Privacy Policy
Last updated: October 16, 2026 (Android: usage counts and creator codes)
Who is responsible
Thümmler AI GmbH, Leonardo-da-Vinci-Straße 15, 14467 Potsdam, Germany. Managing director: Helene Thümmler. Commercial register: HRB 40323 P, Amtsgericht Potsdam. Email: thuemmleraiprojects@gmail.com
The short version
Your exercise history, pain check-ins, goals and settings are stored only on your device. Posture scan photos are analyzed on your device with Apple's Vision framework and are never uploaded. We have no user accounts, no ads, no analytics SDK and no tracking. We do not sell data and do not use your data to train AI.
What data is processed
| Data | Purpose | Where | How long |
|---|---|---|---|
| Goals, pain areas, pain check-ins, completed exercises, streaks, reminder times | Running the app and showing your progress | Only on your device | Until you delete the app or use "Reset data" in Settings |
| Posture scan photo (camera or photo library) | Calculating your posture score on device | Only on your device, the photo itself is not stored by us | Only for the analysis; the score is kept on device |
| Purchase and subscription status, an anonymous app user ID, device and app version | Providing and restoring Pro subscriptions | Apple (App Store on iPhone) or Google (Google Play on Android), and RevenueCat, Inc. (USA) as our processor | As long as needed for the subscription and statutory retention |
| Anonymous usage counts: which screens and steps were used (for example "onboarding finished", "level started", "paywall shown"), app version and app language. No user ID, no device ID, no IP address, no health data, no chat content | Understanding where the app is hard to use and improving it (legitimate interest, Art. 6(1)(f) GDPR) | Our own server (Oracle Cloud Infrastructure, Frankfurt, Germany). Only daily totals per event are stored, so the data cannot be linked to you | Daily totals, deleted after about 13 months |
| Ask Mo chat messages (Pro, only if you use the chat and agree first) plus your goal, pain areas, today's pain level and streak | Generating Mo's chat replies | Sent through our own server (hosted by Oracle Cloud Infrastructure in Frankfurt, Germany) to OpenAI, L.L.C. (USA) as our processor; chat history itself stays on your device | Not stored by us; a daily message counter is kept for 48 hours. OpenAI may retain API data for up to 30 days for abuse monitoring and does not use it for training |
| Notifications | Posture and streak reminders you enable | Scheduled locally on your device | Until you turn them off |
Processors and recipients
Apple (iPhone) and Google (Google Ireland Limited, Android, privacy policy) process payments under their own privacy policies. RevenueCat, Inc. (USA, privacy policy) manages subscription status on our behalf under a data processing agreement; transfers to the USA rely on the EU Standard Contractual Clauses. Our chat relay runs on our own server hosted by Oracle (Oracle Cloud Infrastructure, Frankfurt, Germany). OpenAI, L.L.C. (USA, privacy policy) generates Ask Mo replies, only when you use Ask Mo; the transfer to OpenAI relies on the EU Standard Contractual Clauses. No other recipients.
Legal bases (GDPR)
Art. 6(1)(b) GDPR for providing the app and subscriptions, Art. 6(1)(c) for statutory retention, Art. 6(1)(f) for keeping the service secure and working.
Android version
The Android version of Mo is distributed through Google Play. It processes the same on-device data as described above, with these differences: it has no posture scan and no Ask Mo chat. Like the iPhone app, it sends anonymous usage counts (event name, app version and app language, without any user or device ID) to our own server in Frankfurt, as described in the table above. Purchase and subscription status with an anonymous app user ID is sent to Google Play and RevenueCat to provide and restore Mo Pro. Creator codes: to check a creator code, the app downloads the list of valid codes from our website (hosted on GitHub Pages, GitHub, Inc., USA, which receives the technical connection data of the request such as the IP address). If you open Mo through a creator's link, the app reads the Google Play install referrer once on your device to recognise the code. When you use a valid code, the code is stored with your anonymous RevenueCat user ID so that we can pay the creator their share of the revenue; legal basis is our legitimate interest in paying creators correctly (Art. 6(1)(f) GDPR). Reminders are scheduled locally on your device.
What we do not do
No advertising identifier (IDFA on iPhone, advertising ID on Android), no tracking across apps or websites, no analytics SDKs, no selling or sharing of data, no health data sent to servers except the pain context you choose to share in Ask Mo, no AI training on your data.
Your rights
You have the right to access, rectification, erasure, restriction, data portability and objection (Art. 15 to 21 GDPR). Because your app data stays on your device, you can delete it at any time with "Reset data" or by deleting the app. You can lodge a complaint with a supervisory authority, for example the Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg.
Children
The app is not directed at children under 13.
Changes
We will update this page if the app changes how it processes data.