Privacy Policy

This is an English translation of the German Mentavo privacy policy (Datenschutzerklärung). In case of discrepancies, the German version prevails.

Version 1.2 (draft) · not yet published

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) and other applicable data protection provisions is:

Mentavo
Michel Kaluza
Großherzog-Friedrich-Straße 101
66121 Saarbrücken
Germany

Email: info@mentavo.app

2. Scope

This privacy policy informs you about the processing of personal data in connection with the use of the mobile application Mentavo and its related services.

It applies to all features of the app, in particular:

• registration and sign-in
• use of the personal user account
• journaling
• check-ins
• goals and routines
• AI-powered coaching features
• astrology features
• notifications
• paid subscriptions
• support and communication features

It also applies to this website (mentavo.app), in particular to:

• access to the pages and the log data this generates
• website analytics after consent
• signing up for the newsletter

Where processing differs between the app and the website, this is stated in the relevant section. Consent applies only where it was given.

This privacy policy applies exclusively to Mentavo. External websites or services referenced within the app or on this website are governed by the respective privacy policies of their providers.

3. Principles of data processing

Protecting your personal data is very important to us.

We process personal data exclusively in accordance with applicable data protection law, in particular the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and other applicable statutory provisions.

Personal data is processed only to the extent necessary to provide the app, carry out the user relationship, improve our services, or fulfil legal obligations.

We do not disclose personal data for advertising purposes. We do not sell personal data to third parties.

4. Legal bases for processing

Depending on the type of processing, personal data is processed on different legal bases.

Contract performance

Where processing is necessary to provide the app and its agreed features, it is carried out on the basis of Art. 6(1)(b) GDPR.

This concerns in particular:

• registration
• sign-in
• management of the user account
• storage of personal content
• provision of coaching features
• data synchronization
• subscription management

Consent

Where individual features require prior consent, processing is carried out on the basis of Art. 6(1)(a) GDPR.

Consent given may be withdrawn at any time with future effect.

Legitimate interest

Where necessary, we process data on the basis of our legitimate interest under Art. 6(1)(f) GDPR.

This includes in particular:

• ensuring IT security
• protection against misuse
• error analysis
• app stability
• further development of the app
• fraud prevention
• ensuring functionality

Legal obligations

Where statutory retention obligations exist, processing is carried out on the basis of Art. 6(1)(c) GDPR.

5. What personal data we process

Depending on how the app is used, different categories of personal data may be processed.

Account data

When you register and use a user account, we process in particular:

• email address
• encrypted password (hash)
• user identifier
• account settings
• language settings
• time zone
• registration date
• sign-in status information

Personal profile data

Where voluntarily provided by the user:

• name or display name
• profile picture
• date of birth
• time of birth
• place of birth

Content created by users

Mentavo allows you to save personal content.

This includes in particular:

• journal entries
• daily check-ins
• goals
• sub-goals
• routines
• habit logs
• notes
• coaching content
• chat histories
• feedback
• voluntary information provided during onboarding

This content is processed exclusively to provide the features requested by the user.

Astrology data

To calculate astrology features, Mentavo processes the following information, provided it is supplied by the user:

• date of birth
• time of birth
• place of birth

Technical calculation data may additionally be generated from this, for example:

• coordinates
• time zone
• horoscope data
• astrological constellations

This data is used exclusively to provide the corresponding features within the app.

Progress data

Completed activities give rise to values describing your personal progress:

• experience points per activity, with type, an internal identifier of the source, day and time zone
• total score, current and longest activity streak, number of active days
• achievements unlocked, with the time
• missions with title, description, steps and status
• periods of pauses you have set

The contents of your entries are not part of this. Details are set out in section 14.

Technical information

Technical information may also be processed to ensure the app functions properly.

This includes in particular:

• app version
• operating system
• device information
• language settings
• time zone
• timestamps
• technical error information
• diagnostic information
• log data

This data is not used to profile users for advertising purposes.

6. Special categories of personal data

Mentavo is an app for personal development, self-reflection, and organizing everyday life.

Users decide for themselves what content they enter within the app.

It is therefore possible that users voluntarily enter information that allows conclusions to be drawn about particularly sensitive personal data, for example information about:

• physical or mental well-being
• stress
• sleep
• personal crises
• emotional state
• relationships
• other personal life circumstances

Such information is provided solely on a voluntary basis by the user.

There are no mandatory fields for health information in the app. What you write in the journal, in check-ins or in a conversation is up to you.

Beyond that, you can explicitly allow Mentavo to read values from Apple Health – sleep, steps and workouts. This is switched off by default and granted separately for each kind of data; the details are in section 12.

