Primaly
Privacy Policy
Zero-Friction Labs ("we", "us") establishes this Privacy Policy regarding the handling of user information in the iOS application "Primaly" (the "App"). We comply with applicable data protection laws, including Japan's Act on the Protection of Personal Information (APPI).
1. Core principle: your entries live on your device and in your own iCloud
The App operates no content server of its own for the content you create (tasks, habits, journal entries, mood records, profile, avatar, and more). That content is stored on your device and in your own iCloud (your Apple account). Anything that goes to iCloud is encrypted on your device first, and the key exists only on your devices. Neither we nor Apple can read it (Section 4).
Separately, the App uses an authentication provider for signing in (Section 2), an AI processing provider for the AI assistant (Section 5), and weather services for weather display (Section 3), each receiving only the data that feature needs. To improve the App, it also sends usage statistics (such as which features you use — never what you write) to a server we manage (Section 9). Apart from these, the content you create is not transmitted to or stored on any server, including ours.
2. Account and sign-in
Using the App requires signing in. You may choose either Apple's "Sign in with Apple" or a Google account. Signing in creates an account with Supabase (Supabase, Inc.), our authentication provider, which stores the following to keep you signed in:
- An account identifier (the user ID issued by Apple or Google)
- Your email address (if you choose Apple's "Hide My Email", the private relay address Apple provides instead)
Only if you choose to sign in with Google does any exchange of authentication information occur with Google LLC. If you choose Apple, nothing is sent to Google.
This information is used solely to maintain your sign-in; it is never used for advertising, profiling, or tracking. The journal entries, tasks, and other content you create are not stored on our servers linked to this account. You can delete your account at any time from "Settings › Privacy & Security › Delete account" in the App (Section 11).
3. Information handled on your device
The App handles the following on your device to provide its features. Except for location used for weather, none of it is transmitted externally.
- Profile information (nickname, bio, avatar)
- Tasks, habits, and projects, and their completion status
- Journal entries and records of emotion, body, state of mind, and sleep ratings
- Health data (HealthKit): handled only if you grant permission. It is never
used for advertising and never sold or shared with third parties.
- Sleep duration, sleep stages, step count, workouts (type and duration), time in daylight, mindful minutes, and states of mind that other apps logged in Health (including emotion labels and associated life events): read only, shown when you open a day's record. Never saved to the App's records, used on your device, and never sent to our servers or to the AI.
- State of mind (pleasant ⇄ unpleasant) and feelings: when you close out a day, if another app has already logged a daily mood for that day in Health, the App reads its value and feelings and uses them as the starting point. The state of mind you record and the feelings you choose (optional) are written to Health as that day's daily mood (including when you close out yesterday later). Associated life events are not written, and nothing is written on days another app has already logged a daily mood.
- Screen Time data (which apps you choose to block, and whether blocking is active): handled via Apple's Family Controls / Screen Time APIs. This data does not leave your device and is never sent to the AI. The only exception is usage statistics (Section 9), which record just two actions you take in the App's own screens — "created a block rule" and "started Quick Block (and from where)". Which apps you block, when or how long blocking was active, and your screen time are never sent.
- Calendar: only if you grant permission, calendar events are read read-only to display your day. Event contents never leave your device and are never sent to the AI.
- Location: used for two purposes, handled differently.
- Weather: an approximate location (coordinates rounded to roughly 1 km) is sent to weather services (Apple WeatherKit / Open-Meteo). "While Using the App" only; if you decline, a default region's weather is shown.
- Habit location proof (only if you set one up): a more precise location is used to check whether you are at the place you registered. This check happens entirely on your device; the coordinates are never transmitted.
- Camera images: used for the "photo unlock" alarm challenge. Both the reference photo and the live camera frames are matched entirely on your device and never transmitted.
- Voice input: microphone audio is used only for transcription; we never store or transmit audio. Journal voice input is locked to on-device speech recognition — if on-device recognition is unavailable, recording does not start at all. For voice input elsewhere in the App, audio may be sent to Apple's speech recognition service on devices where on-device recognition is not available (processed by Apple).
- NFC tag information: used to log habits and dismiss alarms.
4. iCloud sync and encryption
The App syncs your entries to your own iCloud so they survive a lost device or a new phone. This is your Apple account's storage, not our server. Sync is on by default and can be turned off at any time in "Settings › Privacy & Security › Sync with iCloud".
Only data encrypted on your device ever leaves for iCloud. Encryption and decryption happen solely on your device, and the key is stored only in your iCloud Keychain. We do not hold this key and have no means of obtaining it. Apple cannot read the contents of what it stores for you.
The flip side is that if the key is lost, not even we can recover your data. Normally iCloud Keychain carries the key across your devices; as a safeguard you can save a copy from "Settings › Privacy & Security › Recovery key".
