Privacy Policy

The controller is DIABOLIQ OÜ (in formation), Tornimäe tn 5, 10145 Tallinn, Estonia, represented by Ralf Joch. The company has not yet been entered in the Estonian commercial register; we will add the registry code once it has been.

For questions about data protection and for your rights you can reach us at support@diaboliq.com or by post at this address.

For an account we need your email address — we send you a link with which you show that the mailbox is yours —, a display name, your confirmation that you are at least 18 years old, and your agreement to the terms of use. Without these details we cannot provide an account. You don’t need one for the information on this website.

So that the coach can tailor a plan to you, it needs your training goal, your training level, your training days, how long you want to train, and your equipment. We process physical limitations only with your explicit consent. Height, weight and date of birth are optional and require separate consent. A profile picture and stating your gender are optional too.

The AI coach is optional. Without your consents for the coach you still have the exercise catalogue, your own plans, your workouts and your progress.

When you visit our website or the app talks to our service, our hosting provider Vercel processes the technically necessary connection data: your IP address, the time, the address requested, details about the browser or app and the operating system, and status and error messages. We need them to deliver content, find errors and fend off attacks. Vercel deletes the runtime logs after 30 days.

We use Cloudflare for our domains. For diaboliq.com and its subdomains Cloudflare handles name resolution (DNS); the connection itself runs directly to Vercel. Requests to www.diaboliq.com, diaboliq.app and diaboliq.de are received by Cloudflare and redirected to diaboliq.com; in doing so Cloudflare processes the connection data of these requests.

The legal basis is Art. 6(1)(f) GDPR: our legitimate interest in providing the service and protecting it against disruption and misuse. Insofar as the processing is necessary for the services of the app, we base it on Art. 6(1)(b) GDPR. We do not use analytics, advertising or tracking services.

Application for the test group. If you apply for the test group on this website, we store your email address and, if you provide them, your first name, where you train and how long you have been training, plus the times of the application and the confirmation. You confirm in the form that you are at least 18 years old; without this confirmation we do not accept the application, and it is not stored separately. We send you an email with a link, and only once you tap it does your application stand. With the second link in that email you withdraw it; we then delete it immediately with all details. An application is not an account.

We use the details only to allocate places in the test group and to write to you about it. When an application is confirmed, we receive a short notification without a name and without an email address. The legal basis is your consent, which you give by submitting (Art. 6(1)(a) GDPR). You can withdraw it at any time via the link in the email or at support@diaboliq.com. We delete unconfirmed applications 7 days after the email, confirmed ones twelve months after the confirmation (section 14).

Anyone who registers a gym as a partner gym at app.diaboliq.com/studio gives us, as the contact person, a name and email address, optionally a phone number, and information about the gym (name, town, address or website, billing details). We send a link to confirm the address, review the request and write after approval or rejection; the emails are sent by Scaleway. The legal basis is Art. 6(1)(b) GDPR where the contact person is the contracting party, otherwise Art. 6(1)(f) GDPR, our legitimate interest in handling the partnership with the gym. We delete unconfirmed requests after 7 days and rejected ones after 30 days; we keep a partner gym's details for the duration of the partnership and afterwards for as long as retention obligations apply, for example for invoices. A gym receives no data about users from us.

If taking part costs a fee after the public launch, we handle it through Stripe. For this, Stripe receives the name and email address of the operator, the billing address, a VAT ID and the payment details the gym enters there itself; we never see card or account details. All we keep are the IDs of the customer and the subscription at Stripe and the state of the subscription. The legal basis is the same as above, for invoices and keeping them also Art. 6(1)(c) GDPR.

For your account we store your email address, your display name, the account status and the time of registration. Added to this are details you don’t type in: the colour scheme you choose in the app, the language of the app, so that our emails and notifications arrive in it, the language of your device and whether it runs iOS or Android, each as at your last use, and the country of your last sign-in. Of your device’s languages we store only the first, as a code such as “en”. The country is only a country code that our hosting provider derives from the IP address; we do not store the IP address itself.

There is no password in the app. You sign in with a link that we send you by email, or with a passkey that you release by unlocking your device, for example with Face ID, Touch ID or your device passcode. The same email contains a six-digit code that you can enter in the app instead. The link and the code are valid for one hour and can only be redeemed once. Of the code, we only store a check value. To prevent guessing, we count wrong entries: after five, a code is used up, and after ten in one day we stop checking codes for your address for up to 24 hours. If you are signing in for the first time, we only create your account once you have redeemed the link or the code and completed registration.

