Privacy Policy
This privacy policy applies to the LuciDrinks mobile app (the “Application”) operated by Phillip Rosenheinrich (the “Service Provider”). LuciDrinks is designed to keep your drink log and insights on your device unless you choose to export or share them.
Data controller
The controller responsible for data processing within the meaning of the EU General Data Protection Regulation (GDPR) is:
Phillip Rosenheinrich, Rosenheinrich Software Solutions
Destouchesstr. 3, 80803 Munich, Germany
Email: [email protected]
Full provider details: Legal Notice
Wellness disclaimer
LuciDrinks provides general wellness and self-tracking features only. It does not provide medical advice, diagnosis, or treatment. Body-intelligence estimates (for example hydration or recovery hints) are informational and may be inaccurate. Always consult a qualified professional for health decisions.
On-device drink data
The Application stores drink entries, timestamps, drink types, notes, analytics, profile settings, and related preferences locally on your device (for example in an on-device database and app storage). The Service Provider does not operate user accounts or a cloud server that receives your drink log.
You can delete individual entries in the app or remove all data by clearing app storage or uninstalling the Application.
No cloud backend
The Service Provider does not run a backend that processes, syncs, or stores your drink log. Core features (log drinks, view analytics, body insights) work without sending your entries to the Service Provider.
Network access may be used only for optional features such as advertising consent (Google UMP), ad delivery, or store billing — not for uploading your drink data for storage or analysis on our servers.
Optional health integration
If you enable it, the Application may read or write selected health metrics (for example sleep or activity data) through Apple Health or Google Health Connect, subject to your device permissions. That data stays under your control on the device and is used locally to enrich insights. The Service Provider does not receive your health data unless you voluntarily share it (for example in a support email).
Drink records and any connected health metrics may qualify as health-related data (a special category of personal data under Article 9 GDPR). This data is processed only on your device and only on the basis of your explicit consent, given by enabling the relevant feature and granting the device permission. You can withdraw this consent at any time by disabling the feature or revoking the permission in your device settings.
On-device AI
When supported on your device, drink recognition and related suggestions may run on-device using Apple Foundation Models (iOS) or Gemini Nano (Android). Images and prompts used for recognition are not sent to the Service Provider’s servers for this purpose.
Advertising (Google AdMob)
The free tier may show banner, interstitial, and rewarded ads through Google AdMob. AdMob and its partners may process device identifiers, IP address, and ad interaction data according to your consent choices (Google UMP; on iOS, App Tracking Transparency where applicable). You can review or change these choices at any time via Reset ad consent in the app’s settings.
Ad provider Google (Google Ireland Ltd. and Google LLC) may process this data on servers outside the European Economic Area, including in the United States. Such transfers are safeguarded by the European Commission’s Standard Contractual Clauses and Google’s certification under the EU–U.S. Data Privacy Framework.
Purchasing LuciDrinks Premium (where available) may remove ads in the Application. See Google’s partner policy: Google advertising technologies.
In-app purchases
Premium features may be sold as a one-time purchase through the Apple App Store or Google Play. Payment and purchase history are handled by Apple or Google, not directly by the Service Provider.
Legal bases for processing
Where the GDPR applies, we rely on the following legal bases:
- Your consent (Art. 6(1)(a), and Art. 9(2)(a) for health-related data) — for advertising and analytics identifiers via Google UMP, and for the optional health integration.
- Performance of a contract (Art. 6(1)(b)) — to provide the Application and process any in-app purchase you make.
- Legitimate interests (Art. 6(1)(f)) — to operate the Application securely, prevent abuse, and answer support requests; balanced against your rights.
On-device drink data is stored locally under your control and is not transmitted to the Service Provider, so no additional legal basis for its transfer to us is required.
Your rights
Because your drink log is stored on your device, you control access, correction, and deletion directly in the app. Subject to the conditions of the GDPR, you also have the right to access, rectification, erasure, restriction of processing, data portability, and to object to processing. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise these rights regarding data the Service Provider processes (for example support email), contact [email protected]. You also have the right to lodge a complaint with a data protection supervisory authority. The authority competent for the Service Provider is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Ansbach, Germany. Depending on your region, you may have additional rights regarding data processed by ad or store providers.
Children
The Application is intended for adults of legal drinking age in your jurisdiction. It is not directed at children under 16. The Service Provider does not knowingly collect personal information from children.
Changes
We may update this policy by posting a new effective date on this page.
Contact
Questions: [email protected]