Privacy Policy for the InflamAI Apps
Key points at a glance
This is an overview; the complete mandatory information is set out in sections 1 to 25.
The controller is Paper News TS UG (haftungsbeschränkt), Hellenstraße 41, 56179 Vallendar. InflamAI is a diary that works on your device: no user account, no server, we never see your records.
Your entries about complaints, medication and your condition are health data. The app processes them because you gave your express consent on first launch. Optional routes to Apple or Google are only activated after an additional, function-specific consent. Before withdrawing the core consent you can export; on final confirmation the health data is deleted from the app (sections 7 and 21).
Data leaves your device only in the ways described below: a video service receives technical retrieval data when a video is played, Tally receives voluntary survey answers, and recipients chosen by you receive an export or a message. Spoken health information and selected values for an Android watch may reach Apple or Google after separate consent (sections 9 and 14). Diagnostic, beta and backup processes additionally depend on your device settings (section 15).
You determine the storage period and can view, change, delete and export everything. Because there is no server copy, the data is lost if the device is lost; so export regularly. You can complain to a data protection supervisory authority at any time (section 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, register court Amtsgericht Koblenz, HRB 29671, VAT ID No. DE355604227, telephone +49 172 7858026, e-mail [email protected]. This address applies to all data protection matters.
2. Scope
This policy applies to the InflamAI app for iPhone and Android, in each case with the watch app (Apple Watch or Wear OS), widgets and complications; we name platform differences expressly. InflamAI is a diary for people with chronic inflammatory conditions and is expressly not a medical device within the meaning of Regulation (EU) 2017/745; it provides no diagnosis, prognosis or treatment recommendation. For data questions, this policy and the consent declaration take precedence over the terms of use. We operate no server: there are no log files, no stored IP addresses and no cookies on our side.
3. The principle: your records stay on your device
InflamAI works entirely on your device; we have no access to your entries at any time. The app contains no third-party analytics service, no advertising service and no crash reporting service. The iOS app uses exclusively Apple building blocks; the Android app additionally uses the usual Google libraries for the interface, the database and the watch connection. Your entries leave your device only through your own actions (section 9) or through the device settings described in sections 14 and 15.
4. What data arises in the app
All information comes from you. The app measures nothing, reads no sensors and takes over no values from other apps; there is no connection to Apple Health or Health Connect, no location reference and no weather function. Depending on use, the following is stored:
- About you: chosen name, year or date of birth, gender, height, weight, language.
- About your condition: selected conditions with additions, diagnosis status and year, duration of complaints, smoking status, previous medication including biologics.
- Your answers to the setup questions, depending on the condition selected.
- Ongoing entries: daily check-in (pain, stiffness, exhaustion, mood, sleep, stress, concentration, swelling, skin), body regions with intensity, flares, condition-specific journals with your own measured values and notes.
- Medication (name, dosage, doses taken, self-counted supply) and cycle records, each entered by hand.
- Exercise sessions and routines, appointments with questions, your own short questions and answers, trigger and free-text notes, voice notes as audio files, feedback to us.
- Settings (reminder and quiet times, speech output, appearance, app lock, Siri switch). Insofar as the app stores time markers for displaying a voluntary survey, this only happens after your separate consent under Section 25(1) TDDDG (German act on data protection in telecommunications and digital services).
- The record of your consents: version, time and the wording of the version you agreed to.
- A technical error log (time, app version, device type, system version, error type, affected data field) without any values from your entries; in the Android app additionally a crash file containing only technical class names and code paths, because error message texts are not recorded. "Delete All Data" removes both.
From this the app derives a few display values for the widget and the watch (such as the number of days with entries). Much of this information constitutes health data under Art. 9(1) GDPR; what follows from that is set out in section 7.
