Privacy Policy

This Policy explains how we collect, use, share, and protect your personal data when you use the Brogress mobile application and the brogress.app website. It is provided in accordance with Articles 12, 13, and 14 of the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

§ 01Who we are

The data controller responsible for processing your personal data is:

We have appointed an external Data Protection Officer (Art. 37 GDPR) to oversee our handling of personal data:

For any privacy question — including requests to access, correct, port, or delete your data, or to withdraw consent — please email hello@brogress.app or contact our DPO directly. We will respond within 30 days as required by Art. 12(3) GDPR.

§ 02Scope of this Policy

This Policy applies to personal data we process when you use the Brogress mobile application on iOS or macOS (the “App”) and when you visit brogress.app (together, the “Service”). Brogress is a self-development app that uses an AI-powered “coach” to help you set goals, reflect on yourself, and build daily habits.

§ 03Personal data we collect

We only collect what we need to operate the Service. Below is a complete list, grouped by category.

3.1 Account data

When you sign in with your Apple ID via Sign in with Apple, we receive and store:

• An opaque, app-specific Apple user identifier
• Your email address (this may be your real address or an Apple “private relay” address — your choice when signing in)
• Your given and family name (only on first sign-in; editable later)

In the App you may additionally provide:

• A display name and a public handle (username)
• Your birthday (used to verify you meet our minimum age requirement)
• Your gender (optional; used to tailor self-reflection items where these differ)
• Your time zone
• A push-notification device token, if you allow notifications, so we can send reminders

3.2 Self-reflection responses (sensitive)

Brogress includes self-reflection assessments — sets of multiple-choice and free-text questions that draw on established psychological frameworks (for example, the Schwartz Personal Values questionnaire and Big-Five-style personality items). Your responses are stored, mapped to internal “six pillar” scores (Heart, Iron, Edge, Flow, Vault, Brain), and used by the coach to personalize its conversations with you.

Because these responses can reveal information about your personality, values, and emotional patterns, we treat this data as sensitive and process it only on the basis of your explicit consent, which you give before completing each assessment.

3.3 Coach conversations and the “private notes” section (sensitive)

When you talk to the coach inside the App, we store:

• Every message you send (including text transcribed from voice — see § 3.8)
• Every reply the coach generates
• Internal “state” updates the coach makes — points awarded, missions completed, achievements unlocked, edits to the coach’s notes about you

We also maintain a coach profile file about you with six sections: persona, hard rules, your stated preferences, coaching style, durable life-context notes (e.g. your job, where you live), and an internal “private notes” section.

3.4 Goals (WOOP)

For each goal you set, we store the four WOOP components — your Wish, the imagined Outcome, the Obstacle (often something internal, e.g. “I procrastinate when I’m anxious”), and your Plan — together with the goal’s status, history, and the conversational elicitation that produced it.

3.5 Missions, achievements, points, breathing sessions

We store the missions you take on (daily and one-off), the achievements you unlock, every point allocation event with the coach’s reasoning attached, and basic metadata for each breathing exercise you complete (technique, length, score, time of day).

3.6 Knowledge graph (sensitive)

As you talk with the coach, it builds a structured knowledge graph of the people, places, employers, hobbies and goals you mention, so that it can refer back to them in later conversations. This graph is stored in Microsoft Azure (Sweden) and partitioned by user — it is not shared between users.

3.7 Social data

If you use friend, challenge, or leaderboard features, we store:

• Your friends list and pending friend requests
• Blocks you set, and reports you submit (and reports submitted about you)
• Challenges you set up with friends and their state
• Activity-feed entries (achievements, milestones, streaks) that are visible to your friends

What becomes visible to a friend. When you add a friend, your handle, level, total points, current streak, your six pillar scores, and your profile picture (if you have uploaded one — see § 3.13) become visible to that friend in the in-app leaderboard and friend list. If you don’t want a friend to see this information, remove them or block them.

