Legal

Privacy Policy

Effective date: 12 November 2026 · Last updated: 12 November 2026 · Version 1.0

Who we are#

Uncount is made by DGTL-T, a sole proprietorship (eenmanszaak) registered in the Netherlands, trading as Uncount, Keurenplein 41, Box D8515, 1069 CD Amsterdam, the Netherlands ("we", "us"). Chamber of Commerce (KvK) number: 42147742.

We are the controller of your personal data. That means we decide why and how it is used, and we are responsible for it.

• Privacy questions and requests: uncountsupport@dgtl-t.com
• Anything else: uncountsupport@dgtl-t.com, or Settings → Contact support inside the app

We are established in the Netherlands, in the EU. We have not appointed a data protection officer (DPO), because the law does not require one for a business like ours.

This policy covers the Uncount iPhone app and this website, uncount.app. "Personal data" means any information about you as a person, even if it doesn't show your name.

How Uncount is built#

Uncount is designed to need as little of your data as possible.

There are no accounts. No sign-up, no email, no password and no social login. On first launch the app creates a random code, the install identifier. It isn't linked to your name, email address or Apple ID. It is stored in your iPhone's Keychain and synced through your iCloud, so it survives a reinstall and is the same on your Apple devices. We use it only to count your daily AI and support use, and to file your latest Daily Insight.

Your data lives in three places:

1. On your iPhone. All app data: your onboarding answers, check-ins, notes, weights, meals, progress, settings, profile picture and Coach chat history. The home-screen widget reads a small summary (streak, today's meals and practice) through an iOS App Group on the same phone.
2. In your own private iCloud. If you are signed in to iCloud, the app keeps a synced copy in Apple's CloudKit private database for backup and for your other devices. This includes your app data, profile picture, install identifier and the current day's Coach conversation. It sits in your private iCloud space under Apple's terms. We cannot access it.
3. On our server. We use Supabase, hosted on Amazon Web Services in the EU (Ireland), to run the AI features, support messages and usage limits. It stores only:
   • per install identifier, daily counts of your AI requests and support messages, so we can apply fair-use limits;
   • per install identifier, your single latest Daily Insight text, which is replaced by the next one after your next check-in;
   • app settings that contain no personal data (for example configuration values the app reads at launch).

Coach messages, and the background information sent with them, pass through the server on their way to the AI provider and back. They are not stored there. Your written check-in notes are not stored there either. Like any hosting provider, Supabase keeps standard technical logs (such as IP address, time and the address requested) for security and operations.

What we collect and why#

The table below lists every kind of data involved. "Legal basis" is the reason the EU and UK GDPR allow the use. Where data stays on your iPhone and in your own iCloud, we never receive it, so we don't process it ourselves; you control it.

Reminders are scheduled on your iPhone itself; no data about them reaches us. We don't use any analytics or crash-reporting tools besides the services named in this policy.

Health data#

Your weight, goal weight, stress, sleep quality, emotional eating, cravings and check-in notes say something about your health. Under the GDPR this is special category data (Article 9), which gets extra protection. In some US states it is consumer health data; our separate Consumer Health Data Privacy Policy covers those laws.

• On your iPhone and in your iCloud, your health data stays with you. We don't receive it.
• For the AI features, some of it is sent to an AI provider through our server, but only on the basis of your explicit consent (Article 9(2)(a)). The app asks for that consent, with a clear Allow button, before anything is sent. You can withdraw it at any time in the app (Settings → Privacy & legal → AI features). Withdrawing doesn't affect what was sent before, but nothing new is sent afterwards.
• We never use your health data for advertising, and never share it with advertisers.

AI features: Coach and Daily Insight#

Uncount has two AI features:

• Coach, an AI chat you can talk to about cravings, hard days and your plan.
• Daily Insight, a short AI-written tip that appears after each evening check-in.

Both have a daily usage limit (for example, 40 Coach messages a day).

Who provides the AI#

• Google (Gemini API), from Google LLC, is our main provider.
• OpenAI (API), from OpenAI, is used only as a back-up when Gemini is unavailable.

