sWeight Privacy Policy

1. Introduction

Welcome to the Privacy Policy for sWeight ("we", "us", or "our"). sWeight is a weight tracking app designed to help you monitor your weight and body measurements while maintaining complete control over your personal health data.

sWeight operates on a local-first principle: all your health data is stored exclusively on your device. There is no cloud synchronization, no account creation, and no remote data storage. This Privacy Policy explains how we collect, use, store, and protect your information when you use our app.

Please read this policy carefully to understand how we treat your health information. By using sWeight, you acknowledge that you have read and understood this Privacy Policy.

Data Controller

The data controller responsible for your personal data is:

Anthony Eli Rasch - sapplify
PO Box 004
91501 Nove Mesto nad Vahom
Slovakia

Email: contact@sapplify.com
Privacy inquiries: privacy@sapplify.com

2. Definitions

To help you understand this Privacy Policy, we define the following terms:

• Personal Data: Any information relating to an identified or identifiable person, including device identifiers that can distinguish your device from others.
• Health Data: Personal data related to physical or mental health, including weight measurements and body measurements. Under GDPR Article 9, this is considered "special category data" requiring additional protections.
• Processing: Any operation performed on personal data, including collection, storage, use, and deletion.
• Device Identifier: A unique code derived from your device's hardware characteristics, used to identify your device for trial management purposes.
• Local Storage: Data stored only on your device, not transmitted to external servers.

3. Data Collection

sWeight is a privacy-focused app. All your health data is stored exclusively on your device and is not transmitted to external servers.

Health Data You Enter

The app collects and stores the following health-related data that you actively provide:

• Weight entries: Your weight measurements with dates, times, and optional notes
• Body measurements: Chest, biceps, waist, hip, and thigh measurements with dates and optional notes
• Personal profile: Height, target weight, and weight goals (lose, maintain, or gain)

App Settings and Preferences

• User preferences: Preferred units (metric/imperial), theme preferences, language settings
• Notification settings: Your reminder preferences and scheduled times
• Terms acceptance: Record of when you accepted our Terms of Service and Privacy Policy

Device Information

For trial management and fraud prevention, we collect:

• Device identifier: A hashed (SHA256) representation of your device's hardware characteristics (see Section 6 for details)
• Trial status: Whether you are in trial period, trial start date, and remaining days

Optional Feedback Data

If you choose to submit feedback through the app, we collect:

• Your feedback message and type (bug report, feature request, general)
• App version and device information (model, operating system)
• Your locale/language
• Email address (optional, only if you provide it for follow-up)

See Section 7 for details on feedback data transmission.

What We DO NOT Collect

• We DO NOT collect your name, address, or personal identification documents
• We DO NOT collect GPS location or movement data
• We DO NOT access your photos, contacts, or other personal files
• We DO NOT use analytics or tracking services
• We DO NOT display advertisements or use advertising networks
• We DO NOT collect medical history, health conditions, or diagnoses
• We DO NOT have access to or collect data from health apps or fitness devices
• We DO NOT collect biometric data such as body scans, fingerprints, or facial recognition
• We DO NOT track you across devices or apps

4. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR) and applicable data protection laws, we process your personal data based on the following legal grounds:

Explicit Consent (Article 9(2)(a) GDPR)

For health data (weight and body measurements), we rely on your explicit consent:

• You provide consent by actively entering your health data into the app
• You can withdraw consent at any time by deleting your data
• Consent is specific to the purpose of weight tracking and personal health monitoring

Contract Performance (Article 6(1)(b) GDPR)

We process data when necessary to provide you with the sWeight service:

• Storing your weight entries and measurements locally
• Calculating statistics, trends, and AI-powered insights
• Managing your app settings and preferences
• Verifying premium purchase status

Legitimate Interest (Article 6(1)(f) GDPR)

We process limited data based on our legitimate interests:

• Trial management: Using device identifiers to manage the 14-day trial period and prevent abuse. Our legitimate interest is to protect our business model while offering a fair trial experience.
• Feedback processing: When you voluntarily submit feedback, processing it to improve our app and respond to your inquiries.