For a passkey we store the public key, a name for the device and the technical details with which we verify a sign-in. The private key stays on your device or in your passkey service, such as the iCloud Keychain. From your device’s authorisation we receive neither facial images nor fingerprints nor your device passcode.

You can change your email address under Account → Profile. For this we send a code to the new address; if you have a passkey, you additionally confirm the change with it, otherwise with a second code to your previous address. Your account only moves once the codes have been entered. Afterwards we write to your previous address that it has been changed, with the new one only partly readable, and sign out all other devices. If the new address already belongs to another account, it only receives a message, and the app does not learn of it. Of the codes we only store check values; they are valid for 30 minutes, only the most recent one counts, after five wrong entries it no longer works, and we do not start more than three changes in 24 hours. We delete the request one week after it expires or is redeemed. The legal basis is Art. 6(1)(b) GDPR, for the codes and the limits also Art. 6(1)(f) GDPR, our interest in protecting your account against takeover.

For signed-in devices we keep sessions with the time of the sign-in and of the last use as well as a technical description of the app or browser. A session is valid for at most 30 days and ends earlier if it has not been used for 14 days.

Our emails are sent by Scaleway from Paris. Your email address and the text of the message are processed in the process. The emails are plain text, without tracking pixels and without health information.

The legal basis is Art. 6(1)(b) GDPR; measures against misuse we base on Art. 6(1)(f) GDPR. Colour scheme, country, language and platform we evaluate only in aggregate: which colours are chosen, for our merch, which countries accounts sign in from, which languages the devices speak, so that we know which translation comes first, and how many use iOS and Android (Art. 6(1)(f) GDPR). Nobody is contacted because of it.

If you use the training features, we store your plans — created by the coach or built yourself — including their earlier versions, and your workouts: when you trained, which exercises with how many sets, repetitions and what weight, and which exercises you skipped. From this we calculate your progress: records, your weekly streak and “Your Glut”. We also keep track of how many plan creations you are entitled to and how many you have used. If you set a pause week, we store only which week it is, never a reason. It keeps your weekly streak, and the weekly target does not apply in it.

If you reach the Flamme, Feuer or Inferno stage, we send your badge to your home (Terms of Use, section 9). For this we ask for your first and last name, delivery address, size, fit and colour. With the order we store these details, your stage, number of workouts and weekly streak on the day of the order, and later the tracking number. The print file carries your badge, your first name and the year you started training. If you choose “Remember for next time”, we keep the address, size and fit with your account; you can change or delete them at any time under Account → Delivery address.

The legal basis is Art. 6(1)(b) GDPR. There is currently nothing to pay for in the app; before subscriptions or purchases start, we will add to this policy.

If you take part in the Ember programme and it has been activated (Terms of Use, section 10), we credit you Ember under the programme terms: for training days that count, up to the weekly goal of your plan, for a full training week, for a check-in with a workout on the same UTC day, and for challenges of ours that you complete or, in the colour battle, win with your colour. For this we keep a journal. It records the occasion, the number of Ember, the day or the reference of the booking and, for a correction, the reason. If we correct your balance, you learn about it through a notification and see the amount and reason in the app. The legal basis for running the programme is Art. 6(1)(b) GDPR.

To detect misuse, we compare training frequency, duration and set patterns and, where applicable, matching delivery addresses. For this we work with your workouts and delivery addresses, which we store anyway; the review list itself stores nothing. This is an automated assessment of usage patterns and is described here as profiling. A conspicuous pattern triggers neither a deduction nor a block. A person reviews the individual case. Before a disputed deduction, we inform you about the reason through a notification and in the app, give you a case number and 14 days for your explanation in the app. Meanwhile your Ember remain usable. You can challenge the decision at support@diaboliq.com; a person reviews it again. The review list serves our legitimate interest in preventing misuse of the bonus programme (Art. 6(1)(f) GDPR).

