Privacy Policy for the InflamAI Apps and the Associated Legal Text Page
The most important points in brief
The controller is Paper News TS UG (haftungsbeschränkt), Hellenstraße 41, 56179 Vallendar.
As part of the core function, the content of the health diary is generally stored locally on your device. There is no user account for this diary content and no server-side storage by us or by a backend service engaged by us; we do not receive an automatic copy of your diary content.
Individual additional functions and platform processes may, however, transmit personal data or health data to the recipients named in each case. This concerns in particular the loading of videos, the voluntary survey, weather for entries, the Community, exports or messages you initiate, watch, voice and assistance functions, and store, beta, diagnostic and backup processes. When the associated legal text page is accessed, Cloudflare processes technical connection and security data. Recipients, purposes, legal bases, possible third-country transfers and storage periods are described below.
The Community is a voluntary area with its own account. What you publish there is stored on a server in Frankfurt am Main that we use for this purpose with Supabase Pte. Ltd. as processor, and is visible to the other members; your diary entries do not go there. Weather for entries transmits rounded coordinates to a weather service after your consent, but no health data.
The app processes health data on the basis of your explicit consent. The core consent for the local health diary is given separately from independent optional functions. Optional functions remain switched off until you make the relevant decision. You can withdraw each consent with effect for the future.
You have in particular rights of access, rectification, erasure, restriction, data portability, objection and complaint to a data protection supervisory authority. Details are set out in sections 20 to 22.
1. Controller
The controller within the meaning of the General Data Protection Regulation is:
Paper News TS UG (haftungsbeschränkt)
represented by its Managing Director Timo Alexander Schmidt
Hellenstraße 41
56179 Vallendar
Germany
Register court Amtsgericht Koblenz, HRB 29671
VAT ID No. DE366550179
Telephone +49 172 7858026
E-mail PaperNews-TS@gmx.de
These contact details also apply to data protection matters.
2. Scope and purpose of the app
This policy applies to the InflamAI app for iPhone and Android, the optional watch apps for Apple Watch and Wear OS, widgets and complications, the optional Community and the associated legal text page. Platform differences are expressly identified.
InflamAI is intended for the personal documentation and organisation of information you provide. The app does not generate a diagnosis, prognosis or treatment recommendation. For the core function, diary content is not stored on a server by us or by a backend service engaged by us. This does not affect the additional, communication, Community, beta, platform, backup and website processes described below.
For data-related matters, this privacy policy and the consent to the processing of health data take precedence over the terms of use.
3. Local core processing and data transfers
As part of the core function, the content of the health diary is primarily stored locally on your device. We do not operate server-side storage for this core function and do not receive an automatic copy of your diary content.
This must be distinguished from data transfers triggered by the use of an additional function, a disclosure you choose, or services and settings of the operating system or distribution platform. These include in particular YouTube, Tally, weather services, the Community, e-mail, export recipients, watch, voice and assistance services, the App Store or Google Play including beta and diagnostic data, and operating-system backups. The respective recipients, data types, purposes and legal bases are described in particular in sections 9, 14, 15 and 16.
We are also responsible for the processing that the app carries out on your device, because we determine how the app handles your information. This applies even though we have no access to the content stored only locally. This is why we obtain your consent for the health data in the diary. For the Community and the voluntary survey, we use processors that process data only on our instructions. Apple and Google are independently responsible for their operating systems, stores and system services such as Siri, dictation, notifications and backups, as is the provider of any voice assistant you use. For a file or message that you pass on yourself, the recipient you choose is responsible from that point on.
4. Which data is processed
The app does not measure health values, does not read health sensors, does not import values from Apple Health or Health Connect and does not write any values there either. It does not use the camera. It uses approximate location and weather data only if you have switched on weather for entries (section 9.7). Depending on your entries and the functions you use, the app processes in particular:
- Master data and settings: chosen name, year or date of birth, gender, height, weight, language, and app, display, reminder, quiet-time, read-aloud, lock and function settings. • Health-related profile information: selected conditions and additions, diagnostic status and year of diagnosis, duration of complaints, smoking status, previous medication including biologics, and answers to setup questions. • Ongoing health entries: pain, stiffness, exhaustion, mood, sleep, stress, concentration, swelling, skin complaints and other symptoms, body regions including intensity and type, difficult days, condition-specific diaries, notes and your own answers. • Information on treatment and everyday life: medication, dosages, doses taken, missed doses, self-counted supply, reminder times, manual cycle records, movement sessions, routines, triggers you enter yourself, appointments, questions for appointments, experience notes on medications, free-text notes and voice notes. • Function and display data: the values intended for local widgets and complications and, after separate activation, for a watch app, as well as manual entries returned from there. • Weather for entries, after separate consent: the weather values for the hour of an entry and the provider; as long as a request is still pending, the rounded coordinates; and a cache with the retrieved hourly values and the rounded locations of the last 48 hours. • Community, after separately joining: the account, content, moderation and technical data listed in section 9.8; on the device, additionally your recovery key, your Community identifier and session data. • Feedback that you note down in the app: your text and the date, only on the device, until you pass it on yourself. • Recipes: your favourites and your shopping list, only on the device. • Consent and contract data: document identifier, version, time consent or agreement was given, current status and, where applicable, time of withdrawal. The complete wording of each released version is archived independently of individual users. • Technical diagnostic data: a local error log with timestamp, app version, device type, system version, type of error and the technical data field concerned, but without values from your entries; in addition, brief crash information that the operating system makes available to the app on the device, on Android where applicable as a local crash file with technical class names and code paths.
