Privacy Policy

    Last updated 2026-05-18 · Version 2026-05-18

    TL;DR

    • No account. No email. No name leaves your phone.
    • Each device has a random ID that stays on the device.
    • Your bed photo is sent to our EU server, forwarded to Google Vertex AI in Frankfurt, then immediately discarded. We never store it.
    • App data on your phone inherits iOS Data Protection — encrypted at rest by iOS while your device is locked.
    • We count aggregate anonymous events only — no per-user behavioral analytics, no IP, no profiles.
    • You can export, reset, or delete your data anytime from Settings.

    Who we are

    BedLock (the "app", "we", "us") helps you build a morning bed-making habit by locking selected apps until you photograph your made bed.

    Data controller: David Ziman operating BedLock as a sole individual, Hungary
    Contact: bedlock.app@gmail.com

    1. What data we process

    CategoryExamplesWhereRetention
    Device identifierRandom UUID generated on first launchOn device (encrypted) + sent with API callsUntil you uninstall or reset
    Onboarding answersAge band, morning habit, primary goalOn device onlyUntil you uninstall or reset
    Verification historyDate + verified/skipped flagOn device onlyUntil you uninstall or reset
    Bed photoCamera captureRAM → our EU server → Google Vertex AI → discardedLess than 60 seconds. Never persisted
    Subscription statusApple receipt + entitlementApple, RevenueCat, on devicePer RevenueCat policy
    Aggregate event countersAnonymous event names (e.g. onboarding_complete, verification_success) with non-personal properties (e.g. age band)PostHog EUCounts only, no identifiers, no IP. No retention of personal data because no personal data is collected
    NotificationsBedtime/lock remindersOn device onlyUntil cancelled
    Locked apps selectionFamily Controls tokensOn device only (Apple)Until you change

    We do not collect: name, email, phone, address, contacts, location, photos library, microphone, biometrics.

    2. Legal bases (GDPR Article 6)

    ProcessingBasis
    Bed verificationPerformance of contract (Art 6(1)(b))
    Subscription managementPerformance of contract (Art 6(1)(b))
    Aggregate event countersNot applicable — these are anonymous counts, not personal data, and fall outside GDPR Article 4(1)
    NotificationsPerformance of contract (Art 6(1)(b))
    Abuse prevention (rate limits)Legitimate interest (Art 6(1)(f)) — we process anonymous device ID and IP only to enforce per-day verification limits, retain these for 24 hours, and never link them to identity. This narrow scope balances our interest in preventing abuse against your privacy.

    3. Third-party processors

    All EU/EEA region where available. DPAs signed with each.

    ProcessorPurposeLocationDPA
    Google Cloud (Vertex AI, Cloud Run, Firestore)Bed verification, backend, rate limitingFrankfurt (europe-west3)Link
    RevenueCatSubscription stateUS (SCCs)Link
    PostHogAggregate event counters (no IDs, no IP)EU (eu.posthog.com)https://posthog.com/dpa — DPA on file as precaution
    AppleFamily Controls, Notifications, App StoreEU/USApple Developer Agreement

    4. Children (GDPR Article 8)

    BedLock is intended for users aged 14 or older (the Hungarian digital-consent threshold). Users under 14 are blocked from self-onboarding. The app offers a "set up for my child" parental flow where:

    • Only the parent or guardian completes onboarding
    • Aggregate event counters remain anonymous in child-mode installs (no identifiers, no IP)
    • The parent retains control via a PIN

    Some EU member states set the threshold at 16. If you are between 14 and 15 and reside in such a state, ask your parent or guardian to set up BedLock for you.

    5. Bed photo handling

    1. You take a photo with the back camera.
    2. The app converts it to base64 in RAM.
    3. It is POSTed over HTTPS to our backend on Google Cloud Run, region europe-west3.
    4. The backend forwards it to Google Vertex AI Gemini in europe-west3 (region pinned contractually).
    5. Vertex returns a verdict (verified / not_made / no_bed / screen).
    6. The backend returns the verdict to your phone.
    7. The photo is discarded server-side immediately.
    8. The local copy is deleted from disk and memory after the call. Orphaned files older than 1 hour are swept on next app launch.

    We never log, store, train on, or share your bed photos.

    6. Local storage and encryption

    App data on your device is held in MMKV stores. These files inherit iOS Data Protection: while your device is locked, the underlying file system is encrypted at rest by iOS using your device passcode and biometrics. We do not add a second app-layer encryption because all data we store is non-sensitive (preferences, anonymous device ID, streak counts) and iOS device-level protection is the industry-standard baseline for this category of data.

    7. How we measure usage

    To improve BedLock we count anonymous events on PostHog (EU). Each event is sent with a shared identifier so it cannot be tied to you, with IP capture disabled, and without building any user profile. We only ever see aggregate counts — for example, "X users completed onboarding today" — never your individual journey. This is not personal data and therefore does not require your consent under GDPR. You can still wipe all data stored on this device anytime via Settings → Privacy & data → Reset all app data.

    8. Your rights (GDPR Articles 15–22)

    Exercise all of these directly inside the app: Settings → Privacy & data.

    • Access (Art 15) — "Export my data" returns a JSON dump
    • Portability (Art 20) — same export
    • Erasure (Art 17) — "Reset all app data" wipes everything on this device. We hold no personal analytics data, so there is nothing else to erase on our servers.
    • Rectification (Art 16) — change inputs in onboarding or settings

    You can also email bedlock.app@gmail.com. We respond within 30 days.

    9. International transfers

    Where data leaves the EU (RevenueCat in the US, Apple infrastructure), we rely on Standard Contractual Clauses (SCCs) per the European Commission's 2021 decision, plus the EU–US Data Privacy Framework where applicable.

    10. Security

    • TLS 1.2+ in transit
    • AES encryption at rest on device
    • Service-account auth (no public API keys on Vertex AI)
    • Rate limiting per device and per IP
    • No server-side log retention of bed photos (redacted at logger level)

    11. Cookies / tracking

    The app does not use cookies. We do not track individuals — only aggregate anonymous event counts on our analytics processor. Web pages at bedlock.app use only essential cookies; no third-party trackers.

    12. Changes

    If we materially change this policy, we bump the in-app consentVersion. On next launch you will be asked to consent again before any data processing resumes.

    13. Supervisory authority

    You can complain to your national data protection authority in your country of residence. Find yours at https://edpb.europa.eu/about-edpb/about-edpb/members_en. Our lead supervisory authority, as the controller resides in Hungary, is the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) — https://naih.hu.