Privacy Policy

1. Scope of this policy

This policy applies to the Daily+ mobile application, the Daily+ API that backs it, and this website. It describes processing carried out by Daily+ as data controller under Regulation (EU) 2016/679 (GDPR).

Daily+ is a local-first application. The default state of the app is that your data is stored in a SQLite database on your device and is never transmitted anywhere. Creating an account, joining a household, restoring a purchase, and using an AI feature are each separate, optional acts that cause specific categories of data to leave the device — each is described below.

2. Who is responsible for your data

The controller for the processing described here is Daily+ (sole trader — registered entity TBC before launch), Registered address TBC before launch, Romania.

You can reach us about anything in this policy at privacy@dailyplus.app.

We have not appointed a Data Protection Officer. Our core activity is not large-scale monitoring or large-scale special-category processing, so Art. 37(1) does not currently require one; we will appoint and publish a DPO here if that changes.

3. What we process

The table below lists every category of personal data involved and where it is held. "On device only" means the data is written to the local database and is not transmitted to us at all.

4. Why we process it, and on what legal basis

Every processing activity has a stated purpose and a single lawful basis under Art. 6, plus an Art. 9(2) condition where special-category health data is involved. Where the basis is consent, you may withdraw it at any time — withdrawal does not affect the lawfulness of processing carried out before you withdrew.

5. Health data

Health and fitness data is special-category data under Art. 9(1). We process it only with your explicit consent under Art. 9(2)(a), and we ask for that consent separately from the general terms — accepting the Terms of Service is not treated as consent to health processing.

With your permission the app reads from and writes to Apple Health (iOS) or Health Connect (Android): workouts, weight and body measurements, sleep, nutrition, hydration, heart rate and related vitals. You choose which categories to allow and you can revoke the permission at any time in your device settings; revoking it stops all reading and writing immediately.

Health data is used only to show you your own logs, trends and insights. It is never sold, never used for advertising, never shared with a third party for that third party’s own purposes, and never used to train an AI model. Health data leaves your device only if you turn on sync, share an item with a household, or submit it as part of an AI request — each of which is an explicit action you take.

6. AI processing

Daily+ has optional AI features: an assistant, photo-to-food recognition, recipe import, and a weekly review. They are premium features and they run server-side — the model does not run on your device.

When you use one, the content of that request is sent from your device to our API, and from our API to a large-language-model provider acting as our processor. We send the minimum needed to answer the request. Requests are processed to produce your answer and are not used by us, or by the provider under our agreement, to train or improve any model.

You are asked for consent before your first AI request and can withdraw it at any time in Settings; withdrawing it disables the AI features and stops any further transmission. AI output is generated text: it can be wrong, it is not medical or professional advice, and it is labelled as AI-generated in the app. See the AI Transparency notice for details of what each feature sends.

7. Who else processes your data

We use the parties below. Each is bound by a written data-protection agreement covering the data it receives, and each is listed with the transfer mechanism that applies where processing takes place outside the EEA. Not all of them act solely on our instructions: the app stores handle your purchase under their own privacy policies, and Google’s handling of advertising data is governed by its own advertising terms alongside our agreement with it. Entries marked "planned" are not in use at the date of this version and will not be used before this list is updated.

8. International transfers

Our database and, where used, our error-reporting and analytics processors are hosted in the EU. The AI providers, the advertising processor (Google AdMob), the subscription infrastructure, the email provider and the app stores are established in the United States.

Transfers to those processors are made under the European Commission’s Standard Contractual Clauses (Decision (EU) 2021/914), supplemented where appropriate by the EU–US Data Privacy Framework where the recipient is certified. We have carried out transfer impact assessments for these recipients and can provide a summary on request.

9. How long we keep things

Retention periods per purpose are in the table in §4. In addition:

• Data that never leaves your device is retained until you delete it in the app or uninstall the app. We cannot delete it for you because we do not have it.
• When you delete your account, server-side personal data is erased within 30 days. Backups roll off within a further 35 days, after which no copy remains.
• Billing records are retained for the statutory accounting period even after account deletion, because Art. 6(1)(c) requires it; they are reduced to the minimum needed for that obligation and the identifiers within them are anonymised.
• An audit record that an AI request was made (timestamp, feature, model, token counts) is retained for 12 months for abuse prevention and cost control. It does not contain the content of the request.
• Server logs are retained for 30 days.