The app stores the timestamps used to display the voluntary survey only for as long as the “Weekly question” switch in the settings is turned on; when it is turned on is set out in section 9.2.
Technical accompanying data and metadata, such as membership of the tester group, access to certain health-related content or device and usage information, may permit conclusions to be drawn about health in the specific context. Where this is the case, we treat it as health data.
5. Purposes of processing
The core consent covers processing on the smartphone for the local health diary: storing entries and showing them again, displaying them over time or graphically on the basis of your own entries, providing local reminders and local widgets, performing local quick actions that you initiate, generating a PDF report or an export file, and re-importing an export file.
Independent optional purposes are activated separately. These include in particular the Apple Watch app, Wear OS synchronisation, making medication names and dosages available for Siri and Shortcuts, the assistant shortcuts on Android, dictation on Apple Watch, weather for entries and the Community. Loading a YouTube video and opening or submitting the voluntary Tally survey are triggered directly by your clearly identified action.
Recipes and the cards in the “Knowledge & everyday life” area are included in the app and work without a network connection; your recipe favourites and your shopping list remain on the device. If you open a link from a knowledge card, your browser loads the external page under the responsibility of its provider.
The app lock, the read-aloud function for fixed app texts, the consent record and the local technical error log pursue the technical purposes described in the respective sections. No purpose includes a medical assessment of your state of health.
6. Legal bases
Your explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR applies to health data. This applies to the core consent and to each separate consent to optional processing of health data.
Art. 6(1)(b) GDPR applies to non-health-related information and technical processing steps that are necessary to provide an app function you request. Art. 6(1)(c) in conjunction with Art. 7(1) GDPR applies to recording consent and handling data-subject rights. Art. 6(1)(f) GDPR applies to the local technical error log, the local Android crash file, the handling of other support requests and the secure provision of the legal text page. Our legitimate interests lie in error analysis, the secure provision of our information and the handling of your request.
The legal bases for voluntary disclosures and third-party services are additionally specified in the respective section, for weather for entries and the Community in sections 9.7 and 9.8.
You are under no statutory or contractual obligation to enter health information. The General Data Protection Regulation permits the processing of health data only in the cases set out in Art. 9(2) GDPR; for the diary, only your explicit consent comes into consideration. Without the core consent, the app may therefore not store any health information; since InflamAI is essentially this diary, the app then cannot currently be used any further. You can decline independent optional functions without losing the local diary.
7. Consent and withdrawal
Health data is information from which details about your physical or mental health emerge. The app processes such data on the basis of your explicit consent under Art. 9(2)(a) GDPR.
The core consent covers the local health diary, including local widgets and local quick actions that you initiate. Separate consent is obtained only for an independent optional purpose in which health data is processed for an additional function or transmitted to a platform or third-party service.
Depending on the additional function, you give consent via a purpose-specific switch or through the clearly identified action by which you load or start the specific function. No further consent is requested for individual data fields or individual technical transmission steps within the same described purpose. Optional consent can be withdrawn at any time with effect for the future; the other functions remain unaffected.
Optional functions are switched off by default. You can withdraw any consent at any time without giving reasons and with effect for the future. You withdraw optional consent via the associated switch and the consent for the Community by deleting your Community account in the app; the processing concerned ends and function-related copies that can be reached are cleared. The local diary and your other decisions remain unaffected.
Before final confirmation of the withdrawal of the core consent, the app offers an export. Upon confirmation, local reminders are removed, displays on widgets and paired devices that can be reached are cleared, and the health data is deleted from the app’s local storage. Export or report files you have created yourself, operating-system backups and copies that can no longer be reached are not deleted automatically. The lawfulness of processing carried out up to withdrawal remains unaffected. If you are a member of the Community, the app also removes the Community access data from your device in this process. Your Community account remains in place until you delete it; afterwards, you can only access it again with your recovery key.
If the purpose, data types, recipients or third-country connection of consent-based processing changes materially, you will be informed again before the changed processing begins and, where required, new consent will be obtained. Purely editorial or linguistic changes without an extension of processing do not trigger a new request.
Only people who are at least 16 years old may use InflamAI. From this age you can give the consents under this policy yourself (Art. 8(1) GDPR). During setup, the app asks for the date of birth and does not let younger people continue.
8. Access to your terminal device under Section 25 TDDDG
Storing and reading information required for the local health diary, local widgets, local quick actions you request, the consent record, the error log, the Android crash file and the Community access data serves the digital service expressly requested by you. Insofar as Section 25 TDDDG applies, no additional terminal-device consent is required for this under Section 25(2) no. 2 TDDDG.
