Privacy Policy

1. Scope

This policy applies to the bauchgefühl app, published on Google Play as Period Tracker & Cycle Diet (package ID com.bauchgefuehl.ios, developer hamstr) and on the Apple App Store as bauchgefühl, and to bauchgefuehl.app (together, the “service”). The app provides menstrual cycle tracking, symptom recording and personalized dietary suggestions based on the cycle phase.

2. Controller

The controller under the GDPR is Josef Haras, operating under the developer name hamstr.

Josef Haras (hamstr)
Dr.-Adolf-Schärf-Platz 10/309
1220 Vienna, Austria
VAT ID: ATU75469459

Email: josef.haras@hamstr.me
Public developer email: office@hamstr.me
Telephone: +43 680 5019637
Website: bauchgefuehl.app

3. Data collected and purposes

3.1 App usage data

We process the following categories:

• Cycle data, including the start and end of menstruation and cycle days.
• Symptoms and wellbeing, such as pain, mood and energy.
• Dietary preferences and intolerances.
• Ingredients and recipes entered by users.
• Email address when registering an account.
• Device information and anonymized usage statistics.

The purpose is to provide app functions: cycle tracking, dietary suggestions and personalized content. Legal bases: Article 6(1)(b) GDPR (performance of a contract) and Article 9(2)(a) GDPR (explicit consent) for health data.

3.2 Website usage data

When you visit the website, technical data is collected automatically: IP address, browser type, operating system, referrer URL and time of access. This data is required to operate the website and is deleted within 30 days. Legal basis: Article 6(1)(f) GDPR (legitimate interests).

The French and Spanish pages do not load the website’s analytics or advertising tools. When you change language, the NEXT_LOCALE cookie remembers your choice for one year. Temporary session storage restores your reading position. The contact form stores a draft locally on your device, which is restored only for 7 days. You can remove this data in your browser settings. Dates entered in the French and Spanish calculators are processed in your browser and are not sent to our server.

3.3 Contact

When you contact us by email, we store your details to handle the enquiry and possible follow-up questions. We do not share this data without your consent. Legal basis: Article 6(1)(f) GDPR (legitimate interests).

3.4 Newsletter and email communication

Website newsletter. With your consent, we send newsletter emails through Brevo (formerly Sendinblue). You can unsubscribe at any time using the link in each email or by contacting office@bauchgefuehl.app. Legal basis: Article 6(1)(a) GDPR (consent).

App service messages. When you start a trial or free access in the app, we send individual service messages to your account email: confirmation at the start and a reminder before access ends. If you have provided a payment method, the reminder precedes the start of a paid subscription and includes the price and cancellation option. These messages form part of contract performance and contain no advertising. Legal basis: Article 6(1)(b) GDPR.

Accompanying emails, only with consent. You may additionally consent in the app to occasional cycle tips and product updates. We record the time and wording of your consent. For these personalized emails, we use your email address and selected account usage details, such as the number of saved recipes and your access expiry date. Your health data—cycle entries and symptoms—remains end-to-end encrypted on your device and is never used for emails. You can withdraw consent at any time through the unsubscribe link or by contacting office@bauchgefuehl.app. Withdrawal does not affect the lawfulness of processing before withdrawal. Legal basis: Article 6(1)(a) GDPR.

Email provider. All these emails are sent through Sendinblue GmbH (Brevo), Köpenicker Str. 126, 10179 Berlin, Germany, acting as a processor under Article 28 GDPR. Processing takes place in the EU. Recipient data is stored while your account exists or until consent is withdrawn and is deleted when the account is deleted.

3.5 Push notifications and automatic backups

We use Google Firebase Cloud Messaging (FCM) to deliver push notifications; see section 4. Visible notifications, such as cycle reminders, are sent only if you enable notifications, which you can disable in settings at any time.

