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Privacy Policy

For the Mindful Pause iOS app · Draft of July 4, 2026 · Effective date: [to be set at publication]

Draft — not yet in force. This document was prepared to accurately describe the app’s actual data flows, but it is not legal advice. Placeholders marked [like this] must be filled in, and the whole document should be reviewed by a qualified professional before publication.

The short version

Mindful Pause has no user accounts and no server of its own. Your pauses, streaks, favorites, reflection answers, and settings are stored locally on your iPhone and are deleted when you delete the app. Data leaves your device in exactly two cases: when you actively use an AI feature (a request is sent to OpenAI), and for install/purchase attribution analytics (AppsFlyer and the Facebook SDK, with tracking gated by iOS App Tracking Transparency). That’s the whole picture; the details follow below.

1. Who is responsible (data controller)

[Full name / company name]
[Street and number]
[Postal code, city, country]
Email: [contact email address]

2. Data stored on your device only

The app stores the following locally on your iPhone (and, for the home-screen widget, in a shared storage area that only the app and its widget can access):

  • Your completed pauses and exercise history, and the streaks calculated from them
  • Favorited quotes and exercises
  • The goals and challenges you select during onboarding
  • Reflection answers you write in the app
  • Settings such as pause length and reminder preferences

This data is not transmitted to us — we could not read it even if we wanted to, because there is no backend. Deleting the app deletes this data. It is not included in any analytics.

3. AI features (OpenAI)

Premium includes AI-powered explanations of quotes and exercises, personalized reflection questions after a session, and a weekly progress review. These features send a request directly from your device to the API of OpenAI, L.L.C. (USA), using the gpt-4o-mini model. A request is only made when you actively use one of these features — never in the background.

Depending on the feature, a request can include:

  • The goal and challenge tags you selected during onboarding
  • The text of the quote or exercise being explained
  • Reflection answers you typed for that session
  • A summary of your practice statistics (for the weekly progress review)

Requests are not linked to an account, name, or email address — the app has none of these. Please write only what you are comfortable sending: anything you type into a reflection that you then ask the AI to respond to is included in the request. OpenAI processes API data under its API data usage policies; according to OpenAI, API content is not used to train its models by default. Since OpenAI is based in the USA, these requests involve a transfer of data outside the EU/EEA.

4. Apple Health (HealthKit)

If — and only if — you grant permission, the app can save the mindful minutes from completed pauses to Apple Health. The app only writes this one data type; it does not read your health data. Health data is managed by Apple Health on your device under Apple’s protections, and it is never sent to us or to any third party by the app. You can revoke this permission at any time in the Health app or in Settings.

5. Analytics and attribution (AppsFlyer, Facebook SDK)

To understand which marketing led to app installs and subscriptions, the app uses the attribution service AppsFlyer (AppsFlyer Ltd.) and the Facebook SDK (Meta Platforms, Inc.). These services process technical event data such as app installs, app opens, and purchase events, together with device information.

Access to your device’s advertising identifier (IDFA) is controlled by Apple’s App Tracking Transparency prompt. If you choose “Ask App Not to Track,” the advertising identifier is not available and cross-app tracking does not take place; attribution is then limited to aggregate, privacy-preserving mechanisms. You can change your choice at any time in Settings → Privacy & Security → Tracking.

6. Reminders (local notifications)

Reminder notifications are scheduled locally on your device based on the times and weekdays you configure. There is no push server; nothing about your reminders leaves your iPhone.

7. Subscriptions (Apple)

Premium subscriptions are purchased and billed through Apple as in-app purchases. Apple processes the payment; we never receive your payment details. The app checks your subscription status through Apple’s StoreKit framework on your device.

8. Your rights

If you are in the EU/EEA, the GDPR gives you the rights of access, rectification, erasure, restriction of processing, data portability, and objection regarding personal data processed about you, as well as the right to lodge a complaint with a data protection supervisory authority. Because almost all app data is stored only on your device, the most direct way to erase it is to delete the app. For anything relating to the third-party services above, or any other privacy question, contact us at [contact email address].

9. Children

The app is not directed at children. We do not knowingly collect personal data from children; the app has no accounts and asks for no personal details.

10. Changes to this policy

We will update this policy when the app’s data practices change and publish the current version on this page, with an updated date at the top.