Privacy Policy

Pain Journal · Effective October 19, 2026 (first published April 23, 2026; see the change log at the end)

1. Data Controller

The data controller for the Pain Journal application is:

Vizaxis Mateusz Olszewski
ul. Dworcowa 22 lok. 32
10-437 Olsztyn, Poland
NIP: 5711684432
Registered in CEIDG (Polish business registry, sole proprietorship).
Email: contact@vizaxis.com

No Data Protection Officer (DPO) has been appointed. Under GDPR Art. 37(1), appointment is mandatory only where the controller's core activities consist of large-scale processing of special-category data. Pain Journal stores health data on the user's device and our cloud-side processing is limited to (i) pseudonymous analytics with no Art. 9 content (see § 2 and § 9) and (ii) user-initiated, opt-in cloud backup that lives in the user's own iCloud container (iOS) or Google Drive App Data folder (Android). None of these meet the EDPB "core activities" or "large-scale" thresholds for an SME sole proprietor. For any data protection question, contact the controller directly at the email above.

2. What Data We Process and Why

All your pain journal entries (body map selections, severity, pain types, symptoms, sleep, medications, notes, and settings) are stored locally on your device only. We do not operate user accounts, cloud storage, or backend servers. We cannot access your locally stored journal data. Even when you contact support, we cannot read or recover entries from your device.

The app uses the following third-party services that process limited data on our behalf or as independent controllers. Apart from the optional cloud backup you switch on yourself (the last two rows), none of these services receive your pain journal entries:

3. We Do Not Track You Across Apps

Pain Journal does not use Apple's IDFA advertising identifier, does not show the App Tracking Transparency (ATT) prompt, and does not link any data from this app with third-party data for advertising or measurement. Firebase Analytics, when you opt in, runs in a privacy-respecting mode using only the per-vendor Firebase Installation ID, never IDFA.

4. Data We Do Not Collect

• Your name, phone number, postal address, or any directly identifying personal information (we never ask for it)
• Your pain journal entries, body map selections, severity ratings, pain types, symptoms, medications, sleep data or notes. These are stored on your device only and are never uploaded to our servers
• Precise location data (GPS, Wi-Fi-based location)
• Contacts, calendar, microphone or phone call data
• Payment card details, billing address, or bank information. All payment processing is handled entirely by Google Play or the Apple App Store
• Diagnostic identifiers across apps for advertising. We do not integrate any advertising SDKs or ad networks

We do not serve ads. We do not sell, rent, or trade any data. There is no business model that involves your data being seen by a third party for marketing.

5. Health Data: Special Category Under GDPR Art. 9

Pain entries, symptoms, medications, and sleep data you record in Pain Journal are health data under Article 4(15) of the GDPR and "special category" data under Article 9. Because of how we built the app:

• By default this data never leaves your device. We do not process health data on our servers, ever. We don't have servers for it.
• If you enable cloud backup, your journal database file is uploaded to your own iCloud container (iPhone, iPad) or Google Drive App Data folder (Android) over an encrypted connection. The file is stored at rest under Apple's or Google's standard server-side encryption. Pain Journal does not add a separate encryption layer of its own. We treat your decision to enable backup as your explicit consent under Art. 9(2)(a) to processing of health data for the sole purpose of backup and restore.
• If you generate a doctor report (PDF) and share it using the system share sheet (e.g. via Mail, Messages, AirDrop, WhatsApp), the destination app or recipient receives the PDF outside our control. Sharing is initiated only by you, on demand.

6. Consumer Health Data Privacy Policy (Washington)

This section is the consumer health data privacy policy required by the Washington My Health My Data Act (RCW 19.373.020). It applies to consumers in Washington and, as our practice, to everyone in the United States.

• Categories of consumer health data we collect: app usage events tied to a random app install ID (screens viewed, feature interactions, subscription status) and crash reports. Because the app is a pain diary, even this usage data can indicate that you use a health app. Your pain entries, symptoms, medications and notes never leave your device.
• Purposes: understanding how the app is used so we can improve it, and finding and fixing crashes. We do not use it for advertising or profiling.
• Sources: the app on your own device. We collect nothing from other sources.
• Categories shared and recipients: usage events and crash reports are shared with Google Firebase (Analytics and Crashlytics), which acts as our processor. Purchase status is shared with RevenueCat, which acts as our processor. We share nothing else with anyone, and we do not sell consumer health data.
• Consent: the app asks for your consent before any of this is collected. Until you choose, nothing is sent.
• Your rights: you can confirm whether we collect your consumer health data and access it, withdraw consent, and have it deleted, including from our processors.
• How to exercise them: withdraw consent at any time in Settings → Privacy Settings. For access or deletion, write to contact@vizaxis.com; we respond within 45 days. If we decline, you can appeal by replying to our answer, and you may contact the Washington Attorney General.

