Privacy Policy

Effective Date: October 16, 2026

This Privacy Policy describes how Loop ("we," "us," "our," or "the app") collects, uses, and protects your information.

1. Information Stored on Your Device

The following data is stored locally on your device, encrypted. We do not collect or store it on our servers. The only information that ever leaves your device is the limited data described in Sections 2 and 3 below (including the Deep Loop AI feature and limited technical data) — everything else stays on your device:

• Your name (optional, used only for personalization within the app)
• Your thought entries, shifts, and reframes
• Your anchors/intentions and categories
• Session history and intensity ratings
• Streak and progress data
• Notification preferences

Encryption: Sensitive data is encrypted using AES-256-GCM authenticated encryption. Encryption keys are stored in your device's hardware-backed secure storage (Android Keystore or iOS Keychain).

Deletion: You may delete all local data at any time via Settings › Privacy › "Delete my device data". Uninstalling the app also removes all local data.

2. Information We Collect

2.1 Usage Analytics

We collect limited, non-identifying usage events to understand how the app is used and improve it:

• Event name (limited to: paywall_viewed, trial_paywall_viewed, trial_paywall_skipped, trial_started, subscription_started, shift_completed)
• Screen name (e.g., "shift," "progress")

These events contain no personal information, no user content, and no identifiers that can be linked to you. Analytics are stored on Supabase servers in Frankfurt, Germany (EU).

Legal basis (GDPR): Legitimate interest in understanding app usage and improving the service (Art. 6(1)(f)).

2.2 Device Identifier

When you use the Deep Loop AI feature, we generate a random device identifier (UUID) to:

• Track free trial usage (6 user messages per device)
• Prevent abuse of the service

This identifier is randomly generated on your device, is not linked to your identity or any account, and cannot be used to identify you personally. It is stored on Supabase (EU).

Legal basis (GDPR): Legitimate interest in fair use enforcement and abuse prevention (Art. 6(1)(f)).

2.3 IP Address

Your IP address is temporarily processed for:

• Rate limiting for service requests (maximum 40 requests per hour) and in-app AI response reports (maximum 10 reports per network address per day) to prevent abuse
• Security monitoring

IP addresses are stored for a maximum of 25 hours and are then automatically deleted. This retention period covers the active rate-limiting window plus a buffer for timezone handling and security review. They are not linked to your identity, content, or usage patterns beyond rate limiting.

Legal basis (GDPR): Legitimate interest in security and abuse prevention (Art. 6(1)(f)).

2.4 Subscription Information

If you purchase a subscription (monthly or annual), the transaction is processed by Apple App Store or Google Play Store and managed via RevenueCat. We receive:

• A pseudonymous user identifier assigned by RevenueCat (not your name or email)
• Subscription status (active, expired, cancelled)
• Purchase events (subscription started, renewed, cancelled)

We do not receive or store your payment details such as credit card numbers, billing addresses, or bank account information.

Legal basis (GDPR): Performance of contract (Art. 6(1)(b)).

2.5 Creator/Promo Codes

If you activate a creator or promotional code, we store:

• The code activated
• A reference to the creator for attribution purposes
• The bonus expiration date
• Related subscription purchase events — the product purchased and its standard price (not your payment details) — so we can calculate the referring creator's commission

This data is linked to your pseudonymous RevenueCat identifier, not to your name. Creators can see only aggregated totals (number of sign-ups, purchases, and commission owed) — never your identity, your entries, or your activity in the app. It is used solely for promotional attribution and commission accounting, and does not involve advertising, profiling, or third-party data sharing.

Legal basis (GDPR): Performance of our agreement with the creator and our legitimate interest in operating a referral program and paying creators accurately (Art. 6(1)(b) and 6(1)(f)).

3. AI-Powered Features (Deep Loop)

3.1 How Deep Loop Works

The thoughts and feelings you share in Deep Loop may reveal information about your mental or emotional state — a special category of personal data under Article 9 GDPR (see Recital 35). We process it only on the basis of your explicit consent under Article 9(2)(a), which you give on the consent screen before your first Deep Loop session and can withdraw at any time in Settings. You may decline, and declining does not affect the rest of the app.

When you use the Deep Loop AI dialogue feature:

1. Your message and recent conversation history are transmitted over an encrypted (HTTPS) connection to our server (Supabase, Frankfurt, EU)
2. The content is processed by OpenAI Ireland Ltd. to generate an AI response; any onward transfers to affiliates or sub-processors outside the EEA are governed by the DPA and applicable Chapter V safeguards.
3. The AI response is returned to you
4. RAMAS TECH does not retain your conversation content after the reply has been provided. OpenAI may retain content submitted to Chat Completions in abuse-monitoring logs for up to 30 days, unless a different documented retention regime applies.
5. Before your message is sent to the model and before the reply is shown to you, the content is subject to OpenAI's automated safety check. Content processed through the moderation service is not retained. If the safety check is unavailable, the dialogue stops and the message is not sent to the model.