We store your explanation with the review, together with the case number and the time. Only authorised team members who decide on the case may read it; the email to the team contains only the case number and a link. Please do not mention diagnoses or other health information that is not necessary for the review. If an explanation contains such information, we process it only insofar as it is necessary for the review and a special legal basis under Art. 9(2) GDPR permits it. We delete the text of your explanation 6 months after the decision; the fact that an explanation was received remains in the journal. Otherwise the legal basis for the explanation is Art. 6(1)(b) GDPR.

If you voluntarily scan the code at the front desk of a partner gym, we link it to your account and the time of the check-in: which gym, on which day, at what time, at most once a day. We use this information to check the conditions of participation and to award the intended Ember bonus; you only get it on a day on which you also train. We do not record GPS; the gym code can nevertheless show that you were at that gym. The gym receives no personal check-in or workout data. We delete a check-in after 12 months, and immediately with your account. The legal basis is Art. 6(1)(b) GDPR.

If you join a challenge, we store the challenge, the time you joined, your Glut stage when you joined, your group and the completion, and for a special also when you reached silver and gold. We calculate your progress from your workouts and check-ins: depending on the challenge, training days, full weeks, check-ins, days with a new record, training minutes by our clock, reps of pull-ups, push-ups, squats and swings, for the Devil’s Trio rounds of pull-ups, push-ups and squats, for the full map the muscle groups your exercises mainly train, for bingo nine squares from these figures and whether an exercise was new to you, or weight moved, meaning weight times reps of your sets, without your body weight. In our challenges we form groups of at most 20 people of the same stage; in challenges among friends there is one group of at most 20 people, regardless of stage. You can leave a challenge as long as it is running and you haven’t completed it; we then delete your participation. The legal basis for the participation you request is Art. 6(1)(b) GDPR.

For a shared goal that everyone works on together, your contribution counts towards the total of all who take part. Participants only see this total once at least 5 have contributed; only you see your contribution, and there is no ranking. For the colour battle, we store the colour of your app when you join as your team. Participants see the average training days per colour, only once a colour has at least 5 members, never individual participants. For your monthly challenge, we calculate a personal goal from your training days in the 8 weeks before and set it up for you only; you take part only once you join, and 90 days after it ends it is no longer linked to your account. In the seasons (Advent, New Year, Summer), a task from the same figures is added every week; if you reach bronze, silver or gold, we store your badge with the season, year and medal until you delete your account.

You only appear in the ranking if you give separate consent and switch it on. Other participants in your group then see your nickname, your progress and your place. Your account name, your email address and individual workouts are not shown there. You choose the nickname yourself, under Account or in a challenge; until then we suggest one. Each nickname exists only once; upper and lower case, accents and punctuation make no difference. If you want to avoid being recognised, choose a nickname that does not identify you; a nickname does not automatically make your information anonymous. Being visible is based on Art. 6(1)(a) GDPR. You consent once, when you first switch the ranking on, and afterwards switch it on and off per challenge. You can withdraw your consent at any time under Account → Consents; we then no longer show you in any ranking. This does not affect the lawfulness of the display up to then. Taking part and Ember do not depend on being visible. If you switch the ranking off, we no longer show you to the others in the ranking. We cannot automatically remove copies others have already made.

If you create a challenge for friends, we store the chosen template, the start, you as the creator and the invitation code. You share the link yourself. Anyone who opens the website behind it sees no information about you or the challenge there. Technical access data when the website is called up are processed in accordance with the general information on hosting and security (section 3).

Ideas. Under Account → Ideas you can send us ideas for Diaboliq, vote on published ideas and report one. If you submit an idea, we store your title and your description, the type of idea, whether we may name you with your nickname if it is implemented, and the time. Please do not send us any information about your health; if your text sounds like it, the app asks you again before sending, and this check happens only on your device. Only our team sees your text. What we publish is never your text but a version we write ourselves; we never name you, and we name your nickname only if you wanted us to and the idea has been implemented. We translate our version into English, French and Spanish with Anthropic (section 7); your text is not sent with it. While you type, the app suggests similar published ideas; for this it sends your text to our server, which reads it only for the search and does not store it. For your vote we store which idea it is for; you can take it back at any time. If you report an idea, we store the reason, your optional text and the time, and our team is notified. You can also report an idea by email to support@diaboliq.com, without an account. If someone misuses ideas, we can block their account for ideas; we record the reason. The legal basis is Art. 6(1)(b) GDPR, for reports and blocks Art. 6(1)(f) GDPR, our interest in keeping ideas free of misuse. We delete your text at the latest 30 days after receipt, even if we have not decided yet, and likewise the optional text of a report; the rest of a report 90 days after it has been dealt with. Votes, submissions, reports and a block go with your account. Our version of an idea remains, without any reference to you.

