Privacy Policy

The website is separate from the app. Without your consent it sets no cookies and loads no third-party trackers. A banner asks whether we may measure website visits; you can reject it and still use the whole site.

If you accept, we load HeyCatch (HeyCatch, Inc., United States), a website analytics tool. It records the pages you view and what you click (for example the download buttons), which link or post brought you here, your IP address, and device and browser details, and it stores an identifier in your browser (local storage and a cookie) so repeat visits can be recognised. It does not record what you type and does not record sessions. We use this only to see which posts, creators and links bring visitors, not for advertising, and we do not sell it. The legal basis is your consent (GDPR Art. 6(1)(a)). HeyCatch acts as our processor under a data processing agreement; because it is based in the US, transfers rely on the EU Standard Contractual Clauses. It is not certified under the EU–US Data Privacy Framework.

We remember your choice in your browser (local storage, key "cw_consent"), which is strictly necessary to not ask you again. To see how the banner performs we count, anonymously and per day, how many times it was shown, accepted and rejected. These counters hold no identifier, IP address or cookie. You can change your choice at any time with "Cookie settings" in the footer; rejecting stops any further collection from then on.

Separately, if we switch on Cloudflare Web Analytics, it measures page views without cookies or cross-site identifiers.

ComniWell ("ComniWell", "we", "us") is a health & fitness app built by ComniWell, a sole proprietorship (eenmanszaak) registered with the Dutch Chamber of Commerce (KVK) under number 42155849, at Hoogstraat 16, 7512 GX Enschede, Overijssel, Netherlands. Contact: support@comniwell.com. We are the data controller for your personal data under the GDPR.

ComniWell is local-first. Your data is stored primarily on your device and synced to our backend (Supabase, hosted in the EU) so you can back it up and use it across devices. We do not sell your data, and we do not use it for advertising.

Only what the app actually needs to run the features you use. Some items below only apply once you turn the feature on, and some arrive with app version 1.1:

• Account data: your email address, for sign-in and account emails.
• Health & fitness data you enter: workouts and training, nutrition and food logs (including when you ate or drank something, if you set it), gut-health entries, supplements and compounds you log, biomarkers you record, habits, wellbeing check-ins (stress and mood, and, if you turn on the optional check-in, energy, muscle soreness and motivation), body measurements, sleep, resting heart rate, and related notes. We also save the daily scores the app calculates from this data (your overall score and its parts), so you can see how they change over time.
• Health Connect and Apple Health data (only with your permission): where you connect Android Health Connect or Apple Health on iPhone, we read data such as steps and activity, resting heart rate, heart rate variability, breathing rate, sleep (including sleep stages and bed and wake times), and weight, to show it alongside your other data. This data is never sold and never used for advertising. By default it is not sent to our AI backend. If you turn on “Include Health Connect / Apple Health data in AI summaries” (in Settings → Health, or when the app first asks about AI), the AI summaries may include sleep duration, steps, resting heart rate and weight from it, sent to our AI provider only when you open a summary; heart rate variability and breathing rate are never sent. You can turn this off at any time. If you also turn on writing, the app sends the workouts, food, water and weight you log to Health Connect or Apple Health; once there, Google’s or Apple’s own terms apply to it. You control these permissions and can revoke them at any time in Health Connect, or in the Health app on iPhone.
• Camera & photos (only when you use an AI photo feature: a meal photo or a nutrition-label scan): the photo is sent to our AI backend, which calls Anthropic's Claude API to estimate nutrients or read the label, then returns the result to your device. We do not store the photo anywhere; on our side it exists only for the duration of that one request and is discarded once the result is returned (our AI provider’s own short retention is described under “Where your data is stored” below). Barcode scanning happens on your device and sends only the barcode number to the food databases listed below.
• Recipe text you paste to import a recipe: sent to our AI backend to structure it into ingredients and quantities. The AI only extracts structure; it does not invent nutrition data.
• Other AI features (describing a meal in words, nutrient estimates for a food, training program and routine generation, exercise substitutions, habit suggestions, weekly recaps and calorie check-ins, "where to focus" tips from your scores, and plain-language narration of your connections and of your sleep, muscle balance, gut health and habit trends): when you use one of these, the data relevant to that feature (for example your training history, nutrition entries, gut-health entries, biomarkers, habit logs or daily scores) is sent to our AI backend, which calls Anthropic's Claude API, to generate the suggestion or narration. Values synced from Health Connect or Apple Health are excluded from these calls unless you turn on “Include Health Connect / Apple Health data in AI summaries”, which is off by default (see above).
• "Ask your data": not currently available. This free-text AI assistant is temporarily disabled while we review how it should handle Health Connect-derived data; this section will be updated when it returns.
• Basic technical data: app version and, when a request to our backend fails, a short error report (the endpoint called, the status code, and a truncated error message) so we can find and fix problems. This does not include your health data or any photo/image content. Error reports are deleted after 90 days. To keep the AI features fair and affordable, our backend also records which AI feature you called and when (never what you sent); these records hold no content, are cleared automatically within a day of your next AI use, and are deleted with your account.
• A record of each AI answer: when an AI feature answers you, we keep the answer the AI gave, which feature and AI model produced it, the app version, its size in tokens, and a fingerprint (a one-way hash) of what was sent, not the content you sent itself. We keep this so we can look into a complaint or a question about something the AI said, and to check our AI costs. You can't see or change these records, and we only read them for those reasons. They are kept for 3 years; if you delete your account, they are no longer linked to you.
• Reports you send about an AI answer ("Report this"): the reason you give, a short excerpt of the answer and your account, kept for 3 years so we can follow up and learn from it.
• Shared food cache: when a food search result from Open Food Facts or USDA is saved to the shared cache that makes searching faster for everyone, we note which account added it, so a wrong or abusive entry can be traced and removed. That link is removed when you delete your account; the food entry itself holds no personal data.
• We do not currently use any third-party analytics or advertising SDK in the app, and we do not track you across other apps or websites. (Website analytics, only with your consent, is described under "Our website" above.)
• We do not currently collect a push notification token. Reminders (workout, water, habit, etc.) and the optional streak and weekly-pattern notifications are scheduled locally on your device and never touch our servers.
• If you use a code in the app: which code your account used, and whether a paid subscription followed, so we can count how codes perform and stop a code being used twice. If you give away a code, you see how many of yours were used, never who used them.
• Subscription data: if you subscribe, we receive your purchase and subscription status and tier, managed through RevenueCat. Payment is processed by Google Play or the Apple App Store — we do not receive your card details.