3.8 Voice

If you record a voice debrief, the audio is transcribed on your device using Apple’s on-device speech recognition. Only the resulting text leaves your phone; the audio itself is never sent to our servers or to any third party.

3.9 Technical / log data

When you use the Service, our servers record:

• The IP address you connect from
• Your device and operating-system type
• Date, time, and details of each request
• Truncated content (first 500 characters) of coach messages, for debugging and quality monitoring

These logs live in Microsoft Azure Application Insights (Sweden Central) and are retained for approximately 90 days, after which they are deleted automatically.

When an error occurs while processing your request, the resulting log line may include your account ID so we can reproduce and fix the problem. We do not enrich logs with your account ID for routine (non-error) requests, and we do not attach it as a structured telemetry dimension — it appears only as text in the body of error messages emitted by our backend code.

3.10 Crash and error reports

If the App crashes or hits an unexpected error, we send a description of the error to Sentry GmbH (de.sentry.io, hosted in Germany). We have configured Sentry not to send your user ID; however, an error message can occasionally include short fragments of text from a server response if our backend ever returns user content inside an error.

3.11 Subscription data

Brogress uses Adapty (Adapty Tech Inc.) as its subscription-management platform. The Adapty SDK is initialized at app launch and, once you sign in, is linked to your Brogress account ID so entitlement checks can route correctly. Through Adapty we and Adapty process:

• The Apple identifierForVendor (IDFV) — a per-vendor identifier scoped to apps from us; it is not the cross-app advertising identifier (IDFA), which we do not access
• Apple App Store and (in future) Stripe purchase events — product, price, country, transaction state, renewal status
• Paywall interactions — which paywall variant you saw, whether you started or completed a purchase, restores
• The Adapty profile ID, mapped to your Brogress user ID

Free-plan usage counter. Independently of Adapty, we count how many AI-coach debriefs you have started (the debriefs_used_lifetime counter on your account) so the app can enforce the lifetime free-plan limit before a paid subscription unlocks unlimited usage. This counter is processed on the contractual basis (Art. 6(1)(b) GDPR) and is purged with everything else when you delete your account.

3.12 What we do NOT collect

For the avoidance of doubt, the App does not access:

• Your contacts, calendar, location, motion data, or HealthKit data; nor your photo library at large — when you choose a profile picture, iOS’ system PhotosPicker hands us only the single image you select, and the App never receives photo-library permission. See § 3.13
• Any data through general-purpose analytics SDKs in the mobile app (Firebase, Mixpanel, Amplitude, Google Analytics, Adjust, AppsFlyer, Branch, Segment, etc. — we use none of these inside the App). Adapty processes IDFV and product-interaction events for the limited purpose of subscription analytics — see § 3.11 and § 5. The brogress.app website uses Google Analytics 4 with opt-in consent only; see § 16
• Any data through advertising SDKs — we serve no ads and use no ad SDKs
• The Apple advertising identifier (IDFA) — we have not implemented App Tracking Transparency and do not request it

3.13 Profile picture (optional)

In Profile › Settings › Edit Profile › Profile picture you may upload an image that will be displayed next to your handle on the profile screen, the leaderboard, the friends list, and friend-request cards inside the App. Uploading a picture is entirely optional — without one, we render a coloured circle containing the first letter of your display name.

What happens when you upload:

• iOS’ system PhotosPicker presents your photo library out-of-process and hands the App the bytes of the single image you selected. The App is never granted general photo-library permission and cannot read any other photo.
• Our backend re-encodes the image as a centred, square-cropped, 512×512 JPEG. The re-encode intentionally discards every EXIF metadata field, including any GPS coordinates that your phone may have embedded when the photo was taken.
• The processed image is stored in a separate, private Azure Blob Storage container named brogress-avatars in Sweden Central. Anonymous public access is disabled at the storage-account level. When the App needs to display your picture next to your handle, our backend serves a URL that includes a long-lived, read-only Shared Access Signature (SAS) scoped to that single container — the same pattern we use for the App’s static character and achievement artwork. The SAS lets the iOS image cache fetch your picture without each individual request being authenticated by your account, while keeping the underlying blob storage closed to the public internet.
• You can replace the picture at any time, or remove it via Profile picture › Remove photo. Removal deletes the blob and reverts the in-app rendering to the initial fallback.
• To deter abuse, profile-picture changes are limited to ten per account per day.
• On account deletion, the avatar blob is purged together with the rest of your data — see § 8.