Physical limitations, such as problems with the knee, back or shoulder, are health data and specially protected. With your explicit consent we store them so that the coach tailors your plan to them and a hard-coded check tests every plan against them.

Height, weight and date of birth we store only with a separate, voluntary consent. They are not a prerequisite for the coach, they appear in your profile and do not go into the plan creation. A date of birth according to which you are younger than 18 we do not store.

The legal basis for both is your explicit consent, Art. 6(1)(a) and Art. 9(2)(a) GDPR. How you withdraw it and what happens then is set out in section 13.

If you like, you tell the coach your gender — female, male or non-binary. We then choose which figure demonstrates an exercise for you, where it exists with both. We use this information for nothing else (Art. 6(1)(b) GDPR).

A profile picture is optional. The app reduces it to 512 × 512 pixels before uploading. Before we store it, we remove embedded metadata — such as place of capture, device and time. We store it in a non-public storage of our hosting provider Vercel in Frankfurt; it can only be retrieved via links that we generate for your account and that expire after 24 hours. Other users do not currently see it. If you remove or replace the picture or delete your account, we delete it immediately; from Vercel’s caches it disappears, according to the provider, within about a minute. It is not analysed biometrically. The legal basis is Art. 6(1)(b) GDPR.

Our coach uses artificial intelligence, namely the Claude API from Anthropic. The contracting party is Anthropic Ireland, Limited; the data are processed mainly in the USA, at Anthropic, PBC and its service providers. The AI processing only begins once you have explicitly consented to the processing of your health information and, in addition, to the use of the AI coach.

Depending on the feature, different things go to Anthropic:

• In the conversation: the course of the current conversation, your training profile and your first name, so that the coach can address you — “Alex Muster” becomes “Alex”. In addition, whether you have already provided details such as height or gender, but not which ones. What you write in the chat yourself also goes to Anthropic: if you answer the question about height, weight, date of birth or gender, the AI reads the value out of your answer, and we store it in your profile, body data only with the consent from section 6. If the coach already knows you, the AI is given its greeting; your training figures it does not get. If you don’t use the app in German, it is told the language, so that it replies in it.
• With a plan request: goal, training level, training days and duration, equipment and physical limitations, plus an extract from our exercise catalogue and, if you don’t use the app in German, the language the plan is to be written in. Name, email address, body data and gender are not sent with it.

The structured transmission reduces the amount of data; that does not make it anonymous. Please don’t mention unnecessary details about yourself in the chat, and none about other people.

The legal basis is your consent, Art. 6(1)(a) GDPR, for health data additionally Art. 9(2)(a) GDPR. On the transfer to the USA see section 11.

We do not store the course of the conversation on our servers: we forward it for the answer, and the app keeps it only in memory while it is running. What you confirm to the coach for your profile we store there, and a plan that has been created becomes your plan (section 5).

Anthropic normally deletes API inputs and outputs within 30 days. Where violations of its policies are detected, Anthropic states exceptions of up to two years for content and up to seven years for safety assessments; statutory retention obligations may be added. We have not agreed zero retention (Anthropic’s information on retention). Anthropic does not train models with this content; the commercial terms rule that out.

The AI makes suggestions. Before a plan is stored, a hard-coded set of rules without AI checks it against your details; anything that doesn’t fit, the check does not let through. If the AI fails or is unavailable, the same set of rules puts together a plan without AI. Recommendations may nevertheless be inaccurate or incomplete. You can reject or change any plan, or build one yourself. We do not take decisions based solely on automated processing with legal or similarly significant effect within the meaning of Art. 22 GDPR.

If you allow notifications, we store your device’s delivery token (push token) and the platform, in order to tell you, for example, that your plan is ready. Delivery takes place via Expo and Apple’s notification service. The notifications contain general texts, no limitations and no contents of your plan. The legal basis is your consent (Art. 6(1)(a) GDPR). The app asks you when you order your first plan — first with our own question, and only after your yes with that of your device —, or you switch notifications on under Account → Notifications. You can withdraw the consent at any time there or in your device’s settings. We delete the delivery token when you switch notifications off — if you switch them off in the settings, the app notices as soon as you next open it —, when you sign out, delete your account or Apple reports it as invalid.

