Privacy Policy

Last updated: August 2026

1. Data Controller (Impressum)

Angaben gemäß § 5 DDG

For questions about this Privacy Policy or your personal data, contact us at [email protected].

2. Website — Beta Signup Email

When you sign up for beta access on our website, we collect your email address. We use it solely to contact you about Anima Cycle beta access and launch updates. We do not share it with third parties or use it for advertising.

Legal basis: your explicit consent given at signup (Art. 6(1)(a) GDPR). You may withdraw consent at any time by emailing [email protected].

Email addresses are stored via Resend (resend.com/privacy), an email delivery service.

3. App Data Stored on Your Device

All health-related data is stored exclusively on your device and is never uploaded to our servers:

• Cycle dates and settings (cycle length, period length)
• Daily mood, energy, and symptom logs
• Journal entries
• Notification preferences
• Onboarding answers (goals, work style)

We have no access to this data. It remains on your device until you delete it.

Anima Cycle does not use Apple HealthKit and does not read from or write to the Health app.

Optional iCloud Sync. Anima Cycle includes an optional iCloud Sync feature that backs up your cycle data across your own devices, using your personal iCloud account (Apple's storage, not our servers). It is off by default — you must turn it on yourself in Settings → Data & Privacy. When off, your data never leaves your device. When on, we still have no access to it — it stays inside your private iCloud account, encrypted end-to-end by Apple, and syncs only between devices signed into that account.

4. Circle — Sharing with a Partner or Friend

Anima Cycle includes an optional feature called Circle that lets you share a simplified summary of your cycle with one partner (free) or friend (requires a Premium subscription) of your choosing. Circle is off unless you actively create an invite — nothing is shared until you do.

What is shared. Circle never shares your raw daily entries, journal, or full symptom list. It shares only a derived, softened summary: your current cycle phase, cycle day, cycle length, period length, a general mood and energy level, a generalized "comfort signal" (e.g. "low energy" rather than your specific symptoms), what you've asked for today (e.g. "just listen"), a short tip, and your last 7 logged days of mood/energy. This summary is rebuilt from your data each time it syncs and replaces the previous one — no separate history beyond 7 days is kept.

How it works technically. Circle runs entirely on Apple's iCloud (CloudKit) — no Anima server is involved. You generate a one-time invite code (valid for 1 hour); the person you invite enters it in the app; you then explicitly approve or decline their request before anything is shared. Once approved, your summary lives in a private, read-only CloudKit share (not publicly accessible) that only the approved person can open from their own iCloud account. We have no access to this data at any point.

Who you invite. You are responsible for choosing who you invite into your Circle and for the accuracy and sensitivity of what you choose to share. The person you invite must also use the Anima Cycle app to view your summary and is subject to the age requirement in Section 15. Once information reaches their device, it is stored and used under their own control, in the same way your data is stored under yours.

Notifications. If you invite someone, their device may generate local notifications (e.g. phase changes, period reminders, your "ask" for the day) based on the last summary it received. These notifications are generated locally on their device and are not routed through any server of ours.

Authorization expires after one year. When you approve someone's request to join your Circle, you're shown exactly what will be shared with them and must explicitly confirm before anything is sent. That authorization is valid for up to one year; before it lapses we show you a reminder to renew it. If you don't renew, sharing is designed to stop automatically the next time you open the app after expiration — though since Circle has no server of its own, this check only runs when you open the app, so it is best-effort rather than an instant cutoff.

Revoking access. You can stop sharing at any time ("Stop sharing"), and the recipient can leave your Circle at any time ("Leave Circle") — both immediately revoke CloudKit read access. Apple's infrastructure may take a short time to fully purge the underlying record after revocation, consistent with standard CloudKit deletion behavior.

Legal basis: your explicit, opt-in, itemized authorization to share (Art. 6(1)(a) and, since this includes health data, Art. 9(2)(a) GDPR), renewed at least annually. You may withdraw this consent at any time by revoking access as described above.