Where such information concerns special categories of personal data within the meaning of Art. 9 GDPR, we base the processing on your explicit consent pursuant to Art. 9(2)(a) GDPR. It serves solely to provide the features you have asked for.

Mentavo is intended for personal support and self-reflection. The app is not a substitute for medical, psychological, psychotherapeutic, or other professional advice or treatment.

7. Minimum age

Mentavo is intended for users aged 14 and older.

Persons under the age of 14 may not use the app.

Where the applicable law of the user's country of residence requires parental consent, the app may only be used with such consent.

8. Registration and user account

Creating a personal user account is required to use essential features.

There are two ways to sign in: an email address and a password, or signing in with your Apple ID (section 9). When you sign in with Apple you do not set a password.

During registration, in particular the following data is processed:

• the email address, or the forwarding address from Apple
• a password – only when registering with an email address
• technical account information

The password is not stored in plain text but is processed exclusively in encrypted form.

The user account enables in particular:

• synchronization between devices
• storage of personal content
• subscription management
• account recovery
• use of AI features
• use of astrology features
• management of personal settings

The user account can be deleted at any time directly within the app. Upon deletion, all personal data is erased, unless statutory retention obligations require otherwise.

9. Signing in with Apple (Sign in with Apple)

Instead of an email address and password, you can sign in with your Apple ID. Apple checks your Apple ID; we then receive only the result and the details listed below.

What we receive

• a user identifier issued by Apple that is unique to Mentavo
• your email address
• your name – only at the very first sign-in, and only if you share it

If you choose “Hide My Email”, we receive an anonymous forwarding address from Apple instead of your own (Private Email Relay, ending in @privaterelay.appleid.com). In that case we never learn your actual address.

We send emails to such forwarding addresses exclusively from noreply@mentavo.app, the sender address registered with Apple for this purpose. Apple delivers them to your real address.

Purpose and legal basis

This processing serves to set up and run your user account. The legal basis is Art. 6(1)(b) GDPR (performance of the usage contract).

Tokens and notifications from Apple

The tokens Apple issues when you sign in are stored in our backend in encrypted form only. We need them to be able to release the link to your Apple account later.

Apple also notifies our backend when you change the email forwarding, withdraw the sign-in for Mentavo, or permanently delete your Apple account. We process these notifications in order to adjust or delete your Mentavo account accordingly.

Recipients and third country

Signing in runs through Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Our backend, which receives the sign-in, is operated with Railway (section 15); section 25 applies to it.

Retention and deletion

The user identifier, the email or forwarding address and the encrypted token are stored for as long as your user account exists.

If you delete your account, we release the link to your Apple account and delete this data. The same happens when Apple notifies us that you have withdrawn the sign-in for Mentavo or deleted your Apple account.

You can also end the access yourself at any time – in the iOS settings under “Apple ID › Sign in with Apple”. Your Mentavo account is not affected by this at first; delete it in the app as well if your content is to go too.

10. AI features (OpenAI)

Mentavo offers AI-powered features to support personal reflection, goal planning, motivation, and coaching.

The provider of these features is OpenAI. To deliver them, the content needed for the purpose is transmitted to the OpenAI API. OpenAI is therefore a recipient of personal data (section 24).

Which features use OpenAI

• the conversation with the coach, including voice mode
• turning voice recordings into text
• the wording of the daily focus and responses to journal entries
• the daily impulse – a short prompt for reflection, at most one a day, created only when you open “Your day”
• suggestions for goals, goal steps, routines and reminders
• the astrology readings (section 11)
• suggestions for personal missions, only on the explicit “Suggest a mission” action (section 14)
• the safety check of content (moderation)

Which data is transmitted

• your messages, questions and instructions
• the context needed for a reply – goals, routines, check-ins, journal entries and earlier conversations, for example
• voice recordings, solely to turn them into text; your replies are not read out loud
• values from Apple Health and your calendar only under the conditions described in section 12

Only what the requested feature needs is transmitted – never everything you have stored. To find matching entries, short excerpts may additionally be converted into a numerical representation.

Web research (optional)

If you allow it in the settings, the coach can research current information on the web when you ask for it. OpenAI runs the search with a tool of its own and summarises what it finds; the sources appear below the reply. No further provider is involved.

Only public terms from your question are meant to go into the search query – no feelings, no health details, no appointments and no names of private individuals. Content from your journal, check-ins, goals and routines is not transmitted. Web research is a separate switch and is off by default.

Mission proposals

If you tap “Suggest a mission”, OpenAI creates a proposal for a small mission from it. Only the following are transmitted for this purpose:

• the names of up to twelve of your routines
• the titles of up to twelve open steps of your active goals

Instead of the internal identifiers, the model only receives short labels such as “R1” or “S1”. Routines marked as done automatically via Apple Health are not offered.

