Privacy Policy
1. Who We Are
Responsible for data processing in connection with the use of the App and this website is:
mina cosmos AG
We have deliberately designed the App so that all personal data is stored "only" in the App / on the user device, and NO personal data is transmitted to us. This Privacy Policy applies to both the mina App and our website (app.mina-cosmos.ch).
"Personal data" means: data that makes a person identifiable.
This Privacy Policy takes into account both the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR). Which regulation applies to you depends on where you live.
Since we do not process personal data of EU users in the App and processing on the website is purely technical, we do not need an EU representative under Art. 27 GDPR.
2. Core Principle: Your Data Stays on Your Device
The mina App is designed so that all data is stored exclusively locally on your device.
This means:
- We do not operate any servers that receive or store personal user data.
- We have no access to your data.
- We cannot view, restore, or delete your data.
- When you delete the App, all locally stored data is also completely deleted.
3. What Data Is Processed?
3.1. Data Stored Locally on Your Device
All content you create or store in the App remains exclusively on your device. This includes for example (non-exhaustive):
- Cycle data
- Symptoms or observations
- Profile settings
- Locally stored usage data
3.2. Technical Data
For the App’s functionality, your device may locally process technical information, e.g.:
- Device model
- Operating system version
- App version
- Local crash information
This data is not transmitted to us.
3.3. Data for In-App Purchases
If you take out a premium subscription, certain data will be processed by external providers:
RevenueCat receives:
- Transaction status
- Product ID
- Store information (Apple/Google)
- Anonymous app install ID
- Device-specific information (e.g., device model)
RevenueCat processes technical data in the USA. Since no personal data is transmitted, this transfer is unproblematic from a data protection perspective. RevenueCat does not receive any content you store in the App, nor any health data.
The payment itself is processed via the Apple App Store or Google Play Store. The privacy policies and right of withdrawal of these providers apply.
3.4. Data Related to Our Website
Our website (mina-cosmos.ch) provides information about the mina App. The landing page app.mina-cosmos.ch provides additional information about the App.
Hosting and Server Logs (app.mina-cosmos.ch)
The landing page app.mina-cosmos.ch is hosted by Vercel Inc. (USA). When the page is accessed, technical data is automatically recorded in server logs (e.g., IP address, date and time, browser, operating system, requested URL). This data is used to ensure operation and to prevent abuse.
Server logs are automatically deleted as soon as they are no longer required.
The landing page does not use cookies or tracking tools.
Vercel is certified under the Swiss-US Data Privacy Framework. More information: vercel.com/legal/privacy-policy
Cookies (mina-cosmos.ch)
Our main website mina-cosmos.ch is operated via Wix.com Ltd. and uses cookies for functionality and security. On your first visit, a cookie banner is displayed where you can manage your consent.
More information about cookies used by Wix: support.wix.com – Cookies and Your Wix Site
Newsletter / Waiting List
When you sign up for our newsletter or waiting list, your email address is transmitted to and stored by Wix.com Ltd. Wix processes this data on our behalf for the management of the mailing list.
Processing is based on your consent (Art. 6 (1) (a) GDPR). Only the email address is collected. There is no transfer to third parties. You can revoke your consent at any time and unsubscribe from the newsletter.
Wix.com Ltd. is based in Israel, which has an EU adequacy decision. More information: wix.com/about/privacy
4. Where Does the Data Come From?
All data comes:
- directly from you
- or from your device (local technical data)
- or from the App Store / RevenueCat in the context of an in-app purchase
We do not obtain any data from third parties, public sources, or external systems.
5. Why We Process Data
Since we do not store or process personal data, data processing is limited to:
5.1. Provision of the App
- Display content
- Enable local storage and push notifications
- Provide App features
5.2. Processing of Premium Subscriptions
- Technical management via RevenueCat and Apple/Google
- Contract processing and fulfillment via Apple/Google
5.3. App Stability (Local)
- Local technical data for troubleshooting (if enabled)
We do not use any tracking tools, analytics services, cookies, or advertising.
6. Legal Bases (FADP & GDPR)
Different data protection laws may apply depending on the user’s place of residence.
Since we do not process personal data, we rely solely on the legal bases for providing the App, technical functionality, and – if enabled – the use of push notifications.
We do not process health data within the meaning of the GDPR.
7. Sharing of Data
We do not share any personal data, except:
- In the context of technical processing of in-app purchases (RevenueCat, Apple, Google)
- In the context of hosting our website (Vercel Inc., USA – DPF certified)
- In the context of newsletter management (Wix.com Ltd., Israel)
We do not sell any data and do not share any content with third parties.
8. Data Security
Since all data is stored locally, responsibility for security rests with the user.
We recommend:
- Activating device lock
- Regular backups of the device and via mina App backup
- Using the latest operating system version
We cannot recover lost data.
If you use backups via iCloud or Google, the privacy policies of those providers apply.
9. Your Rights
In principle, you have the following rights:
- Right to information
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to lodge a complaint with a supervisory authority
Since we do not store personal data, we can only fulfill these rights with respect to data processed in connection with in-app purchases. For locally stored data, you are responsible yourself.
You can delete all locally stored data yourself by:
- Removing individual entries, or
- Uninstalling the App and deleting the data on the device
10. Processing of Data of Minors
10.1 Use by Minors
In principle, the App can also be used by minors. We do not collect any personal data that would allow identification of a person.
10.2 Date of Birth Request
During onboarding, the user’s full date of birth (day/month/year) is requested in order to display age‑appropriate content. This information is stored exclusively locally on the device and is not transmitted to us or to third parties.
10.3 No Special Consent Required
Since we do not process personal or sensitive health data, no parental consent is required.
10.4 Responsibility of Users
Use by minors is the responsibility of the users or their legal representatives, as we cannot verify age, and takes place within the scope of the legal provisions of the respective country of residence.
11. Changes to This Privacy Policy
We may update this Privacy Policy as needed. Changes will be communicated in the App or in the store.
12. Contact
If you have any questions about data protection, you can contact us at any time:
mina cosmos AG