You have the right to object to processing based on legitimate interests. See Section 14 for how to exercise this right.

Legal Obligations (Article 6(1)(c) GDPR)

We may process data when required by law, such as responding to valid legal requests from authorities.

5. AI Processing & Privacy

Local AI Processing: sWeight uses algorithms and statistical analysis to provide personalized insights, predictions, and recommendations. All processing happens entirely on your device.

How AI Works in sWeight

Types of Analysis

Our local AI uses standard mathematical and statistical models to analyze your data. These models are static, deterministic, and fully transparent—we do not use "black box" deep learning, neural networks, or machine learning that could produce unpredictable or unexplainable results:

• Trend analysis: Using linear regression and moving averages to identify patterns in your weight history and calculate trends over time
• Predictions: Extrapolating future weight estimates using mathematical projection based on your historical data patterns
• Behavioral insights: Applying statistical analysis (averages, frequency counts, variance) to identify patterns in your tracking consistency
• Goal progress: Calculating percentage-based progress toward your target weight using simple arithmetic

Every insight can be explained by the underlying math. If you lose 2kg over 4 weeks, the app calculates a rate of 0.5kg/week—there is no hidden logic or unpredictable AI behavior.

Human Oversight

You maintain full human oversight over all AI-generated insights. The AI serves as an assistive tool only:

• Insights are intended to assist your self-monitoring, not replace your judgment
• The AI does not perform automated actions or modify your data without your explicit interaction
• You decide how to interpret and act upon any insights provided
• All features can be used without relying on AI recommendations
• No behavioral manipulation: The App does not "nudge" or "encourage" specific caloric, dietary, or exercise behaviors; it merely reflects mathematical trends of user-provided data

Accuracy Limitations

Because our AI is local-only and does not learn from other users or external datasets, its accuracy is strictly dependent on the frequency, consistency, and quality of the data you provide. The AI cannot account for factors you do not track, such as diet, exercise, medical conditions, or other variables that affect weight. Insights improve as you provide more data over time.

Automated Decision-Making

The AI features in sWeight provide suggestions and insights only. They do not make decisions that produce legal effects or similarly significantly affect you. All insights are informational and should not replace professional medical advice. No profiling is performed, and no decisions are made without your direct involvement.

6. Device Identification

To manage the trial period and prevent abuse, sWeight creates a unique identifier for your device.

What We Collect

We generate a device fingerprint by creating a SHA256 hash of the following device characteristics:

On Android:

• Device model, brand, and manufacturer
• Hardware identifiers (device, hardware, bootloader, board)

On iOS:

• Device model and name
• System name and version
• Vendor identifier (identifierForVendor)

How It's Stored

• The fingerprint is stored as a one-way SHA256 hash (the original values cannot be recovered)
• On Android, the hash is stored in a hidden file on device storage to persist across app reinstalls
• On iOS, it is stored in the app's local storage

Purpose

The device identifier is used solely for:

• Managing the 14-day free trial period
• Preventing trial abuse (multiple trial activations on the same device)
• Recognizing returning users who previously had weight data ("legacy users")

What We DO NOT Do With Device Identifiers

• We DO NOT transmit device identifiers to our servers
• We DO NOT use them for advertising or tracking
• We DO NOT share them with third parties
• We DO NOT correlate them across different apps

Your Rights

You can reset the device identifier by:

• On Android: Clearing app data and the hidden file from external storage
• On iOS: Uninstalling and reinstalling the app

Note: Resetting the identifier will reset your trial status if you have not purchased premium.

7. Data Transmission

sWeight is designed as a local-first app. However, there are limited circumstances where data may be transmitted:

Feedback Submission (User-Initiated)

When you voluntarily submit feedback through the app, the following data is sent to our server:

• Your feedback message and category
• App version
• Device model and operating system version
• Your locale/language setting
• Email address (only if you choose to provide it)

Server location: Frankfurt, Germany (EU)
Endpoint: api.sapplify.com
Encryption: All transmissions use HTTPS/TLS encryption

What Is NEVER Transmitted

• Your weight entries or measurements
• Your body measurements
• Your height, target weight, or goals
• Your notes or personal entries
• Your device fingerprint
• Any health data whatsoever

Offline Functionality

If you submit feedback while offline, it is queued locally and sent when connectivity is restored. You can cancel pending feedback by clearing app data.