3.14 Feedback you send us

If you choose to send us suggestions, ideas, feature requests, bug reports, or other feedback about the Service — for example by emailing hello@brogress.app — we store the message you sent and the email address it was sent from. We use feedback to improve the Service and may quote anonymised excerpts internally or in product communications. We do not publish your name, email address, or any other identifier alongside feedback without your separate consent. The same retention and security commitments described in § 8 and § 11 apply. The Terms of Service grant us a perpetual, royalty-free licence to use Feedback for any purpose (see § 17 of the Terms); this Policy governs how any personal data contained in Feedback is processed.

§ 04How we use your data & legal bases

We process your personal data only on the legal bases set out in Art. 6 (and where applicable Art. 9) of the GDPR.

Where we rely on legitimate interests (Art. 6(1)(f)), you have the right to object to that processing — see § 9.

§ 05Sub-processors and recipients

We use the following carefully selected sub-processors. We do not sell your personal data, and we do not share it with anyone for marketing purposes.

We will update this list before adding any new sub-processor that processes personal data on our behalf. If you would like a copy of any of the data-processing agreements above, please email hello@brogress.app.

In addition to the sub-processors above, we may share your personal data with public authorities (e.g., the German tax office, courts, or police) where we are required to do so by law (Art. 6(1)(c) GDPR).

§ 06What we send to our AI provider

Because this is the data flow most likely to surprise you, we describe it explicitly. Every time the coach replies to you, we send the following to Microsoft’s Azure AI Foundry service (deployed with the EU Data Zone, meaning inference is restricted to Microsoft regions within the European Union):

• Your full coach profile, including the “private notes” described in § 3.3
• Your knowledge graph (people, places, hobbies, goals you have mentioned)
• Your active missions, friends list, and active goals (titles, status, brief previews)
• Up to the last 10 messages in your conversation
• Your current message
• Internal protocol rules (what tools the coach may use, etc.)

We do not send: your email address, your IP address, your device token, your account UUID, or any other user’s data.

§ 07International transfers

The vast majority of your personal data is processed and stored within the European Union. Backend storage (PostgreSQL, Blob Storage, Cosmos DB Gremlin, Application Insights) is deployed to Microsoft Azure’s Sweden Central region; the AI coach is deployed with Microsoft’s EU Data Zone, restricting inference to Microsoft regions within the EU; crash reports are processed by Sentry GmbH in Frankfurt. Microsoft may replicate operational backups to other Microsoft data centres within the EU for redundancy.

Two of our sub-processors are based in the United States:

• Apple handles your Apple-ID authentication and routes push notifications. Apple is certified under the EU–U.S. Data Privacy Framework, which the European Commission has determined provides an adequate level of protection (Art. 45 GDPR adequacy decision).
• Adapty Tech Inc. processes subscription and paywall data on our behalf. Adapty is certified under the EU–U.S. Data Privacy Framework, the UK Extension, and the Swiss–U.S. DPF.

Where any other transfer outside the EEA may incidentally occur (for example, if Microsoft replicates standard backups to a paired region), we rely on the European Commission’s Standard Contractual Clauses (SCCs) (Art. 46(2)(c) GDPR) together with our sub-processors’ supplementary technical and organisational measures.

§ 08How long we keep your data

Account deletion. When you delete your account in Profile › Settings › Delete Account, we purge all of the categories above from our active systems: the relevant rows in our PostgreSQL database, every blob under your user prefix in Azure Blob Storage, your profile picture in the brogress-avatars container, your partition in our Cosmos DB knowledge graph, your Adapty profile (via Adapty’s GDPR delete-profile-and-data API), and we revoke your Apple refresh token. Anything we are legally required to retain is segregated and deleted as soon as the legal retention period expires.