Not transmitted are your chat history, the text of your message, journal entries, check-ins, values from Apple Health and the contents of your calendar. This action carries no free text: a mission is created only by tapping the action, never by anything you write in the chat.

The feature requires your consent to AI processing. Without it no model call takes place. The proposed mission is stored so that you can accept it; what you do not accept is deleted automatically, according to the periods stated in section 14.

Consent

The legal basis is your consent pursuant to Art. 6(1)(a) GDPR. When you start using the app you explicitly agree to the use of OpenAI; without that agreement the AI features are not available. The rest of the app remains usable.

Moderation is separate from this: before content is stored or answered, an OpenAI safety service checks it against the usage rules. This check produces no text and runs independently of the other AI features; it is necessary for operating the service (Art. 6(1)(f) GDPR).

Processing at OpenAI

According to OpenAI’s published information, data submitted through the API is not used to train its models unless this has been explicitly agreed to. To detect misuse, OpenAI may log requests and responses for up to 30 days.

OpenAI is based in the United States; section 25 applies.

Withdrawal

You can withdraw your consent at any time with effect for the future. No new AI replies are produced after that. Replies and messages already generated remain in your conversation until you delete them or your account.

AI-generated content is produced automatically and may be inaccurate, incomplete, or incorrect. It is intended solely for personal support and information.

Mentavo is not a substitute for medical, psychological, psychotherapeutic, legal, or other professional advice.

Further information on data processing by OpenAI is available at:
https://openai.com/de-DE/policies/privacy-policy

11. Astrology features

Mentavo offers astrological evaluations based on the birth data provided by the user.

In particular, the following is processed:

• date of birth
• time of birth
• place of birth

Determining the coordinates of the place of birth (OpenCage)

The calculation requires the geographic coordinates and the time zone of the place of birth. To determine them, our backend transmits the place name you entered to the geocoding service of OpenCage GmbH.

Only the place name itself and the language in which the result should be returned are transmitted. Your name, email address, date of birth, time of birth and user identifier are not transmitted.

This transmission only happens when you enter or change a place of birth, and it is necessary for the astrology features.

According to its own information, OpenCage operates the geocoding on servers in Germany and Finland and deletes queries after six months.

Further information on data processing by OpenCage is available at:
https://opencagedata.com/gdpr

Based on this information, astrological calculations are performed, generating for example:

• horoscope data
• astrological constellations
• planetary constellations
• houses
• aspects
• further astrological calculations

This data is used exclusively to provide the features requested by the user.

The astrological evaluations serve solely for personal entertainment and self-reflection. They do not constitute scientifically verified statements and do not predict future events.

12. Apple Health and calendar

If you want it to, Mentavo can take values from Apple Health and your device calendar into account. All of this is voluntary, switched off by default, and can be turned off again at any time.

Two separate permissions

Two things have to come together before Mentavo can read anything:

• the iOS permission for Apple Health or the calendar, and
• the permission inside Mentavo under “Profile › Connected data”.

You grant each kind of data separately – sleep, steps and workouts are separate decisions, and so are reading the calendar and adding appointments to it.

What is transmitted to us from Apple Health

• Sleep: the day you woke up and the total length of the night in minutes.
• Steps: the day and the daily total that Apple Health itself has formed across all sources.
• Workouts: at first only the number per day. If you also grant the details, the type of workout from a fixed list, its start, end and duration are added.

In particular, we do not receive sleep stages, the times you fell asleep or woke up, heart rate, energy burned, distances, routes or locations, or any indication of which device or app a value came from.

Apple Health reads more than this on your device in order to form these values – the individual stretches of a night, for example. Only the result described above reaches us.

What is transmitted to us from the calendar

From the calendar we receive nothing but figures about how full each day is:

• the number of appointments, of which all-day and back-to-back ones
• the time taken, in minutes
• when the first appointment starts and the last one ends
• the longest free window, and the free time in the morning, afternoon and evening

Titles, locations, attendees, notes and the name of the calendar stay on your device.

What we use these values for

• as background for the coach’s replies
• to choose the daily focus and for the day plan and the week view
• to tick off routines automatically, where you have set them up for that
• to make connections between your entries visible

When something goes to OpenAI

Sharing with OpenAI (section 10) requires its own, newer consent – for Apple Health per kind of data, for the calendar for reading. Earlier consents remain valid for everything without AI: storage, automatic ticking off, the day plan and choosing the daily focus.

Where that consent exists, values only reach OpenAI when your message fits the subject – a question about your sleep, for example, or about how full a day is.

As OpenAI is based in the United States, these values are transferred to a third country in the process; section 25 applies to this. You can withdraw your consent at any time with effect for the future.

