Privacy Policy
Last updated: July 2026
Note: This Privacy Policy is a convenience translation. In case of discrepancies, the German version (Datenschutzerklärung) prevails.
1. Controller
Nina Hoch
KiTrinity
c/o POSTFLEX PFX-914-205
Emsdettener Straße 10
48268 Greven
Germany
E-mail: info@kitrinity.io
2. Overview and Core Principle
Privacy is a core principle of KiTrinity. Our app “OONVAA” is built on a privacy-first approach: with every feature, we think about your privacy first.
By default, your content stays on your device. No registration and no account are required to use the app. We do not run advertising trackers and we do not build usage profiles. Where data does leave your device, this is limited to what is technically necessary, happens with your consent wherever possible, and is fully disclosed in Section 4.7.
When choosing our service providers, we prefer providers based and processing data in Germany or the EU wherever possible.
3. Website (kitrinity.io)
3.1 Hosting
This website is hosted by checkdomain GmbH. When you access the website, technical data (e.g. IP address, browser type, time of access) is automatically stored in server log files. This is based on Art. 6(1)(f) GDPR (legitimate interest in the secure provision of the website).
Provider: checkdomain GmbH, Große Burgstraße 27/29, 23552 Lübeck, Germany. Processing takes place in Germany. A data processing agreement pursuant to Art. 28 GDPR is in place with checkdomain. checkdomain in turn uses sub-processors, whose current list forms part of that agreement.
3.2 Fonts
The fonts used on this website are served locally from our server. No data is transmitted to third parties (e.g. Google Fonts) when the page loads.
3.3 No Cookies, No Tracking
This website sets no cookies and uses no analytics or tracking tools.
3.4 E-mail Waiting List & Newsletter (Brevo)
If you sign up for our waiting list or newsletter, we collect and process your e-mail address for the purpose of notifying you about the app launch or sending the newsletter. Processing is based exclusively on your consent (Art. 6(1)(a) GDPR) using a double opt-in procedure.
- Processor: Brevo GmbH, Köpenicker Str. 126, 10179 Berlin, Germany (data processing agreement in place)
- Data category: e-mail address
- Third-country transfer: Possible via Brevo's sub-processors (including in the USA). Safeguarded by EU Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework.
- Retention: Your data is deleted after you unsubscribe. Unconfirmed entries (double opt-in not completed) are deleted after a reasonable period.
- Withdrawal: You can withdraw your consent at any time via the unsubscribe link in every e-mail. The lawfulness of processing carried out before withdrawal remains unaffected.
Further information on data protection at Brevo: brevo.com/legal/privacypolicy
3.5 E-mail Communication (Proton Mail)
If you contact us by e-mail (e.g. at info@kitrinity.io), we process your e-mail address and the content of your message in order to handle your request. Our mailboxes' ongoing e-mail traffic is also handled via this service.
The legal basis is Art. 6(1)(f) GDPR (legitimate interest in processing and responding to enquiries). If you write to us about topics concerning your relationship with alcohol, your statements may contain health-related data within the meaning of Art. 9 GDPR. Please share by e-mail only what you consciously wish to share.
Processor: Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Geneva, Switzerland (data processing agreement in place). Processing takes place in Switzerland. An adequacy decision of the European Commission exists for Switzerland, so an adequate level of data protection is ensured.
4. The “OONVAA” App
4.1 Local Data Storage
All content you create in the app is stored exclusively locally on your device (SQLite database and SharedPreferences). This includes:
- Sobriety timers and milestones
- Mood diary and craving log
- Diary entries and daily notes
- Settings and personalisation
- Morning routines and difficult days
- Photos you select or take for your diary, vision board or widget
- Contacts you import as trusted persons
- Your self-chosen nickname
This content does not leave your device and is not transmitted to us or to third parties. As this processing takes place exclusively on your device and we have no access to it, we are not the controller in this respect.
Regarding permissions: The app requests access to photos, camera and contacts. These permissions serve exclusively the local features listed above. Neither photos nor contacts are transmitted to us or to third parties. For photos used in the vision board, EXIF metadata (including the location where the photo was taken) is additionally removed before the image is stored.
4.2 Health-Related Information (Special Categories)
“OONVAA” supports you on your way to a changed relationship with alcohol. In doing so, you may provide information that can qualify as health data within the meaning of Art. 9 GDPR (e.g. about drinking behaviour, cravings or how you feel).
This information is generally processed exclusively locally on your device (see 4.1). Health-related content is transmitted to third parties only if you actively use the AI companion Sam (see 4.3), and only on the basis of your prior explicit consent pursuant to Art. 9(2)(a) GDPR.
