This is a translation provided for convenience. The Polish version is legally binding.
This Privacy policy explains what personal data we process in the Rotzer application (the “App”), for what purposes, on what legal basis, and what rights data subjects have. Capitalised terms have the meaning given in the Terms of service.
1. Data controller
The controller of personal data is Kamil Wiącek, a sole trader operating under the business name Kamil Wiącek, ul. Ruczaj 17/8 30-409, Kraków, Poland, NIP (tax ID): 6793371348, REGON: 545269734 (the “Controller”). For any matters concerning personal data, contact kontakt@rotzerapp.kwiacek.com.
2. Data we process
- Account data: first name, e-mail address, password (stored only as a cryptographic hash), optional profile photo, selected language, e-mail verification and Account activity status.
- Family data: Family name, list of members and their roles, Family invitation codes and invitations (including e-mail addresses of invited persons).
- Cycle profile data: display name, date of birth, default temperature measurement method, start date of the last period.
- Health data (special category, Art. 9 GDPR): cycle dates and lengths, temperature readings with measurement time, mucus observations, bleeding, intercourse records, disturbing factors (e.g. illness, medication, alcohol, stress), notes and the cycle phase estimates calculated from them.
- Technical data: IP address, authentication tokens, device and App version information and server logs needed for security and operation of the service. Observation values are not written to logs.
- Push notification data: the device notification token, operating system (iOS/Android), notification language and notification category settings (daily entries, cycles, family, invitations).
- Data stored only on the device: temperature reminder settings and local notifications. They are not sent to the Controller.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and maintaining the Account, handling Families and invitations, providing the service under the Terms | Art. 6(1)(b) GDPR – performance of a contract |
| Recording Observations, keeping the cycle chart, estimating cycle phases and sharing this data with Family members | Art. 9(2)(a) GDPR – explicit consent of the data subject, and Art. 6(1)(b) GDPR |
| Sending Account-related e-mails (address verification, password reset, invitations) | Art. 6(1)(b) GDPR |
| Sending push notifications about Family activity (new and edited entries, cycles, Family membership changes, invitations) | Art. 6(1)(b) GDPR – performance of the contract; sending requires the system notification permission, which can be withdrawn in the phone settings |
| Security, abuse prevention, backups | Art. 6(1)(f) GDPR – the Controller’s legitimate interest |
| Handling complaints, establishing, exercising or defending legal claims | Art. 6(1)(c) and (f) GDPR |
You give consent to the processing of health data when creating the Account by ticking a separate checkbox. We record the date and time of this consent and of accepting the Terms and this Policy. Consent can be withdrawn at any time by deleting the relevant data, the Cycle profile or the Account. Withdrawal does not affect the lawfulness of processing before it. Without processing this data, the core features of the App cannot be used.
4. Data of other people
A Cycle profile may concern a person who has no Account of their own or whose data is entered by other Family members. The User entering such data is responsible for ensuring that the person concerned knows about it, has read this Policy and has consented to the processing of their health data and its sharing with Family members.
5. Who has access to the data
- Family members – all members of a Family see the same Cycle profile data of that Family, as well as the names, e-mail addresses and profile photos of other members. This is a core feature of the App.
- Processors acting on the Controller’s behalf, only to the extent necessary to provide the service:
- Hetzner Online GmbH (Germany) – server and database hosting; data is stored in data centres within the European Union,
- Cloudflare, Inc. (USA) – file storage (profile photos) in Cloudflare R2,
- Resend (Plus Five Five, Inc., USA) – sending Account-related e-mails,
- Expo (650 Industries, Inc., USA) – delivering App updates and relaying push notifications.
Push notifications are delivered through Apple Push Notification service (iOS devices) and Google Firebase Cloud Messaging (Android devices). Notification content contains only the name of the person who performed the action, the Cycle profile or Family name and a date – it never contains health data (measurements, observations, bleeding or intercourse information). Individual notification categories can be turned off in the App (Profile → Notifications), and all notifications in the system settings.
- Apple and Google – as operators of app stores and operating systems they process data under their own policies, as independent controllers.
- Public authorities – only where required by law.
We do not sell data, do not use it for advertising and do not use third-party analytics or advertising tools in the App.
6. Transfers outside the European Economic Area
Because we use service providers based in the USA, data may be transferred outside the EEA. Transfers are based on the European Commission’s adequacy decision (EU-U.S. Data Privacy Framework) for providers participating in it, or on standard contractual clauses adopted by the European Commission (Art. 46(2)(c) GDPR). A copy of the safeguards can be obtained by contacting the Controller.
7. Retention
- Account data is kept until the Account is deleted.
- Family and Cycle profile data, including Observations, is kept until the Family or Cycle profile is deleted. Because this data is shared within the Family, deleting one member’s Account does not delete it while other members remain. If the User was the only Family member, the Family’s data is deleted together with the Account.
- Family invitations are valid for a limited time and expire once used.
- We delete the push notification token when you log out on the device, when the Account is deleted, or when the notification service reports that the token is no longer valid.
- Deleted data may remain in backups for no longer than 30 days.
- Data needed to handle complaints or legal claims is kept until the relevant limitation period expires.
8. Your rights
You have the right to:
- access your data and receive a copy,
- rectification,
- erasure,
- restriction of processing,
- data portability,
- object to processing based on legitimate interest,
- withdraw consent at any time,
- lodge a complaint with the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl) or another EU supervisory authority.
Most data can be edited or deleted directly in the App. For anything else, write to kontakt@rotzerapp.kwiacek.com. We will reply without undue delay and within one month at the latest.
9. Automated processing
The App automatically calculates cycle phase estimates from the Observations entered. The result is informational only, does not produce legal effects or similarly significantly affect you within the meaning of Art. 22 GDPR, and you make decisions based on it yourself. We do not profile users for marketing purposes.
10. Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including encrypted connections (HTTPS), password hashing, token authentication, restricting data access to members of the given Family and excluding Observation values from logs.
11. Providing data
Providing data is voluntary but necessary to create an Account and use the App. Only adults may create an Account.
12. Cookies
The mobile App does not use cookies. The web pages with legal documents do not use tracking or analytics cookies.
13. Changes to this Policy
This Policy may be updated due to changes in law, App features or data processors. We will inform you of significant changes in the App or by e-mail.