5. Purposes
The core consent covers the local health diary: storing entries, displaying them again and presenting them chronologically and graphically on the basis of your own input, local reminders, display in local widgets and on a directly paired Apple Watch, export and PDF report as well as re-importing an export file. Speech output, app lock, consent record and error log process no substantive health information for their own purposes. For Android watch synchronisation via Google, voice commands or dictation via Apple or Google, and for making medication names available to Siri/Shortcuts, we obtain an additional, function-specific consent in each case. No purpose includes assessing your state of health medically (section 17).
6. Legal bases
For health data, your explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR applies (section 7). This applies both to the core consent and to every separate consent to an optional function. For information without a health reference (name, language, settings) the basis is Art. 6(1)(b) GDPR. For the record of your consents and the handling of your rights, Art. 6(1)(c) in conjunction with Art. 7(1) GDPR applies. For the purely technical error log and the crash file, our legitimate interest under Art. 6(1)(f) GDPR in an app whose behaviour can be traced in the event of an error applies; neither contains values from your entries and both stay on your device. For the routes described in section 9, the basis is stated there in each case.
Whether you have to provide information: you are neither legally nor contractually obliged to enter anything; every field is voluntary, and you suffer no disadvantage if you provide nothing. The app simply cannot then fulfil its purpose. Without consent to the processing of your health data you cannot use the app; this is not a coupling to an extraneous consideration but follows from the fact that the app consists of nothing other than your own records.
7. Your consent and its withdrawal
Health data is all information from which something about your physical or mental health can be inferred; in InflamAI these are the entries, journals, medication, cycle, appointments, notes and voice notes named in section 4, as well as the health-related profile information (including gender and date-of-birth information, because they stand in the context of an illness diary). The app processes this data exclusively on the basis of your explicit consent. We obtain the core consent on first launch in a separate step, kept apart from the terms of use and the privacy policy. Optional transfers to Apple or Google receive their own consents immediately before their first activation; they are switched off by default and are not a prerequisite for the local diary. The app records which version you agreed to and when, and stores its wording on your device; in addition we keep every text version we have shipped and will send it to you on request.
You can withdraw any consent at any time without giving reasons, with effect for the future. You withdraw optional consents via the respective switch; the transfer concerned is ended and local display copies are cleared, insofar as the app can access them. Before the final confirmation of the withdrawal of the core consent, the app offers you a complete export. On confirmation, reminders are cancelled, displays on the widget and watch are cleared and the health data is deleted from the local app storage. Export or report files you have created yourself, and operating system backups, are not deleted automatically; you have control over those. The lawfulness of the processing carried out up to that point remains unaffected; you can consent again at any time.
If we substantially change purposes or scope of a processing operation, the existing consent continues to apply only to the purposes already described. New or extended purposes remain switched off until you have expressly agreed to them. Purely linguistic changes without a new purpose do not require renewed consent.
8. Access to your device (Section 25 TDDDG)
Storing your entries, the shared storage area for local widgets and the directly paired Apple Watch, the consent record including its wording, the error log and the crash file are necessary for the diary service you have expressly requested; no additional device consent is required for this under Section 25(2) no. 2 TDDDG. For loading an exercise video and for non-essential time markers for displaying a voluntary survey, we obtain consent in advance under Section 25(1) TDDDG. The survey itself runs in the browser under the responsibility of the survey provider.
9. Ways in which data can leave your device
Each of the following routes requires an action or a separate setting by you. There is no automatic transmission of complete diary entries to us. For optional routes on which health data may reach Apple or Google, we obtain a separate explicit consent before first activation.
9.1 Exercise videos (YouTube)
Videos are embedded via youtube-nocookie.com and only load after your express release; before that there is no connection, and even the preview image is generated locally. When loading, Google (Google Ireland Limited, Dublin; processing by Google LLC in the USA possible) receives your IP address together with technical retrieval data. Diary entries are not transmitted; however, retrieving a video within a health app may allow conclusions to be drawn about health interests. Google is independently responsible for the video service. The legal basis is your prior consent (Art. 6(1)(a), and where there is a possible health reference additionally Art. 9(2)(a) GDPR, as well as Section 25(1) TDDDG). For a transfer to the USA, Google states that it may rely on the EU-U.S. Data Privacy Framework and, in addition, on appropriate safeguards. Without videos the app remains fully usable.