8. App Permissions

sWeight requests only the minimum permissions necessary to function:

Required Permissions

• Internet Access: Used for:
  • Submitting feedback (user-initiated only)
  • In-app purchase verification through app stores
  • Opening links to our website, support pages, or privacy policy
  • Checking for app updates through app stores
• Billing Permission (Android): Required for in-app purchases through Google Play

Optional Permissions

• Notification Access: To send local reminders for daily weight tracking (only if you enable reminders)
• File/Photo Library Access: Only for importing and exporting weight data files (CSV format). We do not access your photos.

Platform-Specific Permissions

Android:

• INTERNET - Network access for feedback and purchases
• BILLING - Google Play in-app purchases
• POST_NOTIFICATIONS (Android 13+) - Local reminder notifications

iOS:

• Documents folder access - For data export/import
• User notifications - For reminder notifications

Permissions We DO NOT Request

• Camera or microphone access
• Contact list access
• Location services (GPS)
• Calendar access
• Health app integration (HealthKit/Google Fit)
• Background location or tracking

9. Purchases & Payments

sWeight offers a one-time premium purchase to unlock full functionality after the trial period.

Premium Features

• Full weight history access (beyond 14 days)
• Advanced statistics and trend analysis
• Behavioral insights and consistency tracking
• Data export functionality
• All premium dashboard features

Payment Processing

All payments are processed exclusively through official app stores:

• Apple App Store: For iOS users - Apple Privacy Policy
• Google Play Store: For Android users - Google Privacy Policy
• Huawei AppGallery: For Huawei Android devices - Huawei Privacy Policy

What We Track

• Whether you have purchased premium (boolean status)
• Whether you are a "legacy user" (had existing data before trial system)

What We DO NOT Track

• Credit card or payment method details
• Billing address or name
• Transaction IDs or purchase receipts
• Purchase history or amounts

We never see or store your payment details. All payment processing, refunds, and subscription management is handled entirely by the respective app store.

10. Data Sharing

We are committed to keeping your health data private. Here's our complete data sharing policy:

We DO NOT Share Your Health Data

• We DO NOT sell your data to anyone
• We DO NOT share data with advertisers or marketing companies
• We DO NOT share data with data brokers or analytics firms
• We DO NOT share data with social media platforms
• We DO NOT share your weight or body measurements with any third party

User-Initiated Data Sharing

You have full control over sharing your data through the export feature (premium users):

• Export format: CSV (comma-separated values)
• What you can export: Weight history, body measurements, settings
• You choose recipients: Email, cloud storage, healthcare providers, etc.

Legal Requirements

We may disclose information if required by law, such as in response to a valid court order or government request. We will notify you of such requests when legally permitted. We have never received such a request to date.

11. Third-Party Services

sWeight minimizes third-party dependencies to protect your privacy. The following services may be involved when you use the app:

App Distribution & Purchases

• Apple App Store: App distribution and in-app purchases for iOS - Privacy Policy
• Google Play Store: App distribution and in-app purchases for Android - Privacy Policy
• Huawei AppGallery: App distribution and in-app purchases for Huawei devices - Privacy Policy

Feedback Processing

• Sapplify API: Our own server (Frankfurt, Germany) for processing user-submitted feedback only

Huawei-Specific Services (Huawei Devices Only)

• Huawei IAP: In-app purchase processing for Huawei devices
• Huawei Update Service: App update checking on Huawei devices

What We DO NOT Use

• No Google Analytics or any analytics service
• No Firebase Analytics or Crashlytics
• No advertising networks (Facebook Ads, Google Ads, etc.)
• No social media SDKs or integrations
• No third-party crash reporting that transmits data
• No user tracking or behavioral analytics

Fonts

The app includes fonts locally bundled within the app. No external font loading or requests are made during app use.