To provide and sync the app's features; to generate AI estimates and answers from data you submit; to authenticate you and send account emails (sign-up confirmation, password reset); to send the local reminders you've enabled; to keep the service secure and fix problems. That's it — we don't use your data for advertising, and we don't sell it.

• Contract — to provide the app you signed up for.
• Explicit consent (special-category data) — we process your health data only with your explicit consent, given when you start using the app's health features, withdrawable at any time (Art. 9 GDPR). Sending synced Health Connect or Apple Health data to our AI provider needs its own explicit opt-in, also withdrawable at any time.
• Consent — for optional features like Health Connect and Apple Health access and local notifications, withdrawable any time.
• Legitimate interests — to keep the service secure and functioning (e.g. the error reports and food-cache attribution described above), and to be able to investigate and answer complaints or legal claims about AI answers (the AI answer records and reports). Where those records contain health information, we rely on Art. 9(2)(f) GDPR (establishing, exercising or defending legal claims) in addition to your consent.

Our AI features (meal and label estimates, recipe import, program and routine generation, exercise substitutions, habit suggestions, "where to focus" tips, and trend narration) are automated but informational only. They don't produce legal or similarly significant effects, and we don't use them to make automated decisions about you. Outputs are always framed as estimates or narration, never as exact figures or medical interpretation.

Before some AI features run, our backend automatically checks what you typed (and, for the weekly calorie check-in, your target and goal rate) for signs that a plan wouldn't be safe without professional guidance, such as chest pain, pregnancy, being under 18, a calorie target under 1,200 kcal or losing more than 1 kg a week. If it finds one, the AI isn't called and you see a message suggesting you talk to a doctor, midwife, dietitian or qualified coach. This check doesn't store anything extra, doesn't use up a free AI try, and isn't a medical assessment.

The Sleep screen compares your own logs (for example caffeine, alcohol, meal and training times, stress, steps, habits and supplements) with your sleep to show patterns, such as which evenings tend to come before your lower-scoring nights. This runs on your device, nothing about it is stored or sent anywhere, and it's informational only: patterns in your own data, not medical interpretation or advice. You can switch each source off in Sleep settings. Compounds logged as medication or hormone are never used.

The app also calculates scores on your device, such as your sleep, gut and readiness scores and the patterns behind them, from data you've logged. They are informational only and don't make decisions about you. Your daily overall score and its parts are saved to your account so you can see your history; readiness and the patterns behind it are never stored. Scores only reach our AI backend if you use an AI feature that needs them, such as "where to focus" tips.

Health data is sensitive. We process it only to provide the app's features, only with your consent where required, and we never sell it or share it for advertising. Data from Health Connect or Apple Health is used to show it back to you and to work out your own scores in the app. It goes to our AI provider only if you turn on “Include Health Connect / Apple Health data in AI summaries” (off by default; Settings → Health, or the switch on the first AI consent screen), and then only to write the summary you open. Heart rate variability and breathing rate are never sent to it. Revoking a permission or turning the switch off stops that processing.