If you ask the coach about specific appointments, the app reads the period you asked about on your device and sends, with that one request, at most 30 appointments from a period of at most 31 days, with exactly four details: title, start, end, and whether the appointment lasts all day. We do not store these appointments as a calendar of our own. What the coach writes about them in its reply does, however, remain as a message in your conversation.

For the wording of the daily focus, details from Apple Health and the calendar are filtered out before the request goes to OpenAI. There they only take effect in the preceding selection, which happens without AI.

Adding appointments

Mentavo only creates an appointment after you have explicitly confirmed it – either through the card in the conversation or through a clear yes in the chat or by voice. Without that confirmation nothing is written to your calendar. Mentavo does not change or delete existing appointments.

Mentavo never writes anything back to Apple Health.

Retention period

• sleep, steps and the number of workouts: no longer than 30 days
• details of individual workouts: no longer than 7 days
• the calendar figures: no longer than 28 past days; days in the future remain for as long as the permission exists

Older values are deleted by our system on its own, whether or not you open the app.

Withdrawing a permission

If you only withdraw the permission in the iOS settings, Mentavo stops reading new values – the permission inside Mentavo and the values already transmitted remain for the time being. To delete them, also switch the connection off under “Profile › Connected data”.

With that step we withdraw the permission, delete the transmitted values from that source and remove what was learned from them. The signal concerned no longer appears in stored daily recommendations and is never included in another AI request.

What does remain is content that came out of it earlier: replies the coach has already written and messages in your conversation, routines already ticked off, the visible text of an earlier daily focus, and appointments you have confirmed. You can delete these individually; deleting your user account (section 26) removes them completely.

13. Reminders

You can create reminders yourself, or tell the coach what to remind you of.

What is stored

• the title you give it
• a note, if you write one
• the day, the time and the time zone you created the reminder in
• for repeating reminders, the repeat rule and any individual exceptions
• whether the reminder is still open or done

The title and the note are your own text. They appear in no log.

What we use them for

To remind you at the time you chose, and to show the reminder in “Your day” and in your planning. The notification itself is scheduled by your app, on your device – see section 22.

The legal basis is Art. 6(1)(b) GDPR: a reminder is a feature you asked for yourself.

When the title goes to OpenAI

Only when the conversation is about reminders – when you create, check, move, complete or delete one. In every other conversation, reminders are not part of the context the coach receives. Section 10 applies.

Nothing without your confirmation

When the coach proposes a reminder, or wants to change or delete one, it happens only once you confirm the card. Mentioning one in passing does nothing.

Retention period

Reminders are stored until you delete them or delete your user account. Deleting the account removes them completely.

14. Personal progress (Mentavo Progress)

Mentavo shows you your personal progress: experience points, a level, one of six ranks, achievements, your activity streak, your week and a chronicle of your milestones. These values are derived from activities you complete in the app anyway.

Why we process this data

Progress is part of the app and makes visible what you have actually done over a longer period. The legal basis is performance of the user agreement pursuant to Art. 6(1)(b) GDPR (section 4). The caps that prevent misuse are additionally based on our legitimate interest pursuant to Art. 6(1)(f) GDPR.

What points are based on

Only completed activities are taken into account:

• daily check-in
• journal entry
• completed routine
• completed goal step
• daily focus achieved
• weekly reflection
• milestone and completion of a goal
• completed mission

In addition there are bonuses for longer activity streaks. They arise from the number of your active days, not from a single activity.

Routines marked as done automatically via Apple Health are not included. Values from Apple Health and the contents of your calendar are not processed for progress.

What is stored in the process

For each entry we store in particular the type of activity, an internal identifier of the source (for example the identifier of a goal step), the number of points, the local calendar day, the time zone and the time. In addition we store technical details that make an entry traceable – such as the version of the rules applied, the reason for a cap, and, for a correction, the reference to the entry that was reversed. We do not store the contents of your entries.

One exception concerns the check, not the storage: for a journal entry the length of the text is checked, because points are only awarded from a minimum length onwards. The text itself is read for that purpose but is not stored in the progress data.

In addition we store your total points, your current and longest activity streak, the number of your active days, achievements you have unlocked together with the time, and the setting that determines whether progress is shown to you.

What is calculated rather than stored

Level and rank are not stored but calculated from your total points each time they are shown. The same applies to your weekly progress, to the “Your path” chronicle and to the state of a running mission.

Achievements and streaks

An achievement is unlocked once its condition is met; its identifier and the time are stored. A day counts towards your streak if at least one activity was recorded on it. A single missing day may automatically count as a rest day; two missing days in a row end the streak. Points already awarded are not affected.

Pause mode

You can set a pause so that a planned break does not end your streak. For this we store the first and the last day of the pause, the time zone at the time it was created, the time of creation and of the last change, and – if you end it early – that time as well.