12. Data Security

We implement security measures to protect your health data:

Local Data Security

Device Cloud Backup Disclosure

While sWeight does not transmit your health data to its own servers, your data may be included in your device's native cloud backup services if you have them enabled:

• iOS: Your sWeight data may be included in iCloud Backup if you have this service enabled. Apple encrypts iCloud backups, but your data would be stored on Apple's servers.
• Android: Your sWeight data may be included in Google One or device backups if you have backup enabled. Google encrypts these backups, but your data would be stored on Google's servers.

This is your choice and responsibility. Cloud backup allows you to restore your weight history if you switch devices or reinstall the app. You can manage your device's cloud backup settings:

• iOS: Settings > [Your Name] > iCloud > iCloud Backup, or exclude specific apps under iCloud > Manage Storage
• Android: Settings > Google > Backup

We are not responsible for the security or privacy practices of Apple, Google, or other third-party cloud backup providers. Please review their respective privacy policies if you use their backup services.

Transmission Security

• All network communications use HTTPS/TLS encryption
• Server located in Frankfurt, Germany (EU jurisdiction)
• 30-second timeout on all requests

Limitations

Please note:

• The local SQLite database is not encrypted at rest (relies on device security)
• Device fingerprint data uses Base64 encoding for storage
• Security depends significantly on your device's own security measures

Your Responsibility

To maximize security of your health data, we recommend:

• Enable device lock screen protection (PIN, password, biometric)
• Keep your device operating system and sWeight app updated
• Review your device's cloud backup settings if you wish to prevent cloud storage of your health data
• Be cautious when sharing exported data
• Do not use sWeight on shared or public devices
• Create regular local backups using the export feature

13. Data Retention & Deletion

Health Data Retention

• All health data (weight, measurements) is stored locally on your device indefinitely until you delete it
• We do not have access to your health data and cannot delete it remotely
• You have complete control over data retention

Device Identifier Retention

• Device identifier files persist on your device until manually removed
• On Android, the identifier file may persist in external storage after app uninstall
• On iOS, uninstalling the app removes all app data including identifiers

Feedback Data Retention

• Submitted feedback is retained on our servers for up to 2 years
• Feedback is used to improve the app and respond to inquiries
• You can request deletion of feedback data by contacting us

How to Delete Your Data

Delete All Local Data

Within the app: Go to Settings > Delete All Data. This permanently removes all weight entries, measurements, and settings from your device.

Complete Data Removal (Android)

To fully remove all data including device identifier:

1. Delete all data within the app
2. Uninstall the app
3. Use a file manager to delete any hidden files (.sweight_*) from your device storage

Complete Data Removal (iOS)

Uninstalling the app removes all local data and identifiers.

Delete Feedback Data

Email privacy@sapplify.com to request deletion of any feedback you have submitted.

14. Your Rights

You have comprehensive rights over your personal and health data:

General Rights (All Users)

• Access: View all your data within the app at any time
• Export: Download your complete data in CSV format (premium feature)
• Correction: Edit any weight entry, measurement, or setting directly in the app
• Deletion: Delete individual entries or all data at any time
• Withdraw Consent: Stop using the app and delete your data at any time

GDPR Rights (EU/EEA Users)

Under the General Data Protection Regulation, you have the following rights:

• Right of Access (Art. 15): Request confirmation of what personal data we process
• Right to Rectification (Art. 16): Request correction of inaccurate data
• Right to Erasure (Art. 17): Request deletion of your personal data ("right to be forgotten")
• Right to Restriction (Art. 18): Request limitation of processing
• Right to Data Portability (Art. 20): Receive your data in a machine-readable format (CSV export)
• Right to Object (Art. 21): Object to processing based on legitimate interests
• Right to Withdraw Consent (Art. 7): Withdraw consent for health data processing at any time
• Right to Lodge a Complaint: File a complaint with your local data protection authority

CCPA/CPRA Rights (California Users)

California residents have additional rights under the California Consumer Privacy Act and California Privacy Rights Act:

• Right to Know: What personal information is collected, used, and disclosed
• Right to Delete: Request deletion of personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt-out of the sale or sharing of personal information
• Right to Non-Discrimination: Not be discriminated against for exercising privacy rights

We do not sell or share your personal information. We do not "sell" your data as defined by the CCPA, nor do we "share" it for cross-contextual behavioral advertising. We have no advertising in our app and do not monetize your data.