In your device’s protected keychain the app stores your sign-in, your display name — so that it can greet you even before loading —, whether it appears light or dark, your colour scheme, the language if you have chosen one, the area in which you last left it, and whether you have a plan, so that it starts there again, plus your choice about notifications and the registered delivery token. While we are testing, an access credential is added. When you sign out, it removes sign-in, name and start area. It keeps your choice about notifications for your account, with a marker it calculates from your email address, so that it applies again after your next sign-in; if another account signs in, it lapses. Whether a passkey has already been used on the device it also remembers beyond signing out, so that it shows the passkey sign-in at the top. If you delete your account, it removes both. Appearance, colour and language remain on the device. An ongoing conversation with the coach it keeps only in memory. Images such as the exercise videos and your profile picture it caches, so that they don’t have to be reloaded every time.

The app also stores an ongoing workout on your device after every set, so that nothing is lost without a connection, and sends it to us as soon as there is one. If you sign out in the middle of a workout, it first ends the workout and sends us what is still missing, provided there is a connection. It then removes the workout from the device, so that nobody who signs in there next can see it.

If you switch on a reminder under Account → Reminders, the app schedules it on your device. For this it keeps your setting there, your last workout (plan, day of the plan, time), how often you have trained this week and the pause weeks you have set, because no reminder comes during them. Nothing is stored with us for this, and no notification service is involved. No reminder mentions anything about body, health or weight. When you sign out, including after deleting your account, the app removes the setting and all scheduled reminders. If, after six weeks with the same plan, it suggests your next block and you tap “Later”, it remembers this on the device for two weeks; it removes this too when you sign out. If you open the link to a challenge before you are signed in, it keeps the invitation code on the device so that it can ask you after signing in whether you want to join. The code is valid for seven days. It is deleted as soon as the app has asked you, when you sign out, and after expiry the next time the app reads it.

The app only accesses the camera and photos when you take or select a profile picture, and only with your permission. For your passkeys it uses the system’s authorisation, that is Face ID, Touch ID or your device passcode.

If you download your data under Account → Data & legal, the app briefly places the file in its cache to offer it to you for saving or sharing, and deletes it as soon as you are done, at the latest at the next start or when you sign out. Whatever you save or share yourself is then wherever you put it.

We deliver updates to the app via Expo. For this, the app sends the app version and the operating system at every start, with a random identifier that it creates once for this purpose; Expo also learns your device’s IP address, but nothing from your account. The legal basis is Art. 6(1)(f) GDPR, our interest in fixing errors quickly and keeping the app secure.

We do not use advertising trackers or services for usage profiles, we do not sell data and do not pass it on for advertising purposes.

The website diaboliq.com does not set cookies. If you switch there between light and dark, your browser remembers the choice in local storage under “diaboliq-theme”, until you delete it there. Fonts and images we deliver ourselves; we do not embed content from other providers.

If you open a link from our emails in the browser instead of in the app, we set the sign-in cookie “diaboliq_sitzung” when you redeem it on app.diaboliq.com. Like every session it is valid for at most 30 days.

These forms of storage are strictly necessary for the function you have requested in each case (§ 25 Abs. 2 Nr. 2 TDDDG). The further processing we base on the grounds named in this policy. Anything that requires consent beyond that, such as notifications, only happens once you have agreed.

We use service providers insofar as this is necessary for the features described. Insofar as they process data on our behalf, they are bound by our instructions under a data processing agreement pursuant to Art. 28 GDPR. Some additionally process certain data as controllers in their own right; that is noted in the respective entry.

Vercel Inc., USA

Operation of the website and backend, whose functions run in Frankfurt, and the non-public storage for profile pictures and deletion records, also in Frankfurt. Vercel processes the connection data and everything our backend processes.

Databricks, Inc., USA, for Neon

Database for account, profile, plans, workouts, usage volume, records and test group applications. It runs in Frankfurt.

Anthropic Ireland, Limited, Ireland

AI conversation and plan suggestions, processed mainly at Anthropic, PBC in the USA (section 7).

Scaleway SAS, France

Sending our emails from Paris. No transfer outside the EU.

