Last updated: October 2025
Privacy Policy
1. Data Controller
Name: Mauro Frehner
Email: [email protected]
Project: SteadyTurtle
2. Data We Process
- Account data: username, email address, password (encrypted)
- Usage data: app activities (e.g. participation in challenges)
- Technical data: IP address, time zone, device information
- Content data: content voluntarily provided, such as profile pictures or text
We do not process sensitive data (health, religion, political opinions).
3. Purposes
- Provision of app features (challenges, statistics, friends)
- Account management and support
- Error analysis and improvement
- Compliance with legal obligations
4. AI Coach (Turtley) – OpenAI
Our app optionally offers an AI coach called Turtley, which is based on the technology of OpenAI. If you activate this feature (opt-in), the text you enter will be transmitted to OpenAI in order to generate responses. If you do not activate this feature (opt-out), no chat data will be sent to OpenAI.
- Use is voluntary and can be changed at any time in the app settings.
- Legal basis: consent (Art. 6 para. 1 lit. a GDPR).
- Further information: OpenAI Privacy.
5. Disclosure and Data Processing
We do not share personal data with third parties unless this is necessary for operation (e.g. hosting, cloud services) or required by law. Contracts for data processing and GDPR compliance are in place with all service providers.
6. Storage, Location and Security
Data is generally stored within the EU (or in accordance with EU Standard Contractual Clauses). We implement technical and organisational measures to protect data against loss, misuse and unauthorised access.
7. Retention Period
Personal data is stored only for as long as necessary for the respective purpose or as required by legal obligations. Afterwards, it is deleted or anonymised.
8. Rights of Data Subjects
- Right of access, rectification, erasure, restriction of processing
- Right to object to processing
- Right to data portability
- Withdrawal of consent with effect for the future
- Right to lodge a complaint with a data protection supervisory authority
9. Contact
For questions or to exercise your rights:
Email: [email protected]
Subject: Data protection request
10. Changes
We may update this privacy policy if legal, technical or operational changes require it. The current version is always published here.