Sensitive Personal Information: Your health data (weight, body measurements) is "Sensitive Personal Information" under California law. We only use this data for the weight tracking service you requested. We do not use sensitive personal information for secondary purposes.

Right to Limit Sensitive Personal Information

California law provides the right to limit the use and disclosure of sensitive personal information. Because all processing in sWeight is local to your device, you maintain the ultimate control over your sensitive data:

• You can delete individual weight entries or body measurements at any time within the app
• You can delete all historical data via Settings, which immediately terminates all local AI analysis of that data
• You can uninstall the app to remove all sensitive data from your device
• No sensitive data is transmitted to our servers, so there is nothing to limit on our end

Since we do not collect, store, or process your sensitive personal information on our servers, the "Right to Limit" is inherently satisfied by our local-only architecture. You have complete and immediate control.

UK GDPR Rights (United Kingdom Users)

Following Brexit, the United Kingdom has adopted the UK GDPR, which mirrors the EU GDPR with minor modifications. For users in the United Kingdom:

• All references to GDPR in this policy include the UK GDPR as retained in UK law
• You have the same rights as EU users listed above (access, rectification, erasure, restriction, portability, objection)
• You may lodge complaints with the Information Commissioner's Office (ICO) at ico.org.uk

LGPD Rights (Brazil Users)

Users in Brazil have rights under the Lei Geral de Proteção de Dados (LGPD), which are similar to GDPR rights:

• Confirmation and Access: Confirm whether we process your data and access it
• Correction: Request correction of incomplete, inaccurate, or outdated data
• Anonymization, Blocking, or Deletion: Request anonymization or deletion of unnecessary or excessive data
• Data Portability: Request transfer of your data to another service provider
• Information about Sharing: Know which third parties have access to your data
• Revocation of Consent: Withdraw consent at any time

Since all health data is stored locally on your device, you can exercise these rights directly within the app. For questions about LGPD compliance, contact us at privacy@sapplify.com.

Exercising Your Rights

Since all health data is stored locally on your device, you can exercise most rights directly within the app. For rights related to feedback data or device identification, contact us at privacy@sapplify.com.

We will respond to verified requests within 30 days (or 45 days for complex requests, with notification).

15. Children's Privacy

Under 2026 data protection regulations, health data from minors under 16 is classified as sensitive personal information requiring special protections. We have chosen to set a minimum age of 16 to ensure compliance and protect young users.

Age Restrictions

• Minimum age: Users must be at least 16 years old to use sWeight
• Higher age jurisdictions: In jurisdictions where a higher age is required for consent to health data processing, that higher age applies
• United States: Users must be at least 13 years old under COPPA; however, we recommend users be 16+ due to the sensitive nature of health tracking

Why Age Restrictions Matter

Weight tracking can be a sensitive activity, particularly for minors. Unhealthy focus on weight can contribute to eating disorders and body image issues. We recommend:

• Parents/guardians supervise any use by minors between 13-16 (where legally permitted)
• Minors should use weight tracking apps only under guidance from healthcare professionals
• Focus on overall health rather than weight numbers alone

Parental Notice

If you are a parent or guardian and discover your child under 16 has been using sWeight:

• All health data is stored only on the child's device—we do not have access to it
• To remove all data: Uninstalling the app will permanently delete all health data from the device
• Alternatively, you can delete data within the app via Settings > Delete All Data before uninstalling

If you believe your child under 13 has submitted feedback through the app (which would be transmitted to our server), please contact us at privacy@sapplify.com and we will delete any such data promptly.

16. International Users

sWeight is available to users worldwide and supports 15 languages.

Local-Only Data

Since all health data is stored exclusively on your device, there are no cross-border data transfers for your weight entries, measurements, or personal health information. Your data never leaves your device.