5. Data sent externally when using the AI assistant "Prima"
Using the AI assistant is optional. Data is sent only when you actively use a feature that needs AI; the App performs no automatic transmission without an action from you. So if you do not open a feature that uses AI, nothing about your records is sent to the AI (tasks, records, and alarms keep working without it). Using AI features requires signing in, and the sign-in screen displays a reference to this Policy. The recipient is Anthropic, PBC (Claude API), our AI processing provider. You may also have all transmission to the AI stopped for your account, without deleting your account — contact us at the address in Section 16.
Your journal text is treated separately from everything else. Journal sharing is off by default and becomes active only if you choose it after reviewing what is sent, in "Settings › Journal & AI". The monthly issue (the AI-written monthly report) is also produced only when this opt-in is on. While it is off, the monthly issue is composed on your device from a fixed template and nothing is sent.
When you use a feature that needs AI, the following may be sent:
- Your messages to Prima and the conversation history (older history is summarized and used as ongoing context) — when you talk with Prima
- Body, state of mind, emotion, and sleep ratings — when you use AI on a chat or on that day's record
- Task and habit names — when you use an AI feature on that task or habit (such as suggesting a next step)
Additionally, only if you turn on "Share journal with AI", the following is sent. The amount differs by purpose, so we state it precisely:
- Journal formatting: the full text of that day's journal
- Automatic theme tagging: the full text of that day's journal
- Retroactive tagging when a new theme is discovered: roughly the first 300 characters of each of up to 1,200 past entries, so that earlier entries matching the new theme can be found across your whole history. These are sent in batches of 100, capped at 12 batches per discovery. This happens automatically and is the largest transmission the App makes.
- Background context for Prima: roughly the first 40 characters of each recent day
- Monthly issue (monthly report): a summary of the month's records (such as your average body and state of mind) plus roughly the first 200 characters of each day (with an overall cap). This is produced automatically when the month turns
- Journal chat input: exactly what you write to Prima
Step, sleep, workout, time-in-daylight, and mindful-minute data read from HealthKit, the states of mind from Health shown on a day's record, Screen Time data, calendar events, location, and camera images are never sent to the AI. The sleep and body ratings (each 1–5) and the state of mind you record yourself in the App are separate records and may be included in the AI's context (for state of mind, this includes when you keep a starting value from Health).
Data sent to the AI is never used to train or improve AI models. Anthropic does not use inputs received via the API for model training. However, for abuse prevention and safety purposes, inputs and outputs are retained by Anthropic for up to about 30 days before deletion (per their commercial terms of service). For details and disclaimers about AI features, see "Notes on AI".
6. Purpose of use
Information we obtain and process is used solely to provide the App's features (sign-in, sync, alarms, task/habit management, journaling, the AI assistant, weather display, displays based on health data, and recording your state of mind in Health), and to improve the App through usage statistics (Section 9). If we ever intend to use it beyond these purposes, we will obtain your consent in advance.
7. Disclosure to third parties / processing delegation
Except where required by law, we do not provide or sell user information to third parties. Transmission to the following is delegated processing, limited to what each App feature requires:
- Supabase, Inc. — authentication (Section 2) and storing usage statistics (Section 9)
- Google LLC — identity verification, only if you sign in with Google (Section 2)
- Anthropic, PBC — generating AI responses (Section 5)
- Apple Inc. / Open-Meteo — weather data (Section 3)
- Apple Inc. — iCloud storage (Section 4; contents are encrypted and unreadable to Apple)
8. Cross-border data transfers
In connection with the above, your data may be processed on servers located outside Japan. Anthropic, PBC and Google LLC are United States entities, the weather service Open-Meteo is a German entity, and Supabase's infrastructure may also be located outside Japan. We delegate processing only to the extent required to provide the App's features, after confirming that these providers maintain appropriate security measures. For providers located outside Japan, we confirm — through our agreements with them and their published data-handling policies — that they maintain, on an ongoing basis, systems ensuring protection equivalent to what Japan's Act on the Protection of Personal Information requires. If you would like information about the destination country's data-protection regime or the measures a provider takes, contact us at the address in Section 16. Where personal data of users in the EEA or the United Kingdom is transferred outside those regions, we rely on providers that offer lawful transfer mechanisms such as the European Commission's Standard Contractual Clauses (SCCs) (Section 13).
9. Usage statistics, and no tracking
The App uses no third-party analytics tools, no crash-reporting tools, and no advertising SDKs.
To improve the App, it sends the following usage statistics to a server we manage (on Supabase). This is on by default.
- What is sent: tabs you open, how far you got in onboarding, how you heard about the App and the worries you tapped (if you answered), the fact that you used features such as steps, closing the day, the journal, tasks, habits, alarms, and App Block, opening the plans screen and purchases, the App and OS version, device type, display language, and whether you are on a paid plan
- What is never sent: anything you write (tasks, habits, journal, feelings, conversations with Prima), health data, location, calendar events, and the apps you block or your screen time
Usage statistics carry only a random number created for each device and are never linked to your account (email address or user ID). They are deleted automatically after 13 months. You can turn them off at any time in "Settings › Privacy & Security › Share usage statistics"; doing so also deletes what that device has sent. Deleting your account deletes them too.