5. Sensitive Health Data — No Sale, No Sharing

Anima Cycle collects menstrual cycle and reproductive health data. This data is stored on your device (and, only if you opt in to iCloud Sync, within your own private iCloud account — see Section 3) and is never:

• Sold to any third party
• Shared with advertisers or data brokers
• Used for targeted advertising
• Disclosed to law enforcement without a valid legal order
• Transferred to our servers or any third-party cloud service (the optional iCloud Sync feature, off by default, syncs only within your own private iCloud account — see Section 3; the optional Circle feature shares only a derived summary, and only with a partner or friend you explicitly invite and approve — see Section 4)

We are committed to protecting your reproductive health information. Your cycle data belongs to you alone.

6. Legal Basis for Processing (GDPR Art. 13)

We process your data on the following legal bases:

• Cycle and health data (Art. 6(1)(a) GDPR) — based on your explicit consent given during onboarding
• Special category health data (Art. 9(2)(a) GDPR) — based on your explicit consent given during onboarding
• Circle sharing (Art. 6(1)(a) and Art. 9(2)(a) GDPR) — based on your explicit, itemized authorization at the time you approve a specific person's request, valid for up to one year and renewable
• Analytics (Art. 6(1)(a) GDPR) — based on your explicit opt-in consent during onboarding

7. Analytics (Optional)

If you opt in during onboarding, Anima Cycle uses PostHog to collect anonymous usage analytics — such as which features you use and how you navigate the app. This data is identified only by a random device ID (no name, email, or health data is ever included).

Legal basis: your explicit consent (Art. 6(1)(a) GDPR).

You can withdraw consent at any time in Settings → Privacy & Data.

PostHog's privacy policy: posthog.com/privacy

8. Cookies

Our website uses a small number of strictly necessary cookies. We do not use advertising or tracking cookies.

• Cloudflare security cookies (__cf_bm, cf_clearance) — set by Cloudflare, our infrastructure provider, for bot protection and security. These are technically necessary. __cf_bm expires after 30 minutes of inactivity; cf_clearance expires after 30 minutes by default. Cloudflare's privacy policy: cloudflare.com/privacypolicy

No analytics cookies are set unless you have opted in to analytics in the app. No advertising or profiling cookies are used.

9. Third-Party Services

PostHog (analytics, opt-in only) — processes anonymous usage events on EU servers (Frankfurt, Germany). No other third-party SDKs receive your data.

Apple iCloud/CloudKit (optional iCloud Sync and optional Circle sharing) — Apple acts purely as infrastructure: your synced or shared data stays inside your (and, for Circle, your invited partner's or friend's) private iCloud account. We have no access to it and do not operate any server in this data path.

No advertising SDKs, no tracking frameworks, no data brokers.

PostHog is a US-based company. Although your data is stored on EU servers, transfers to PostHog are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an adequate level of data protection.

10. Data Retention

Local data remains on your device until you delete it via "Reset all data" in Settings.

Circle summary data lives in CloudKit only while sharing is active; revoking access ("Stop sharing" or "Leave Circle") removes it, subject to Apple's normal deletion propagation time. Even without manual revocation, sharing authorization expires after one year unless renewed — see Section 4.

Anonymous analytics events (if opted in) are retained by PostHog for 12 months.

Your email address (from beta signup) is deleted once you withdraw consent or upon request.

11. Your Rights (GDPR)

If you are in the EU/EEA, you have the following rights:

• Right of access — you can view all your data directly in the app
• Right to erasure — delete all local data via Settings → Reset all data, and revoke any Circle sharing via "Stop sharing" or "Leave Circle". To remove anonymous analytics, contact us at [email protected]
• Right to data portability — your health data is stored locally on your device and is always under your direct control. Analytics data held by PostHog is pseudonymous (random device ID only) and not linked to your identity, which limits portability in practice; you may contact us to request what we can provide
• Right to rectification — request correction of inaccurate personal data we hold (applies to analytics data; local health data can be edited directly in the app)
• Right to restriction of processing — request that we limit how we process your data in certain circumstances, e.g. while a dispute is being resolved
• Right to withdraw consent — opt out of analytics at any time in Settings → Privacy & Data, or revoke Circle sharing at any time
• Right to object — contact us at [email protected]
• Right to lodge a complaint — you have the right to lodge a complaint with your local supervisory authority

We do not hold your health data on our servers, so there is nothing to access or transfer from our side.

12. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority.

Germany: Bundesbeauftragter für den Datenschutz und die Informationsfreiheit (BfDI) — www.bfdi.bund.de

For other EU countries, please contact your national data protection authority.

13. California Residents (CCPA) — Do Not Sell My Personal Information

We do not sell personal information. California residents have the following rights under the California Consumer Privacy Act (CCPA):

• Right to notice — you have the right to know what categories of personal data are collected and for what purpose.
• Right to access / right to know — you may request information about the personal data we have collected about you in the past 12 months, including its sources, the business purpose, and any third parties with whom it is shared.
• Right to delete — you may request deletion of personal data we hold. Since all health data is stored locally on your device, you can delete it at any time via Settings → Reset all data. For analytics data (if opted in), contact us at [email protected].
• Right to opt out of sale — we do not sell your personal data to any third party, under any circumstances.
• Right to non-discrimination — we will not discriminate against you for exercising any of your CCPA rights. You will receive the same level of service regardless.

To exercise any of these rights, contact us at [email protected]. We will respond within 45 days.

14. Other U.S. State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Maryland, or another U.S. state with a comprehensive consumer privacy law, you have rights similar to those in Sections 11 and 13: to confirm whether we process your personal data and access it, to correct inaccuracies, to delete your personal data, to data portability, and to opt out of the sale of personal data, targeted advertising, and profiling that produces legal or similarly significant effects. We do not sell personal data, do not use it for targeted advertising, and do not perform this kind of profiling — so these opt-out rights are, in effect, already honored by default. To exercise any right under this section, contact us at [email protected]; we will not discriminate against you for doing so.

Washington and Nevada residents: these two states have separate laws specifically covering "consumer health data," including reproductive and sexual health information — see our Consumer Health Data Privacy Policy for the disclosures those laws require, including how the optional Circle feature is treated.

15. Age Requirement

Anima Cycle is intended for users aged 16 and older. We do not knowingly collect data from users under 16 years of age. This also applies to anyone you invite into your Circle — see Section 4.

16. Data Deletion

You can permanently delete all local data at any time using "Reset all data" in Settings. This action is irreversible.

17. Data Security

Your health data never leaves your device and is protected by your device's built-in security (encryption at rest, device passcode/biometrics). We do not have access to this data.

For server-side components (PostHog analytics, if opted in), all data is transmitted over encrypted connections (TLS) and stored on PostHog's EU servers in Frankfurt, Germany. We apply industry-standard security practices to any data we do process.

No method of electronic storage or transmission is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If we become aware of a security breach affecting your personal data, we will notify affected users and the relevant authorities as required by applicable law — including, in the EU, the relevant supervisory authority within 72 hours under GDPR Art. 33 and affected users under Art. 34, and, in the United States, in accordance with the FTC Health Breach Notification Rule and applicable state breach-notification laws.

18. Business Transfer

If Anima Cycle is involved in a merger, acquisition, asset sale, or other business transfer, any analytics data we hold (anonymous usage events from opted-in users) may be transferred as part of that transaction. We will notify you via a notice within the app before such data becomes subject to a different privacy policy.

Your health data is stored exclusively on your device and is not part of any such transfer — we do not hold it on our servers.

19. Do Not Track (CalOPPA)

Anima Cycle does not track your activity across third-party websites or applications over time for advertising purposes. We do not respond to browser "Do Not Track" (DNT) signals, as we do not engage in the type of cross-site tracking that DNT is designed to address.

If you have opted in to analytics, you can withdraw consent at any time in Settings → Privacy & Data.

20. Changes to This Policy

We may update this policy from time to time. Significant changes will be communicated within the app. Where processing is based on your consent (e.g. analytics, Circle sharing), material changes to how we process that data will require a fresh consent — continued use alone will not be sufficient.