Legal
Privacy Policy
Your health entries stay on your iPhone. Your cycles, symptoms, moods and health profile are stored encrypted on your device only – we never receive them. Data leaves your iPhone only in the cases described below, for example when you ask the AI assistant a question, and only with your consent.
1. Who is responsible
The controller under the EU General Data Protection Regulation (GDPR) for the codeXX.health app and this website is:
Roman Sturzeis
Hütteldorfer Str. 12
1150 Wien
Austria
Email: codexx.health@gmail.com
codeXX.health is a start-up project in its founding phase, funded by the aws First Incubator. No company has been founded yet. If a company takes over the app, we will update this policy and tell you in the app beforehand.
We are not required to appoint a data protection officer. Please send all privacy questions to the email address above.
2. Overview
| Data | Where it is processed | Legal basis (GDPR) |
|---|---|---|
| Health entries and health profile | Only on your iPhone, encrypted | Art. 6(1)(b), Art. 9(2)(a) (section 3.1) |
| Account (email address, name, sign-in method) | Google Firebase, database in the EU | Art. 6(1)(b) |
| Questions to the AI assistant (optional) | Google Cloud in the EU, not stored | Art. 6(1)(a), Art. 9(2)(a) |
| Usage statistics and crash reports (optional, off by default) | Google Firebase | Art. 6(1)(a) |
| Loading recipes, workouts and articles | Contentful | Art. 6(1)(f) |
| Subscription | Apple | Art. 6(1)(b) |
| Study application on this website | Google Firebase, database in the EU | Art. 6(1)(b) |
3. The app
3.1 Your health entries – only on your iPhone
This covers your period dates, symptoms, moods and notes, the details from onboarding and your profile (for example date of birth, height, weight, health conditions, contraception, cycle lengths and preferences), cycle predictions, the recommendations you saved or completed and how you use recommendations.
- These data are stored only on your iPhone. The app encrypts them (AES-256); the key is kept in the iOS Keychain, and iOS data protection secures them in addition.
- Predictions and recommendations are calculated on your iPhone. We have no access to these data. They are not sent to us or to anyone else – except the details you send with a question to the AI assistant (3.3) and files you export yourself.
- Your entries are part of your iPhone backup. With an iCloud backup or an encrypted backup on your computer they move to a new iPhone; these backups are provided by Apple or by your computer, not by us. There is no synchronisation between devices yet.
- You can export everything as a file (Profile → Privacy & Data → Export Your Data), delete it (Delete Your Data), or remove it by deleting the app.
Health data are special categories of personal data (Art. 9 GDPR). Where this processing on your device is attributable to us, it is based on your explicit consent, which you give when you set up the app (Art. 9(2)(a) GDPR), and serves to provide the app to you (Art. 6(1)(b) GDPR). You can withdraw your consent at any time by deleting your entries or the app.
3.2 Your account
To use the app you create an account with your email address and a password, or with Sign in with Apple. We store your email address (with Sign in with Apple possibly a private relay address from Apple), an optional display name, the sign-in method, whether you have completed onboarding, time stamps (account created, last sign-in) and your privacy settings. Your account contains no health data; our database rules reject them.
Service provider: Google Firebase – Cloud Firestore with its database location in the European Union, and Firebase Authentication, which may also process your sign-in data in the USA (section 5). Google processes these data on our behalf (Art. 28 GDPR). Legal basis: performance of the contract (Art. 6(1)(b) GDPR). We keep the data until you delete your account, which you can do at any time in the app (Profile → Privacy & Data → Delete Account).
Test versions of the app used until October 2026 also stored health entries in this database. When you sign in with a current version, the app moves them to your iPhone and deletes them on the server.
3.3 AI assistant (optional)
When you ask the AI assistant a question, the app sends your question, the app language, your current cycle phase and up to ten categories of symptoms you logged recently (for example “cramps” – no notes, dates or other entries). The assistant only works after you have agreed to this in the app. You can withdraw your consent at any time in Profile → Privacy & Data (“AI Assistant”).
Your question is processed by our server function in Google Cloud (region europe-west1, Belgium) and answered by Claude, an AI model developed by Anthropic that runs on Google Cloud Vertex AI with processing in the European Union. Google acts as our processor and does not use the data to train AI models. We do not store your questions or the answers. To prevent misuse and limit costs we store, per account, only the number of questions per day and per month; these counters are deleted automatically when you delete your account.
Legal basis: your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). The answers are general wellbeing information, not medical advice.
3.4 Usage statistics and crash reports (optional)
Both are switched off until you allow them in the app. Google Analytics for Firebase then records how the app is used along fixed steps, for example “onboarding completed” or “recommendation opened” – never health data such as symptoms, moods, cycle phase, dates or notes. Firebase Crashlytics sends crash reports with device model, iOS and app version and the technical details of the crash. Advertising features and ad personalisation are switched off.