If you choose to tell us why you are deleting your account, that answer is stored without the device number or your account, and is used only to improve the App.
Neither this website nor the App uses cookies, SDKs, or pixels for advertising or tracking, and we do not collect data for the purpose of tracking users. We do not track you across other companies' apps or websites (the activity governed by App Tracking Transparency).
10. Security
Data stored on your device is protected by iOS data protection. Data synced to iCloud is additionally encrypted on your device, with the key existing only in your iCloud Keychain (Section 4). All communication sent externally for sign-in or AI processing uses encrypted transport (TLS/HTTPS). The API key used for AI processing is held only on our server side and is not contained in the App. That said, no transmission over the internet or electronic storage is absolutely secure; we take security measures that are reasonable in scope.
11. Data retention and deletion
Data on your device is retained until you delete it, and is erased when you delete the App. Account information on Supabase is retained until you delete your account. Usage statistics and account-deletion reasons are deleted automatically after 13 months (Section 9).
Running "Settings › Privacy & Security › Delete account" in the App performs the following in order:
- Erases your data on the device (journal, emotions, conversations, records, and so on)
- Deletes the copy synced to iCloud
- Destroys the encryption key — so that even if any deletion above did not complete, whatever remains cannot be decrypted by anyone
- Deletes the usage statistics that device has sent (Section 9)
- Permanently deletes your account on Supabase
Data sent to Anthropic for AI processing is not used for model training (Section 5) and is deleted after their retention period. Permissions for OS-managed data such as HealthKit can be changed or revoked at any time in the iOS Settings app. States of mind the App has written to Health become Health data, so they remain even if you delete your account or the App; you can view and delete them in the Health app at any time. Note that an active paid subscription (Premium) is managed by the App Store and is not automatically cancelled when you delete your account; cancel it from "Settings › Apple Account › Subscriptions" in iOS.
12. Your rights
You may request the following regarding your information. The App's data lives on your device and in your own iCloud, and most of it you can view, edit, and delete yourself within the App.
- Access: data on your device is viewable in the App at any time. Contact us if you would like disclosure of your account information.
- Correction: your profile and records can be edited in the App at any time.
- Deletion: deleting your account (Section 11) erases your server account, your on-device data, and the copy in iCloud.
- Suspension and withdrawal of consent: journal sharing with AI (including the monthly issue), iCloud sync, and usage statistics can each be turned off in Settings at any time (turning off usage statistics also deletes what that device has sent). All other transmission to the AI happens only when you use a feature that needs it. You may also have all transmission to the AI stopped for your account — contact us at the address in Section 16 and we will do so without deleting your account. Permissions for HealthKit, location, camera, microphone, and calendar can be revoked in the iOS Settings app.
- We also respond to other requests available under applicable law (suspension of use, suspension of provision to third parties, and so on).
Please direct such requests to the contact in Section 16.
13. For users outside Japan (GDPR, U.S. state laws, and similar)
The App is also provided outside Japan. The controller of your personal data is Zero-Friction Labs.
If you live in the EEA or the United Kingdom (GDPR / UK GDPR): our legal bases for processing your personal data are:
- Performance of a contract: sign-in, iCloud sync, management of the paid plan (Sections 2, 4, and 11), and providing the AI features you asked to use (Section 5)
- Consent: sharing journal text with the AI (including the monthly issue), and each permission such as location and HealthKit (Sections 3 and 5). You can withdraw consent at any time
- Legitimate interests: preventing abuse and keeping the service secure (Section 10), and improving the App through usage statistics (Section 9; never linked to your account, and you can turn them off in Settings at any time)
In addition to the rights in Section 12, you have the right to request restriction of processing and data portability, and the right to lodge a complaint with the supervisory authority (data protection authority) in your country. Cross-border transfers are handled as described in Section 8.
If you live in the United States (California and other state privacy laws): we do not sell your personal information and do not share it for targeted advertising (Section 9). Sensitive personal information (such as health data and precise location) is handled on your device only, to the extent needed for features you have enabled. To exercise rights of access, deletion, or correction, contact us as described in Section 16. We will not treat you adversely for exercising your rights.
14. Children's privacy
The App is intended for users aged 16 or older, and we do not knowingly collect personal information from users under 16. If we learn that we have collected personal information from a user under 16, we will delete it promptly.
15. Changes to this policy
We may revise this policy in response to legal changes or new features. When we do, we will set an effective date and announce the change on this website, and for significant changes that materially affect how your data is handled, we will ask for your renewed consent within the App.
16. Contact
For inquiries about this policy, or requests for disclosure or deletion, please contact support@primalyapp.com.
Operator: Zero-Friction Labs / Responsible person: 中島 康晴