Prior consent under Section 25(1) TDDDG is obtained for loading a YouTube video. For the non-essential timestamps used to display the voluntary survey, you give this consent during app setup when you tap “Continue” after agreeing to these legal texts. Below the line on the privacy policy, a note there states that the app occasionally asks how you are getting on with it, that for this purpose it remembers on your device when it last asked, and that this can be switched off in the settings at any time. You can withdraw it at any time via the “Weekly question” switch in the settings and grant it again in the same way. What applies after an update from an earlier version is set out in section 9.2. The survey itself runs in the browser under the responsibility of the survey provider.
The app reads the approximate location only if you have consented to weather for entries and allowed location access in the operating system; Section 25(1) TDDDG is an additional legal basis for this. On iPhone, the app reads the device token for notifications only if you are a member of the Community, have switched on reply notifications in your Community profile and have allowed notifications; it serves solely the notice about replies that you requested (Section 25(2) no. 2 TDDDG).
9. Routes by which data can leave your device
Each of the following routes requires an action, consent or separate setting by you. Complete diary entries are not automatically transmitted to us.
9.1 Exercise videos via YouTube
Videos are embedded via youtube-nocookie.com and load only after your express approval via the preceding loading screen. Before then, there is no connection to YouTube; the preview image is also generated locally.
When the video is loaded, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, receives in particular your IP address and technical access data. Further processing by Google LLC in the USA is possible. Diary entries are not transmitted; accessing a video within a health app may, however, permit conclusions to be drawn about health interests. Google is independently responsible for the video service.
The legal basis is your prior consent under Art. 6(1)(a) GDPR, additionally Art. 9(2)(a) GDPR where there is a possible health connection, and Section 25(1) TDDDG. According to its information, Google may use an adequacy decision, in particular the EU-U.S. Data Privacy Framework, or appropriate safeguards under Art. 46 GDPR for third-country transfers. The app remains usable without videos. Information from Google: https://policies.google.com/privacy.
9.2 Voluntary survey via Tally
The voluntary survey asks for your assessment of the app and is not intended for health data. It does not ask about your condition, diagnosis, symptoms or the severity of an illness, and no branch of the questionnaire depends on a state of health. Free-text fields state that no health data should be entered. At the end of each questionnaire, a mandatory field asks you to confirm that your answers may be evaluated; without this confirmation the questionnaire cannot be submitted. The survey runs in the browser; the app does not read the responses and does not prefill anything. It opens the same form address for all participants of the same language and does not pass any identifier or information from the app to Tally.
The request to take part appears in the app roughly every seven days and ends on 30 November 2026 at 23:59. You can dismiss it at any time without any disadvantage, using the close button at the top left or “Not now”; both have the same effect and neither is counted. With a new installation, you give the consent required for the associated timestamps during app setup; what applies after an update is set out in the next paragraph. In the settings you can turn the survey off at any time via the “Weekly question” switch and turn it back on in the same way; once it is off, no further request appears and no timestamp is updated. A switch that has been turned off stays off: agreeing to a new version of these texts does not turn it back on. Once the survey has ended, the switch is removed because there is nothing left to turn off.
Earlier versions of the app asked about the survey on a separate screen, and a refusal given there could not be reversed anywhere. That screen has been removed. If you agreed there, that remains the case. If you were never asked there or refused, the survey is switched on after the update until you turn it off using the switch; the app sets the timestamp to the time of the update. If you refused, the app also shows you a one-time notice explaining the new procedure, that every request can be dismissed and where the switch is located; if you were never asked, no such notice appears.
Tally BV, Sint-Pietersnieuwstraat 11, 9000 Ghent, Belgium, processes the responses for us as a processor under Art. 28 GDPR. According to Tally, form data is transmitted and stored in encrypted form and hosted in Europe. The providers named in Tally’s current list of subprocessors may process connection and operational data; third-country processing may occur in this context. According to Tally, it provides contractual data protection safeguards for this.
The legal basis for voluntarily opening and submitting the survey is Art. 6(1)(a) GDPR; Section 25(1) TDDDG applies to the timestamps used for the display. The survey is not intended for health data. If you nevertheless enter such information inadvertently, we do not use it for the survey and delete it without undue delay after becoming aware of it, unless a statutory obligation prevents this.
We delete every survey response no later than seven months after we receive it. For each individual response the period runs from the day it reaches us and is independent of the end of the survey; extending the survey period does not extend it. It applies in the same way to responses to earlier versions of the questionnaire, including those still held in a survey account used previously. According to Tally, after deletion by us it removes deleted form data from backups no later than within 90 days. Information from Tally: https://tally.so/help/gdpr.
9.3 Dictation on Apple Watch
If you activate the optional dictation function on Apple Watch, you can dictate health-related notes. The InflamAI app does not itself record any audio and receives the recognised text from the system input. Depending on the device, language and system settings, Apple may process what is spoken on the device or on servers; processing by Apple companies outside the EEA may occur. What is spoken may contain health data such as a pain value, a symptom or a medication name.