Stripe Payments Europe, Limited, Ireland

Fee for partner gyms after the public launch: name and email address of the operator, billing address, VAT ID and payment details. Stripe also processes data at Stripe, Inc. in the USA (EU-US Data Privacy Framework, standard contractual clauses) and is itself responsible for fraud prevention and its own legal obligations.

650 Industries, Inc. (Expo), USA

Forwarding of notifications including the delivery token, and delivery of app updates. For aggregated data that no longer relates to you, Expo is itself the controller under its own terms.

Apple

Delivery of the notifications, App Store, TestFlight during the test phase (section 12) and, if you use it, the iCloud Keychain for your passkeys. Apple processes data for this as a controller in its own right; we do not get access to your keychain.

Cloudflare, Inc., USA

Name resolution (DNS) for our domains and the redirection of www.diaboliq.com, diaboliq.app and diaboliq.de.

Microsoft Ireland Operations Limited, Ireland

Microsoft 365 for our support mailbox: your address, your message and whatever is necessary for the communication.

Print shop and delivery service

Production and delivery of your badge: name, delivery address, size, fit and the print file. The print shop works on our behalf. The delivery service delivers the parcel and processes your name and address for this under its own responsibility.

Within our company only those people get access who need it for their task. To authorities or other bodies we only pass on data if we are legally obliged to do so or another statutory basis exists.

Some of our providers are based in the USA or use infrastructure or personnel there and in further countries. Your data may therefore be processed outside the European Economic Area, even though our servers and our database are in Frankfurt. This concerns above all:

• Anthropic: the contents of the AI coach, processed mainly in the USA;
• Vercel and Databricks: access from the USA, for example for operations and support;
• Expo: delivery tokens, notifications and the app’s requests for updates;
• Cloudflare: connection data, via its worldwide infrastructure;
• Microsoft: our support mailbox, with access from the USA.

For these transfers we rely on the standard contractual clauses of the European Commission (Art. 46(2)(c) GDPR, Implementing Decision (EU) 2021/914), which are contained in the providers’ contracts. They oblige the recipients to provide data protection guarantees. You can obtain a copy on request to support@diaboliq.com; details of third parties that require protection may be redacted in it.

If you write to support@diaboliq.com or via the form on the support page, we process your address, your message and the details about your account that we need for the answer; the mailbox is with Microsoft 365. A message from the form is sent by Scaleway as an email to this mailbox; in our database we store nothing of it, only how many messages come in on a day, so that nobody can bring the form down with masses of messages. Enquiries about your account we handle under Art. 6(1)(b) GDPR, requests concerning your data protection rights under Art. 6(1)(c) GDPR and everything else under Art. 6(1)(f) GDPR, because we want to answer it properly.

Please don’t send us any diagnoses or other health information in support that we don’t need. If they are nevertheless necessary for a matter, we will agree the way forward with you beforehand. An email alone we do not understand as explicit consent to use health data further.

While Diaboliq is in its test phase, the app comes through Apple TestFlight. Apple processes invitation, device, usage and crash information for providing the service and for its own operational purposes, as a controller in its own right; Apple’s information “TestFlight & Privacy” describes this. We receive the details intended for the test and your voluntary feedback, possibly with screenshots; which details we see also depends on how you were invited. We use them to organise the test and fix bugs (Art. 6(1)(f) GDPR) and read them in App Store Connect without making copies of our own. Please don’t send health information or screenshots of it in your feedback. Which additional features are switched on in the test, on Android also through Google Play’s internal test, and what they do with your data is set out in our privacy information for the test (in German).

For operations we process the technical data that we need for security and troubleshooting (Art. 6(1)(f) GDPR). The quality of the plans we measure with technical values per plan creation: model and versions, duration, AI consumption and how serious the findings of the check were. These metrics contain no profile, no plan, no reference to your account and no health information, and they bear only the day, not the time of day. AI consumption we count per day and model, without reference to persons. We do not evaluate your health information for product improvement.

