art. 6(1)(f)). Contract, for checking your subscription (Art. 6(1)(b)). [TO DECIDE: legal bases to be confirmed by a lawyer.]
Transfers outside the EU
The relay and Mistral process in the EU. Apple's processing is covered by Apple's terms. [TO DECIDE: how to describe Apple's role.]
Your rights
You can ask for access, correction, deletion, restriction and portability, and you can object to processing based on legitimate interest. Most of your data is only on your phone, where you will be able to export and delete it yourself once those options are built. Because we don't link the relay's key to you, we may not be able to find it for you. You can write to us at the email in the Impressum.
How to contact us
The controller is the provider named in the Impressum. Contact: [PLACEHOLDER: contact email or address for data protection requests].
How long data is kept
On your phone, your data stays until you delete it or remove the app. Your consent record is also on the device and is removed with the app. The copy for "What was shared?" is replaced when a later request gets a final answer that isn't a crisis, and a request with a crisis answer is never kept. The relay's key expires 30 days after last use, and its logs are kept for 7 days. [TO DECIDE: confirm the retention periods before release.]
Do you have to provide data?
No. The app works without sending anything. Cloud AI is optional, and without it the app suggests practices on your device.
Automated decisions
The app makes no automated decisions with legal or similarly significant effects. AI output is generated text; it only suggests practices from our library, and you decide.
Withdrawing consent
Switch off cloud AI in settings at any time. It takes effect at once and does not affect what happened before.
Complaints
You can complain to a data protection supervisory authority, for example in the country where you live or work.
Age
The app is for people aged 16 and over. You confirm this yourself when you start; we don't check it. [TO DECIDE: whether a self-declared age is enough under GDPR Art. 8.]
No accounts, no tracking
No accounts, no advertising IDs, no tracking tools and no usage telemetry in this version. Crash reports reach us only if you share analytics in iOS settings. Apple collects them under its own terms and passes them on to us in aggregate.
Language
These texts are in English only for now. [TO DECIDE: whether English-only texts are enough for users in Germany; see the legal research in the trust docs.]
Changes
If this policy changes, the version and date above change. [TO DECIDE: how users are told of material changes.]