A pause starts no earlier than today and lasts one to seven days; within 90 days a maximum of 14 pause days is possible, and only one pause runs at a time. A pause does not change points, levels or achievements.

Corrections

The record of entries is only added to, never overwritten. If you undo a completion, a counter-entry is created; the original entry remains. This keeps it traceable how a score came about.

Hiding progress

You can hide progress in the app’s “My progress” area. After that no new progress data is created, no further missions are generated, and the coach receives no progress details. Data already stored remains until you delete your account. The automatic deletion of mission proposals you have not accepted, described below, continues to run even while progress is hidden.

Progress details in the coach conversation

If you ask the coach about your progress, or you have just reached a level, it receives a short note containing your level, rank, score, the points remaining to the next level, your current and longest streak, and the titles and state of your running missions. This note is transmitted to OpenAI as part of the conversation (section 10). It contains no content from your journal, check-ins, Apple Health or calendar.

Retention and deletion

Progress data is stored until you delete your user account; it is deleted together with the account (section 26).

For mission proposals you have not accepted, the following also applies: they are deleted automatically once their retention period of 30 days has passed. For a declined proposal the period starts when you decline it; for an expired proposal it starts at the end of the acceptance window.

The clean-up runs several times a day on our servers – regardless of whether you keep using Mentavo, and regardless of whether you have hidden progress. Technical faults can delay the deletion; the next run catches up. Accepted missions are not affected: they are part of your progress and are removed when your account is deleted.

Your rights under section 28 – access, rectification, erasure, restriction, data portability and objection – also apply to progress data. You can delete your account, and with it all progress data, yourself at any time.

15. Hosting and technical infrastructure

Mentavo consists of the mobile app, our own backend, and this website. We use the following service providers to operate them.

Database and file storage (Supabase)

We use Supabase's services to provide the app.

Supabase handles exactly two tasks:

• the PostgreSQL database holding your account data and your content
• the file storage for profile pictures you upload yourself

Signing in to your user account does not run through Supabase but through our own backend (see the following subsection and section 8).

The database is operated in the Stockholm region (Sweden), that is, on servers within the European Union.

Where legally required, a data processing agreement pursuant to Art. 28 GDPR is in place with Supabase.

Further information on data processing by Supabase is available at:
https://supabase.com/privacy

App backend (Railway)

Between the app and the database sits our own backend. It is operated with the hosting provider Railway. All requests from the app run through this backend, for example registration and sign-in, the storage of content, and the handling of the AI features.

Our backend also verifies email address and password during registration and sign-in and issues the session tokens. Passwords are stored exclusively as a hash value.

In doing so, Railway processes the data that such a request technically involves:

• the content and time of the request
• the interface address called
• the IP address of the requesting device
• technical operating logs

The provider is Railway Corporation, 548 Market St PMB 68956, San Francisco, CA 94104, USA. Railway acts as a processor on our behalf.

Our service runs in Railway's “EU West” region in Amsterdam (Netherlands). As Railway is a US company and uses its own sub-processors for operations, access from a third country cannot be ruled out; section 25 applies to this.

Further information on data processing by Railway is available at:
https://railway.com/legal/privacy

Website (IONOS)

This website is hosted with IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany.

When our pages are accessed, the web server creates log files. According to IONOS, these record in particular the address or file accessed, the page visited before, browser type and version, operating system, device type, the time of access, and the IP address in shortened form.

This processing is necessary for the secure and stable operation of the website. The legal basis is our legitimate interest in technically faultless operation pursuant to Art. 6(1)(f) GDPR.

IONOS states the retention period for this log data as eight weeks. It is deleted afterwards.

The log files are not combined with other data sources and are not used to identify individual visitors.

Newsletter sign-up runs through a PHP script on the same web space; what is processed in the course of it is described in section 19.

16. Subscription management (RevenueCat)

We use RevenueCat to manage paid subscriptions.

RevenueCat processes technical information required to manage subscriptions.

This includes in particular:

• subscription status
• product identifier
• purchase history
• platform (iOS or Android)
• technical device identifiers, where necessary for matching

RevenueCat does not receive journal entries, chat histories, or other personal content.

Processing is carried out exclusively to manage and synchronize paid subscriptions.

Further information is available in RevenueCat's privacy policy.

Further information on data processing by RevenueCat is available at:
https://www.revenuecat.com/privacy

17. Error analysis and stability (Sentry)

We use Sentry to improve the stability and security of the app.

Sentry helps us detect and fix technical errors and crashes.

In doing so, in particular the following technical information may be processed:

• crash reports
• stack traces
• device information
• operating system version
• app version
• time of the error
• technical diagnostic information

Mentavo does not transmit journal entries, coaching content, chat histories, or other personal content via Sentry.