The function remains switched off until you have given your explicit consent. The legal basis for our processing is Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. Apple is independently responsible for its dictation and speech recognition service in accordance with Apple’s terms. Our app then stores only the recognised text for the diary entry you selected. You can withdraw your consent and type on the smartphone instead. Information from Apple: https://www.apple.com/legal/privacy/de-ww/.
9.4 Export and PDF report
You can generate an export file and a PDF report. Both are created on your device and may contain health data and, depending on the selection and export format, voice notes. The export file also contains the stored weather values; the PDF report does not contain any. You can also pass on a single day from the history as text. The app passes the file or text to the operating system’s share dialog. Only when you select a destination does the content reach the recipient you choose, not us.
The legal basis for generation is your core consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. Disclosure to the selected recipient is triggered solely by you. You can use the same share dialog to send a technical error log or feedback; you can inspect the content before sending it.
9.5 Store review and message to us
You submit a store review to Apple or Google. We do not transmit any diary entries in the process. If you tap “Contact Support” in the settings or want to report an example post in the Community, the app opens your e-mail app with the address help@inflamai.org; you determine the content. For all other matters, in particular regarding your rights under section 21 and for notices under the DSA, you can reach us at PaperNews-TS@gmx.de.
The mailbox PaperNews-TS@gmx.de is technically operated by GMX, a service of 1&1 Mail & Media GmbH, and the address help@inflamai.org via the iCloud Mail e-mail service of Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland; processing by Apple Inc. in the USA is possible there. In both cases, at least the sender and recipient addresses, timestamp, technical transmission data and message content are processed. We process your message for the purpose of responding under Art. 6(1)(b) GDPR if it concerns performance of the user contract and otherwise on the basis of our legitimate interest in handling enquiries under Art. 6(1)(f) GDPR.
Please do not send health data by e-mail. If we nevertheless receive such information inadvertently, we do not use it for handling the support request, delete it without undue delay after becoming aware of it unless a statutory obligation prevents this, and, where necessary, ask you to send a new message without health information. We delete other support correspondence once its purpose has been fulfilled and statutory retention obligations have expired, generally no later than after twelve months. Information from GMX: https://www.gmx.net/datenschutz/ and from Apple: https://www.apple.com/legal/privacy/de-ww/.
We handle notices of illegal content in the Community that you send us by e-mail in accordance with Art. 16 of Regulation (EU) 2022/2065 (Digital Services Act, DSA); the legal basis is Art. 6(1)(c) GDPR. We delete them six months after they have been resolved. We handle notices about example posts on the basis of our legitimate interest in the accuracy of our own content under Art. 6(1)(f) GDPR and likewise delete them six months after they have been resolved.
9.6 Siri, Shortcuts and voice assistant
On iPhone, you can make entries via Siri or the Shortcuts app without opening InflamAI and query the status of your diary. Whether you do so is your decision; each of these routes begins only with your own command and works only if you have agreed to the core consent. Siri asks for values that you speak or tap, such as pain, mood and exhaustion on a scale, the duration of morning stiffness, symptoms, an affected body region, a medication dose, a counter or an event entry, and passes them to the app; the app records a voice note itself. The app stores this information, like any other input, only on the device and responds with a confirmation that Siri displays or speaks. This response may contain health information, for example the pain value entered, the number of days with an entry in the last 30 days or the number of medications still due today.
The recipient of your voice input and of the responses is Apple. Depending on the device, language and system settings, Apple processes what is spoken on the device or on servers; processing by Apple companies outside the EEA, in particular in the USA, is possible. Apple is independently responsible for Siri and Shortcuts under its own terms. The legal basis for storing the entries in the app is your core consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR.
The optional provision of the names and dosages of your active medication to Siri and Shortcuts is separate from this. This function is switched off by default. Only after your explicit consent under section 5.3 of the consent to the processing of health data pursuant to Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR does the iPhone app make this information available to the system function; you can then select a medication by voice, and responses may name your medications. Information from Apple: https://www.apple.com/legal/privacy/de-ww/.
On Android, the app registers neutrally named shortcuts with the operating system only after your consent to “Assistant shortcuts” (section 5.3 of the consent to the processing of health data); through them, your device’s voice assistant can open an entry or create a counter or event entry. The names do not mention any diagnosis, and the app does not pass any health values to the assistant. The provider of the assistant is independently responsible for processing your voice input. On withdrawal, the app removes the shortcuts again.
The app remains usable without Siri, Shortcuts and the voice assistant. Audible output may be perceived by other people. You can withdraw the optional consents in the app settings and additionally manage Siri, Shortcuts or the assistant in the system settings.
9.7 Weather for entries
If you switch on weather for entries, the app requests the approximate location of your device once for a new check-in, a difficult day, a body map entry or a symptom entry, on iPhone with reduced accuracy and on Android solely via the permission for approximate location. It rounds the coordinates to about 10 kilometres (0.1 degrees, in Germany a grid of roughly 11 × 7 kilometres) and retrieves temperature, apparent temperature, humidity, air pressure, precipitation, weather conditions and wind, in a single request for all hours of the quarter of the day in which the entry falls (0 to 6, 6 to 12, 12 to 18 or 18 to 24 hours). As a result, the app makes no more than four requests per day for the same location. It keeps the retrieved hourly values with the rounded location in a cache on the device for no more than 48 hours, so that further entries in the same period do not trigger a new request. It does not retrieve weather for entries whose time is more than three hours in the past.