When data is sent#

Only when you send a Coach message or submit a daily check-in, and only after you have given permission. The first time you open Coach or finish a check-in, the app explains what is sent and to whom, and asks you to tap Allow or Not now. Without that permission, Coach and the Daily Insight are switched off and the rest of Uncount works as normal. You can change your answer at any time in Settings → Privacy & legal → AI features (tap the profile button at the top right of the home screen to open Settings).

What is sent#

Each request goes from your iPhone to our server, which passes it on to the AI provider. It contains:

• your install identifier and App Store country;
• your first name;
• your weight unit and local time;
• how many days you have used the app;
• your MRI score, band and weekly change;
• your recent check-ins: stress, sleep and emotional-charge ratings, the day's score, and your written notes;
• weight data: current weight, goal, number of weigh-ins, change over 4 weeks, expected weekly loss and projected arrival;
• your streak, today's meal windows and how many you've eaten, your practice and lesson progress, and today's insight;
• for Coach, the messages of the conversation.

We don't send your email address, your Apple ID, your profile picture or your purchase history.

What the providers may do with it#

The data is used only to write your reply or insight. We use the providers' paid API services, under which:

• Google does not use your prompts or responses to improve its products. It logs them for a limited period only to detect and prevent violations of its Prohibited Use Policy, for safety and security, and for any legally required disclosures (Gemini API terms).
• OpenAI does not use data sent to its API to train or improve its models. It keeps abuse-monitoring logs for up to 30 days unless the law requires longer (OpenAI API data controls).

Both act on our instructions under data processing terms. Our server does not store Coach messages or your notes; it keeps only your latest Daily Insight, as explained above.

Accuracy#

AI answers are written automatically and can be wrong, incomplete or out of date. They are not medical, psychological or nutritional advice. Don't rely on them in an emergency. See our Health & Wellness Disclaimer.

Your choice#

Saying no to AI is fine: everything else keeps working. To withdraw your permission later, go to Settings → Privacy & legal → AI features. Withdrawing stops any further sending. To also remove your stored latest insight, see Deleting your data.

Advertising measurement and tracking#

We advertise Uncount on TikTok and want to know which ads work. There are no ads inside the app, and we don't sell your data.

The tracking question. On first launch, iOS shows Apple's App Tracking Transparency question. Our explanation in it reads: "Uncount uses this to see which of our ads led you to the app. Your weight and health data is never shared for this."

What TikTok receives. The app uses the TikTok Business SDK, and our server uses TikTok's Events API, to report:

• app events: install or launch, start of a free trial, subscription, and purchase with amount and currency;
• your IP address, device information (such as model and iOS version) and a random identifier that TikTok's SDK creates for the app;
• the IDFV, a code Apple gives each app maker for your device;
• only if you allow tracking: a hashed (SHA-256, a one-way scrambled form) version of your RevenueCat user ID and the IDFA, Apple's advertising identifier.

If you don't allow tracking, the app and our server don't send your user ID or the IDFA, and if you turn tracking off later, the app tells TikTok to forget the link it had. TikTok's SDK still attaches the IDFV, IP address and device information to app events; it has no setting to switch that off without also switching off the events themselves. TikTok also uses Apple's SKAdNetwork, which reports installs without identifying you.

What TikTok never receives. Your health data, weight, check-ins, notes or Coach messages. These are never shared with TikTok or any other advertiser.

TikTok receives this data under its business terms and may also use it for its own purposes, such as measuring and improving ad delivery and preventing fraud. See TikTok's privacy policy (EEA, UK and Switzerland) or here (US).

How to opt out.

• Turn tracking off at any time: iOS Settings → Privacy & Security → Tracking, then switch off Uncount (or "Allow Apps to Request to Track").
• You can also object to advertising measurement, or (in the US) opt out of "sharing", by emailing uncountsupport@dgtl-t.com or using the in-app support form. We'll ask TikTok to delete the data it received about your device.

Purchases and subscriptions#

Apple handles all payments through the App Store. We never see your card details.

We use RevenueCat (RevenueCat, Inc., USA) to know whether your subscription is active and to restore purchases. RevenueCat receives an anonymous app user ID, your purchase and subscription events (product, price, currency, dates, trial status), your App Store country, the IDFV (and the IDFA only if you allow tracking), your IP address and basic device information.

