Privacy Policy — Conception Calendar

⚠️ DRAFT — must be reviewed by legal counsel before publishing. This text reflects the app’s actual technical behavior to speed up legal review; it is not legal advice. The App Store requires a hosted Privacy Policy URL — publish this on a web page.

Last updated: 2026-08-02 · Data controller: Kerim Öz · Contact: gencersalih@gmail.com

Summary

• Your data stays only on your device. It is not sent to our servers, not written to iCloud, not sold, and not shared with advertisers or third parties.
• Single exception: if you use the optional AI Coach, your question and a minimized cycle summary are transmitted — only with your separate explicit consent — to Google (Gemini API, abroad) to generate a reply. Without that consent, no data leaves your device.
• Health and sexual-life data are treated as special-category data and processed with your separate explicit consent.
• You can export (JSON) or fully delete your data at any time and withdraw consent.

1. Data processed

Only data you enter or (with permission) read from Apple Health: - Menstrual cycle dates and flow - Basal body temperature (BBT) - Cervical mucus observations - Ovulation test result - Sexual activity - Consent records and an on-device audit log (event metadata only; no health values)

2. Purpose and legal basis

Data is processed only on your device for fertile-window estimation and education. Legal basis: your explicit consent (GDPR Art. 9 / Turkish KVKK Art. 6), obtained separately for health and sexual-life data.

3. Storage, transfer, security

• Storage: On device, encrypted with OS Data Protection.
• Transfer: Except for the AI Coach feature below, data is not transferred to any server, cloud, or third party. iCloud sync is disabled.
• Third parties: No ad, analytics, or tracking SDKs; health data is never shared.
• Apple Health (HealthKit): Read/written only with permission; HealthKit data is not used for advertising and not stored in iCloud (App Store 5.1.3).

4. AI Coach (optional, separate explicit consent)

The TTC Coach, offered with the Premium subscription, uses cloud-based AI to answer your questions. It works only with your separate explicit consent; without consent no data leaves your device and the rest of the app remains fully functional.

• What is sent (minimized summary): cycle phase (e.g. follicular/fertile/luteal), cycle day (integer), prediction confidence, coarse cycle regularity (“regular”/“variable”), and the question you write. Before sending, your question is scanned on-device and server-side for identifiers such as email addresses, phone numbers, or IBANs, which are removed where detected.
• Never sent: basal body temperature values, mucus/flow/test records, sexual activity data, exact calendar dates, name/date of birth, device or account identifiers.
• Processor and transfer: The question and summary are transmitted to Google (Gemini API) servers (abroad) to generate a reply. A paid API tier is used; Google does not use this content to train its models. Legal basis: your explicit consent under GDPR Art. 9 / KVKK Art. 6 (special-category data) and KVKK Art. 9 (transfer abroad), and third-party AI permission under App Store rule 5.1.2(i).
• No retention: The transfer happens transiently to produce the reply; questions and answers are not stored on our servers, and chat history is never written off your device.
• Withdrawal: Withdraw consent anytime in Settings with one tap; the cloud feature stops immediately and the app keeps working with on-device features.

5. Your rights (GDPR / KVKK)

• Access/Portability: Export your data as JSON in-app.
• Deletion: “Delete all my data” permanently erases everything.
• Withdraw consent: Withdrawing consent deletes related data and stops processing.
• Requests: gencersalih@gmail.com

6. Children

Not intended for users under 18.

This app is not a medical device; results are estimates and cannot be used for contraception. See the Medical Disclaimer.