Privacy Policy

1.Controller

Lutz Hein, Tom Luxemburg 25, 54296 Trier, Germany · Email: lutz@sthein.de (see the legal notice).

2.Core principle: local-first, your data stays with you

Plan4Life is a local-first app. Everything you create — your profile, your goals, plans, daily schedules, reflections and coach conversations — is stored on your device (SwiftData) and synchronised solely to your private iCloud (Apple CloudKit, private database).

• We run no server of our own for this content and have no access to it.
• There is no user account, no registration and no email or password prompt.
• iCloud synchronisation runs through your own Apple account; Apple provides the iCloud infrastructure (see Apple's privacy policy). Legal basis: Art. 6(1)(b) GDPR

3.AI coach (optional premium feature)

If — and only if — you actively use the AI coach, the following is transmitted to our service and forwarded from there to our AI processor:

• a pseudonymised excerpt of your plan (the „context“), stripped of obvious personal details, and
• the text of your message to the coach.

Before sending, the app checks your message and blocks it if it contains obvious contact details (an email address or phone number). Names, contact details and account identifiers are not transmitted.

How the processing runs:

• Transmission to our edge function at Supabase (server location Frankfurt, EU, region eu-central-1). Content is not stored permanently there; all that is stored is a counter that limits usage (protection against abuse and runaway cost), see section 4.
• Forwarding to the AI service Anthropic PBC (Claude), USA, which generates the reply.

Transfer to a third country (USA): Anthropic is a US provider; your coach text may be transferred to the USA for processing. That transfer is covered by the EU Standard Contractual Clauses (SCC), which form part of the data processing agreement concluded with Anthropic. The app obtains your explicit consent to the coach before you first use it, and you can withdraw that consent at any time. No adequacy decision (EU-US Data Privacy Framework) is relied upon. Legal basis: Art. 6(1)(a) GDPR (processing) · Art. 46(2)(c) GDPR (SCC) · additionally Art. 49(1)(a)

Processors (Art. 28 GDPR):

• Supabase — operates the edge function and the counter database (EU region, Frankfurt), on the basis of a data processing agreement.
• Anthropic PBC (Claude) — AI processing (USA), on the basis of a data processing agreement including the EU Standard Contractual Clauses. Anthropic does not use the transmitted content to train its models; API requests are retained only briefly.

4.Device pseudonym (usage limit)

To limit coach usage — protecting against abuse and uncontrolled cost — the app sends a randomly generated identifier (UUID) with each coach request. It has no connection to your hardware, your name or your contact details and is generated locally on the device. It serves the server-side usage counter and nothing else. Legal basis: Art. 6(1)(f) GDPR

5.Calendar (optional, off by default)

If you switch it on in Settings, Plan4Life shows your appointments beside your daily plan so that you can spot overlaps. To do so the app reads — with your explicit permission via Apple's EventKit — the events in the calendars you select yourself. The feature is off by default. Legal basis: Art. 6(1)(a) GDPR (consent)

• Shared calendars: if you select a shared calendar (family or work, for example), it may contain other people's appointments. Those, too, are displayed only locally on your device.
• Your appointments never leave your device. They are not stored, not synchronised to iCloud and not transmitted to the AI coach or its provider — the context the coach receives (section 3) cannot technically contain appointments.
• Writing: at your request, Plan4Life adds milestones to a calendar of your choice. If you pick a shared calendar for this, the other participants will see that entry — that is the sharing you set up in Apple's Calendar yourself; Plan4Life shares nothing beyond it.
• Withdrawal: you can revoke access at any time in the iOS settings, or switch the feature off inside Plan4Life. If you delete your data (section 8), Plan4Life also removes the calendar events it created and your calendar selection.

6.What we do NOT do

• No tracking, no analytics or statistics tools, no advertising identifiers (no Google Analytics, Firebase, Sentry, Amplitude or similar; no IDFA / App Tracking Transparency prompt).
• No disclosure of your content for advertising or profiling purposes.
• No sale of data.

7.Subscriptions (Premium)

Purchasing and managing the premium subscription runs entirely through Apple (App Store / StoreKit). Payment data is processed by Apple; we receive no payment or contact details. Apple's privacy terms apply.

8.Deleting your data (Art. 17 GDPR)

In the app under Settings → „Delete all data“ you can remove all data locally and from your private iCloud. Since we hold no content-related server data and no account, this makes the deletion complete. The server-side usage counter contains no personal data and is reset on a rolling basis.

9.Your rights

Access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection (Art. 21) and withdrawal of consent given (Art. 7(3)).

Competent supervisory authority (place of residence Trier → Rhineland-Palatinate): Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz (LfDI RLP), Hintere Bleiche 34, 55116 Mainz, Germany.

Contact for data subject rights: lutz@sthein.de.

10.Changes

We update this policy when features or the legal situation change. Last updated: 13 July 2026.