§ 09Your rights under the GDPR

Under the GDPR you have the rights set out below. To exercise any of them, email hello@brogress.app from the address associated with your account; we will respond within 30 days (Art. 12(3) GDPR). Exercising your rights is free of charge.

• Right of access (Art. 15) — receive a copy of your personal data and information about how we process it. We currently provide this on email request; an in-app self-service export is on our roadmap.
• Right to rectification (Art. 16) — correct inaccurate data. Most account fields are editable in the App in Profile Settings; you can also email us for anything else.
• Right to erasure / “right to be forgotten” (Art. 17) — delete your account at any time inside the App in Profile › Settings › Delete Account. This wipes your data from our systems as described in § 8.
• Right to restriction (Art. 18) — ask us to stop using (but keep) certain data while a question about it is being resolved. Email us.
• Right to data portability (Art. 20) — receive your data in a structured, commonly used, machine-readable format. Email us.
• Right to object (Art. 21) — object to processing based on our legitimate interests (Art. 6(1)(f)). The simplest way to fully exercise this right is to delete your account.
• Right to withdraw consent (Art. 7(3)) — where we rely on your consent (assessments, push notifications), you can withdraw it at any time without affecting the lawfulness of processing before the withdrawal. Withdraw consent for assessments by deleting your account; for push notifications, by disabling notifications in iOS Settings or by removing your device token in the App.

Right to lodge a complaint (Art. 77). If you believe we have mishandled your personal data, you can complain to a supervisory authority. The competent authority for our company is:

You may also lodge a complaint with the supervisory authority in the EU Member State of your habitual residence or place of work.

§ 10Automated decisions and profiling

The App computes derived metrics about you — your six pillar scores, your overall level, your point total, suggested challenges, and which achievements to surface — based on your activity. These are automated, but they have no legal effects or similarly significant effects on you, and so Art. 22 GDPR does not apply: they only determine what you see inside the App.

The coach also generates and updates the “private notes” described in § 3.3, which is a form of profiling within the meaning of Art. 4(4) GDPR. The notes are used solely to make the coach’s replies more consistent and personal to you; they are not shared with any third party other than our AI provider, and they have no effects outside the App. You can request a copy of the notes by emailing us.

§ 11Security

We protect your personal data with appropriate technical and organisational measures (Art. 32 GDPR), including:

• TLS / HTTPS for all network traffic between your device, our backend, and our sub-processors
• AES-256 at-rest encryption (Microsoft-managed keys) for the databases and blob storage that hold your data on Microsoft Azure
• iOS Keychain for the auth token stored on your device
• Strict access controls on our backend — only authorized personnel and Microsoft sub-processor staff with operational access

We will notify you and the competent supervisory authority of a personal data breach in line with Articles 33 and 34 GDPR.

§ 12Minors

Brogress is intended exclusively for adults. You must be at least 18 years of age to create an account or otherwise use the Service. By creating an account, you confirm that you are at least 18. If we become aware that we have collected personal data from a person under 18, we will delete that data as soon as possible. If you believe a person under 18 is using the Service, please email hello@brogress.app.

§ 13Aggregated and de-identified data

We may aggregate and irreversibly de-identify usage data from across our user base — for example, the distribution of pillar scores, achievement unlock frequencies, completed-debrief counts per cohort, paywall conversion rates, and retention curves — in order to understand how the Service is used, to evaluate features, and to make product decisions. Aggregated and de-identified data is not personal data within the meaning of Recital 26 of the GDPR (or § 1798.140(m) of the California Consumer Privacy Act). We do not attempt to re-identify aggregated data, we do not combine it with personal data after de-identification, and we may retain it indefinitely for the purposes above. We do not sell or share aggregated data for advertising purposes.