We obtain this explicit consent separately within the app, before you use Sam for the first time. It is voluntary, separate from any other consent, and can be withdrawn at any time with effect for the future. If you do not use Sam, no health-related content is transmitted.
4.3 AI Companion Sam (Pro Feature)
Sam uses the language model Mistral Large from Mistral AI, a European provider based in Paris, France. When you send Sam a message, the following happens:
- Pseudonymisation before transmission: Personal names and places in your messages are automatically replaced with placeholders before transmission (e.g. [PERSON_1], [PLACE_1]). Please note: this is pseudonymisation, not full anonymisation. The remaining content of your message is transmitted.
- Transmission: The pseudonymised message is sent over an encrypted connection (HTTPS) to our proxy server (api.kitrinity.io, hosted at Hetzner in Germany), which forwards the request to Mistral AI. A pseudonymous device identifier is also transmitted.
- No storage of content: Neither we nor Mistral AI store your chat histories permanently. The chat history is stored exclusively locally on your device.
Legal basis: Art. 6(1)(a) and Art. 9(2)(a) GDPR (explicit consent). You actively decide to use Sam.
Processors:
- Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (operation of the proxy server; data processing agreement in place)
- Mistral AI, 15 rue des Halles, 75001 Paris, France (processing of language model requests; data processing agreement in place)
4.4 In-App Purchases and Subscription Status (RevenueCat)
Purchases and subscriptions are processed via the Google Play Store or the Apple App Store. To manage and verify purchase status, we use the service RevenueCat.
RevenueCat generates a pseudonymous identifier when the app starts and uses it to check whether a valid purchase or an active subscription exists. This check also takes place if you do not use any paid feature. Only the pseudonymous identifier and the subscription status are transmitted: no content, no payment data and no profiling. Payment data is processed exclusively by the respective app store; we only receive the information whether a valid purchase exists.
Legal basis: Art. 6(1)(b) GDPR (performance of the contract / provision of purchased features) and Art. 6(1)(f) GDPR (legitimate interest in correct subscription management).
Provider: RevenueCat, Inc., USA. Third-country transfer safeguarded by EU Standard Contractual Clauses.
4.5 Info Library (News and Professional Articles)
The app contains an info library with editorial content as well as current articles from public news and professional sources (RSS feeds, e.g. health authorities and specialist media).
Retrieval via our server: The app does not fetch the preset sources directly from the respective provider, but via our proxy server (api.kitrinity.io, Hetzner, Germany). This means the third-party provider does not learn your IP address. Your language selection and a pseudonymous device identifier (for abuse prevention) are transmitted in the process. No content from the app is transmitted and no usage profile is created.
Custom feeds: If you add your own feed, the app fetches it directly from the respective provider. In that case, your IP address is transmitted to the provider you chose; we have no influence over their data processing. If you do not want this, do not add custom feeds.
Titles, a short excerpt and a link to the original source are displayed. Tapping an article opens the respective provider's website in your browser; from that point on, their privacy policy applies.
Legal basis: Art. 6(1)(b) GDPR (provision of the feature you use) and Art. 6(1)(f) GDPR (legitimate interest in abuse-free operation).
4.6 Feedback Form
When you give feedback in the app, our form on oonvaa.app opens in your browser. So that we can classify your request, the following technical details are pre-filled: category (bug / idea / cancellation), language, whether you use the Pro version, platform (iOS/Android), operating system version, device model, and app and build version. This information does not allow any conclusions about your identity and serves exclusively for troubleshooting.
Deliberately not transmitted is your usage segment (observe / reduce / abstinence) or any other content from the app. What goes into your feedback text is entirely your decision.
E-mail address: Providing an e-mail address is voluntary and only necessary if you would like a reply.
- Storage location: The data is stored exclusively on our own server (Hetzner, Germany). No third-party form services are used.
- Deletion of the e-mail address: As soon as your request has been answered and resolved, your e-mail address is deleted automatically, at the latest after 30 days.
- Remaining details: The technical details and your free text are used further without any personal reference, in order to reproduce and fix bugs.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in improving the app and fixing bugs); for a voluntarily provided e-mail address additionally Art. 6(1)(a) GDPR (consent through deliberate provision).