Support and feedback#

• The support form sends the email address you enter, your message, your install identifier and your RevenueCat user ID.
• The feedback form sends a star rating, an optional message, your install identifier and your RevenueCat user ID.

Both are delivered by email through Resend (Resend, Inc., USA) to uncountsupport@dgtl-t.com, and kept in that mailbox so we can answer you and improve the app. The identifiers let us find your server records if you ask us to delete them.

Permissions on your iPhone#

• Notifications: reminders for your check-in, meals, practice, weigh-in and the end of a free trial. They are scheduled on your iPhone; there is no push server.
• Photos: you choose a profile picture with Apple's photo picker. The app sees only the one photo you pick, and it stays on your device and in your iCloud.
• Tracking: Apple's App Tracking Transparency question, explained above.
• App Store rating: Apple's standard rating prompt.

Uncount does not access your location, contacts, camera, microphone or Apple Health (HealthKit).

Who receives data#

We share data only with these providers, each for the purpose described.

We may also disclose data if the law requires it, or to protect our rights in a legal dispute. If our company is ever sold or merged, this policy continues to apply to your data.

International transfers#

Our server is in the EU. Some providers are based in the USA or may process data there. When data leaves the EU, the EEA or the UK, it is protected as follows:

• Google, Amazon Web Services, Resend and Vercel are certified under the EU-US Data Privacy Framework (and its UK Extension), which the European Commission recognises as giving adequate protection. Their contracts also include Standard Contractual Clauses.
• OpenAI, RevenueCat, Supabase (for support access and sub-processors outside the EU) and TikTok use the Standard Contractual Clauses: model contracts approved by the European Commission, with the UK Addendum for UK data.

You can ask for a copy of the relevant safeguards at uncountsupport@dgtl-t.com.

How long we keep data#

• On your iPhone and in your iCloud: until you delete it (see Deleting your data).
• Coach messages and AI request data: not stored on our server. Google keeps logs for a limited period and OpenAI for up to 30 days, for abuse monitoring.
• Latest Daily Insight: until your next check-in replaces it, and at most 30 days after your last check-in, or earlier on request.
• Usage counts: 30 days.
• Server logs: up to 7 days.
• Support and feedback emails: up to 2 years, or earlier on request.
• Subscription data (RevenueCat): while you have or had a subscription, and as long as needed for records and disputes.
• Advertising measurement data: kept by TikTok under its own retention policy.
• Website logs: a short period under Vercel's policy.

How we protect your data#

• Minimal data: no accounts, no passwords, and a random install identifier instead of your name or email.
• Encryption in transit: all connections between the app, our server and our providers use HTTPS (TLS).
• Locked-down server: the database is protected by row-level security (rules that block direct access), and the keys for the database and the AI providers exist only on the server, never in the app.
• Your own iCloud: your synced copy is protected by your Apple Account. With Apple's optional Advanced Data Protection turned on, Apple encrypts it end-to-end.

No system is perfectly secure, but we take care to keep what little we hold safe.

Your rights#

Because Uncount has no accounts and most data never leaves your phone, you control most of it directly: you can see, change or delete it in the app. For data we or our providers hold, you have the rights below.

In the EU, the EEA and the UK#

• Access: get a copy of the personal data we hold about you.
• Rectification: have incorrect data corrected.
• Erasure: have your data deleted.
• Restriction: ask us to pause using your data while something is checked.
• Portability: receive data you gave us in a common, machine-readable format.
• Objection: object to uses based on our legitimate interests, such as advertising measurement.
• Withdraw consent: at any time, for example for the AI features, without affecting what happened before.
• Complaint: contact a data protection authority. In the Netherlands that is the Autoriteit Persoonsgegevens; elsewhere in the EU, the authority in the country where you live. We'd appreciate the chance to help first.

In California and other US states with privacy laws#

Depending on where you live, you have the right to:

• know what personal information we collect, use and disclose, and to get a copy;
• delete it;
• correct it;
• opt out of the sale or sharing of personal information and of targeted advertising;
• limit the use of sensitive personal information;
• appeal a decision we make about your request;
• not be discriminated against for using these rights.