We also send invisible system pushes to all devices on which you are signed in, regardless of notification settings. These never display anything and contain no content or health data. They briefly wake the app in the background to prepare an encrypted backup and, if you enabled “Proactive messages”, prepare a proactive message; see the Google Vertex AI subsection below. The backup leaves your device only with end-to-end encryption, so we cannot read its contents.

Legal bases: Article 6(1)(b) GDPR (contract performance: providing backups); for visible reminders, your consent through notification settings under Article 6(1)(a) GDPR.

3.6 Recipe suggestions based on swipes

When you save a recipe by swiping right or dismiss it by swiping left, our server uses these signals to suggest more suitable recipes in the AI chat. Among similarly suitable recipes, saved recipes are preferred and dismissed recipes avoided. Safety exclusions, such as allergens and intolerances, always apply. This is your own app usage behavior, used only in the recipe function you actively request. The swipes themselves are not transmitted to the AI service. Legal basis: Article 6(1)(b) GDPR.

4. Services and recipients

Supabase

Supabase provides database infrastructure and authentication. Data is stored in the EU, in Frankfurt, Germany, and is subject to the GDPR. A data processing agreement is in place.

Google Vertex AI: recipe suggestions

To generate personalized recipes, we transmit your cycle phase, symptoms, dietary preferences, entered ingredients and requested preparation time to Google Vertex AI. The data is used only to generate the requested response and is not used to train AI models. A data processing agreement, including EU standard contractual clauses, applies under the Google Cloud Data Processing Addendum.

Legal bases: Article 6(1)(b) GDPR (contract performance) and Article 9(2)(a) GDPR (explicit consent given through active, voluntary use of the AI recipe function by submitting your request).

Google Vertex AI: proactive messages

If you enable “Proactive messages” in settings, which is off by default, the app occasionally prepares a personal push message, for example about a cycle phase transition or your activity. Unlike other reminders calculated entirely on your device, these messages are generated on the server. In the background, including when closed, the app transmits your current cycle phase and, if you additionally enabled Health access, a summary of recent activity and sleep to Google Vertex AI in the EU region europe-west3. At most one such message is generated per day.

This processes health data: your cycle phase already qualifies as a special category of personal data under Article 9 GDPR, and activity and sleep add further health data when Health access is enabled. Processing relies solely on your explicit consent through the switch. You can withdraw it at any time by switching the setting off; no further data is then transmitted for this purpose. Data is used only to generate the individual message, not to train AI models, either by us or Google. The Google Cloud data processing agreement, including EU standard contractual clauses, applies.

Legal bases: Article 6(1)(a) and Article 9(2)(a) GDPR (explicit consent).

Brevo, formerly Sendinblue

We use Brevo (Sendinblue GmbH, Berlin) for the website newsletter and app service and accompanying emails described in section 3.4. Data is stored in the EU. A data processing agreement is in place.

Google Analytics

On website pages where it is enabled, Google Analytics analyzes website usage. IP addresses are anonymized before storage. Processing relies on your consent through the cookie banner, Article 6(1)(a) GDPR. You can object to collection by installing Google’s Analytics opt-out browser add-on. This tool is not loaded on French and Spanish pages.

PostHog: website analytics and session replay

On pages where it is enabled, PostHog uses EU hosting in Frankfurt. Before consent, we collect only anonymous usage data without device storage, cookies or recognition; your IP address is anonymized and not stored. After consent through the cookie banner, PostHog uses cookies for audience and funnel analysis and session replay: anonymized page interactions, with masked input fields and no recordings of sensitive areas such as quiz, login or checkout. Replay retention is 30 days. A data processing agreement is in place.

Legal bases: before consent, Article 6(1)(f) GDPR (legitimate interest in anonymous reach measurement without accessing your device); after consent, Article 6(1)(a) GDPR. Consent can be withdrawn through the cookie banner. PostHog website tracking is not loaded on French and Spanish pages.

PostHog: app usage analytics

We use PostHog Inc. to understand app usage, with processing exclusively on EU servers in Frankfurt, at eu.posthog.com. IP addresses are anonymized before storage.