On iPhone, the recipient is Apple via the WeatherKit service. According to Apple, location information is used only to provide weather forecasts, is not associated with personal identifiers and is not tracked across requests; processing by Apple Inc. in the USA is possible. On Android, the recipient is OpenMeteo GmbH, Hintere Schilligmatte 6, 6463 Bürglen, Switzerland; for Switzerland there is an adequacy decision of the European Commission. According to its own information, Open-Meteo answers requests via servers in Europe and North America and keeps logs containing the IP address and the address requested, and thus also the rounded coordinates and the period requested, for up to 90 days. Information: https://www.apple.com/legal/privacy/de-ww/ and https://open-meteo.com/en/terms.
Only the rounded coordinates, the quarter of the day and the technically necessary connection data such as the IP address are transmitted. No health data and no content of the entry is transmitted. Because the request comes from a health app and at the time of an entry, it may nevertheless indicate that a health diary is being used. The legal basis is your explicit consent under section 5.6 of the consent to the processing of health data pursuant to Art. 6(1)(a) and Art. 9(2)(a) GDPR, and for location access additionally Section 25(1) TDDDG.
The app stores the weather values only locally with the respective entry and shows them on the entry and in the day view of the history. It does not include any weather values in the PDF report. It calculates no connection, evaluates nothing and predicts nothing. If the device is offline, the app keeps the rounded coordinates of an entry for no more than seven days in order to make up the request, and deletes them afterwards or as soon as the weather for that entry has been retrieved; in the cache, they remain for no more than 48 hours. On withdrawal, with “Delete weather data” in the settings and with “Delete All Data”, the app clears the cache immediately. Without your consent, the app neither requests the location nor contacts a weather service. You can switch it on during the setup of the app or later in the settings; in both cases it is initially switched off.
9.8 Community
The Community is a voluntary area of the app in which members write posts and replies in topic rooms, react with a heart or “Helpful”, report posts and block other members. You join it separately: from the age of 16, after agreeing to the Community rules and after giving your explicit consent under section 5.7 of the consent to the processing of health data. Your diary entries do not go into the Community.
The following is processed:
- Account: your public Community identifier, your username, your language, which follows the language of your app, the confirmation that you are at least 16 years old, the version and time of your agreement to the Community rules and to section 5.7, your setting for reply notifications, the status of your account and the date you joined; • Sign-in: a technical login identifier derived from part of your recovery key and, of the secret part, only a non-reversible check value; no e-mail address and no telephone number; • Content: your posts and replies with room, title, text, language and times, and your reactions, reports and blocks; • Moderation: measures concerning your posts and your account, including the reasons, and your appeals; • Technical data: with every connection, your IP address, the time, the interface called, the app and system identifier (user agent) and the approximate country derived from the IP address, in logs of the platform and of the sign-in service; • on iPhone, if you switch on reply notifications and allow notifications, the device token for notifications.
Your posts and replies are visible, with your username, only to members of the Community. If a post is written in a language other than that of the reading person’s app, the app shows its language code next to it. Posts held back for review and hidden posts are seen only by you and the moderation team, and reports only by the moderation team. Other members cannot see who reported or reacted to which post; they see only the number of reactions.
While the Community is still small, the rooms also contain posts and replies from example profiles. There is no real person behind them: we generated these profiles and their texts as examples, they were not written by real people, and we are responsible for them ourselves. They do not reflect the experiences of any particular person and are marked “Example” next to the username. You see the examples in the language of your app. You can react and reply to example posts; we process this like any other reaction or reply. The reporting function and blocking are not available for them; instead, “Report by email” on the post opens an e-mail to help@inflamai.org (section 9.5). As soon as a room has ten visible topics from members in one language, the server automatically hides the example posts in that language there, and in all languages at the latest 90 days after we posted them. Your replies to them remain visible to you in your profile and stored until you delete them or your account.
The Community runs on the platform of Supabase Pte. Ltd., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513, which processes the data as our processor under Art. 28 GDPR. The database is located in an Amazon Web Services data centre in Frankfurt am Main (region eu-central-1). Supabase uses sub-processors, including Amazon Web Services, Cloudflare and Supabase, Inc., which are based in the USA; requests pass through the Cloudflare network; for the server functions, the apps and the server expressly request the Frankfurt region. Processing outside the EEA, in particular in the USA and in Singapore, is nevertheless possible. For such transfers, the Supabase data processing agreement contains the European Commission’s standard contractual clauses; where a sub-processor is certified under the EU-U.S. Data Privacy Framework, that adequacy decision may additionally be relied upon. Information from Supabase: https://supabase.com/privacy.
