ichini! Privacy Policy
Last Updated: 13 June 2025
1. Introduction
This Privacy Policy explains how Sebastian Bitzer ("we", "us", "our") collects, uses, and shares your personal data when you use the ichini! website and related services (collectively the "Service"). It also describes your privacy rights and how the law protects you. Unless otherwise defined here, capitalised terms have the meaning given in our Terms of Service.
2. Data We Collect
2.1 Data you provide directly
- Account details – name, email address, password (hashed).
- Optional demographics – date of birth, gender.
- Fitness profile – information you choose to provide about your current fitness level, workout preferences and goals, and any relevant health details such as pre‑existing conditions (special‑category data – processed only with explicit consent).
- Workout feedback – per‑exercise ratings, comments, unplanned breaks.
- Videos you upload and publish.
- Billing data – Stripe customer ID, subscription status, invoices, and (optionally) billing address/VAT ID.
2.2 Data we collect automatically
- Technical logs – IP address, browser type, device OS, request timestamps, error traces.
- Usage analytics – page views and events recorded by our self‑hosted Plausible instance (no cookies, no personal identifiers).
- Crash reports – client‑side errors may be transmitted to our servers to diagnose issues; you may object to this processing at any time via settings or by contacting support.
- Cookies – we set one session cookie for authentication; the Service functions without tracking cookies.
2.3 Future integrations
If you connect a wearable or use social login (Apple, Google, Instagram), we will receive profile data (name, email) and, in the case of wearables, fitness metrics you explicitly authorise. We will update this Policy before enabling such features.
3. How We Collect Data
We collect data through:
- Registration and profile forms.
- Workout creation and feedback interfaces.
- Secure APIs from Stripe, OpenAI/Anthropic (workout generation), and Plausible (analytics).
- Server and application logs collected by nginx, PostgreSQL, Redis, and our backend application.
4. Purposes & Legal Bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Account setup & login | Contract performance (1)(b) |
| Determining account existence during sign-in/up flow | Legitimate interest (1)(f) |
| Subscription billing & tax records | Contract performance (1)(b); Legal obligation (1)(c) |
| Personalised workouts (non‑health data) | Legitimate interest (1)(f) |
| Health‑related inputs | Explicit consent (Art. 9 (2)(a)) |
| Algorithm improvement (anonymised data) | Legitimate interest (1)(f) |
| Transactional e‑mails (password resets and critical account notices) | Contract performance (1)(b) |
| Marketing newsletter | Consent (1)(a) |
| Analytics & crash logs | Legitimate interest (1)(f) |
| Ads / retargeting (future) | Consent (1)(a) |
5. Sharing & International Transfers
We share personal data only with the following processors:
- Stripe Inc. (USA) – payments. Transfers safeguarded by EU‑US Data Privacy Framework and Standard Contractual Clauses (SCCs).
- Scaleway SAS (France) – transactional e‑mail.
- OpenAI LLC and Anthropic PBC (USA) – AI workout generation; protected by SCCs / DPF.
- EU‑based hosting provider – hosts our API, database, and analytics services in EU data centres.
- EU‑based object‑storage provider (planned) – will store user‑uploaded videos and media backups.
- Future social‑login providers (Apple, Google, Meta) under SCCs / adequacy decisions.
6. Cookies & Tracking
We use one essential session cookie for authentication. Our self‑hosted Plausible analytics is cookieless. We will request consent before using any advertising or cross‑site tracking cookies.
7. Data Retention
- Account data – stored until you delete your account or after 3 years of inactivity.
- Workout logs – retained indefinitely in anonymised or aggregated form for algorithm training.
- Raw logs (nginx, DB, Redis) – rotated every 90 days.
- Payment records – kept 10 years as required by tax law.
- Back‑ups – encrypted daily; retained for 30 days, with an additional encrypted copy stored in EU object storage, then automatically purged.
8. Security Measures
- TLS 1.3 for all data in transit.
- PostgreSQL restricted by role‑based access; privileged actions are logged.
- Daily encrypted backups stored in EU data centres and replicated to EU object storage.
- SSH key + 2FA access; firewall segmentation.
- Planned annual external penetration test once active accounts exceed 10 000.
9. Your Rights
You have the right to:
- Request access to your personal data;
- Request rectification or erasure;
- Restrict or object to processing;
- Data portability;
- Withdraw consent at any time (does not affect prior processing);
- Lodge a complaint with your local data‑protection authority.
To exercise these rights, contact us at support@ichini.app. We may need to verify your identity before responding.
10. Children
The Service is not intended for children under 16. We do not knowingly collect personal data from anyone under 16. If you are a parent or guardian and believe we have collected data from a child, please contact us and we will delete it.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be announced 30 days before they take effect via e‑mail or in‑app notice.
12. Contact
Sebastian Bitzer
ID 328003, c/o Mailboxde.com GmbH, Äussere Weberstr. 57, 02763 Zittau, Germany
Email: support@ichini.app