9.2 Voluntary survey (Tally)
The survey asks for your assessment of the app, not about your health; the free-text fields expressly point out that no health data should be entered. It runs in your device's browser; the app reads nothing from it and pre-fills nothing. Tally BV (Ghent, Belgium) processes the answers for us as a processor under Art. 28 GDPR. According to Tally's information, form data is stored encrypted via Google Cloud in Belgium; Cloudflare and other providers named in Tally's current sub-processor list may process connection or operating data (https://tally.so/help/gdpr). Processing of connection data in the USA is possible; for this, according to the providers' statements, the EU-U.S. Data Privacy Framework or other appropriate safeguards are used. The legal basis for opening and submitting is your consent under Art. 6(1)(a) GDPR and, insofar as device information is not necessary, Section 25(1) TDDDG. The survey is not intended for health data. If you nevertheless enter such information inadvertently, we will not use it and will delete it without undue delay once we become aware of it; please do not send us any health information for this purpose. We delete survey answers no later than twelve months after the end of the survey; according to its own information, Tally removes deleted data from backups within 90 days as well.
9.3 Dictation on the watch
On both watches you can dictate a note after separate explicit consent. The app itself makes no audio recording and receives only the recognised text from the system input. Whether recognition runs on the device or on servers is determined by the device, the language and the system settings; what is spoken, for example a pain value or a medication name, may go to Apple or Google and may also be processed in the USA. Apple and Google respectively are independently responsible for their speech recognition and, according to their own statements, may rely on the EU-U.S. Data Privacy Framework or other appropriate safeguards. Our processing is then limited to storing the recognised text locally. You can withdraw the dictation consent at any time and type on the phone instead.
9.4 Export via the share dialogue
You can have the complete export file and a PDF report generated at any time; both are created on your device and contain your entries including voice notes. The app passes the file to the operating system's share dialogue; only when you select a destination does it leave the device, to the recipient you have determined, not to us. The legal basis is your explicit consent (Art. 6(1)(a), Art. 9(2)(a) GDPR); at the same time we thereby fulfil Art. 20 GDPR. Via the same dialogue you can send us the error log or feedback; that too only at your instigation and after you have seen the content.
9.5 Store review and message to us
You give a review to Apple or Google; we transmit nothing in the process and do not learn who has reviewed. If you write to us, the app opens your e-mail app with our address; you determine the content. Our mailbox is technically operated by GMX, a service of 1&1 Mail & Media GmbH. In the process at least the sender and recipient address, time stamps, technical transmission data and the message content are processed; the provider's information is available at https://www.gmx.net/datenschutz/. We process your message in order to answer it under Art. 6(1)(b) or (f) GDPR. Please do not send health data by e-mail. If we nevertheless receive such information inadvertently, we will not use it, will delete it without undue delay once we become aware of it and will, if necessary, ask for a new message without health information. We delete other support correspondence as soon as it is no longer needed and no retention obligation stands in the way, as a rule no later than after twelve months.
9.6 Siri, Shortcuts, assistant
Individual functions can be triggered via voice assistance; the app can be operated fully without it. Making medication names and dosages available to Siri/Shortcuts and the processing of spoken health information are explained separately and are switched off by default. Only after your respective explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR does the iPhone app make the released information available to the system function, or does the voice assistance process your words. Apple or Google may also process voice data in the USA and are independently responsible for their service; according to their own statements, the EU-U.S. Data Privacy Framework or other appropriate safeguards are used. We do not learn what you have said. Information may be reproduced audibly; bear in mind anyone listening. You can withdraw any optional consent in the app or system settings.