4.7 Transparency: What Leaves Your Device, and What Does Not
We disclose which data leaves your device and in which case. All content you create in the app (timers, mood and craving log, diary, photos, contacts, settings) stays exclusively on your device.
| When | Where to | What | Trigger |
|---|---|---|---|
| On every app start | RevenueCat (USA) | Pseudonymous identifier to check subscription status. No content, no profiling. | Automatic |
| Info library opened | api.kitrinity.io (Hetzner, DE) | Language selection, pseudonymous device identifier | You open the info library |
| Custom feed added | Directly to the chosen provider | Your IP address (technically unavoidable with a direct fetch) | You add a custom feed |
| Sam consent given | api.kitrinity.io (Hetzner, DE) | Pseudonymous device identifier, consent version, language | You activate Sam |
| Sam message | api.kitrinity.io → Mistral AI (FR) | Pseudonymous device identifier, pseudonymised message (names/places replaced) | You write to Sam |
| Sam summary | api.kitrinity.io → Mistral AI (FR) | Pseudonymous device identifier, pseudonymised conversation | After a conversation with Sam |
| Image for vision board | Unsplash (USA) | Only your search term | You search for an image (Pro) |
| Feedback | oonvaa.app (Hetzner, DE) | Technical details (category, language, Pro status, platform, OS/app version, device model) and whatever you write yourself | You give feedback |
| Community (planned, not yet active) | Our own server (Hetzner, DE) | Self-chosen nickname, profile picture and the posts you share; a technical identifier to attribute your own posts | Only on active participation |
What does not leave your device: your diary entries, your mood and craving log, your timers, milestones, photos, imported contacts, your nickname, your usage segment and your settings.
As soon as the community feature becomes available, we will update this overview and the date of this policy accordingly.
4.8 Image Search for Vision Board (Unsplash)
If you search for an image in the vision board (Pro feature), your search term is transmitted to the image service Unsplash in order to display matching images. No further data is transmitted.
Legal basis: Art. 6(1)(b) GDPR (provision of the feature you use).
Provider: Unsplash Inc., USA. Third-country transfer safeguarded by EU Standard Contractual Clauses.
4.9 No Advertising Tracking, No Profiling
The app does not create usage profiles and contains no analytics or advertising tracking tools. We do not sell data and we do not run advertising. Crash reports are not collected automatically. Technically necessary transmissions are limited to the bare minimum and are fully disclosed in the overview under 4.7.
4.10 No Registration
Using the app requires no registration and no account. An optional nickname stays locally on your device and is not transmitted.
4.11 Domains and DNS (IONOS)
The domains kitrinity.io and oonvaa.app are registered with IONOS. In the course of domain administration and DNS operation, IONOS processes technical data (e.g. DNS queries). This is based on Art. 6(1)(f) GDPR (legitimate interest in operating the domains).
Provider: IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. Processing takes place in Germany.
4.12 Server Security (CrowdSec)
On our proxy server (api.kitrinity.io) we use CrowdSec to detect and repel attacks. CrowdSec analyses server log files locally and shares aggregated, anonymised attack patterns with the CrowdSec community (so-called “signals”). Individual IP addresses from your requests may be included in anonymised form.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the security of our infrastructure).
Provider: CrowdSec SAS, France. Processing takes place within the EU.
4.13 Data Backups
To safeguard our infrastructure, we create regular backups of the proxy server (api.kitrinity.io). These backups are stored encrypted and contain no content from the app (as this resides exclusively on your devices). Backups are deleted automatically after a reasonable period.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operational security and recoverability).
4.14 Community Feature (in Preparation)
A community feature is planned but not currently active. As long as this feature is not enabled, no data processing takes place through it.
Once the community becomes available, it will be provided via a server we operate ourselves in Germany (Hetzner), not via third-party platforms. Participation will be voluntary and separate from the rest of the app's functionality: the core app will remain usable without an account.
Participation will be pseudonymous. You choose a nickname and a profile picture; registration with your real name, e-mail address or a password is not required. Please note, however: posts you publish in the community are stored on our server and are visible to other participants. The content of your posts may contain health-related information (Art. 9 GDPR); therefore publish only what you consciously wish to share. A pseudonymous identifier is used to technically attribute your own posts (e.g. for editing or deleting them).
Before the community launches, we will supplement this Privacy Policy with the specific details on data processed, retention periods, deletion concept, moderation and legal basis (including the explicit consent under Art. 9 GDPR for publishing health-related posts).
5. Your Rights
You have the following rights regarding your personal data:
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR)
- Withdrawal of consent (Art. 7(3) GDPR), including the explicit consent under Art. 9
As all content created in the app is stored locally on your device, you have full control at all times. You can delete this data completely by uninstalling the app. For data processed by us or our processors in the context of the waiting list/newsletter (Brevo), feedback or Sam, you can exercise your rights via the contact address given above.
6. Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection supervisory authority. The competent supervisory authority depends on your place of residence.
7. Changes
We reserve the right to amend this Privacy Policy in order to adapt it to changes in the legal situation or changes to the app. You will always find the current version on this page.