Privacy policy

1. In short

• Your entries are stored and analysed on your iPhone.
• Anything that syncs is end-to-end encrypted. We cannot read the content.
• No tracking, no ads, no third-party analytics, no selling of data.
• External AI (“cloud AI”) only with your explicit consent – using small excerpts in which names are replaced with placeholders.
• You can export everything and delete your account with all data at any time.

2. Controller

Controller within the meaning of the General Data Protection Regulation (GDPR): [CONTROLLER].

Data protection officer: [DATA PROTECTION OFFICER, if any].

3. Processing in the app

3.1 Storage and analysis on your iPhone

Rapport stores what you enter – journal entries, check-ins, reflections, voice notes and their transcripts, the people, feelings and needs in your entries, experience chains derived from them, possible patterns and your ratings, experiments, the app’s memories and your settings – in a database on your iPhone. It is protected by iOS data encryption; you can also turn on an app lock with Face ID or passcode. Voice notes are transcribed on the device.

Experience chains, pattern calculations and the detection of possible crisis signals run on your device.

This information may be health data within the meaning of Art. 9 GDPR. The legal basis is your explicit consent (Art. 9(2)(a), Art. 6(1)(a) GDPR), which you give when setting up the app and can withdraw at any time with effect for the future.

3.2 Apple Intelligence (on device and Private Cloud Compute)

For wording – for example in guided reflections or explanations of a pattern – Rapport uses Apple’s language models, which run on your iPhone. For more demanding tasks Apple may pass a request to Apple’s “Private Cloud Compute”; according to Apple, data there is used only to answer the request and is not stored. We do not receive any content. Using the privacy level in Settings you can limit this to the on-device model. Legal basis: Art. 9(2)(a), Art. 6(1)(a) GDPR. [Legal classification of Apple’s role for Private Cloud Compute]

3.3 Anonymous account and Sign in with Apple

So that your encrypted data can be backed up and opened on a new device, the app creates an anonymous account with our service provider Supabase without asking for any details. A random user ID, sign-in tokens and technical timestamps are stored; when connecting, your IP address is processed for technical reasons. No name or email address is collected.

You may choose to sign in with Apple. We request neither your name nor your email address. Apple provides an identifier unique to this app in a signed token, which is linked to your account.

Legal basis: Art. 6(1)(b) GDPR (providing the features you use).

3.4 End-to-end encrypted sync

Before content leaves your iPhone it is encrypted there with a key only you hold (AES-GCM, 256-bit). Per record, the server stores only: the encrypted content, a random value used for encryption, an identifier, the data type, a version number, the key version, times of change or deletion and your user ID. These metadata are not encrypted; the content is.

The key is kept in your device’s keychain (synced via iCloud Keychain if you wish) and – if you write it down – with you as a recovery key. We have no access to it and can neither read nor restore content.

The database is operated by Supabase in the EU (Frankfurt am Main). With the privacy level “Local only” no content is synced. Legal basis: Art. 6(1)(b) GDPR; for content additionally your consent under Art. 9(2)(a) GDPR.

3.5 Record of your consents

When you give or withdraw consent, we store its type (for example “storing sensitive data” or “cloud AI”), the version of the consent text and the times – without any content. The purpose is accountability under Art. 7(1) GDPR; the legal basis is Art. 6(1)(c) GDPR.

3.6 Cloud AI – only with your explicit consent

Some features, such as in-depth reviews or connections across many entries, can use an external language model. This only happens if you explicitly switch on “Cloud AI” in Settings.

• On your device, the app assembles the smallest possible excerpt and first replaces names and places with placeholders (for example “[Person A]”). The mapping stays on your iPhone. Pseudonymised data is still personal data.
• The excerpt is sent encrypted (TLS) to our AI gateway and passed on from there to [AI PROVIDER, EU REGION].
• The gateway stores no content: request and response exist in memory only while being processed. Only metadata such as task type, model, size, duration and status are logged. Gateway hosting: [GATEWAY HOST, EU REGION].
• Retention at the AI provider: [to be confirmed – goal: no retention].

Legal basis: Art. 9(2)(a), Art. 6(1)(a) GDPR. You can withdraw consent at any time in Settings; after that no excerpts are sent.

3.7 Abuse protection

To make sure only genuine Rapport apps use the AI gateway, the app uses Apple’s “App Attest” service. The gateway keeps a public key of your app instance and a counter for this. It also counts requests per user ID and day (rate limits and daily quotas). Legal basis: Art. 6(1)(f) GDPR – our legitimate interest in secure and affordable operation.

3.8 Rapport Plus and purchases

Subscriptions are purchased through the App Store. Apple handles payment; we receive no payment data. The app checks whether a subscription is active using Apple’s StoreKit on your device. Apple’s privacy policy applies to Apple’s processing.

3.9 Reminders

If you turn on gentle reminders, the app schedules them locally on your iPhone. They contain no content from your entries and are not sent through our servers.

3.10 No tracking

Rapport contains no analytics or advertising tools, uses no advertising identifier and does not track you across apps or websites. Apple provides developers with aggregated statistics and crash reports only if you have turned on “Share with App Developers” in your iPhone settings; they contain no content from your entries.

3.11 Crisis help

The help page with emergency numbers works offline. If you call someone from there, the call goes through your iPhone’s Phone app – we learn nothing about it.

4. This website

Hosting and server logs. The website is hosted by [WEBSITE HOST, e.g. Vercel Inc.]. When you visit, the server processes technically necessary data: IP address, date and time, page requested, referrer and browser identifier. The purpose is delivering and securing the website; the legal basis is Art. 6(1)(f) GDPR. Retention: [to be confirmed].

No cookies, no tracking. The website sets no cookies, uses no analytics services and loads no fonts or scripts from third-party servers.

Day and night look. If you switch the look yourself, your browser remembers the choice in local storage (key “rapport-theme”). It never leaves your device. Legal basis: § 25(2) no. 2 TDDDG [to be confirmed].

Contact by email. If you write to us, we process your message in order to reply (Art. 6(1)(b) or (f) GDPR). Please don’t send us content from your entries.

5. Recipients and service providers

Transfers outside the EU: [to be confirmed – e.g. for providers based in the US: adequacy decision / standard contractual clauses].

6. Retention and deletion

• On your iPhone: until you delete the data or remove the app.
• On the server: until you delete your account. “Delete account and all data” in Settings removes your account, all encrypted records and your consent records. Individually deleted entries are marked as deleted for syncing; final removal: [period to be confirmed]. Provider backups: [retention to be confirmed].
• AI gateway: no content; quota counters apply per day.
• Website logs: [to be confirmed].

7. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)), directly in the app’s settings.

Because your content is end-to-end encrypted, we cannot see it. For content, the app’s own features work best: export, edit and delete. For anything else, contact us at [EMAIL].

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example [COMPETENT SUPERVISORY AUTHORITY].

8. Further information

No automated decisions. Rapport makes no decisions with legal or similarly significant effects (Art. 22 GDPR). Possible patterns are suggestions you rate yourself.

Minimum age. Rapport is intended for adults aged 18 and over.

Security. Transport encryption (TLS), end-to-end encryption of content, server access rules under which each account can only see its own records, and no content in logs or notifications.

Changes. We update this policy when the app or the law changes. Last updated: [DATE].