Privacy Policy
Scope
This privacy policy applies to the use of the app Gratitude as well as to the associated website and its contact form / the option to contact us by email. The data controller within the meaning of the GDPR is:
Operator: Maximilian Otto
Address: Stiftstr. 3, 59555 Lippstadt
Email: gratitude@maxot.de
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1. Overview — what data is processed and why
A. App functionality / server processing
• Stored metadata : Category titles, entry titles and, where applicable, timestamps sent by the app to my backend server. Storage is voluntary and does not contain any personal data.
Purpose: Generation of reflection questions and suggestions by AI (Anthropic), caching of already generated responses, avoidance of duplicate generation.
Legal basis: Performance of a contract / pre-contractual measures or legitimate interest (stable functionality, optimisation, performance).
Note: User-typed, longer-form texts / journal entries are not transmitted to my server (they remain local or in iCloud, see iCloud section).
B. Use of AI (Anthropic)
• Data transmitted to the Anthropic API (category titles, entry titles, and questions) is used to generate questions and suggestions. These API requests are routed through my server. API inputs and outputs are stored by Anthropic for a maximum of 7 days and then automatically deleted. The data is not used to train AI models.
Legal basis: Legitimate interest / service fulfilment; where required, consent (e.g. for analyses or if special personal data were to be transmitted — see below).
C. Contact form / email on the website
• When you contact me via the form or by email, I store the contact data you provide (name, email address, content of the message).
Purpose: Processing your enquiry and correspondence.
Legal basis: Fulfilment of an enquiry or legitimate interest / contract performance.
D. iCloud Sync
• If you are signed in with an Apple ID on macOS and iCloud Sync is active, your local entries (texts, metadata) are synchronised via iCloud. Data in iCloud is subject to Apple's iCloud policies. Some iCloud data is end-to-end encrypted; other data is encrypted in transit & at rest by Apple.
Legal basis: Contract performance / user choice (opt-in functionality).
E. Log and operational data
• Server logs, diagnostic and error data (e.g. for stability, security incidents).
Purpose: Operational security, abuse prevention, bug fixing.
Legal basis: Legitimate interest.
F. In-app purchases (StoreKit)
• Purchases within the app are processed exclusively via Apple's StoreKit framework. I have no access to payment data or credit card information. Apple's privacy policies apply to the processing of this data.
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2. Recipients / third parties (processors & sub-processors)
For the purposes stated above, I share personal data with the following service providers:
1. Overview — what data is processed and why
A. App functionality / server processing
• Stored metadata : Category titles, entry titles and, where applicable, timestamps sent by the app to my backend server. Storage is voluntary and does not contain any personal data.
Purpose: Generation of reflection questions and suggestions by AI (Anthropic), caching of already generated responses, avoidance of duplicate generation.
Legal basis: Performance of a contract / pre-contractual measures or legitimate interest (stable functionality, optimisation, performance).
Note: User-typed, longer-form texts / journal entries are not transmitted to my server (they remain local or in iCloud, see iCloud section).
B. Use of AI (Anthropic)
• Data transmitted to the Anthropic API (category titles, entry titles, and questions) is used to generate questions and suggestions. These API requests are routed through my server. API inputs and outputs are stored by Anthropic for a maximum of 7 days and then automatically deleted. The data is not used to train AI models.
Legal basis: Legitimate interest / service fulfilment; where required, consent (e.g. for analyses or if special personal data were to be transmitted — see below).
C. Contact form / email on the website
• When you contact me via the form or by email, I store the contact data you provide (name, email address, content of the message).
Purpose: Processing your enquiry and correspondence.
Legal basis: Fulfilment of an enquiry or legitimate interest / contract performance.
D. iCloud Sync
• If you are signed in with an Apple ID on macOS and iCloud Sync is active, your local entries (texts, metadata) are synchronised via iCloud. Data in iCloud is subject to Apple's iCloud policies. Some iCloud data is end-to-end encrypted; other data is encrypted in transit & at rest by Apple.
Legal basis: Contract performance / user choice (opt-in functionality).
E. Log and operational data
• Server logs, diagnostic and error data (e.g. for stability, security incidents).
Purpose: Operational security, abuse prevention, bug fixing.
Legal basis: Legitimate interest.
F. In-app purchases (StoreKit)
• Purchases within the app are processed exclusively via Apple's StoreKit framework. I have no access to payment data or credit card information. Apple's privacy policies apply to the processing of this data.
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2. Recipients / third parties (processors & sub-processors)
For the purposes stated above, I share personal data with the following service providers:
• Ionos : Hosting provider of the backend server. Server location: Germany. A data processing agreement exists with Ionos.
• Anthropic (API for AI generation). Prompts/metadata are transmitted to Anthropic. Anthropic documents in its policies how API inputs and outputs are handled. A data processing agreement pursuant to Art. 28 GDPR exists with Anthropic. API data is not used for training AI models.
• Apple / iCloud & StoreKit: Apple is the recipient of synchronised iCloud data and handles purchases via StoreKit. Payment data is processed exclusively by Apple; I only receive a purchase confirmation. iCloud storage and payment processing are subject to Apple's privacy and security policies. Legal exceptions in certain countries may change access conditions.
• Additional technical sub-processors (e.g. email provider, crash reporting) may be used — we document these in an internal register and conclude DPAs where required.
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3. Data transfers outside the EEA
Anthropic may use server locations outside the European Economic Area (EEA). For such transfers, I ensure that an adequate level of protection exists (e.g. standard contractual clauses, DPA, binding corporate rules), or we use services/options that offer data residency in the EU. Please refer to the respective provider contracts and privacy documents for details.