7. Brazil (LGPD)

In Brazil, usage analytics and crash reports from a health app can reveal health information, which the Brazilian General Data Protection Law (LGPD, Law 13.709/2018) treats as sensitive personal data under Art. 11. We therefore process them only on your consent (Art. 11, I), asked before anything is collected. Google Firebase (Analytics and Crashlytics) processes this data as our processor. Your pain entries stay on your device and are never sent to us.

You can withdraw consent at any time in Settings → Privacy Settings. Under LGPD Art. 18 you have the right to confirmation of processing, access, correction, anonymization, blocking or deletion, portability, information about sharing, and revocation of consent. Write to contact@vizaxis.com; you may also complain to the Brazilian data protection authority (ANPD).

8. Data Sharing

We do not sell, rent, or trade your data. The third-party services listed in Section 2 process data as follows:

• Google (Firebase Analytics, Crashlytics, Remote Config, Sign-In, Drive App Data) acts as a data processor under Google's Data Processing Terms. The Drive App Data folder is private to your Google account; Google's role for the backup files is that of a storage provider for your data, not ours.
• Apple Inc. (iCloud), only if you enable cloud backup on iOS, stores the backup files in your own iCloud account as an independent controller for the iCloud service. The data resides in storage you already own; we do not receive it.
• RevenueCat acts as a data processor for purchase management. See RevenueCat DPA.
• Anthropic (Claude), only if you write to us by e-mail, acts as a data processor for AI translation of your request (see Section 19). See Anthropic Privacy Policy.

We do not share data with any other third parties. Health data is never shared with anyone, by anyone other than you.

9. Consent, Legal Basis, and Opt-Out

Your legal basis for analytics and crash reporting depends on where you are.

If you are in the EU, EEA, UK, Switzerland, China, Brazil or the United States: starting with version 1.6.4, the app asks for your consent before any analytics or crash reporting is collected. New users are asked at the end of the welcome flow; if you installed an earlier version in one of these regions, the app asks once on first opening after the update. Until you choose, nothing is sent. Versions before 1.6.4 asked only in the EU, EEA and UK. The events themselves never carry your pain, symptom, medication, or other health entries; that data stays on your device only. Legal basis: consent under Art. 6(1)(a) GDPR, and storage of identifiers on your device under ePrivacy Directive Art. 5(3), in the EU, EEA and UK; consent under the Swiss Federal Act on Data Protection in Switzerland, PIPL in China, LGPD Art. 11 in Brazil (Section 7) and the Washington My Health My Data Act in the United States (Section 6). You can withdraw consent at any time in Settings → Privacy Settings.

If you are elsewhere: analytics and crash reporting are enabled by default to help us improve the app. Legal basis: legitimate interest under Art. 6(1)(f) GDPR. The data is limited to first-party product-usage events (screens viewed, features used, funnel steps) and contains none of your pain, symptom, medication, or other health entries. The in-app event payloads are sanitised so that special-category health data never leaves your device. You can opt out at any time in Settings → Privacy Settings; we keep a written legitimate-interest assessment (LIA) on file documenting the purpose, necessity, and balancing test.

In both cases, when you turn analytics off:

• Firebase Analytics collection is fully disabled
• Firebase Crashlytics collection is fully disabled
• No usage or crash data is sent to Google
• Core app functionality (logging pain, body map, reports, reminders) remains fully available

Cloud backup is a separate, opt-in choice in Settings → Cloud Backup. It is off by default. Disabling backup stops future uploads; existing backup files remain in your iCloud or Google Drive until you delete them.

Note: opting out does not affect data already collected before you changed your preference. To request deletion of previously collected analytics data, contact us.

10. Data Retention and Deletion

On your device: All journal entries, body map data, settings, and report PDFs are stored locally. You can delete individual entries from the entry detail screen, or wipe everything from Settings → Can't be undone → Reset app data. Uninstalling the app permanently deletes all local data.

In your Google Drive (if backup enabled on Android): Backup files persist until you delete them. Disabling backup in the app (Settings → Cloud backup → Disable) stops future uploads. You can:

• Delete all backup files from your Drive at drive.google.com/drive/u/0/settings → Manage apps
• Revoke Pain Journal's Drive access entirely at myaccount.google.com/permissions

In your iCloud (if backup enabled on iOS): Backup files persist until you delete them. Disabling backup in the app stops future uploads. To delete the files: iOS Settings → your Apple Account → iCloud → Manage Account Storage → Pain Journal → Delete Data.

Third-party services: Data processed by third-party services is subject to their retention policies as described in Section 2. We do not control third-party retention, but you can contact us to request that we initiate deletion where technically possible.

11. Data Security

Your local data is protected by your device's built-in security (device encryption, screen lock, sandboxed app storage). All network communications with third-party services use HTTPS encryption in transit. Backup files are stored in your own iCloud container (iOS) or Google Drive App Data folder (Android), private to your account and to Pain Journal, and Apple and Google encrypt files at rest on their servers.