10. Microphone and voice notes
A recording only starts if you trigger it yourself; the system asks for the microphone permission separately and it can be withdrawn at any time. Recordings are held as audio files in an area accessible only to the app; no transcription takes place, and the iOS app deliberately does not integrate the speech recognition component. We do not receive your voice notes; they are included in the export (9.4), and you can delete each one individually.
11. Biometric app lock
The voluntary lock, switched off by default (Face ID, Touch ID, fingerprint, device lock), is checked by your operating system; biometric characteristics remain in the secured area of your device, and the app receives only the result of the check. We process no biometric data within the meaning of Art. 9 GDPR. The legal basis for switching it on is your consent (Art. 6(1)(a) GDPR).
12. Reminders
Reminders (check-in, medication, supply, routines) are scheduled and triggered entirely on your device; there is no push service, no registration via a server, and no content leaves the device. The Android app additionally uses the system permissions for exact alarms and for receiving the boot event; both serve only your reminders and transmit nothing. You can switch off reminders and the notification permission at any time.
13. Speech output
The speech output, which can be switched off, uses your operating system's voice on the device; no text goes onto the internet. Only fixed app texts are spoken (Android: the breathing exercise instructions; iOS: currently a sample sentence in the settings), never your entries. The legal basis is Art. 6(1)(b) GDPR.
14. Watch, widgets and complications
Watch, widget and complication read only the display values intended for them from a protected storage area. On the iPhone, watch synchronisation runs directly via the device pairing. On Android it is handled by the wearable service of Google Play services; the recipient is Google Ireland Limited, and further processing by group companies, in particular Google LLC in the USA, is possible. Android watch synchronisation remains switched off until you have given separate explicit consent to it under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. According to its own information, Google may rely on the EU-U.S. Data Privacy Framework or other appropriate safeguards. No data reaches us. If you withdraw, the app ends the synchronisation and clears the display copies it can reach. Widgets can be removed at any time.
15. App Store, Google Play, diagnostics, beta
Apple (Apple Distribution International Ltd., Cork) and Google (Google Ireland Limited, Dublin) are independently responsible for distribution, installation and updating; only aggregated evaluations from this reach us. Their privacy information: https://www.apple.com/legal/privacy/de-ww/ and https://policies.google.com/privacy.
If you have agreed in your device settings to share analytics and diagnostic data, crash and usage data from the app may go to Apple or Google; this is a setting of your device, not a function of our app, the providers are independently responsible (DPF-certified), and you can switch the sharing off at any time. This data does not reach us.
During the test phase, beta information reaches us. On the iPhone the test runs via Apple TestFlight: we receive the name and e-mail address of the invited tester, installation status, session and crash counts as well as submitted feedback including screenshots, device model and system version. On Android it runs as a closed test via Google Play: we maintain the list of approved test addresses; from Google we additionally receive aggregated figures on installations, crashes and stability as well as feedback that you submit via the Google Play test function. Because membership of the tester group of an illness diary app can in itself suggest something about health, we treat all of this information like health data; the legal basis is your explicit consent (Art. 9(2)(a) GDPR), which we obtain before the invitation or activation — without it we invite no one. You can withdraw it at any time; we will then remove you from the tester group and delete your information, at the latest three months after the end of the test phase. Apple for TestFlight and Google for Google Play are at the same time independently responsible.
16. No tracking, no advertising
No advertising identifier, no cross-device or cross-app tracking, no identifier of our own that would make you recognisable, no usage profile, no sale of data, no disclosure for advertising purposes, no usage statistics. Crashes and errors appear exclusively in the local log (section 4); there is no automatic transmission.
17. No automated decision-making
There is no decision based solely on automated processing which produces legal effects or similarly significantly affects you within the meaning of Art. 22 GDPR. Likewise there is no profiling within the meaning of Art. 4(4) GDPR: the app does not use your information to evaluate personal aspects automatically or to form a health, behaviour or risk profile about you. It calculates no health or risk score and forms no risk or severity class. It uses neither machine learning nor artificial intelligence for your entries; displays reproduce solely your own input in chronological and graphical form. If you operate the app via Siri or an assistant, the voice function works under the responsibility of Apple or Google (9.6).