10. Your rights

Under the GDPR you have the following rights. To exercise any of them, write to privacy@dailyplus.app. We answer within one month, extendable by two further months for complex requests, and we will tell you if we need the extension. We do not charge for this.

We may ask you to confirm control of the email address on the account before acting on a request — not to obstruct you, but because acting on an unverified erasure request would itself be a breach.

• Access (Art. 15) — a copy of the personal data we hold about you, and the information in this policy. The app also has an on-device export you can run yourself at any time.
• Rectification (Art. 16) — correction of inaccurate data. Most of it you can edit directly in the app.
• Erasure (Art. 17) — deletion of your account and its data. See the account deletion page for what this covers and the timeline.
• Restriction (Art. 18) — we stop processing while a dispute about accuracy or lawfulness is resolved.
• Portability (Art. 20) — your data in a structured, machine-readable format, or transmitted to another controller where technically feasible.
• Objection (Art. 21) — to processing based on legitimate interests. We do no direct marketing and no profiling for marketing, so there is nothing you would need to object to for that purpose.
• Withdrawal of consent (Art. 7(3)) — for health processing and for AI features, at any time, in Settings. It is as easy to withdraw as it was to give.
• Complaint (Art. 77) — to your local supervisory authority. Ours is the ANSPDCP — Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (https://www.dataprotection.ro). You may also complain to the authority in your own country of residence.

11. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you by automated means, and we do not profile you for that purpose. Art. 22 does not apply.

The app does compute recommendations from your own data — energy targets, training progression, urgency scores, correlations. These are suggestions shown to you, they are editable, and they have no effect outside the app.

12. Security

Data on our servers is encrypted in transit (TLS) and at rest. Access is limited to what is needed to operate the service, authentication uses hashed credentials and short-lived sessions, and row-level access checks are enforced server-side and covered by an adversarial test suite so that one account cannot read another’s data.

We run a coordinated vulnerability disclosure programme; the policy is published on our security page and machine-readably at /.well-known/security.txt. Confirmed personal-data breaches are notified to the supervisory authority within 72 hours as required by Art. 33, and to affected users without undue delay where Art. 34 applies.

No system is perfectly secure, and we do not claim otherwise.

13. Analytics, cookies and tracking

The app contains no analytics SDK and no crash-reporting SDK at the date of this version. It does contain an advertising SDK, Google AdMob, shown only to users on the free plan; Premium removes advertising entirely. We do not sell personal data.

Consent for ad personalization is collected through Google’s User Messaging Platform (UMP) immediately before your first ad is shown — not at launch and not during onboarding — and you can reopen that choice at any time from Settings. On iOS, personalized ads additionally require you to authorize the operating system’s App Tracking Transparency prompt, which advertising shares with any other feature that needs it rather than showing a second prompt. Declining consent, declining tracking, or having an unconfirmed age does not stop ads from appearing — each of those makes the ads you see non-personalized instead. See the AdMob row in §7 for what Google receives and §8 for where it is processed.

If we add product analytics or crash reporting, it will be behind a separate, revocable consent, it will never carry health values, and this policy and the processor list above will be updated before it ships.

This website sets no cookies and embeds no third-party scripts. See the Cookies notice for the detail.

14. Children

Daily+ is not intended for anyone under 16, and the Terms of Service require you to be at least 16. We do not knowingly process data from children.

We are candid about the current state of enforcement: the age requirement is stated in the Terms but is not yet verified at sign-up. An age gate is planned before general availability. If you believe a child has used the app, write to us and we will delete the account and its data.

15. Changes to this policy

Each version of this policy carries a version identifier and an effective date, shown at the top of the page. The app records which version you accepted.

For a material change we will notify you in the app and ask you to review the new version before continuing to use features affected by it. Non-material changes (clarifications, typos, a processor’s corporate name) are published here with a new version identifier.

16. Contact

For anything in this policy, including any of the rights in §10, write to privacy@dailyplus.app. For security reports, use security@dailyplus.app and follow the disclosure policy.