Likewise, no personal information such as name or email address is automatically transmitted to Sentry.

Processing is carried out exclusively to improve the technical stability of the app.

Further information on data processing by Sentry is available at:
https://sentry.io/privacy

18. Sending emails (Resend)

We use the Resend service to send transactional emails.

This includes in particular:

• registration
• password reset emails
• notifications about reported chat content

Only the personal data necessary to send the respective email is processed for this purpose.

Emails are sent exclusively to fulfil the requested function.

Further information on data processing by Resend is available at:
https://resend.com/legal/privacy-policy

19. Newsletter (Brevo)

You can subscribe to a newsletter on our website. The newsletter covers new articles in the Mentavo Journal and, occasionally, changes in the app. It is not required in order to use the app.

Sign-up using the double opt-in procedure

An email address is the only information required to subscribe. After you submit the form, we send an email containing a confirmation link to that address. Your address is only added to the recipient list once you have clicked that link. Without this confirmation you will not receive the newsletter.

The procedure serves as evidence that the sign-up genuinely originates from the holder of the email address provided.

Data processed

• the email address you provide,
• the time of the sign-up and the time of the confirmation,
• the language version of the website used to sign up (German or English) and the placement of the sign-up form used.

The language information is used solely to send the newsletter in the language in which it was subscribed to. We do not collect any further details; a name or salutation is not required in order to subscribe.

When the form is submitted, our web server does not store your IP address. In order to limit abusive bulk sign-ups, it derives only a hash value generated with a secret key, which is evaluated exclusively within a ten-minute window and then discarded automatically. Your IP address is not passed on to any third party as part of the newsletter sign-up.

Sending service provider

We use the Brevo service to manage the recipient list and to send the newsletter.

Brevo acts as a processor on our behalf. Which data Brevo processes beyond that for its own purposes, for example to operate and secure the service, follows from Brevo's privacy policy.

Further information on data processing by Brevo is available at:
https://www.brevo.com/legal/privacypolicy/

Legal basis

The legal basis for sending the newsletter is your consent pursuant to Art. 6(1)(a) GDPR.

The sign-up and confirmation are logged on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR in being able to demonstrate the consent given.

Withdrawal and unsubscribing

You may withdraw your consent at any time with effect for the future, without affecting the lawfulness of processing carried out up to the withdrawal.

Every newsletter email contains an unsubscribe link for this purpose. Alternatively, a message to info@mentavo.app is sufficient.

Retention period

Your email address is stored for as long as the newsletter subscription exists. After you unsubscribe, it is no longer used to send the newsletter.

We retain the records of sign-up and confirmation for as long as this is necessary in order to demonstrate consent.

No combination with data from the app

The newsletter recipient list is kept separately from your Mentavo user account. Subscribing to the newsletter does not require a user account, and the data processed for the newsletter is not combined with content from the app.

20. Website analytics (Google Analytics)

To analyze the use of our website, we use Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Analytics helps us understand how visitors use our website and supports us in continuously improving it.

Activation only after consent

We implement Google Analytics using what is known as Basic Consent Mode: the Google Analytics tag (gtag.js) is only technically loaded after you have actively consented to the analytics category in our cookie consent banner.

Without your consent, no Google Analytics script is loaded, no requests are sent to Google's servers, and no Google Analytics cookies are created (in particular, no _ga cookie).

If you decline the analytics category, Google Analytics remains fully deactivated. You can change your decision at any time via the “Cookie Settings” link in our website's footer.

Data processed

Once consent has been given, the following data may in particular be processed:

• pages visited (page views)
• technical information about device and browser
• approximate location information derived from the IP address (the IP address itself is not stored by Google Analytics)
• interactions with the website (e.g. navigation, time spent)

Google Analytics uses cookies or comparable storage technologies for this purpose, provided you have consented.

Advertising features disabled

We have technically disabled Google Signals as well as advertising-related personalization features. We use Google Analytics exclusively for reach/usage analysis, not for advertising purposes, remarketing, or conversion tracking.

Legal basis

The legal basis for this processing is your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw this consent at any time with future effect, without affecting the lawfulness of processing carried out prior to withdrawal.

Data transfer by Google

The use of Google Analytics may involve the transfer of data to Google servers, including outside the European Union or the European Economic Area. Further information on data processing by Google is available at:
https://policies.google.com/privacy

21. Usage analytics in the app (optional)

This section concerns the mobile Mentavo app only. The website analytics described in section 20 are separate from it: consent given on the website does not apply to the app, and consent given in the app does not apply to the website.

If you consent in the app, we record how new users get started with Mentavo. The sole purpose is to improve that first experience – to see which introduction steps are clear and where people get stuck.