Legal basis: your consent (Art. 6(1)(a) GDPR; § 165(3) of the Austrian Telecommunications Act 2021). You can withdraw it at any time in Profile → Privacy & Data. Usage statistics are deleted after at most 14 months, crash reports after at most 90 days.
3.5 Recipes, workouts and articles
The app loads its content from the content service Contentful. The app always loads complete content collections and selects what fits you on your iPhone, so no personal or health data are sent – only the technically necessary connection data such as your IP address. Legal basis: our legitimate interest in delivering the app's content (Art. 6(1)(f) GDPR). Provider: Contentful GmbH, Berlin, Germany, together with Contentful Inc., USA.
3.6 Subscription
Subscriptions are sold and paid through the Apple App Store. Apple processes your payment data as an independent controller under its own privacy policy. We only learn whether a subscription is active. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
3.7 Reminders
Reminders are scheduled locally on your iPhone. We do not send push messages from our servers. You decide in the iOS settings whether the app may show notifications.
3.8 Federated learning (not active)
We are developing a way to improve predictions together without sharing anyone's entries (federated learning). It is currently switched off. Before it is switched on, we will update this policy and ask for your separate consent.
3.9 When you contact us
If you write to us, we process your email address and your message to answer you (Art. 6(1)(b) or (f) GDPR). Our mailbox is provided by Google (Gmail). We delete your messages when your request has been dealt with, unless we must keep them longer by law.
4. This website
4.1 Hosting
This website is hosted by Google Firebase Hosting. When you visit it, the server processes your IP address, the time, the page requested and information about your browser in order to deliver the website and keep it secure (Art. 6(1)(f) GDPR). We do not use cookies, analytics or tracking on this website, and our font is loaded from our own server.
4.2 Applying for the closed study
If you apply for our closed study, we store your name, your email address, the time of your application, the page you came from and technical information about your browser (user agent) in Google Cloud Firestore (database location in the EU) in order to contact you about the study. To send the form, your browser loads a script from Google's servers (gstatic.com), which processes your IP address. Legal basis: steps taken at your request before taking part (Art. 6(1)(b) GDPR). We delete your application when the study has ended, at the latest on 31 December 2027, or earlier if you ask us to. Before you take part you will receive separate information about the study and its own consent form.
5. Recipients and transfers outside the EU
- Google (Google Ireland Limited, Dublin, Ireland, and Google LLC, USA): Firebase (account, database, website hosting, optional usage statistics and crash reports), Google Cloud (server function, AI assistant via Vertex AI) and Gmail – as our processor.
- Contentful (Contentful GmbH, Berlin, Germany, and Contentful Inc., USA): delivery of the app's content.
- Apple (Apple Distribution International Ltd., Ireland): App Store, payments and Sign in with Apple, as an independent controller.
Where data reach the USA, the transfer is based on the adequacy decision for the EU-US Data Privacy Framework of 10 July 2023 for certified companies, and otherwise on the EU Standard Contractual Clauses. We do not sell your data and do not use it for advertising.
6. How long we keep data
- Health entries: on your iPhone until you delete them or the app.
- Account and privacy settings: until you delete your account.
- AI assistant: questions and answers are not stored; the question counters until you delete your account.
- Usage statistics: at most 14 months; crash reports: at most 90 days.
- Study applications: until the end of the study, at the latest 31 December 2027.
- Emails: until your request has been dealt with, unless the law requires longer.
7. Your rights
You have the right to access your data (Art. 15 GDPR), to rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20), and to object to processing based on our legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)).
Because we cannot access the data on your iPhone, you exercise these rights for your health entries directly in the app: export everything as a file, correct entries, or delete them. For everything else, write to codexx.health@gmail.com. We reply within one month.
You also have the right to lodge a complaint with a supervisory authority. In Austria this is the Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, dsb@dsb.gv.at, www.dsb.gv.at. You can also contact the authority in the EU country where you live.
8. Do you have to provide data?
An email address (or Sign in with Apple) is needed to create an account. Everything else is voluntary. Without the AI assistant, usage statistics or crash reports the app works in full; without health entries it cannot give you predictions or personal recommendations.
9. No automated decisions
Predictions and recommendations are suggestions calculated on your iPhone. They have no legal or similarly significant effect on you, so Art. 22 GDPR does not apply.
10. Minimum age
The app is intended for people aged 18 and over.
11. Security
Connections are encrypted (TLS). On your iPhone your health entries are encrypted by the app (AES-256) and protected by iOS. Our database rules only allow each person to access their own account, reject health data in the account, and our server functions run with the minimum permissions they need.
12. Changes to this policy
We update this policy when the app or the law changes. The current version is always available here. We will tell you about important changes in the app and, where your consent is required, ask you again.