The legal basis for the Community data is your explicit consent under section 5.7 of the consent to the processing of health data pursuant to Art. 6(1)(a) and Art. 9(2)(a) GDPR. We process the technical logs on the basis of our legitimate interest in secure, stable and abuse-protected operation under Art. 6(1)(f) GDPR. To limit registrations, we do not store the IP address in plain text but only as a check value salted anew each day, which we delete after 24 hours. Also to protect against abuse, the server records when an account sends posts, replies, reactions and reports and when it changes its language, and limits their number per period; we delete these events after two days.
Before sending in the app and once more before publication on the server, every post is automatically compared with fixed word lists containing certain terms relating to suicide and self-harm as well as insults and degrading slurs, and checked for telephone numbers, e-mail addresses and links that are not permitted; the server also checks for repetitions and too many posts in a short time. If the check in the app is already triggered, the text does not leave your device. If a post contains terms relating to suicide or self-harm, it is neither published nor stored, and the app shows helpline numbers; this only establishes whether these words occur and does not assess you or your situation. If it is only the server that is triggered, it counts, without any reference to you, only how often this happens on a given day. If you expressly send such a post for review, it is stored and visible only to you and the moderation team until it is approved. If at least three different members report a post, it is automatically hidden pending review. Restrictions, suspensions and exclusions of accounts are always decided by a human being.
For moderation, we process reported and held-back posts, reports and moderation measures on the basis of your consent under section 5.7 and, insofar as we fulfil obligations under Regulation (EU) 2022/2065 (Digital Services Act, DSA), under Art. 6(1)(c) GDPR. If we become aware of information giving rise to a suspicion of a criminal offence involving a threat to the life or safety of a person, we are obliged under Art. 18 DSA to inform the competent law enforcement or judicial authorities and to provide them with the information available. We comply with orders from authorities under Arts. 9 and 10 DSA only to the extent required by law.
On iPhone, you can be notified about replies to your posts. If you switch on reply notifications in your Community profile and allow notifications, the app transmits the device token for notifications assigned by Apple to the server. When there is a new reply, the server can then send you a notification via the Apple Push Notification service, with a general text such as “New reply” and a technical reference to the topic, without post content and without names. Apple processes the device token and the notification in doing so; processing by Apple Inc. in the USA is possible. You can switch reply notifications off in the Community or in the system settings. On Android, there are no push notifications; the app shows new replies only while it is open.
You can export your Community data as a file at any time in the app and delete your account in the app. On deletion, your profile, your reactions, blocks, appeals and device tokens are deleted, your identifier is removed from reports and moderation records, and your posts are, at your choice, deleted or continue to be displayed without any reference to you as posts by a “Deleted member”. We can no longer attribute anonymised posts to you afterwards; if a post itself contains information by which you can be recognised, delete it individually beforehand or choose complete deletion. “Delete All Data” in the settings removes only the access data on your device; your Community account then remains in place.
10. Microphone and voice notes
A voice note starts only when you initiate it yourself. The operating system requests microphone permission separately, and you can withdraw it in the system settings. The recording is stored as an audio file in the app’s local storage area. InflamAI does not transcribe the voice note or send it automatically. We do not receive your voice notes. Depending on the export you select, they may be included in an export file; you can delete each voice note individually.
11. Biometric app lock
The voluntary app lock using Face ID, Touch ID, fingerprint or device lock is switched off by default. Verification is carried out by the operating system. Biometric characteristics remain in the device’s secure area; the app receives only the result of the verification. We do not process biometric characteristics. The legal basis for the function activated by you is Art. 6(1)(b) GDPR.
12. Reminders
Reminders for check-ins, medication, supplies and routines as well as recipe cooking timers are scheduled and triggered on your device. We do not operate a push server for this purpose. The Android app may use system permissions for exact alarms and receipt on restart for this purpose; these serve solely to restore your local reminders. You can switch reminders and notification permission off at any time. Notifications about replies in the Community on iPhone under section 9.8 are separate from this.
13. Read-aloud function
The read-aloud function, which can be switched off, uses the system voice on the device. Under the current range of functions, only fixed app texts are spoken, not your diary entries. The function does not transmit these texts to a server operated by us. The legal basis is Art. 6(1)(b) GDPR.
14. Watch app, widgets and complications
Local widgets and complications display only the local display values intended for them. You can remove them at any time.
14.1 Apple Watch
The Apple Watch app is an independent optional function. After you activate it, InflamAI can transmit the following health data between the iPhone and the paired Apple Watch: current check-in values and entry status, medication names, dosages, dose times and dose status, selected pain regions, entry and counter values, and check-ins, medication doses, movement, complaint, cycle and event entries that you enter on the watch.
Transmission takes place via Apple’s WatchConnectivity between the iPhone app and the associated watch app. We do not receive this data. Apple provides the operating system, device pairing and transmission service and processes technical connection and device data under its own responsibility. An optional dictation function is separate from this and is described in section 9.3.
The legal basis for processing health data for watch use is your separate explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. Upon withdrawal, the app ends synchronisation and clears the health and display copies it can reach on the watch. Copies that cannot be reached must be deleted on the paired device or by removing the watch app.