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4. Retention period / storage
• Category and entry titles / AI cache on server: The transmitted metadata is transferred without user ID, device ID or other identifiers and cannot be attributed to any person on the server side. The data is automatically filtered for personal information such as names or locations; if personal information is found, or if the user has not consented to storage, the data is deleted immediately after processing. If no personal information is contained and consent to storage has been granted, the data is stored permanently.
• Contact emails: For as long as necessary to process the enquiry + statutory retention obligations.
• Local app data / iCloud: For as long as the user retains the data or until they delete it.
• Logs / diagnostic data: Typically time-limited (e.g. 30–90 days), except for security-relevant incidents.
(Practical recommendation: define concrete retention periods in months/years in an internal policy — this improves GDPR compliance.)
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5. Your rights (GDPR)
As a data subject, you have the following rights:
• Rectification (Art. 16).
• Erasure (“right to be forgotten”, Art. 17).
• Restriction of processing (Art. 18).
• Data portability (Art. 20).
• Objection to processing based on legitimate interests (Art. 21).
• Withdrawal of consent (Art. 7(3)) without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint with a supervisory authority (Art. 77).
(Art. 13 GDPR – the right of access does not apply as no personal information is stored.)
If you wish to exercise any of these rights, please write to: gratitude@maxot.de . I usually respond within one week.
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6. Security
I employ technical and organisational measures to protect your data (transport encryption TLS for API requests, access controls, secure storage, regular updates). Nevertheless, absolute security on the internet cannot be guaranteed; I document incidents and report notifiable data breaches to the supervisory authority and affected persons as required by the GDPR.
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7. Contact forms / email
When you contact me via the website, I store your name, email and message for processing; this data is stored on my server / in my email inbox and may be archived. The legal basis is the processing of the enquiry or legitimate interest.
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8. Changes to this privacy policy
I update this privacy policy when processes or legal bases change. For material changes, I will inform you via the app/website.
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9. Contact / complaints
Privacy contact:
You have the right to lodge a complaint with a supervisory authority (e.g. the data protection authority responsible for your place of residence in Germany: the state authority of your federal state).
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Sources / further reading (selection)
• Regulation (EU) 2016/679 (GDPR) — official text.
• European Data Protection Board — guidelines on transparency / legitimate interests (refer to current guidelines).
• Apple — iCloud data security & encryption; note on changes in some countries (e.g. UK case 2025).
• Anthropic (API for AI generation). Prompts/metadata are transmitted to Anthropic. Anthropic documents in its policies how API inputs and outputs are handled. A data processing agreement pursuant to Art. 28 GDPR exists with Anthropic. API data is not used for training AI models.
• Apple / iCloud & StoreKit: Apple is the recipient of synchronised iCloud data and handles purchases via StoreKit. Payment data is processed exclusively by Apple; I only receive a purchase confirmation. iCloud storage and payment processing are subject to Apple's privacy and security policies. Legal exceptions in certain countries may change access conditions.
• Additional technical sub-processors (e.g. email provider, crash reporting) may be used — we document these in an internal register and conclude DPAs where required.
⸻
3. Data transfers outside the EEA
Anthropic may use server locations outside the European Economic Area (EEA). For such transfers, I ensure that an adequate level of protection exists (e.g. standard contractual clauses, DPA, binding corporate rules), or we use services/options that offer data residency in the EU. Please refer to the respective provider contracts and privacy documents for details.
⸻
4. Retention period / storage
• Category and entry titles / AI cache on server: The transmitted metadata is transferred without user ID, device ID or other identifiers and cannot be attributed to any person on the server side. The data is automatically filtered for personal information such as names or locations; if personal information is found, or if the user has not consented to storage, the data is deleted immediately after processing. If no personal information is contained and consent to storage has been granted, the data is stored permanently.
• Contact emails: For as long as necessary to process the enquiry + statutory retention obligations.
• Local app data / iCloud: For as long as the user retains the data or until they delete it.
• Logs / diagnostic data: Typically time-limited (e.g. 30–90 days), except for security-relevant incidents.
(Practical recommendation: define concrete retention periods in months/years in an internal policy — this improves GDPR compliance.)
⸻
5. Your rights (GDPR)
As a data subject, you have the following rights:
• Rectification (Art. 16).
• Erasure (“right to be forgotten”, Art. 17).
• Restriction of processing (Art. 18).
• Data portability (Art. 20).
• Objection to processing based on legitimate interests (Art. 21).
• Withdrawal of consent (Art. 7(3)) without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint with a supervisory authority (Art. 77).
(Art. 13 GDPR – the right of access does not apply as no personal information is stored.)
If you wish to exercise any of these rights, please write to: gratitude@maxot.de . I usually respond within one week.
⸻
6. Security
I employ technical and organisational measures to protect your data (transport encryption TLS for API requests, access controls, secure storage, regular updates). Nevertheless, absolute security on the internet cannot be guaranteed; I document incidents and report notifiable data breaches to the supervisory authority and affected persons as required by the GDPR.
⸻
7. Contact forms / email
When you contact me via the website, I store your name, email and message for processing; this data is stored on my server / in my email inbox and may be archived. The legal basis is the processing of the enquiry or legitimate interest.
⸻
8. Changes to this privacy policy
I update this privacy policy when processes or legal bases change. For material changes, I will inform you via the app/website.
⸻
9. Contact / complaints
Privacy contact:
You have the right to lodge a complaint with a supervisory authority (e.g. the data protection authority responsible for your place of residence in Germany: the state authority of your federal state).
⸻
Sources / further reading (selection)
• Regulation (EU) 2016/679 (GDPR) — official text.
• European Data Protection Board — guidelines on transparency / legitimate interests (refer to current guidelines).
• Apple — iCloud data security & encryption; note on changes in some countries (e.g. UK case 2025).