Privacy Policy

1. Who we are

Habiglow (the mobile app and the website habiglow.eu) is operated by Maroš Kuzemka, sole trader (Slovak Republic), company ID (IČO): 57935700, place of business: Nová Sedlica 8, 067 68 Nová Sedlica, Slovakia (“we”, “us”). We are the controller of your personal data under the EU General Data Protection Regulation (GDPR) and Slovak Act No. 18/2018 Coll. on personal data protection.

Questions about your data: [email protected]. We have not appointed a data protection officer – it is not required under Article 37 GDPR.

2. Data that stays only on your phone

Everything you enter in Habiglow is stored only on your device, in the app’s own storage. We do not receive it and cannot see it:

• your name or nickname, your goals and focus areas,
• your habits, daily entries, the “how is today feeling” choice and statistics,
• your journal entries and weekly reflections,
• your children’s details that you enter – name or nickname, age and an animal avatar – their tasks, stars, rewards, collection and challenges,
• reminder settings (reminders are scheduled locally on your phone; we do not run a push server).

You can delete all of it at any time in the app (More → Delete data and start over) or by deleting the app. If you lose or reset your phone without an account, this data cannot be recovered by us.

3. Data we process

• Subscription (Habiglow Pro): you buy and manage the subscription through the Apple App Store or Google Play. To confirm that your subscription or free trial is active, we use RevenueCat, which receives a random (pseudonymous) app user ID, the IP address of the request, purchase and receipt details (product, dates, status), country and the type of device and operating system. We never see your name, card or payment details – those stay with Apple or Google. Legal basis: performance of the contract (Article 6(1)(b) GDPR). This data is necessary to provide Habiglow Pro – without it the subscription cannot be verified.
• Support: if you e-mail us, we process your e-mail address and the content of the message to answer you. Legal basis: our legitimate interest in answering, or the contract (Article 6(1)(f) or (b) GDPR). Giving us your e-mail is voluntary, but we cannot reply without it.
• Website: when you visit habiglow.eu, Cloudflare processes technical data (IP address, browser, time) to deliver the site and protect it against attacks. The website uses no analytics, no advertising and no tracking cookies. Legal basis: legitimate interest in a secure website (Article 6(1)(f) GDPR).

The app contains no advertising and no analytics or tracking tools. We do not sell or share your data for advertising, and we do not use it for profiling or automated decision-making.

The app currently has no user accounts. If we add an optional account (for example to restore your data on a new phone), we will update this policy before the feature is available and ask for your explicit consent where the law requires it.

4. Children

Habiglow is intended for adults – parents and caregivers aged 18 or over. Children do not have accounts and do not sign in. The kids mode is used together with a parent on the parent’s own phone or tablet.

You decide what you enter about your child. We recommend using a nickname. Your child’s data stays on your phone. We do not knowingly collect personal data directly from children, and the kids mode contains no ads and no third-party tracking. If your subscription has ended, the app shows the subscription screen, which is meant for you as the parent.

5. Your journal

Journal entries and your daily mood may contain very personal thoughts. They stay on your phone – we never receive, read or analyse them.

6. How long we keep data

• Data on your phone: until you delete it or the app.
• Subscription records at RevenueCat: while the subscription is active and at most 3 years after it ends, unless you ask us to delete them earlier.
• Support e-mails: as long as needed to resolve your request, at most 3 years.
• Website technical logs: short-term, usually up to 30 days.

To delete your subscription record at RevenueCat or your support e-mails earlier, write to [email protected].

7. Who helps us (processors and recipients)

• Apple (App Store) and Google (Google Play) – distribution of the app and sale of the subscription. They act as sellers under their own terms and privacy policies.
• RevenueCat, Inc. (USA) – processor for confirming subscriptions and free trials.
• Cloudflare, Inc. (USA) – processor for hosting and security of the website and forwarding e-mails sent to our addresses.
• Google LLC (Gmail) – our support mailbox; for this service Google acts as an independent controller under its own privacy policy.

Our processors are bound by data processing agreements to protect your data at least as well as described in this policy.

Transfers outside the EU: RevenueCat – standard contractual clauses (Article 46(2)(c) GDPR); Cloudflare and Google – standard contractual clauses (Article 46(2)(c) GDPR) and, where the provider is certified, the European Commission’s adequacy decision for the EU–US Data Privacy Framework (Article 45 GDPR). You can request a copy of the safeguards at [email protected].

8. Your rights

• access to your data and a copy (Article 15 GDPR),
• rectification (Article 16),
• erasure (Article 17),
• restriction of processing (Article 18),
• data portability (Article 20),
• objection to processing based on legitimate interest (Article 21).

To use your rights, write to [email protected]. We will answer within one month (for complex requests this can be extended by two more months; we will tell you). You can also file a complaint with the supervisory authority: Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27, Slovakia, www.dataprotection.gov.sk – or with the authority in your country.

9. Changes

If we change this policy, we will publish the new version here and, for important changes, let you know in the app.