OpenAI processes this data under their API Data Usage Policy, which states that API inputs are not used for model training. We do not include your name, email, or any account identifier in requests to OpenAI.

Abuse prevention: If our systems detect misuse, attacks or content flagged by the safety service, we may record the matched pattern or flagged category names, a salted SHA-256 fingerprint of the input, a salted hash of the IP address, and the first eight characters of the device identifier. We never record the message text in this log. These records are automatically deleted after 30 days.

International transfers: RAMAS TECH has appointed OpenAI Ireland Ltd. as processor under Article 28 GDPR. The main contractual relationship is within the EEA. To the extent that OpenAI Ireland transfers data to affiliates or sub-processors outside the EEA, those onward transfers are governed, under clause 4.1 of the DPA, by Standard Contractual Clauses or an adequacy decision.

3.2 AI Safety and Limitations

• AI responses are generated automatically without human review
• AI is NOT a substitute for professional mental health advice, therapy, or counseling
• AI may occasionally produce inaccurate, unexpected, or inappropriate responses
• We implement content safety filters and prompt security measures, but cannot guarantee all responses will be appropriate

If you encounter concerning AI content, please contact us at ramas.app111@gmail.com. On Android, you can also report an AI reply directly from the Deep Loop screen using “Report this response”. You select one reason from a fixed list and there is no free-text field. The report does not include the conversation, your message, the AI reply, or any user or device identifier. We retain only anonymous daily totals for each reason to assess and improve Deep Loop’s safety filters and system instructions. To prevent misuse, the network address is processed solely to enforce a limit of 10 reports per day and is automatically deleted within 25 hours, as described in Section 2.3. It is not stored with or linked to the anonymous totals.

Legal basis (GDPR): Your explicit consent, which we obtain on the consent screen before your first Deep Loop session and which you may withdraw at any time in Settings (Art. 6(1)(a)). Where the content you choose to share reveals information about your mental or emotional state — a special category of personal data under Article 9 GDPR — we rely on your explicit consent under Art. 9(2)(a) for processing it. For the limited abuse-prevention logging described above, our legal basis is our legitimate interest in keeping the service secure (Art. 6(1)(f)).

Record of consent: To demonstrate that you gave or withdrew consent, we keep a minimal record containing the event and time, the version of the wording shown, and the related pseudonymous device or subscription identifier. The record does not contain conversation content or any description of your emotional or mental state. It is retained for five years from your last consent action and is then automatically deleted. The legal basis is Art. 6(1)(c), in conjunction with Arts. 5(2), 7(1) and 24 GDPR; where necessary, Art. 6(1)(f) also applies for the establishment, exercise or defence of legal claims.

4. Voice Input

When you use voice input to speak your thoughts:

• Your speech is recognized on your device only. The app requests on-device speech recognition, so your audio is not sent to Apple or Google servers.
• If your device cannot recognize your language on-device, voice input is simply unavailable (you can type instead) — audio is never sent to the cloud as a fallback.

We do not receive, store, access, or transmit your voice recordings. Audio is processed on-device in real time by your operating system and converted to text. We receive only the transcribed text; the audio is never stored.

5. Crash Reporting

We use Firebase Crashlytics (operated by Google LLC) to collect crash reports when the app encounters errors. This includes:

• Device model and operating system version
• App version and state at crash time
• Error messages and stack traces
• Technical device identifiers used solely for crash grouping

Crash reports do NOT include your name, thoughts, entries, reflections, or any user-generated content. Crash data is retained for 90 days and used solely to diagnose and fix bugs.

Legal basis (GDPR): Legitimate interest in app stability and error diagnosis (Art. 6(1)(f)).

6. Specialist Directory

6.1 What We Display

Loop includes an optional directory of independent wellness specialists (therapists, psychologists, coaches). Specialist profiles are provided by the specialists themselves and include name, credentials, bio, photo, contact information, languages, location, and professional type.

6.2 Featured and Sponsored Listings

Some specialists may appear as "Featured" or have promoted visibility. This placement is arranged directly between the specialist and Loop by Ramas, clearly labeled, and based on listing agreements — NOT on your personal data, behavior, or usage patterns.

Important: We do NOT use your personal data, thoughts, emotions, session history, or app activity to target, recommend, or personalize specialist listings.

6.3 Independent Professionals

Specialists are independent professionals, not employees or agents of Loop by Ramas. We do not verify credentials, licenses, or qualifications. We do not guarantee the quality of their services. You must verify credentials independently before engaging any specialist.

7. Sharing Features

7.1 Progress Report Sharing

You may choose to generate and share a PDF progress report with a specialist. This feature is:

• Voluntary — you initiate the sharing
• User-controlled — you choose whether to include your name (anonymous by default)
• Local — the PDF is generated entirely on your device and shared via your device's standard share function

We do not receive, transmit, or store shared reports.

7.2 Anonymity Consideration

Even when sharing anonymously, your progress data and patterns may contain information that could potentially identify you to a recipient who knows you. You are solely responsible for the content you choose to share and the consequences of sharing.

8. Push Notifications

Push notifications are scheduled and delivered locally on your device. Your notification preferences are stored only on your device. No notification content, timing, or preferences are transmitted to our servers.

9. Third-Party Services

Our processing arrangements are documented as follows: OpenAI Ireland Ltd. is appointed as processor under a DPA signed on September 6, 2026; onward transfers outside the EEA are governed by Standard Contractual Clauses. RevenueCat processes pseudonymous subscription data under its DPA and SCCs incorporated into the applicable Terms of Service. Supabase processes data under its DPA and SCCs incorporated into the accepted Terms; the primary database is hosted in Frankfurt, while the contractual counterparty is Supabase Pte. Ltd., Singapore. Google Firebase processing is governed by Google Data Processing and Security Terms; transfers to Google LLC may also rely on its active EU-U.S. Data Privacy Framework certification. Apple and Google Play process store and payment data under their own privacy terms and applicable Chapter V safeguards.

10. Data Retention

11. Children's Privacy

Loop is for adults only and is not intended for anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18.

The date of birth is used only for this check on your device and is not stored, either on the device or on our servers. The app retains only a local flag confirming that the age verification was successfully completed. Age verification is required during app setup via date-of-birth entry. Users who indicate they are under 18 are blocked from using the app.

If we discover that someone under 18 has provided information to us, we will promptly delete any associated data. If you believe someone under 18 has used Loop, please contact us immediately at ramas.app111@gmail.com.

12. Your Privacy Rights

All Users

• Delete your data: Settings › Privacy › "Delete my device data" (removes all local data)
• Uninstall: Removes all local data from your device
• Delete your server data: The limited data held on our servers is linked only to a random Device ID and a pseudonymous subscription ID, not to your name. In Settings › Privacy, tap Request server data deletion. This immediately deletes creator or promo attribution, paid and trial usage counters, free-trial usage counters and the request-cooldown record linked to those identifiers. As a fallback, email ramas.app111@gmail.com; we will process the request within 30 days. We retain only: (i) creator commission and accounting records where required by tax or accounting law, on the basis of Art. 6(1)(c) GDPR; (ii) the consent record described in Section 3 for five years; and (iii) short-lived security records until their automatic expiry under Section 10.

European Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request that we limit processing of your data
• Objection: Object to processing based on legitimate interest
• Data Portability: Receive your data in a structured, machine-readable format
• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time
• Lodge a Complaint: File a complaint with your local data protection authority

To exercise these rights, contact ramas.app111@gmail.com. We will respond within 30 days (or as required by law).

California Users (CCPA/CPRA)

If you are a California resident, you have the following rights:

• Know: Request information about what personal information we collect and how we use it
• Delete: Request deletion of your personal information
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. We do not use sensitive personal information for purposes other than those disclosed in this Privacy Policy.

13. Security

We implement technical and organizational measures to protect your data:

• Encryption: Local data encrypted with AES-256-GCM authenticated encryption
• Secure Key Storage: Encryption keys stored in Android Keystore / iOS Keychain
• Transport Security: All network communications encrypted via HTTPS/TLS
• Access Control: Row-level security policies on database tables
• Rate Limiting: Protection against automated abuse
• No Accounts: No passwords to compromise; no centralized user database

While we implement reasonable security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

14. Do Not Track

Loop does not respond to "Do Not Track" browser signals because the app does not track users across third-party websites or applications.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Effective Date" at the top of this policy. For significant changes, we will provide notice within the app.

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

16. Contact

RAMAS TECH di Darya Samarska — operator of the Loop app (published on Google Play as "Ramas App"), Italy
Email: ramas.app111@gmail.com

For privacy inquiries, data requests, or complaints, please email us. We aim to respond within 30 days.