Consumer Health Data Privacy Policy

Last updated: August 2026 · Applies to Washington and Nevada residents

This notice supplements our general Privacy Policy and is published separately, as required by the Washington My Health My Data Act (RCW 19.373) and Nevada's consumer health data law (NRS 603A). It covers "consumer health data" as those laws define it — information that identifies your past, present, or future physical or mental health status, including reproductive and sexual health information. Everything in our general Privacy Policy still applies; this page adds the specific disclosures these two laws require.

1. Consumer Health Data We Collect

Through your direct use of the Anima Cycle app, we collect:

Cycle dates and settings (cycle length, period length)
Daily mood, energy, and symptom logs
Journal entries
Onboarding answers related to your goals and health context
If you use the optional Circle feature: a derived summary built from the above (cycle phase, cycle day, cycle length, period length, general mood/energy, a generalized comfort signal, what you've asked for that day, and your last 7 logged days of mood/energy) — see our Privacy Policy, Section 4 for full detail

None of this data is stored on our servers or accessible to us — Anima Cycle has no backend. It lives only on your device. If you turn on the optional iCloud Sync feature, it also syncs across your own devices through your private iCloud account, purely so your data follows you between your iPhone and iPad — we still have no access to it (see Privacy Policy, Section 3). The only way any of this data leaves your device at all is the optional Circle feature described below, and even then only a limited derived summary, only with someone you explicitly invite and approve.

We do not collect consumer health data through Apple HealthKit, and we do not use location data of any kind — see Section 6.

2. Purpose of Collection

This data is processed automatically, on your device, to provide the app's core functionality: cycle tracking, predictions, and insights. We have no access to it and are not involved in that processing. If you choose to use Circle, the app additionally builds a derived subset of it, on-device, into the summary shared with the partner or friend you invite — again without passing through us. If you opt in during onboarding, an anonymized, non-health usage signal (see Section 4) is also processed for product analytics.

3. Sources of Consumer Health Data

Directly from you, through what you log in the app. We do not purchase, license, or otherwise obtain consumer health data about you from any other source.

4. Third Parties and Affiliates We Share Consumer Health Data With

We do not sell consumer health data, and we do not share it for advertising, marketing, or any purpose unrelated to providing the app to you. The only disclosure of consumer health data that exists in Anima Cycle is:

A partner or friend you specifically invite through Circle. This happens only if you actively generate an invite, and only after you explicitly approve that specific person's request to join. You choose whether to enable this at all, whom to invite, and can revoke access at any time (Section 5 explains how consent is captured for this).

Beyond that single case, no consumer health data is shared with anyone:

Apple (iCloud/CloudKit) acts purely as infrastructure for both the optional iCloud Sync feature and Circle. Your data is routed through Apple's servers to reach your own devices, or the device of a partner/friend you've approved, but Apple is not a party we disclose data to for its own purposes — it never leaves your (or your invitee's) private iCloud account.
PostHog (our analytics provider, only used if you opt in) never receives consumer health data. It receives anonymous product-usage events only — which screens you open, which features you tap — identified by a random device ID, with no cycle dates, symptoms, mood, journal content, or Circle data of any kind included.

5. How We Obtain Consent Before Sharing Through Circle

Before any consumer health data is shared with a partner or friend, all of the following must happen inside the app:

You generate a time-limited invite code and choose to send it to a specific person.
After they enter that code and identify themselves, you are shown a dedicated authorization screen — separate from any other consent you've given in the app — naming that specific person, listing exactly which categories of data will be shared with them, and stating the purpose. Nothing is shared until you explicitly confirm this screen; declining or leaving it unanswered means nothing is shared.
Your authorization is valid for up to one year from the date you confirm it. Before it lapses, we show you a renewal prompt; if you don't renew, the share is designed to be cut off automatically the next time you open the app after expiration (see the enforcement note below).
You can revoke access at any time via "Stop sharing," and the person you invited can leave via "Leave Circle" at any time — both immediately cut off further data sharing.

Enforcement note: Anima Cycle has no backend server of its own — Circle runs entirely peer-to-peer through Apple's iCloud (CloudKit), as described in our Privacy Policy, Section 4. The one-year expiration is enforced by the app itself, checked each time you open it. This means enforcement is best-effort rather than a server-side hard cutoff: if you don't open the app again after your authorization lapses, the automatic cutoff won't run until you do. You can always revoke access manually at any time regardless of this, from either side of the connection.

6. No Geofencing

Anima Cycle does not use location data, GPS, or any other geolocation capability anywhere in the app, and does not implement geofencing around any healthcare facility, reproductive or sexual health facility, or mental health facility, as addressed by RCW 19.373.030. We have verified this directly against the app's source code, not just its stated design.

7. No Sale of Consumer Health Data

We do not sell consumer health data, as "sale" is defined under RCW 19.373 and NRS 603A, under any circumstances.

8. Your Rights

You have the right to:

Confirm and access whether we are collecting, sharing, or selling your consumer health data, and to access that data — you can already see all of it directly in the app.
Withdraw consent to our collection or sharing of your consumer health data — for Circle, this means revoking access as described in Section 5; for the app generally, this means using "Reset all data" in Settings.
Request deletion of your consumer health data, including data we've shared with a partner or friend through Circle (which we will do by revoking their access). We have no processor that holds any copy of your consumer health data to begin with — see Section 1.
Appeal a denial of a request under this notice by contacting us at the address below; we will respond to your appeal within a reasonable time.

To exercise any of these rights, contact us at [email protected]. We aim to respond within 45 days, consistent with how we handle privacy requests generally.

9. Changes to This Notice

We may update this notice as our practices change or as guidance under these laws develops. Material changes will be reflected here with an updated date, and, where they affect how Circle sharing works, communicated within the app.

10. Contact

Viktoriia Ponomarova · Grashofstraße 19, 80995 München, Germany · [email protected]