What we collect, in the terms of these laws (over the last 12 months):

• Identifiers: install identifier, RevenueCat user ID, IDFV, IDFA (only if you allow tracking), IP address, and your email address if you contact support.
• Commercial information: subscription purchases and trials.
• Internet or network activity: app events used for advertising measurement; server and website logs.
• Sensitive personal information: health data (weight, stress, sleep, emotional eating, notes), sent to our AI providers only with your consent.
• Inferences: your MRI score and plan estimates, calculated on your iPhone.

We disclose these to the service providers listed in Who receives data, for the purposes described.

Selling and sharing. We do not sell personal information for money. However, sending identifiers and app events to TikTok to measure our ads may count as "sharing" for cross-context behavioral advertising under the CCPA, or targeted advertising under other state laws. To opt out, turn off tracking in iOS (Settings → Privacy & Security → Tracking), and if you like, email uncountsupport@dgtl-t.com or use the in-app support form saying "Do not sell or share my personal information"; we'll then ask TikTok to delete what it received about your device. We don't knowingly sell or share data of anyone under 16.

Sensitive personal information. We use it only to provide the features you ask for, never to infer characteristics about you or for advertising.

Global Privacy Control. This website uses no advertising or tracking technology, so there is nothing for a Global Privacy Control signal to switch off. If that ever changes, we will honour the signal as an opt-out.

How to use your rights#

Email uncountsupport@dgtl-t.com, or send a message through Settings → Contact support in the app.

Because we don't know your name or email, the easiest way for us to find your data is a request sent from the in-app support form: it includes your install identifier and RevenueCat user ID automatically. If you email us instead, we may ask you to send a short message from the app so we can match the identifiers.

• We reply within one month (GDPR), which we may extend by two months for complex requests, or within 45 days (US state laws), which we may extend once by 45 days. We'll tell you if we need longer.
• It's free.
• In California, you can use an authorised agent; we may ask for proof that they act for you.
• If we refuse a request, we explain why. You can appeal by replying with "Appeal" in the subject line. We answer appeals within the time the law sets (for example 45 or 60 days). If you're unhappy with the outcome, you can contact your state's attorney general.

Deleting your data#

1. On your iPhone: delete the Uncount app. This removes all app data from that device.
2. In iCloud: open iOS Settings → [your name] → iCloud → Manage Storage → Uncount and delete the data.
3. On our server and with our providers: send "Delete my data" through Settings → Contact support in the app (or email uncountsupport@dgtl-t.com). We delete the usage counts and latest insight linked to your install identifier, delete your support and feedback emails, and ask RevenueCat and TikTok to delete what they hold about you.

Deleting the app does not cancel a subscription. Cancel it first; see Support.

Children#

Uncount is for adults aged 18 and over. It is not directed at children, and we don't knowingly collect data from anyone under that age. If you believe a child has used Uncount and sent us data, contact uncountsupport@dgtl-t.com and we'll delete it.

Automated calculations#

Your MRI score, plan estimate and estimated arrival month are calculated automatically, on your iPhone, from your own answers and weigh-ins. They are wellness estimates. They don't produce legal effects or anything similarly significant for you, such as decisions about credit, insurance or employment. How they work is explained on How Uncount works.

This website#

This website is a simple information site. It has no accounts and no forms. When you visit, our website host, Vercel, automatically records standard server logs (IP address, browser type, page requested and time) to deliver the site and keep it secure, based on our legitimate interests. They are kept for a short period under Vercel's policy.

The site loads no third-party scripts or fonts: its fonts and images are served from our own domain. Links to the App Store take you to Apple, where Apple's privacy policy applies.

Cookies#

This website uses no cookies, pixels or similar tracking technologies, and nothing is stored on your device when you visit. That's why there is no cookie banner. If this ever changes, we will update this section and ask for your consent before anything non-essential is used.

Changes to this policy#

We may update this policy when the app or the law changes. We'll change the date at the top, note the change in the Legal Center, and for important changes tell you in the app or on this website before they take effect.

Contact#

DGTL-T, Keurenplein 41, Box D8515, 1069 CD Amsterdam, the Netherlands

Email: uncountsupport@dgtl-t.com · Chamber of Commerce (KvK): 42147742

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