Privacy Policy

Last updated: April 2026

1. Controller

Nina Hoch
KiTrinity
c/o POSTFLEX PFX-914-205
Emsdettener Straße 10
48268 Greven
E-Mail: info@kitrinity.io

2. Overview

Data protection is a core principle of KiTrinity. Our app “Bleib Nüchtern” stores all personal data exclusively on your device. There is no registration, no account, and no tracking.

3. Website (kitrinity.io)

3.1 Hosting

This website is hosted via Cloudflare Pages. When you visit the website, technical data (e.g. IP address, browser type, time of access) is automatically stored in server log files. This is done on the basis of Art. 6(1)(f) GDPR (legitimate interest in the secure provision of the website).

Provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the EU-US Data Privacy Framework.

3.2 Google Fonts

This website uses fonts from Google Fonts. When loading the page, data is transmitted to Google servers (e.g. IP address). Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Legal basis: Art. 6(1)(f) GDPR.

3.3 No Cookies, No Tracking

This website does not use cookies and does not employ any analytics or tracking tools.

3.4 Email Waitlist & Newsletter (Brevo)

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

Processor: Brevo GmbH, Köpenicker Str. 126, 10179 Berlin (DPA concluded ✅)
Data category: Email address
Third-country transfer: Possible (USA, India). Safeguarded by EU Standard Contractual Clauses and EU-U.S. Data Privacy Framework.
Retention: Your data is deleted upon 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 email. The lawfulness of processing carried out prior to withdrawal remains unaffected.

More information on Brevo's privacy practices: brevo.com/de/legal/privacypolicy

4. App “Bleib Nüchtern”

4.1 Local Data Storage

All user data in the app is stored exclusively on your device (SQLite database and SharedPreferences). This includes:

Sobriety timer and milestones
Mood journal and craving log
Journal entries and daily notes
Settings and personalization
Morning routines and difficult days

This data does not leave your device and is not transmitted to us or third parties.

4.2 AI Companion Sam (Pro Feature)

Sam uses the Mistral Large language model from Mistral AI (European provider based in Paris, France). When you send Sam a message, the following happens:

Anonymization before transmission: Personal names and places in your messages are automatically replaced with placeholders (e.g. [PERSON_1], [PLACE_1]) before being transmitted to the AI service.
Transmission: The anonymized message is sent via an encrypted connection (HTTPS) to a European proxy server (api.kitrinity.io, Hetzner, Germany), which forwards the request to Mistral AI.
No storage: Neither we nor Mistral AI store your chat history. The chat history is stored exclusively on your device.

Legal basis: Art. 6(1)(a) GDPR (consent) – you actively choose to use Sam.

Provider: Mistral AI, 15 rue des Halles, 75001 Paris, France.

4.3 In-App Purchases

Purchases are processed via Google Play (RevenueCat). We do not receive any payment data. We only receive information about whether a valid purchase exists.

4.4 No Registration

The app does not require registration or an account. An optional nickname stays locally on your device and is not transmitted.

4.5 No Tracking, No Analytics

The app contains no analytics or tracking tools. We do not collect usage data, crash reports, or device information.

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)

Since all app data is stored locally on your device, you have full control at all times. You can completely delete your data by uninstalling the app.

6. Right to Complain

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.