14.2 Wear OS
The Wear OS app is an independent optional function. After you activate it, InflamAI can transmit the following health data between the Android smartphone and the paired Wear OS watch: current check-in values and entry status, medication names, dosages, dose times and dose status, selected pain regions, movement and counter values, and check-ins, medication doses, movement, complaint, cycle and event entries that you enter on the watch.
Transmission takes place via the Data Layer API of Google Play services. The recipient of technical transmission data is Google Ireland Limited; processing by Google LLC in the USA is possible. According to Google’s technical documentation, transmission may take place via Bluetooth or, if the devices are not directly connected, with end-to-end encryption via servers operated by Google.
The legal basis for processing health data for watch use is your separate explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. According to its information, Google may use an adequacy decision, in particular the EU-U.S. Data Privacy Framework, or appropriate safeguards under Art. 46 GDPR for a third-country transfer. Upon withdrawal, the app ends synchronisation and clears the health and display copies it can reach. Information from Google: https://policies.google.com/privacy.
15. App Store, Google Play, diagnostics and beta
Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, are each independently responsible for distribution, installation and updating. We may receive aggregated analyses from them regarding installation, stability and use of the distribution platform. Privacy information: https://www.apple.com/legal/privacy/de-ww/ and https://policies.google.com/privacy.
If you have agreed in the device settings to share analytics and diagnostic data, app crash and usage data may reach Apple or Google. This is an operating-system or store setting and not a separate analytics service built into InflamAI. You can manage sharing in the system settings. The analyses that the respective provider makes available to us depend on its platform terms and your settings.
During a test phase, we may receive beta information. With Apple TestFlight, this may include in particular the name and e-mail address of invited persons, installation status, session and crash counts, and feedback you submit together with a screenshot, device model and system version. In a closed Google Play test, we maintain the list of approved test addresses; we may also receive aggregated figures on installation, crashes and stability, as well as feedback you submit.
Because membership of the tester group for a health diary app may itself permit conclusions to be drawn about health, we treat personal beta information as health data in the specific context. Insofar as we process such data to organise a closed test, we obtain explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR before invitation or approval. You can withdraw consent; we then remove you from the tester group we manage and delete the beta information we hold unless statutory obligations prevent this, no later than three months after the end of the test phase. Independent processing by Apple or Google is governed by their respective terms.
16. Accessing the legal text page and Cloudflare
The legal texts are also available at app-data.inflamai.org. The page is provided using services of Cloudflare, Inc., 101 Townsend Street, San Francisco, California 94107, USA, and its subprocessors. In this context, Cloudflare processes in particular the IP address, date and time of access, address accessed, browser and device information, referrer, security events and other technically necessary connection data. The page also uses a Cloudflare function to protect the published e-mail address against automated harvesting.
The processing serves to provide the legal texts securely, stably and with protection against misuse. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure and reliable publication of the information required by law and contract. Insofar as Cloudflare stores information in or reads information from the terminal device, this occurs only to the extent necessary for the website service expressly requested, on the basis of Section 25(2) no. 2 TDDDG.
Cloudflare may process technical data outside the EEA, in particular in the USA. For restricted third-country transfers, Cloudflare’s current data processing agreement provides in particular for the European Commission’s standard contractual clauses and additional safeguards; where the requirements are met, an adequacy decision may also be relied upon. We do not store any additional access logs for the legal text page ourselves. Otherwise, the storage period for technical data is determined by the Cloudflare service used and Cloudflare’s policies. Information from Cloudflare: https://www.cloudflare.com/privacypolicy/.
17. No separate analytics service and no advertising
The app contains no separate analytics or tracking service and does not transmit diary content for analytics or advertising purposes. InflamAI contains no advertising, no sale of diary data, no disclosure for advertising purposes and no cross-app or cross-device tracking by us.
This must be distinguished from aggregated store, installation, stability and beta analyses under section 15 and technical security and connection data when accessing the legal text page under section 16 and in the Community under section 9.8.
18. No automated decision-making
No decision based solely on automated processing that produces legal effects or similarly significantly affects you within the meaning of Art. 22 GDPR takes place. Nor does profiling within the meaning of Art. 4(4) GDPR take place. The app does not use your information to evaluate personal aspects automatically or to create a health, behavioural or risk profile about you. It calculates no health or risk score and forms no risk or severity class. The displays reproduce your own entries over time or graphically. The app does not relate weather values to your information. The automated checks in the Community hold a post back or hide it pending review; restrictions and suspensions of accounts and appeals are always decided by a human being. Posts appear in order of their most recent activity, not according to your health information.
The app uses neither machine learning nor artificial intelligence for your entries, and it contains no model that predicts flares, the course of a condition or risks. Because your diary entries do not reach us, we do not use them for research or for training such models either.
19. Security
We implement technical and organisational measures under Art. 32 GDPR. Core processing is designed for local storage. On iOS and Android, data is stored in storage areas provided for the app and protected by the operating system. Protection also depends on an activated device lock, an up-to-date operating system and secure handling of export and report files. Insofar as the app itself establishes network connections to external endpoints, encrypted HTTPS connections are used. The optional app lock provides additional access protection.
