CueRise Privacy Policy
Last updated: [DATE]
Introduction
This policy explains what personal data CueRise collects, how it is used, and what rights you have over it. CueRise is operated by [COMPANY NAME], a company registered in England and Wales ([COMPANY NUMBER]), whose registered office is [REGISTERED ADDRESS] ("we", "us", "our").
For the purposes of UK data protection law, we are the data controller for the personal data described in this policy.
If you have questions about this policy or how we handle your data, contact us at [CONTACT EMAIL].
CueRise is a wellbeing and personal-development app. It is not a medical device and does not provide medical, clinical, or therapeutic services.
The short version
Most of what you put into CueRise never leaves your phone. Your journal entries, moods, habits, streaks, and personal settings are stored locally on your device.
Three things are exceptions, and only when you choose them:
- If you chat with Malou, our AI coach, your messages and limited context are sent to our server and on to our AI provider so a reply can be generated.
- If you turn on AI journal analysis, short excerpts of your journal entries are sent to generate your weekly reflection. This is off by default.
- If you send us feedback, your message is sent to our server along with an anonymous device identifier.
- The app records anonymous usage events (such as "ritual completed") so we can tell whether CueRise is helping people. These contain no content of any kind.
We do not use third-party analytics, advertising, or tracking software of any kind. We do not sell your data. We do not use your content to train AI models.
Data stored only on your device
The following is stored locally on your iPhone using Apple's on-device storage and is not transmitted to us:
- Journal entries and written reflections
- Mood entries
- Completed exercises, habits, streaks, and progress history
- Your chosen identity, focus, and personal anchors
- App settings, reminder times, and preferences
Because this data is stored on your device, we cannot access it, and we cannot retrieve or restore it for you. If you delete the app, this data is deleted with it and cannot be recovered.
Data sent to our servers
1. AI coach conversations (Malou)
When you send a message to Malou, the following is transmitted to our backend (hosted by Supabase) and forwarded to our AI provider (Google, via the Gemini API) so that a response can be generated:
- The message you typed
- Recent messages in the current conversation
- Limited contextual information from your app usage: your chosen display name, your selected identity and focus, your current streak, recent mood indicator, which practices you completed today, your daily intention if set, and aggregate measures of your recent activity
- Short summaries of your recent coaching sessions
- Short excerpts of your recent journal entries, where journal analysis is enabled
Legal basis: performance of a contract — this processing is necessary to provide the coaching feature you have chosen to use.
2. Weekly reflection (optional, off by default)
If you enable AI journal analysis in Settings, then when a weekly reflection is generated, excerpts of your journal entries from the past week and your mood entries for that period are sent to our backend and forwarded to our AI provider to produce the reflection.
This feature is disabled by default. You can turn it on or off at any time in the app under Profile → AI journal analysis. If it is off, journal content is never transmitted.
Legal basis: consent. You may withdraw consent at any time by disabling the feature.
3. Anonymous usage measurement
To understand whether CueRise is working — how many people are active, how many complete a ritual, and whether people keep using it over time — the app records a small number of anonymous events.
What is sent: the name of the event (for example, "app opened" or "ritual completed"), the number of days since the app was installed, the app version, and the anonymous device identifier described below.
What is never sent: the content of anything you write, your journal entries, your mood values, your messages to Malou, your name, or any other personal detail. We record that an action happened, not what it contained.
We do not use any third-party analytics, advertising, attribution, or tracking software. This measurement is first-party only and goes to our own infrastructure.
Because the device identifier persists, we can tell that the same installation returned on a later day, which is what allows us to measure retention. It does not identify you, and it gives us no way to contact you.
Legal basis: legitimate interests — understanding product usage in order to improve the app. We have limited this processing to anonymous, non-content events to minimise its impact on your privacy.
4. Feedback
If you choose to send feedback, we receive your written message, the sentiment you selected, the app version, a tag indicating where in the app you sent it from, and an anonymous device identifier.
The device identifier is a randomly generated value created when you first use the app. It is not derived from your device's hardware identifiers and does not identify you personally. It exists only so that multiple pieces of feedback from the same installation can be grouped together.
Legal basis: legitimate interests — improving our product based on user feedback.
Data we do not collect
We want to be specific about this, because it matters:
- We do not use third-party analytics, tracking, advertising, or attribution software. We record only the anonymous, content-free usage events described above, on our own infrastructure
- We do not collect your name, email address, or phone number
- We do not require an account, and there is no login
- We do not collect your location
- We do not access your contacts, photos, microphone, or camera
- If you enable calendar integration, CueRise writes ritual events to your calendar. To let you remove them again, it looks through your calendar for events it created itself, identified by a CueRise marker. It does not use, store, or transmit any information about your other events, and no calendar data ever reaches our servers
- We do not use your data to train AI models
- We do not sell, rent, or share your data with third parties for their own purposes
Special category data
Some of what you write in CueRise — particularly journal entries — may reveal information about your mental or emotional state. Under UK GDPR this may constitute special category data, which receives additional protection.
Where such data is processed (specifically, journal content sent for AI analysis or coaching), we rely on your explicit consent, which you give by enabling AI journal analysis or by choosing to share personal content with Malou. You can withdraw that consent at any time by disabling the feature or by not using the coaching feature.
We do not use this data for any purpose other than generating the response or reflection you have requested.
Who processes your data
We use the following processors:
| Provider | Purpose | Location |
|---|---|---|
| Supabase | Backend infrastructure and database hosting | EU (London region) |
| Google (Gemini API) | AI response generation | See Google's terms |
| Apple | App distribution and subscription processing | See Apple's policies |
These providers process data on our instructions under data processing terms. Data may be transferred outside the UK; where this happens, transfers are made under safeguards permitted by UK data protection law, such as International Data Transfer Agreements or adequacy regulations.
Apple processes your subscription and payment information directly. We never see your payment details.
How long we keep data
- Coaching conversations: messages are sent to generate a reply and are not retained in our database beyond what is necessary to produce that reply. Conversation history is stored on your device.
- Journal excerpts sent for reflection: used to generate the reflection and not retained beyond that purpose.
- Feedback: retained for up to 24 months, after which it is deleted or anonymised.
- Usage events: retained for up to 24 months, after which they are deleted or aggregated into anonymous totals.
- On-device data: retained until you delete it or delete the app.
Your rights
Under UK data protection law you have the right to:
- Access the personal data we hold about you
- Have inaccurate data corrected
- Have your data erased
- Restrict or object to processing
- Data portability
- Withdraw consent where processing is based on consent
- Lodge a complaint with the Information Commissioner's Office (ico.org.uk)
To exercise any of these rights, contact us at [CONTACT EMAIL]. We will respond within one month.
Please note: because most of your data is stored only on your device and we operate no user accounts, we usually hold very little data that could identify you. For feedback, you would need to tell us the approximate date and content so we can locate the entry.
To delete your on-device data, delete the app from your iPhone. This removes all locally stored data permanently.
Children
CueRise is not intended for children under 13, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.
Security
We use HTTPS for all data in transit. Our backend database is access-restricted and not publicly readable. Data stored on your device is protected by your device's own security, including your passcode and Apple's file encryption.
No system is completely secure. We take reasonable measures appropriate to the nature of the data we handle.
Changes to this policy
We may update this policy from time to time. Material changes will be notified in the app. The "last updated" date at the top shows the current version.
Contact
[COMPANY NAME] [REGISTERED ADDRESS] [CONTACT EMAIL]
If you are unhappy with how we have handled your data, you may complain to the Information Commissioner's Office: ico.org.uk, or 0303 123 1113.