Usage analytics are switched off by default. Nothing is pre-selected, and Mentavo is fully usable without this consent.

Data processed

Once you have given consent, we process:

• which introduction steps were shown and completed
• whether a registration or a sign-in took place
• whether a first message to the coach was sent and a first response received
• whether notifications were allowed or declined, and where in the app the request appeared (settings or reminder)
• that the app was opened, at most once per day
• the platform (iOS or Android) and the app version
• the times of these events

We only record that such an event occurred. No free-text input is transmitted.

Installation identifier

So that the individual events can form a sequence at all, the app stores a randomly generated identifier for this installation on your device and sends it, together with the data listed above, to our own servers.

This identifier is neither a device, hardware, nor advertising identifier. It is only created after you have given consent, and it is removed along with the app.

If you register or sign in, the identifier is linked to your user account. The data is therefore pseudonymous, not anonymous.

Age

Mentavo can be used from the age of 14 (section 7). You can only consent to usage analytics, however, if you are at least 16 years old; the setting in the app states this explicitly.

There is no technical age check at this point – the statement rests on your own declaration. If we learn that a consent came from a younger person, we delete the data concerned.

What is expressly not recorded

• the content of your conversations with the coach
• journal entries, check-ins, goals, and routines
• health data
• astrology content
• your name and email address
• device and advertising identifiers

No external analytics provider

The app's usage analytics run exclusively on our own infrastructure (see section 15). No analytics SDK and no external analytics provider is involved. The data is not disclosed to third parties and is not used for advertising.

Legal basis

The legal basis for this processing is your consent pursuant to Art. 6(1)(a) GDPR. For storing the identifier on your device, we rely on Section 25(1) TDDDG.

Retention period

The individual events recorded are deleted no later than 90 days after they were collected.

To document your consent, we store the time it was given and the version of the consent text. This record is subject to the same 90-day limit; it is renewed monthly for as long as you use the app with consent given. If you withdraw or stop using the app, it expires.

Withdrawal

You can withdraw your consent at any time with effect for the future, without affecting the lawfulness of processing carried out up to that point. You will find the setting in the app under “Profile › Legal information › Usage analytics”. Collection stops immediately.

When you withdraw, we delete the data recorded for this installation and, if you are signed in, the data linked to your account as well. If there is no internet connection at the moment of withdrawal, the deletion is completed as soon as the app is online again; the app shows you this pending task and lets you retry it.

Deleting your user account also deletes this data.

22. Notifications

Mentavo can remind you of reminders, routines, goals, check-ins and the daily impulse, provided you have allowed notifications.

Where notifications come from

Notifications are scheduled on your device and triggered there. We do not send them: there is no push service, and your app does not give us any device identifier for notifications.

So that your app knows what is due and when, it fetches a plan for the next fourteen days from us. It contains the times and – for reminders – their titles; both are stored with us anyway (section 13). The notification itself is only created from this on the device.

Repeating notifications are scheduled on the device in advance. If you do not open Mentavo for a longer period, the series ends until the app fetches the plan again.

What appears on the lock screen

For reminders, by default only that something is due – not what it is about. The title is shown only once you explicitly switch on the “Content in the notification” setting.

The notification for the daily impulse never states its content, only that it is ready.

Permission and withdrawal

Whether notifications may appear is your decision in your device’s system dialog. You can switch them off again at any time in your device settings or in the app; notifications already scheduled are then dropped.

23. Communication with support

When users contact our support team, we process the personal data necessary to handle the request.

This includes in particular:

• email address
• content of the request
• time of contact
• voluntarily provided information

Processing is carried out exclusively to handle the respective request.

24. Recipients of personal data

As a general rule, personal data is not disclosed to unauthorized third parties.

Where necessary to provide the app and this website, personal data may be transmitted to carefully selected service providers.

We currently use in particular the following service providers:

• Apple (signing in with Apple)
• Supabase (database and file storage)
• Railway (operation of the app backend)
• IONOS (hosting of this website)
• OpenAI (AI features)
• OpenCage (coordinates of the place of birth)
• RevenueCat (subscription management)
• Sentry (error analysis)
• Resend (transactional email delivery)
• Brevo (newsletter delivery, only after consent)
• Google Analytics (website reach/usage analysis, only after consent)

All service providers are used exclusively within the scope of applicable legal provisions.

25. Transfers to third countries

Some of the service providers used may be based outside the European Union or the European Economic Area, or may process data outside these regions. This concerns OpenAI (section 10) and Railway (section 15) in particular: both companies are based in the USA – in Railway’s case even though our service runs in the Amsterdam region.

Where personal data is transferred to third countries, this is done exclusively in compliance with Art. 44 et seq. GDPR.