§ 14Business transfers

In the event of a merger, acquisition, reorganisation, financing, asset sale, insolvency, or similar transaction, your personal data may be transferred to a successor or affiliated entity. Any such transfer will remain subject to this Privacy Policy, or to a privacy policy that is at least as protective. Where the transfer would materially change how your personal data is processed, we will notify you in the App or by email at least 30 days in advance, and you may delete your account before the transfer takes effect — see § 8 on what happens when you delete.

§ 15US Residents and US state consumer rights

15.1 Who this section applies to

This section provides additional disclosures and rights for residents of the United States, in particular under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) and its 2026 implementing regulations. Parallel rights apply to residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and Texas (TDPSA); where those laws grant rights that go beyond the CCPA, we honour them. For residents of the European Union, the United Kingdom, and Switzerland, the rights described in § 9 apply instead and are usually broader than those listed below.

15.2 Categories of personal information we collect

Below is the same data described in § 3, mapped onto the categories defined in CCPA § 1798.140(v). For each category we identify the source, the purpose, and the recipients — named sub-processors are listed in § 5.

We retain each category for the periods described in § 8. You have the right to access this data including data older than 12 months, by emailing hello@brogress.app.

15.3 We do not sell or share personal information

We do not sell personal information for monetary or other valuable consideration, and we do not share personal information for cross-context behavioural advertising, as those terms are defined in CCPA §§ 1798.140(ad) and (ah). Brogress runs no advertising, embeds no advertising or analytics SDKs, and does not have advertising or data-broker partners. No “Do Not Sell or Share My Personal Information” opt-out mechanism is therefore required, but if you would like written confirmation of this for your records, email hello@brogress.app with the subject line Do Not Sell or Share.

15.4 We do not use automated decision-making technology for significant decisions

The automated processing described in § 10 (computing your six-pillar scores, awarding points, surfacing achievements, generating coach replies and the “private notes”) determines only what you see inside the App. It does not make decisions that affect your employment, housing, credit, education, healthcare, insurance, or access to essential goods and services, and it does not have any legal or similarly significant effect on you. The CCPA right to opt out of ADMT for significant decisions therefore does not apply; you may nonetheless stop all automated processing at any time by deleting your account.

15.5 We do not run a financial-incentive programme

Brogress charges a flat subscription price (see § 3.11). We do not offer rewards, discounts, free service, or other financial incentives in exchange for the collection, retention, sale, or sharing of personal information. There is therefore no financial-incentive notice to make under CCPA § 1798.125(b).

15.6 Use of sensitive personal information

We use the sensitive personal information listed in § 15.2 only to provide and personalise the contracted Service as described in § 3, § 4, and § 6. We do not use sensitive personal information to infer characteristics about you that fall outside the Service, to target advertising, or for any of the secondary purposes that would trigger the CCPA right to limit (CCPA § 1798.121). The 2026 CCPA regulations classify the contents of messages as sensitive personal information unless the recipient is the intended recipient; the AI coach you converse with is the intended recipient of your messages within the meaning of the regulation, and the contents of those messages are not disclosed to any human at Microsoft except under the limited 30-day abuse-monitoring process described in § 6.

15.7 Your rights as a US resident

• Right to know (CCPA § 1798.110) — what categories of personal information we collect, the sources, the purposes, and the categories of recipients. This information is in §§ 3, 4, 5 and 15.2.
• Right to access (CCPA § 1798.110(a)(5)) — receive a copy of the specific personal information we hold about you, including data older than 12 months (per the 2026 CCPA regulations). Email hello@brogress.app.
• Right to delete (CCPA § 1798.105) — delete your account from Profile › Settings › Delete Account, or by emailing us. The purge is described in § 8.
• Right to correct (CCPA § 1798.106) — most account fields are editable in-app under Profile › Settings; for anything else, email us.
• Right to opt out of sale or sharing (CCPA § 1798.120) — not applicable; we do not sell or share (see § 15.3).
• Right to limit use of sensitive personal information (CCPA § 1798.121) — already limited to the contracted Service (see § 15.6); no further opt-out mechanism is required.
• Right to opt out of ADMT for significant decisions — not applicable; we do not use ADMT for significant decisions (see § 15.4).
• Right to non-discrimination (CCPA § 1798.125) — exercising any of the rights above does not change the price you pay, the features available to you, or the quality of the Service.
• Right to appeal a denied request — email hello@brogress.app with the subject line Privacy Appeal within 30 days of our response.