For the Community, all connections are encrypted. Access to the database is restricted row by row, and every change runs through vetted server functions. The app stores the recovery key and session data on iPhone in the keychain without iCloud synchronisation and on Android encrypted with a key from the Android Keystore; on the server, only a non-reversible check value of the secret part of the key is held. Notifications contain no post content.
On Android, operating-system backups and device transfer are disabled for the app according to the current technical implementation. On iOS, the storage areas containing ongoing diary records, including the medication list, widget values, voice notes and weather values, are excluded from iCloud backup. Depending on the system configuration, the name, date-of-birth information, gender, information from the initial setup and individual settings may, however, be included in an iCloud backup. If you also wish to exclude this, disable backup for InflamAI in the iPhone settings.
20. Storage period, deletion and data portability
Your local entries remain stored for as long as the core consent remains in effect and you wish to retain them. You can delete individual entries, remove local app data using “Delete All Data”, withdraw the core consent after being offered an export, or delete the app.
Upon optional withdrawal, the function concerned is disabled and the function-related copies that the app can reach are cleared. Operating-system backups, export and report files you have created yourself and copies on a paired device that can no longer be reached may remain after deletion in the app and must be removed at their respective storage locations.
The local consent record contains no diary content. It comprises the document identifier, version, time consent or agreement was given, current status and, where applicable, time of withdrawal. “Delete All Data” or removing the app may also delete this local record. Independently of this, we retain each released text version without reference to individual users.
We delete support messages once their purpose has been fulfilled and statutory retention obligations have expired, generally no later than after twelve months. We delete survey responses no later than seven months after we receive them; this period applies regardless of when the respective survey ends. We do not receive a copy of your diary entries.
Stored weather values remain locally with your entries until you delete them in the settings, choose “Delete All Data” or remove the app; the app deletes pending rounded coordinates after seven days at the latest and the cache of hourly values after no more than 48 hours.
The following periods apply to the Community:
- Account and profile data: until you delete your account; • Posts and replies: until you delete them or your account; on deletion of the account, deleted or anonymised at your choice; this also applies to posts that the moderation team has hidden or removed and to posts awaiting review: they remain stored unchanged, visible only to the moderation team and, if hidden or awaiting review, to you, and have no separate deletion period; • Reactions and blocks: until you remove them or delete your account; • Reports: six months after they have been resolved; • Moderation log: 24 months after the measure concerned; appeals together with the associated measure; • Events used to limit posts, replies, reactions, reports and language changes: two days; check values of the IP address at registration: 24 hours; • Device tokens for notifications: until you switch off reply notifications, sign out, delete your account or Apple reports them as invalid, at the latest once they have not been renewed for 270 days; • Daily count of posts not published because of terms relating to suicide or self-harm (date and number only, without text and without reference to any person): 13 months; • Session data of the sign-in service, including IP address and user agent: as long as the session is used, at most 30 days after its last use; • Technical logs of the platform and audit logs of the sign-in service: no more than 30 days.
The export function provides a structured, re-importable file and a PDF report, thereby supporting the exercise of your right to data portability under Art. 20 GDPR. For the Community, there is a separate export of your data stored there.
21. Your rights
Subject to the statutory requirements, you have in particular the following rights:
- access under Art. 15 GDPR, • rectification under Art. 16 GDPR, • erasure under Art. 17 GDPR, • restriction of processing under Art. 18 GDPR, • data portability under Art. 20 GDPR, • withdrawal of consent given under Art. 7(3) GDPR, • objection to processing based on legitimate interests under Art. 21 GDPR, and • complaint to a supervisory authority under Art. 77 GDPR.
For your Community data, you obtain access and a copy yourself in the app: the Community export provides the data stored for your account as a file. You can also delete posts and your account in the app. Because we know neither your name nor your e-mail address, we can only attribute a request made by e-mail to a Community account if you provide us with suitable information for this purpose; never pass on your recovery key in doing so.
You can view, rectify, delete and export locally stored diary entries in the app. We cannot ourselves provide access to, modify or delete data that we do not hold. If your request concerns messages, survey responses, beta information, website processes or other data held by us or our processors, write to PaperNews-TS@gmx.de. As a rule, we respond to requests within one month in accordance with Art. 12(3) GDPR.
You may object under Art. 21 GDPR, on grounds relating to your particular situation, to processing based on Art. 6(1)(f) GDPR.
22. Right to lodge a complaint with a supervisory authority
Under Art. 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority. You may in particular contact a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement.
For the controller at its registered office, the competent authority is the Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz, Hintere Bleiche 34, 55116 Mainz. Further information: https://www.datenschutz.rlp.de/.
23. Governing language version, version and new processing operations
The source text is the German version. Translations are intended to convey the same content in an understandable way. Mandatory data protection and consumer rights are not restricted by linguistic discrepancies.
For new or materially changed processing operations, the information required under Art. 13 GDPR will be provided in good time. Where new consent is required, it will be obtained before processing begins. Purely editorial changes without an extension of consent-based processing do not lead to a new consent request.
Status of this version: 17 October 2026, version 3.9.
InflamAI