Feedback Data

If you choose to submit feedback, it is processed on servers located in Frankfurt, Germany (European Union). This means:

• EU users: Data remains within the EU
• Non-EU users: Data is transferred to the EU, which maintains high data protection standards under GDPR

Supported Languages

sWeight is available in:

• English, German (Deutsch), French (Francais), Italian (Italiano), Spanish (Espanol)
• Portuguese (Portugues), Dutch (Nederlands), Polish (Polski)
• Czech (Cestina), Slovak (Slovencina), Turkish (Turkce), Russian
• Japanese, Chinese, Korean

Unit Support

sWeight supports both metric (kg, cm) and imperial (lbs, inches) measurement systems.

17. Data Breach Notification

We take data security seriously. Since your health data is stored only locally on your device, server-side breaches cannot expose your weight or measurement data.

What Could Be Affected

In the unlikely event of a security incident on our feedback server, the following data could potentially be affected:

• Feedback messages and their metadata
• Email addresses provided voluntarily in feedback
• Device model and OS information from feedback submissions

Notification Process

In the event of a data breach affecting personal data on our servers, we will:

• Assess immediately: Investigate the scope and impact
• Notify authorities: Report to the Slovak data protection authority within 72 hours as required by GDPR Article 33
• Notify affected users: Inform you without undue delay if the breach poses a high risk to your rights, as required by GDPR Article 34
• Provide details: Explain the nature of the breach, potential consequences, and measures taken

Local Data Security

Your health data stored locally on your device is not affected by server-side security incidents. This is a key benefit of our local-first architecture. However, you should:

• Keep your device secure with screen lock
• Keep your operating system updated
• Be cautious about installing apps from unknown sources

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, add new features, or comply with legal requirements.

How We Notify You

When we make material changes, we will notify you by:

• Displaying an in-app notification requiring acknowledgment
• Updating the "Last updated" date at the top of this policy
• Requiring re-acceptance for significant changes (tracked within the app)
• Updating the privacy policy in app store descriptions

Version Tracking

The app tracks which version of the Terms of Service and Privacy Policy you have accepted. If we make significant changes, you will be prompted to review and accept the updated policies.

Your Continued Use

Your continued use of sWeight after changes are posted constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you should stop using the app and delete your data.

We encourage you to review this Privacy Policy periodically.

19. Governing Law

This Privacy Policy and any disputes arising from it are governed by the laws of the Slovak Republic, without regard to conflict of law principles.

Jurisdiction

For users in the European Union, any disputes shall be subject to the jurisdiction of the courts in Slovakia, unless mandatory consumer protection laws in your country of residence provide otherwise.

EU Users - Supervisory Authority

If you are located in the European Union, you have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your data protection rights.

As we are based in Slovakia, our lead supervisory authority is:

Urad na ochranu osobnych udajov Slovenskej republiky
(Office for Personal Data Protection of the Slovak Republic)
Hranicna 12
820 07 Bratislava 27
Slovak Republic
Website: dataprotection.gov.sk
Email: statny.dozor@pdp.gov.sk

Dispute Resolution

We encourage you to contact us first at privacy@sapplify.com to resolve any concerns or disputes. We are committed to working with you to reach a fair resolution.

20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your data, please contact us:

General Inquiries:
contact@sapplify.com

Privacy & Data Protection:
privacy@sapplify.com

Postal Address:
Anthony Eli Rasch - sapplify
PO Box 004
91501 Nove Mesto nad Vahom
Slovakia

Response Time

We are committed to addressing your privacy concerns and will respond to your inquiry within 30 days. For complex requests, we may extend this by an additional 60 days with notification.

Data Protection Requests

For specific data protection requests (access, deletion, correction of feedback data), please include:

• A clear description of your request
• The email address used when submitting feedback (if applicable)
• Any relevant details to help us locate your data

We may need to verify your identity before processing certain requests.

Health Disclaimer

sWeight is not a medical device and is not intended to diagnose, treat, cure, or prevent any disease. For health-related questions about weight management, please consult qualified healthcare professionals.