Privacy Policy

Last updated: June 2026

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

Data protection is a core principle of KiTrinity. Our app “OONVAA” is built on a Privacy First approach: for every feature, we think about your privacy first.

By default, your content stays on your device. There is no registration and no account required to use the app. We do not run advertising tracking and we do not create usage profiles. Where data does leave your device, this is limited to what is technically necessary, happens only with your consent where possible, and is fully disclosed in Section 4.7.

When selecting our service providers, we prefer, wherever possible, providers based and processing data in Germany or the EU.

3. Website (kitrinity.io)

3.1 Hosting

This website is hosted by checkdomain GmbH. When the website is accessed, 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 under 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 Waitlist & Newsletter (Brevo)

If you sign up for our waitlist or newsletter, we collect and process your e-mail address for the purpose of notifying you at app launch or for sending the newsletter. Processing is based solely on your consent (Art. 6(1)(a) GDPR) using a double opt-in procedure.

For more information: brevo.com/legal/privacypolicy

3.5 E-mail Communication (Proton Mail)

If you contact us by e-mail (e.g. at info@kitrinity.io) or send us feedback from within the app, 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 handling and answering requests). If you write to us on your own initiative about topics relating to 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 disclose.

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 by the European Commission exists for Switzerland, so an adequate level of data protection is ensured.

4. App “OONVAA”

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:

This content does not leave your device and is not transmitted to us or to third parties. Since this processing takes place exclusively locally on your device and we have no access to it, we are not the controller in this respect.

4.2 Health-Related Information (Special Categories)

“OONVAA” supports you on the path towards 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. regarding drinking behaviour, cravings or how you are feeling).

This information is, in principle, processed exclusively locally on your device (see 4.1). Health-related content is transmitted to third parties only when you actively use the AI companion Sam (see 4.3), and only on the basis of your prior explicit consent under 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 other consents, 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:

Legal basis: Art. 6(1)(a) and Art. 9(2)(a) GDPR (explicit consent). You actively decide to use Sam.

Processors:

4.4 In-App Purchases and Subscription Status (RevenueCat)

Purchases and subscriptions are processed via the Google Play 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 a 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 No Advertising Tracking, No Profiling

The app creates no usage profiles and contains no analytics or advertising tracking tools. We do not sell data and do not run advertising. Crash reports are not collected automatically. Technically necessary transmissions (e.g. the subscription status check described in 4.4) are limited to the minimum and disclosed in the overview under 4.7.

4.6 No Registration

Using the app requires no registration and no account. An optional nickname stays locally on your device and is not transmitted.

4.7 Transparency: What Leaves Your Device, and What Does Not

We disclose which data leaves your device and under what circumstances. All content you create in the app (timer, mood and craving log, diary, settings) remains 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
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 history After a conversation with Sam
Image for Vision Board Unsplash (USA) Only your search term You search for an image (Pro)
Redeem voucher code api.kitrinity.io (Hetzner, DE) Pseudonymous identifier, code You redeem a code
Feedback E-mail program Only what you write yourself You write feedback
Community (planned, not yet active) Own server (Hetzner, DE) Self-chosen nickname, profile picture and the posts you share; a technical identifier to attribute your own posts Only with active participation

What does not leave your device: your diary entries, your mood and craving log, your timers, milestones and settings.

As soon as the community feature is available, we will update this overview and the date of this policy accordingly.

4.8 Image Search Vision Board (Unsplash)

When you search for an image in the Vision Board (Pro feature), your search term is transmitted to the image service Unsplash to display matching images. No other data is transmitted.

Legal basis: Art. 6(1)(b) GDPR (provision of the feature you are using).

Provider: Unsplash Inc., USA. Third-country transfer safeguarded by EU Standard Contractual Clauses.

4.9 Domains and DNS (IONOS)

The domains kitrinity.io and oonvaa.app are registered and DNS-managed via IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. Domain registration data (registrant details) is processed in accordance with ICANN requirements. Processing takes place in Germany and the EU.

Legal basis: Art. 6(1)(c) GDPR (compliance with a legal obligation, namely ICANN registration requirements) and Art. 6(1)(b) GDPR (performance of the domain registration contract).

4.10 Server Security (CrowdSec)

Our servers use the open-source security tool CrowdSec to detect and block attack patterns (e.g. brute-force attempts, credential stuffing). CrowdSec analyses server log data locally and, as part of its collaborative threat-intelligence network, shares anonymised attack signals (IP addresses of identified attackers) with the CrowdSec community blocklist.

No personal content, user data or app data is shared. Only IP addresses that have been identified as the source of attacks are reported. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in protecting our infrastructure and users against attacks).

Provider: CrowdSec SAS, Paris, France. Processing of anonymised signals takes place in the EU.

4.11 Data Backups

We perform regular encrypted backups of our server infrastructure (configuration, application data, databases) to protect against data loss. Backups are stored on servers operated by Hetzner Online GmbH in Germany.

Backups contain technical operational data (e.g. pseudonymous identifiers, consent records, e-mail addresses of newsletter subscribers) but no app content, since all content you create in OONVAA is stored exclusively locally on your device (see 4.1). Legal basis: Art. 6(1)(f) GDPR (legitimate interest in ensuring operational continuity and data integrity).

4.12 Community Feature (in Preparation)

A community feature is planned but not yet active. As long as this feature is not enabled, no data processing takes place through it.

Once available, the community will be provided via a server we operate ourselves in Germany (Hetzner), not via third-party platforms. Participation is voluntary and separate from the rest of the app's functionality: the core app remains usable without an account.

Participation is pseudonymous. You choose a nickname and a profile picture; registration with a real name, e-mail address or password is not required. However, please note: posts you publish in the community are stored on our server and visible to other participants. The content of your posts may contain health-related information (Art. 9 GDPR); therefore, only publish what you consciously wish to share. A pseudonymous identifier is used for the technical attribution of your own posts (e.g. for editing or deleting).

Before launching the community, we will supplement this privacy policy with specific details on processed data, retention periods, deletion concept, moderation and legal basis (including explicit consent under Art. 9 GDPR for publishing health-related posts).

5. Your Rights

You have the following rights regarding your personal data:

Since all content created in the app is stored locally on your device, you have full control at all times. You can completely delete this data by uninstalling the app. For data processed by us or our processors in connection with the waitlist/newsletter (Brevo) or Sam, you can exercise your rights via the contact address above.

6. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority depends on your place of residence.

7. Changes

We reserve the right to update this privacy policy to adapt it to changed legal situations or changes to the app. You can always find the current version on this page.