Barsuk e.U., Auhofstrasse 245A/5A, 1130 Vienna, Austria. Contact for privacy requests: info@barsukai.com.
Ciclunia stores all entries (cycle, period, symptoms, body map, temperature, mood, weight, sleep, medication, notes, photos) on your device. The app uses no third-party analytics or tracking services and sends no crash reports containing content. Apart from the photo transfer with its small usage signal described in section 3 and the voluntary sharing of entries under section 3a, as well as fetching messages under section 3b, no data is transferred to us or third parties. Photos are downscaled, stripped of location metadata and stored encrypted with a device-bound key.
You can export your data as JSON or CSV at any time and remove everything with "Delete all my data".
Photos you add in Ciclunia are also transferred to us to improve the app. A small usage signal (see below) goes with it, so that we know how many installations exist. This feature is on by default. It is shown to you during setup in the step "Your data is yours" and can be switched off there and at any time under Profile → Privacy & data → "Share photos and a usage signal with the developer". Completing setup with the switch on counts as your consent; date and status are stored on your device.
Legal basis: Art. 6(1)(a) and Art. 9(2)(a) GDPR (consent to processing health data), given by completing setup after the disclosure was shown.
Data shared: the photo (downscaled, without metadata such as location), the category you chose (e.g. skin, belly) and the cycle day of the photo. Each photo is linked to a random pseudonym generated on your device.
Usage signal: while the switch is on, each time the app starts it tells our server that this installation exists. Only the random pseudonym, the app version and the app language (e.g. "en") are sent; the time of the report is recorded on the server. This shows us how many installations exist and how active they are, even if you share no photos. No entries, health data, device identifiers or advertising ids are sent, and the signal is tied to the same switch as the photos. The legal basis is also your consent (Art. 6(1)(a) GDPR).
Never shared: name, birth year, calendar dates, notes, other entries, device identifiers, advertising ids.
Purpose: analysing photos to improve the app's documentation and comparison features and to develop new functions. No sharing with third parties, no training of third-party models without a separate consent.
Transfer and storage: encrypted (HTTPS) to a server under our control hosted by Hetzner Online GmbH, data centre Falkenstein, Germany. Access is restricted to the developer of Ciclunia.
Retention: until revocation, at most 24 months after transfer, then automatic deletion. The usage signal is deleted once an installation has not reported for 24 months.
Revocation: at any time by switching sharing off in the app. All photos shared so far and the record of your pseudonym (usage signal) are then deleted from our server, and the app stops reporting. Deleting a single photo in the app deletes its shared copy as well. "Delete all my data" also deletes all shared photos. Revocation does not affect the lawfulness of processing carried out before it.
In addition to photos you can voluntarily share your entries. This feature is off by default. It only becomes active if you choose it yourself and confirm that you are at least 16 years old: either by answering “Yes, I’ll share” in the question at the end of setup (nothing is pre-selected), or later with the switch on the Today screen (“Help make Ciclunia better”) or under Profile → Privacy & data → “Share my entries with the developer” and your explicit agreement in the dialog. The date and status of your consent are stored on your device. The app works fully without this feature.
Legal basis: your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR), revocable at any time with effect for the future.
Which data: When you switch it on, and then once a day, a current copy of your entries is sent and replaces the previous one: period, symptoms, mood, energy, cervical mucus, temperature, sleep, weight and ovulation and pregnancy tests, each with the date of the day. From the body map: the marked spot, the kind (for example stabbing or rash) and the strength from 1 to 10, also with the date. Notes and photos from the body map are not part of it (photos follow their own switch in section 3). In addition, if you entered them in your profile: your age in years (computed on the device from your birth year; the birth year itself is not sent), your place of residence and your height. Each profile detail is voluntary on its own. The data is assigned to a random pseudonym generated on your device that is not linked to the photo pseudonym.
What is not transferred: name, e-mail address, birth year and date of birth, notes, medication, sex entries, photos (own switch), location (GPS), device identifiers, advertising IDs. The IP address is not stored.
Note on identifiability: age, place of residence, height and weight together with health data can make you identifiable in some cases, especially in small towns, even without your name. Pseudonymised data remains personal data. If that bothers you, leave details out or do not share.
Purpose: developing, checking and improving Ciclunia’s estimates and analyses, so that the app can give you more accurate analyses of your own cycle. These improvements reach you through app updates; the analyses themselves still run on your device, and nothing about you is sent back from the server, apart from personal messages under section 3b. No advertising, no sale, no disclosure to third parties.
Transfer and storage: encrypted (HTTPS) to a server under our control at Hetzner Online GmbH, data centre Falkenstein, Germany. Access only by the controller personally, protected by a strong password and a lockout after failed attempts.
Retention: until you revoke, at most 24 months after the last transfer. Then automatic deletion.
Revocation: at any time by switching the switch off in the app. Everything you shared is then deleted from our server. “Delete all my data” also deletes the shared copy. Revocation does not affect the lawfulness of processing carried out until then.
While photo sharing (section 3) or the sharing of entries (section 3a) is switched on, the Ciclunia team can send you personal messages under the respective random pseudonym, for example tips about the app or pointers to patterns in the data you shared. The messages are written by a person; they are not medical advice.
How it works: On start and about once a day the app asks our server whether there are messages for your pseudonym. Only the pseudonym that is already used for sharing is sent. New messages are stored on your device and, if you allowed notifications, announced with a notification that does not contain the message text. Replying is not possible.
Legal basis: your consent to the respective sharing (Art. 6(1)(a) and Art. 9(2)(a) GDPR), which covers these messages.
Retention: on the server until you revoke, at most 24 months after sending; the server also records when the app fetched a message. Fetched messages stay on your device until you choose “Delete all my data”.
End: If you switch the respective sharing off, the messages to that pseudonym are deleted on the server and the app stops asking.
Reminders are generated locally on the device and contain no cycle data. Notifications about new messages (section 3b) only say that a message is there, not what it says.
Notifications (optional), Internet (exclusively for photo transfer under section 3 and the voluntary sharing of entries under section 3a, as well as fetching messages under section 3b). Photos are selected through the system photo picker or the camera, without access to your whole gallery.
Access, rectification, erasure, restriction, data portability, withdrawal of consent and complaint to a supervisory authority. Because local data exists only on your device, you exercise these rights for local data directly in the app. For shared photos and shared entries contact info@barsukai.com and state your pseudonym (shown under Profile → Privacy & data) or use the in-app revocation.
Changes to this policy are published in the app and at this location.