To protect against mass requests and unreasonable operating costs, we limit messages to the coach to 25 per account and UTC day. The UTC day starts at 0:00 Coordinated Universal Time; this may differ from your local time. A request may contain at most 20,000 characters. For this we store the account identifier, the UTC day and the number of counted requests, not their texts. The counter is deleted after 2 days, and immediately when the account is deleted. The processing is based on Art. 6(1)(f) GDPR. The limit restricts access to the coach until the next UTC day. It is a fixed technical rule and not an automatic accusation of misuse. The processing of the conversation content by the AI provider and its retention periods are described in section 7; the statement on the counter concerns only the counter for the message limit. If the conversation costs of all accounts together exceed the set daily limit, the team receives a notification with totals. It contains no conversation content and blocks no account.

Because each nickname exists only once, someone could try out whether a name is taken. That is why we count, per account and day, how often someone wanted to choose a taken one; after 10 such attempts, the nickname cannot be changed that day. Only the number is stored, never the name; it is gone after 2 days, and immediately with your account. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest in protecting members from someone finding out through their nickname that they use our app.

We record when you gave or withdrew a consent and in which version its text existed, and we log administrative operations. The consent records serve our accountability (Art. 5(2) and Art. 7(1) in conjunction with Art. 6(1)(c) GDPR).

You can withdraw any consent in the app under Account → Consents or write to us. The withdrawal takes effect for the future; it does not affect the lawfulness of processing based on your consent before its withdrawal.

• Health data: We delete your limitations from the profile, your plan orders including the details in them and the coach’s texts in your plans — rationale and notes, in earlier versions too, because they can name a limitation. Exercises, sets and repetitions remain. The coach is then no longer available to you.
• Body data: We delete height, weight and date of birth from your profile.
• AI coach: We no longer pass any data to the AI. Your stored plans and workouts remain.
• Ranking: We no longer show you in any ranking. Taking part, progress and Ember remain.

You delete your account under Account → Data & legal or with an email to us. We then immediately delete your profile including training profile, limitations and body data, your profile picture, your plans, workouts, pause weeks and plan orders, your check-ins, your participation in challenges, your season badges, your nickname, the number of your messages to the coach and of your attempts with taken nicknames, your submissions, votes and reports on ideas, pending changes of your email address, your devices, passkeys and sessions, plus a test group application with the same email address. Challenges you created can continue for the other participants; we remove the link to your account. This does not automatically make information still held by other participants anonymous. What remains are the consent, usage and Ember journals, with Ember reviews and explanations, and administrative logs, attached to an identifier that no longer bears a name or an email address, and for 40 days a record that and when you deleted (section 14). We delete these journals three years after the end of the year in which you deleted your account, administrative logs three years after the end of the year in which they were created, and the text of an explanation to a review as early as 6 months after the decision. Pseudonymised data remain personal data insofar as they can be attributed. An erasure request is not a waiver of existing contractual, order or refund claims; for necessary evidence, required data may be kept to a limited extent on a separate legal basis. In our backups the data remain for up to 30 days, at Anthropic until the end of the periods applying there (section 7). Deleting the app from the device does not delete your account.

We store personal data only for as long as the respective purpose requires or a legal obligation exists. A withdrawal or a justified erasure request shortens the following periods. The periods in our database are implemented automatically by a daily run.

Account, profile, plans, workouts, pause weeks, nickname and season badges

until you delete your account

Participation in a challenge

90 days after it ends, for a withdrawn one after the withdrawal; immediately with your account. You only appear in the ranking while you have it switched on and your consent applies.

Invitation code on your device

valid for seven days; deleted as soon as the app has asked you whether you want to join, when you sign out, and after expiry the next time the app reads it

Limitations and body data

until you withdraw the consent, delete the detail or delete your account

Conversation with the coach

only in the app’s memory while it is running

AI inputs and outputs at Anthropic

normally up to 30 days, exceptions in section 7

Registration that was not completed

The link and the code are valid for one hour; we delete the address one day after they expire.

Application for the test group

unconfirmed 7 days after the email, confirmed twelve months after the confirmation; immediately if you withdraw it

Plan orders

30 days after they are completed

Sign-in links and codes

7 days after expiry or redemption

Requests to change your email address

one week after expiry or redemption

Challenges for a passkey sign-in

They are valid for a few minutes and are deleted one day after they expire.