18. Security
We take measures under Art. 32 GDPR that correspond to the protection required for health data; the most effective protection is the design itself — what is not transmitted cannot be intercepted. iOS stores the data with file protection classes that tie access to the unlocked state; the stores holding your records (including the medication list, widget values and voice notes) are excluded from the iCloud backup; what can end up in a backup and survive deletion there are the name, date-of-birth information, gender, your answers from the initial setup (selected conditions, the medication and pain regions stated there, and further setup answers) and individual settings values; anyone who wants to exclude that as well should exclude InflamAI from the backup. Android: backup and device transfer are switched off completely, and the data is held in the system-encrypted area accessible only to the app. Connections made by the app run without exception over HTTPS; in addition, the biometric app lock protects it if you wish.
19. Storage period and deletion
Your entries remain stored for as long as the core consent exists and you wish to keep them. You delete individual entries in the app, everything at once via "Delete All Data", or by removing the app. Before withdrawing the core consent you can export; on final confirmation the health data is deleted from the local app storage. A minimal local record of the version and time of consent and withdrawal contains no diary content and serves solely the accountability obligation under Art. 7(1) GDPR; "Delete All Data" or removing the app deletes this record too. Operating system backups, display copies on a paired device that can no longer be reached, and export and report files you have created yourself may survive deletion in the app and must be removed by you at the respective storage location. We have no copy of your diary entries. We delete support messages once their purpose is fulfilled, as a rule no later than after twelve months; survey answers no later than twelve months after the end of the survey. We delete health data transmitted inadvertently without undue delay once we become aware of it.
20. Data portability
The app hands your data out to you as a structured, machine-readable export file (which can be read back in) and as a PDF report; with this you exercise Art. 20 GDPR directly in the app (9.4).
21. Your rights
You have the following rights: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), withdrawal of consents given (Art. 7(3)), objection to processing based on legitimate interests (Art. 21) and complaint to a supervisory authority (Art. 77 GDPR, section 22).
Because your diary data is held only on your device, you exercise access, rectification, erasure and portability directly in the app. We ourselves can neither provide information about these entries nor change them, because they are not available to us (Art. 11 GDPR). Before withdrawing the core consent, the app offers an export; afterwards the health data is deleted on final confirmation. If you wish to restrict a processing operation, or if your request concerns messages, survey answers or other data held by us, write to [email protected]. We will mark the data concerned and, during a justified restriction, process it only in accordance with Art. 18 GDPR. We reply in principle within one month (Art. 12(3) GDPR). You can object at any time and without formality to processing based on legitimate interests under Art. 21 GDPR; grounds relating to your particular situation are sufficient.
22. Supervisory authority
You can lodge a complaint with the supervisory authority of your place of residence, place of work or the place of the alleged infringement. The authority responsible for us: Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz, Hintere Bleiche 34, 55116 Mainz, Germany.
23. Who the app is intended for
InflamAI is aimed at adults who wish to document their chronic inflammatory condition themselves; it is not aimed at children and adolescents and is not marketed to them (no offer within the meaning of Art. 8 GDPR). No age verification takes place. If a minor has nevertheless created entries, they or a person with parental responsibility should remove them via "Delete All Data"; they are not available to us. Only enter information about your own health.
24. Changes to this policy
We adapt this policy when the app or the legal situation changes; the version stored in the app, with its number and date, is authoritative. In the event of substantial changes we will point this out in the app and, where necessary, obtain fresh consent (section 7). For new purposes we will inform you in advance and obtain your consent.
25. Governing language version
The source text is the German version. Translations are intended to convey the same content in an understandable way. Mandatory data protection rights and other mandatory consumer rights are not restricted by linguistic discrepancies.
Version 3.5, as of 20 August 2026.
InflamAI