15.8 Authorised agents

You may designate an authorised agent to submit a request on your behalf. The agent must provide written authorisation signed by you, and we may verify the authorisation directly with you before fulfilling the request. We may deny a request from an unverified agent.

15.9 Verification

We verify your identity by matching the email address you contact us from against the email address associated with your Brogress account. For requests involving sensitive personal information or deletion, we may ask additional questions tied to your account activity (for example, the approximate date of your first debrief, the topic of a recent conversation, or your subscription start date) before fulfilling the request. We will not request more information than necessary to verify identity.

15.10 Response timeline

We respond to verifiable consumer requests within 45 days of receipt, extendable by up to 45 additional days where reasonably necessary, with notice to you, in line with CCPA § 1798.130(a)(2). For requests under the GDPR (EU/UK residents), our response window is one month per Art. 12(3) GDPR (see § 9).

15.11 Annual disclosure metrics

For the preceding 12 months: number of personal-information sales: zero (we do not sell). Number of personal- information sharing transactions for cross-context behavioural advertising: zero (we do not share). We will publish access-, deletion-, and correction-request volumes annually in this section starting with our first full operating year after launch.

15.12 Notice at collection

This Privacy Policy serves as our notice at collection under CCPA § 1798.100(b). We provide the same notice in-App on the Welcome screen before you sign in, and a link to this Policy is available from the App’s settings menu.

15.13 Children’s information

Per § 12, Brogress is for adults aged 18 and over only. We do not knowingly collect personal information from anyone under 18, which exceeds the CCPA threshold of 16 (consent required for sale or sharing) and the COPPA threshold of 13. We do not sell or share personal information regardless of age.

§ 16Cookies and analytics on the website

The brogress.app website uses two categories of storage:

1. Strictly necessary — a single localStorage key (brogress.consent.v1) that remembers your cookie-banner choice, and short-lived cookies the page sets for its own operation (session keep-alive, CSRF). These are exempt from § 25 (1) TDDDG and rest on Art. 6 (1)(f) GDPR (legitimate interest in a functional website).
2. Google Analytics 4 (only after you click “Accept” on the cookie banner) — we use Google Analytics 4 to count visits to brogress.app and identify which marketing channel referred them (the utm_source parameter on your inbound URL). Lawful basis: your consent (Art. 6 (1)(a) GDPR + § 25 (1) TDDDG). You can withdraw your consent at any time via the Manage cookies link in the page footer.

When you have given consent, Google Analytics 4 collects: the page URL, the referring URL, an anonymised IP address (Google truncates the IP before storage and we have IP-anonymisation enabled), browser, OS, and device class, a pseudonymous client identifier stored in a first-party _ga* cookie, and the standard utm_* parameters on your inbound link. We have switched off Google Signals data collection, granular location/device data collection, and ad personalisation signals; data redaction is enabled to strip query parameters that look like personal data. Data retention inside the GA4 property is set to 2 months, the shortest retention period Google permits.

Google LLC (United States) is our processor for the analytics service; the processor relationship and EU–U.S. transfer safeguards (Standard Contractual Clauses + EU–U.S. Data Privacy Framework) are summarised in § 5. The mobile App does not use web cookies and is not covered by this section.

§ 17Changes to this Policy

We will post a new version of this Policy here whenever we make a material change. The “Effective” date at the top reflects the version currently in force. For changes that affect how we use your personal data in a substantial way, we will additionally notify you in the App or by email. For US residents, we will provide notice of material changes to § 15 at least 30 days before they take effect.

§ 18Contact

For any privacy question, request, or complaint: