Privacy Policy

1.1 Information You Provide Directly

When you register an account or interact with Alumea, we collect information you explicitly provide:

• Account Information: Full name, email address, password, date of birth, and account preferences.
• Wellness & Health Information:Self-reported symptoms, mood logs, check-ins, journal entries, cognitive exercise responses, and reflection records. Under data protection regulations (such as UK and EU GDPR), this sensitive information is categorized as "Special Category Data."
• Transaction & Subscription Data: Purchase records, subscription tiers, and payment status processed via third-party billing providers. Alumea does not store full credit card numbers or financial account credentials.
• Customer Support Data: Records of communications, feedback, and technical support inquiries submitted to us.

1.2 Information Collected Automatically

When accessing the Services, certain technical and usage data is automatically transmitted from your device:

• Device & Identifier Information: Operating system type and version, unique device identifiers, device model, hardware specifications, and system language settings.
• Usage & Event Data: App feature interaction, time spent within specific tools, session timestamps, and navigation flows inside the app.
• Network & Technical Data: IP address, connection status, application build version, performance metrics, and system crash diagnostics.
• Coarse Location Data: Country or region-level location inferred solely from IP address for localized compliance and currency formatting.

1.3 Data Derived from Third-Party Integrations

To manage subscriptions and deliver core functionality, Alumea integrates with trusted external platforms:

• Google Cloud & Firebase: Cloud hosting infrastructure, secure user authentication, database management, and essential application analytics.
• RevenueCat: In-app purchase validation, subscription status tracking, and entitlement management across mobile App Stores.
• Stripe: Direct web checkout and billing processing. Stripe directly handles sensitive financial data under PCI-DSS compliance; Alumea receives only transaction tokens, last-4 card digits, and billing country.
• Postmark: Secure transactional email infrastructure for account verification, password resets, and critical service notifications.
• Google Tag Manager & Google Analytics (Web): Used on our official website (https://alumea.app) to evaluate website traffic. Analytics operate in cookieless mode by default until user consent is granted. Health and wellness data recorded within the Alumea application is never transmitted to Google Analytics or marketing tags.

1.4 Anonymized and Aggregated Data

We may transform personal, health, and usage data into anonymized, de-identified, or aggregated formats. Effective anonymization removes or modifies identifiers so that data cannot reasonably be linked back to an individual.

We use non-identifying aggregated metrics and anonymized datasets to conduct product safety research, evaluate exercise efficacy, discover general usage patterns in health anxiety management, and optimize application features. Anonymized data may be retained after account termination. We do not attempt to re-identify anonymized datasets, nor do we share identifiable user content with external artificial intelligence providers for model training.

3.1 Data Hosting Location

All primary user data, account records, and cloud databases are hosted on secure Google Cloud Platform (GCP) infrastructure located within Europe (EEA).

3.2 Security & Encryption Standards

We implement administrative, technical, and physical safeguards designed to protect personal information:

• Data in Transit: All network traffic containing personal or health information is secured using Transport Layer Security (TLS 1.2+ / SSL).
• Data at Rest: Databases and cloud storage repositories utilize AES-256 bit encryption. Sensitive local device storage is further protected using secure system keychains and client-side encryption.
• Access Control: Internal administrative access to systems is restricted based on strict least-privilege role permissions and multi-factor authentication.

4.1 Authorized Service Providers

We engage vetted third-party service providers who assist in operating our Services under strict confidentiality and data processing agreements:

• Google Cloud / Firebase: Infrastructure hosting, database storage, authentication, and core application performance monitoring.
• RevenueCat: Subscription management and mobile App Store entitlement synchronization.
• Stripe: Direct payment processing for web transactions.
• Postmark: Delivery of transactional emails and security notifications.

4.2 Legal Obligations and Harm Prevention

We may disclose personal data if required to do so by applicable law, court order, subpoena, or governmental regulation, or when we determine in good faith that disclosure is necessary to:

• Comply with mandatory legal process or law enforcement requests.
• Enforce our Terms of Service.
• Protect the rights, property, safety, and security of Alumea, our users, or the public.
• Prevent imminent physical harm or address emergency situations involving severe danger to life.

4.3 Business Successors

In the event of a merger, acquisition, corporate reorganization, asset sale, or bankruptcy, user data may be transferred to the acquiring entity as part of business assets. Users will be notified of any such ownership transition via email or prominent notice on our website.

6.1 Right to Access

You have the right to request information regarding the personal data we process about you and obtain a copy of your records. You can inspect your data directly inside the application settings or submit an access request by emailing support@alumea.app. For additional guidance, visit our Data Policy Page.

6.2 Right to Correction

You have the right to request the correction or updating of inaccurate or incomplete personal information. You can edit your profile details directly within the app or contact support for assistance.

6.3 Right to Deletion

You have the right to request the deletion of your account and associated personal data. You may delete your account directly inside the app (navigate to Settings > Account Details > Delete Account) or send a deletion request to support@alumea.app. Upon confirmation, your personal data will be permanently purged from our active systems within 30 days, except where retention is legally mandated (such as for tax, accounting, or regulatory compliance).

Please note that posts previously shared in public community areas may have been viewed or saved by other users before account deletion. We remove your community posts from active production systems but cannot retrieve external copies held by third parties.

6.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format to enable transfer to another digital service.

6.5 Right to Object and Restriction

You have the right to object to specific processing activities or request that we restrict the scope of how your data is processed. Where restriction is requested, certain non-essential application features may become limited.

6.6 Right to Withdraw Consent

Where data processing is predicated on explicit consent (such as health anxiety check-ins and reflection logs), you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6.7 Email Communication Preferences

You may opt out of receiving promotional or marketing emails at any time by clicking the "unsubscribe" link located at the bottom of any email we send, or by contacting support@alumea.app. Even if you opt out of marketing communications, Alumea will continue to send essential service-related emails, such as security alerts, account verification notices, and subscription billing confirmations.

6.8 Right to Opt-Out of Sale or Sharing

Alumea does not sell personal information, nor do we share your personal data with third parties for cross-context behavioral advertising. If our business practices change in the future, we will notify you and provide an explicit opt-out mechanism.

6.9 Right to Non-Discrimination

We will never discriminate against you for exercising any of your legal privacy rights. We will not deny you access to the Services, charge different rates, or deliver a diminished quality of service because you exercised your rights.

6.10 How to Exercise Your Rights

To exercise any privacy rights, contact our data protection team at support@alumea.app. To protect your privacy and security, we will verify your identity before fulfilling your request. We respond to all valid requests within a reasonable timeframe (typically within 30 days or sooner as required by law).

6.11 Additional Legal Protections by Jurisdiction

• United Kingdom: UK residents hold statutory rights under the UK GDPR and Data Protection Act 2018. You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk.
• European Economic Area (EEA): EEA residents hold statutory rights under the EU General Data Protection Regulation (EU GDPR). You have the right to lodge a complaint with your local national Data Protection Authority (DPA).
• United States: US residents (including California residents under the CCPA/CPRA) hold specific statutory privacy rights. Because Alumea does not sell or share personal data for behavioral advertising, California residents are opted out of data sale/sharing by default.

6.12 Special Category Data (Mental Health & Wellness Information)

Certain information you choose to log inside Alumea (including health anxiety symptoms, emotional check-ins, and cognitive exercise logs) constitutes Special Category Data under UK GDPR and EU GDPR. We process this sensitive data strictly on the basis of your explicit consent provided during account registration and app usage. You can withdraw your consent at any time by deleting your account, after which your Special Category Data will be purged as specified in Section 6.3.

9.1 Data Retention Policy

We retain personal data for as long as your account remains active or as required to fulfill the purposes outlined in this policy. Upon account deletion, personal records are removed from active production systems within 30 days, except where retention is required by law. Fully de-identified, aggregated metrics may be retained indefinitely for analytical research.

9.2 Incident & Breach Notification

In the event of a security breach compromising your personal data, Alumea will notify affected users and relevant regulatory supervisory authorities (such as the UK ICO or EU DPAs) without undue delay, in accordance with applicable statutory timelines.