We never collect health data for analytics. Cycle data, symptoms, moods and other health information remain encrypted on your device and are never transmitted to analytics systems. We collect only usage behavior, such as which functions are used or where problems occur, at two levels:

• Anonymous statistics without consent. During installation, onboarding and registration, technical events are fully anonymous. No identifier is stored on your device, the data cannot be assigned to a person, and each app launch starts a new, unlinkable session. This shows, for example, where users leave onboarding. Since the data is anonymous, no personal data is processed.
• Statistics with consent. Only with your explicit consent after registration do we link usage events pseudonymously to your account—for example, that a function was used or an entry created, never the entry’s content. You can withdraw consent at any time using “Usage statistics” in app settings. Collection stops and the analytics identifier is discarded.

Legal bases: Article 6(1)(a) and Article 9(2)(a) GDPR. Recipient: PostHog Inc. as processor, with EU hosting and a data processing agreement including EU standard contractual clauses.

Google Firebase: app notifications and crash reports

The app uses Firebase Cloud Messaging for push delivery and Crashlytics and Performance Monitoring for crash and performance reports. These process technical device details, such as device token, model, operating system and app versions and crash logs, without health data. Classical scheduled cycle reminders are calculated entirely on your device; server-generated proactive messages are described above. Firebase Analytics is not used.

Legal bases: Article 6(1)(b) GDPR for app functions you enable and Article 6(1)(f) GDPR for the legitimate interest in stability and troubleshooting.

Facebook Pixel

On website pages where it is enabled, Facebook Pixel supports conversion tracking and remarketing with your consent under Article 6(1)(a) GDPR. You can withdraw consent through the cookie banner. It is not loaded on French and Spanish pages.

Google Tag Manager

On pages where tracking is enabled, Google Tag Manager manages our tracking tools. The Tag Manager itself does not collect personal data. It is not loaded on French and Spanish pages.

App stores

The app is distributed through Google Play and the Apple App Store. When downloading and using those stores, Google’s and Apple’s respective privacy policies apply. We have no influence over their processing.

5. Retention and deletion

We retain personal data only as required for the relevant purpose or statutory retention obligations:

• Account and app data: until account deletion or upon request.
• Newsletter data: until unsubscription.
• Contact enquiries: 2 years after correspondence ends.
• Technical website logs: at most 30 days.
• Accounting data: 7 years under Austrian tax law.

You can delete your account and associated data in the app under “Profile → Delete account” or through our website. A 7-day grace period applies: signing in again during that period cancels deletion. Afterwards, the account and associated personal data are automatically and irreversibly deleted from our systems and those of the processors listed in section 4. Deletion is fully completed within 30 days at the latest. Data subject to statutory retention, such as accounting records, is excluded. Deleting your account does not cancel an App Store or Google Play subscription; cancel any active subscription separately in the store settings.

6. Your rights

Under the GDPR, you have the following rights:

• Access to your personal data: Article 15.
• Rectification of incorrect or incomplete data: Article 16.
• Erasure, unless statutory retention applies: Article 17.
• Restriction of processing: Article 18.
• Data portability in a machine-readable format: Article 20.
• Objection to processing based on legitimate interests: Article 21.
• Withdrawal of consent for the future: Article 7(3).

To exercise these rights, contact office@bauchgefuehl.app. You also have the right to complain to the Austrian data protection authority:

Österreichische Datenschutzbehörde
Barichgasse 40–42
1030 Vienna
dsb@dsb.gv.at
www.dsb.gv.at

7. Data security

We implement technical and organizational safeguards against accidental or deliberate manipulation, loss, destruction and unauthorized access. All data transmissions use TLS/HTTPS encryption. Safeguards are continuously improved as technology develops.

8. Updates

This translation reflects the German policy dated July 24, 2026 and clarifies the French and Spanish website behavior as of September 14, 2026. We may update it to reflect changes in our services or applicable requirements. The new version applies on your next visit.