This policy covers the Tracelle app and the website tracelle.app. The short version: your health data never leaves your iPhone.
Netting UG (haftungsbeschränkt)
Pöckinger Fußweg 3, 82340 Feldafing, Germany
Email: hallo@tracelle.app
Tracelle stores all your entries exclusively locally on your iPhone. There is no account and no server to which health data is transferred. We, the developers, cannot see your entries.
If you delete the app, all local data is deleted with it. Make a backup beforehand if you want to keep it. Legal basis for processing on your device is your consent (Art. 6 (1) (a) and Art. 9 (2) (a) GDPR), which you can withdraw at any time in the app.
Purchases and subscriptions (if offered) are handled entirely by Apple through the App Store. We receive no payment data from Apple, only anonymous, aggregated sales reports. Apple's privacy policy applies to the App Store itself.
The website uses no cookies, no tracking and no analytics tools. Fonts, images and videos are loaded only from our own web space; no third-party content such as Google Fonts or YouTube is embedded. We process personal data only when you visit the site (hosting logs) and when you voluntarily join the waitlist.
The website is hosted by Netlify, Inc. (San Francisco, USA). When you visit the site, Netlify processes technically necessary data (IP address, date and time, page requested, browser type) in server logs. Legal basis is our legitimate interest in providing the website securely (Art. 6 (1) (f) GDPR). Netlify is certified under the EU-U.S. Data Privacy Framework; standard contractual clauses apply in addition.
If you join the waitlist, your email address and the language of the page you signed up on (German or English) are sent to us via Formspree, Inc. (USA) and used only to inform you about Tracelle's launch and early access. Legal basis is your consent (Art. 6 (1) (a) GDPR). We keep your address until you unsubscribe or the purpose no longer applies; we keep proof of your sign-up as long as needed to document your consent. You can withdraw your consent at any time, informally by email to hallo@tracelle.app or via the unsubscribe link; your address will then be deleted. Formspree processes the data in the USA. Formspree is not certified under the EU-U.S. Data Privacy Framework (inactive since 26.04.2022 according to the official list), and we have no data processing agreement for the free plan we use. The transfer to the USA is therefore based on your explicit consent (Art. 49 (1) (a) GDPR), which you give by submitting the form. There is a risk that US authorities access the data and that you do not have the same legal remedies there as in the EU. We plan to move the waitlist to a provider based in the EU before launch.
If you contact us by email, we process your details (email address, content of your message) to answer your request (Art. 6 (1) (b) or (f) GDPR). We delete requests once they are settled, unless statutory retention periods apply.
We host this website with Netlify on the basis of Netlify's data processing agreement under Art. 28 GDPR; transfers to the USA rely on the EU-U.S. Data Privacy Framework, with standard contractual clauses in addition. For the waitlist (Formspree) see section 5. Our email (hallo@tracelle.app) runs on Apple's iCloud+ Mail; Apple does not offer a separate data processing agreement for it, Apple's privacy policy applies. Please do not send us health data by email. We take appropriate technical and organisational measures (Art. 32 GDPR), including TLS encryption of this website and data minimisation.
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21). Contact hallo@tracelle.app. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). Our competent authority is the Bavarian State Office for Data Protection Supervision (BayLDA), Germany. Health data stored only on your device is not accessible to us; you can view, export or delete it yourself in the app at any time.
October 2026. The German version (Datenschutzerklärung) is the legally binding one. We update this policy when the app, the website or the services we use change.