Sessions

30 days after sign-out or last use

Number of your messages to the coach

2 days; immediately with your account

Number of your attempts with taken nicknames

2 days; immediately with your account

Delivery tokens for notifications

until you switch notifications off, sign out, delete your account or Apple reports them as invalid

Profile picture

until you remove it, replace it or delete your account; about a minute longer in the provider’s cache

Delivery address in a badge order

90 days after dispatch; if the delivery is still open by then, once it is completed

Saved delivery address

until you delete it under Account or delete your account

Text of your idea and optional text of a report

at the latest 30 days after receipt, even without a decision

Reports on ideas without their text

90 days after they have been dealt with; immediately with your account

Submissions and votes for ideas

until you take back your vote or delete your account

File of your data on the device

until you have saved or shared it, at the latest until the next start of the app or until you sign out

Metrics on quality and AI consumption

without any reference to you and therefore without a time limit

Consent records and usage journal

as long as your account exists; afterwards without name and email address, until 3 years after the end of the year of the deletion

Ember: bookings, reviews and receipt of explanations

as long as your account exists; afterwards without name and email address, until 3 years after the end of the year of the deletion

Text of your explanation to a review

6 months after the decision; the fact that an explanation was received remains in the journal

Check-ins at partner gyms

12 months; immediately with your account

Requests and contact persons of partner gyms

unconfirmed 7 days, rejected 30 days; otherwise for the duration of the partnership, the contact person until 12 months after it ends, company and contract details as long as retention obligations apply

Administrative logs

3 years after the end of the year in which they were created; after the deletion of your account without name and email address

Account without use

After 24 months without a sign-in we write to you. If you don’t sign in within 30 days, we delete the account.

Support enquiries

12 months after they have been dealt with, unless a longer retention obligation exists

Feedback and crash reports from TestFlight

at Apple, according to Apple: feedback one year, crash and usage data until the bug is fixed; we make no copies of our own

Runtime logs at Vercel

30 days

Database logs at Neon

three days; the database can be rolled back by up to six hours

Delivery receipts at Expo

24 hours

Our own backups

encrypted, at most 30 days

Records of deletions and withdrawals

identifier, type and time only, 40 days

What lies temporarily in backups we do not use for ongoing operations. If we have to restore from a backup, we apply deletions and withdrawals that have happened since again before the data are used once more. For this we record every deletion and every withdrawal outside the database, without name and email address: only the identifier of your account, what was deleted or withdrawn, and when. These records remain for 40 days, longer than any backup, and not longer. They are kept in the non-public storage of our hosting provider Vercel in Frankfurt; the legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 5(2) and Art. 17 GDPR. After a restore you sign in again.

Subject to the statutory conditions, you have the right to

• access to information on whether and which data we process about you, including a copy (Art. 15 GDPR);
• rectification of inaccurate data and completion of incomplete data (Art. 16 GDPR);
• erasure of your data (Art. 17 GDPR);
• restriction of processing in the cases provided for by law (Art. 18 GDPR);
• data portability: to receive the data you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another controller (Art. 20 GDPR);
• withdraw consents you have given, with effect for the future (Art. 7(3) GDPR).

Objection: Insofar as we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), including profiling based on them (section 5), you can object on grounds relating to your particular situation. Write to us at support@diaboliq.com. We will then no longer process the data, unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or we need it for the establishment, exercise or defence of legal claims (Art. 21 GDPR).

In the app you can download all your data as a file in JSON format under Account → Data & legal and delete your account yourself there too. You can also exercise your rights at support@diaboliq.com, even if you can no longer get into the app. If we have reasonable doubts about your identity, we will ask for what we need in order to identify you reliably.

We answer requests free of charge and without undue delay, at the latest within one month. If we need the extension permitted by law, we will tell you within that month why.

You can also lodge a complaint with a data protection supervisory authority, in particular in the Member State in which you live or work or in which the infringement allegedly took place. The supervisory authority responsible for us is the State Commissioner for Data Protection of Lower Saxony (Landesbeauftragter für den Datenschutz Niedersachsen). An overview of all authorities is kept by the European Data Protection Board.

Diaboliq is for ages 18 and up. At registration you confirm that you are at least 18 years old, and a date of birth according to which you are younger we do not store. If you are younger, please don’t create an account. If you notice that a minor has an account, please let us know at support@diaboliq.com.

We adapt this policy when features, processing operations or legal requirements change, and we inform you of material changes in an appropriate way. If a new processing operation needs your consent, we obtain it before it begins. An amended policy alone does not extend a consent you have already given.