Where necessary, appropriate safeguards are used, such as the standard contractual clauses approved by the European Commission or other legally recognized protection mechanisms.

26. Retention period

Personal data is stored only for as long as necessary to fulfil the respective purposes.

As a general rule:

• Account data is stored until the user account is deleted.
• Journal entries, check-ins, goals, routines, and other personal content are stored until deleted by the user or until the user account is deleted.
• Subscription information is stored in accordance with statutory and tax-related retention obligations.
• Technical error logs are stored only for as long as necessary for error analysis and to ensure app stability.
• The email address used for the newsletter is stored for as long as the subscription exists (see section 19).
• The individual events recorded by the app's usage analytics are deleted no later than 90 days after collection (see section 21).
• Values from Apple Health are stored for no longer than 30 days, details of individual workouts for no longer than 7 days, and the calendar figures for no longer than 28 past days (see section 12).
• Reminders are stored until you delete them or delete your user account (see section 13).
• Of the daily impulse we store only the finished text, no sources and no excerpts.
• Progress data is stored until the user account is deleted (see section 14).
• Mission proposals that were not accepted are deleted automatically 30 days after they expire or are declined, regardless of whether the app continues to be used (see section 14).

After the user account is deleted, all personal data is erased, unless statutory retention obligations require otherwise.

Mentavo does not create long-term backup copies of personal user data for the purpose of later restoration after an account has been deleted.

27. Data security

We take appropriate technical and organizational measures to protect personal data from loss, misuse, unauthorized access, alteration, or disclosure.

This includes in particular:

• encrypted data transmission (TLS)
• access restrictions
• authentication mechanisms
• secure storage of personal data
• regular security updates
• monitoring of technical stability
• measures to prevent misuse

Despite all technical and organizational measures, complete security of data transmission over the internet cannot be guaranteed.

28. Rights of data subjects

As a data subject, you have in particular the following rights under the General Data Protection Regulation (GDPR):

Right of access (Art. 15 GDPR)

You have the right to request confirmation as to whether we process personal data about you. If so, you have the right to obtain access to that data and further information about its processing.

Right to rectification (Art. 16 GDPR)

You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data.

Right to erasure (Art. 17 GDPR)

You have the right to request the erasure of your personal data, provided the statutory requirements are met.

Your user account can be deleted at any time directly within the Mentavo app.

Upon deletion of the user account, all personal data is erased, unless statutory retention obligations or other legal grounds prevent immediate erasure.

Right to restriction of processing (Art. 18 GDPR)

Under the statutory requirements, you have the right to request the restriction of the processing of your personal data.

Right to data portability (Art. 20 GDPR)

You have the right to receive the personal data you have provided to us, which we process automatically on the basis of your consent or for contract performance, in a structured, commonly used, and machine-readable format, or to have it transferred to another controller where technically feasible.

Right to object (Art. 21 GDPR)

Where personal data is processed on the basis of legitimate interests, you have the right to object to this processing at any time for reasons arising from your particular situation.

Withdrawal of consent

Where the processing of personal data is based on consent, you may withdraw this consent at any time with future effect.

The lawfulness of processing carried out prior to withdrawal remains unaffected.

29. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates data protection law.

You may contact, in particular, the supervisory authority responsible for your place of residence or the authority responsible for us.

30. No automated decision-making

Mentavo does not make automated decisions within the meaning of Art. 22 GDPR that produce legal effects concerning users or similarly significantly affect them.

Content generated by the integrated AI is intended solely for personal support and does not constitute an automated decision in the legal sense.

31. No disclosure for advertising purposes

Mentavo does not use personal data for personalized advertising.

In particular, there is:

• no sale of personal data,
• no rental of personal data,
• no disclosure of personal data to advertising networks,
• no profiling for advertising purposes.

The newsletter offered on our website is sent exclusively on the basis of your explicit consent and is not personalized (see section 19).

32. Changes to this privacy policy

We reserve the right to amend this privacy policy where necessary due to technical, legal, or organizational changes.

The current version is available at any time within the app and on our website.

Users will be informed of material changes in an appropriate manner within the app.

33. Privacy contact

If you have questions about the processing of personal data or wish to exercise your data protection rights, you can contact us at any time.

Mentavo
Michel Kaluza
Großherzog-Friedrich-Straße 101
66121 Saarbrücken
Germany

Email: info@mentavo.app

34. Final provisions

Mentavo was developed with the goal of supporting users in their personal development, self-reflection, and organization of everyday life.

The protection of personal data is an essential part of this commitment.

We are committed to processing personal data exclusively within the framework of applicable law and to taking appropriate technical and organizational measures to ensure an adequate level of protection.

Thank you for trusting Mentavo.