Supplements, peptides, and compounds you log are treated as neutral data — we record what you tell us without judgment, and we never use it to recommend, endorse, or provide dosing guidance.

ComniWell is not a medical device and does not diagnose, treat, cure, or prevent any medical condition. It is a self-tracking and informational tool only — always talk to a qualified healthcare professional about medical questions or before making health decisions.

A small number of service providers who process data only on our instructions, never as data they can use for their own purposes:

• Supabase — authentication, database and sync. Hosted in the eu-west-1 (Ireland) region.
• Brevo (France, EU) — delivers our account emails (sign-up confirmation, password reset) for our sign-in system, and the waitlist confirmation on our marketing website (comniwell.com). It receives your email address and the email content, never your health data.
• Cloudflare — hosts our website.
• Zoho Mail (Zoho, EU data centre) — hosts the mailbox for @comniwell.com addresses, so it processes the emails you send us.
• HeyCatch (United States) — website analytics, only if you accept the cookie banner. See "Our website" above.
• Open Food Facts and USDA FoodData Central — public food-database lookups (barcode/text search terms only, no account-identifying data). Text searches of USDA FoodData Central are relayed through our own backend so our API key stays private; we do not keep the search text.
• ComniWell's own AI backend (hosted in the EU, Amsterdam region), which calls Anthropic's Claude API server-side — for meal-photo estimates, recipe import, program/routine generation, and the other AI features described above.
• Google Health Connect — on-device, under your permission (Android only).
• Apple Health (HealthKit) — on-device, under your permission (iPhone only).
• RevenueCat + Google Play Billing / Apple App Store — manages subscriptions and purchases; the stores process your payment details, which we never receive.
• Expo (EAS Update) — delivers app updates. When the app checks for an update it sends a random installation ID, your device platform and the app version; Expo also sees your IP address. No account, contact or health data is sent.

We do not sell your data or share it with data brokers or advertisers.

Your Supabase-synced data is stored in the eu-west-1 (Ireland) region, within the EEA. Our own AI backend, which handles AI requests before calling Anthropic, is also hosted in the EU (Amsterdam). Anthropic's API infrastructure sits outside the EEA; that transfer is governed by Anthropic's Data Processing Addendum, which incorporates the EU Standard Contractual Clauses (Module Two, controller-to-processor) as the transfer safeguard. Expo (app update delivery) is US-based; that transfer relies on Expo's Data Processing Addendum and the EU Standard Contractual Clauses. By default, Anthropic does not use data sent through its API to train its models. Anthropic may keep requests sent through its API for a limited period (up to 30 days) to run the service and check for abuse.

We keep your data until you delete it or your account — including a long-inactive account, which we don't automatically delete. When you delete your account in the app, your personal data is deleted from our live systems immediately. If you request deletion by emailing us instead, we act on it within 30 days. Except anything we must retain by law and the unlinked AI answer records described below, nothing is kept past that. Our database provider makes daily backups that are kept for 7 days, so deleted data can remain in a backup for up to 7 days before it is gone for good; backups are only used to recover from a failure.

Fixed retention periods: error reports 90 days; AI answer records and AI reports 3 years (AI answer records are unlinked from you when you delete your account); subscription records as long as tax law requires (7 years in the Netherlands).

Meal photos: we do not retain them — see "What we collect" above for what our AI provider keeps briefly.

Your sign-in session is stored encrypted on your device; other app data sits in the app’s private storage and relies on your phone’s own protection (screen lock and device encryption). Data is encrypted in transit (HTTPS/TLS) and at rest by our database provider, and each account’s data is separated by row-level access rules on our backend. No system is perfectly secure, but we take reasonable measures to protect your data.

If we discover a data breach affecting your personal data, we'll investigate and contain it promptly, and where required by law, notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and affected users without undue delay.

You can access, correct, export, delete, restrict, or object to processing of your data, and withdraw consent at any time. Use the in-app tools below, or email support@comniwell.com. You may also complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

• In-app: Profile (the person icon on the Insights tab) → Account → Delete account permanently deletes your account and all its data immediately. Emailing us instead takes up to 30 days — see "How long we keep it" above.
• Export: a full personal-data export (JSON) is built into the app, in-app and instant.
• See our Account & Data Deletion page for full steps.

ComniWell is not directed at children and is intended for users 16 and older; we rely on you confirming this when you create an account, rather than an active age-verification check. We do not knowingly collect data from children; contact us if you believe a child has provided data.

We'll update this page and change the "Last updated" date when our practices change; significant changes will be announced in-app.