Pain Journal does not apply an additional encryption layer of its own to backup files (the SQLite database file is uploaded as-is over an encrypted connection). The protection of the stored file is the provider's encryption at rest and your own account security.

Because journal data lives on your device, the security of the device itself matters: keep your screen lock enabled, keep your operating system updated, and be cautious about who has physical access to your unlocked device.

12. Your Rights Under GDPR

Under the General Data Protection Regulation, you have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Erase your data, the right to be forgotten (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20) for the personal data we hold about you. See the explanation under "Data portability" below
• Object to processing (Art. 21)
• Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (Art. 7(3))

For locally stored data and iCloud or Drive backups, you exercise these rights directly on your device and in your Apple or Google account. For data held by third-party processors (Firebase, RevenueCat), contact us at contact@vizaxis.com and we will assist you.

Data portability (Art. 20). Pain Journal stores your journal entries on your device only. Because we never receive that data, we are not the controller of it under Art. 4(7) and Art. 20 does not require us to provide an export of it. You can still export your own journal at any time using the in-app features: PDF reports (free) and CSV export (Premium feature, available in Settings → Your pain data → Export data (CSV)). For the personal data we do hold about you (Firebase analytics events tied to your app instance, Firebase Crashlytics records, RevenueCat subscription history), email us at contact@vizaxis.com and we will provide a machine-readable export within 30 days at no cost.

We will respond to data rights requests within 30 days.

13. Supervisory Authority

You have the right to lodge a complaint with your local data protection supervisory authority. For Poland:

Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2, 00-193 Warszawa, Poland
uodo.gov.pl

14. Children's Privacy

Pain Journal is not directed at children under 16 (the age of digital consent in Poland under GDPR). We do not knowingly collect personal information from children. If you believe a child under 16 has used the app in a way that resulted in personal data being processed by our third-party services, contact us and we will take steps to delete such data.

15. International Data Transfers

Third-party services (Google LLC, Apple Inc., RevenueCat Inc., Anthropic PBC) are based in the United States and may process data outside the European Economic Area. These transfers are governed by:

• The EU-U.S. Data Privacy Framework (where applicable)
• Standard Contractual Clauses (SCCs) incorporated into the providers' data processing agreements

16. Not Medical Advice

Pain Journal is a personal logging tool. It is not a medical device, not a diagnostic tool, and does not provide medical advice. Reports generated by the app summarize what you entered. They do not interpret, diagnose, or recommend treatment. Always consult a qualified healthcare professional for any medical decisions, and do not rely solely on Pain Journal in an emergency. This is also stated in the Terms of Service.

17. Changes to This Policy

We may update this Privacy Policy when our data practices change. The updated version will be posted at this URL with a revised effective date. For material changes that affect how your data is processed, we will provide notice through the app. The change log in Section 20 records every revision.

18. Contact

For questions about this Privacy Policy or to exercise your data protection rights:

Vizaxis Mateusz Olszewski
Email: contact@vizaxis.com
ul. Dworcowa 22 lok. 32, 10-437 Olsztyn, Poland
NIP: 5711684432

19. Contacting Support by E-mail

When you write to us at contact@vizaxis.com, we process your e-mail address and the content of your message only to answer your request.

• Storage: your message is stored with our e-mail provider, Google (see Section 8).
• AI translation: so that we can answer in several languages, the text of your request is sent to an AI translation service, Anthropic (Claude). Model training on this content is switched off in our account. Anthropic is listed in Section 8 and Section 15.
• Legal basis: Art. 6(1)(b) GDPR where your request concerns a purchase or subscription, otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering the people who write to us).
• Retention: as long as needed to handle your request.
• Without AI: if you prefer a reply without AI translation, say so in your message and the text of your request will not be sent to the translation service.

Please do not send health data or journal content by e-mail. We do not need it to help you.

20. Change Log

• 2026-10-19 (October 19, 2026): added Section 6 (Consumer Health Data Privacy Policy for Washington) and Section 7 (Brazil, LGPD); consent is now asked in the EU, EEA, UK, Switzerland, China, Brazil and the United States, starting with version 1.6.4 (Sections 2 and 9); later sections renumbered.
• 2026-09-29: added Section 17 on contacting support by e-mail, including AI translation of support requests by Anthropic (Claude); added Anthropic to the processors in Section 6 and the international transfers in Section 13; the change log moved from Section 17 to Section 18.
• 2026-09-18: added the iCloud backup used on iOS (Sections 1, 2, 5, 6, 8, 9, 10, 13); removed the "continued use constitutes acceptance" sentence (Section 15), which is not a valid consent mechanism; removed a planned in-app encryption layer that will not ship; corrected the analytics retention period; removed "photos", which the app does not record; corrected the wording of the reset path.
• 2026-05-15: added the NIP to Sections 1 and 16.
• 2026-04-23: first published.