nudgPrivacy policy
Privacy policy.
Draft for review. This policy describes how nudg handles data today. Items in [square brackets] still need filling in, and it needs a review by a privacy lawyer before nudg is released to the public.
In short
- nudg combines your health, spending and screen time data to show you patterns in your own life. That is the only thing we use it for.
- We never sell your data and never use it for advertising.
- Screen time data stays on your iPhone. Apple doesn't let nudg see which apps you use or for how long.
- Health and spending data is stored encrypted, kept for a limited time, and deleted when you delete your account.
- Ask nudg sends relevant data to an AI provider only after you agree.
Who we are
nudg is run by [legal entity name], [registered address] (“nudg”, “we”, “us”). We are the data controller for the personal data described here. Our data protection contact is [name], reachable at privacy@trynudg.app.
Our UK representative under Article 27 of the UK GDPR is [UK representative name and address].
What we collect
| Data | Where it comes from | What it includes |
|---|---|---|
| Account | Sign in with Apple | An identifier from Apple (stored only as a one-way hash), and your confirmation that you are 18 or over and agree to this policy. |
| Health | Apple Health, with your permission | Up to 92 days of daily sleep, sleep stages, heart rate variability, resting heart rate, steps and exercise minutes, and your recent workouts. |
| Spending | Your bank, through an open banking provider, with your permission | Up to 180 days of transactions (date, merchant, amount, category) and the name of your bank. We get read-only access and can't move money. |
| Screen time | Apple's Screen Time system, on your iPhone | The apps and limits you choose, held as private tokens on your phone. nudg is told when a limit is reached but never sees app names or minutes used. This stays on your device. |
| Location context | Worked out from your spending | The city you are in, used to fetch weather and air quality. |
| Ask nudg chats | You | Your questions and nudg's answers, kept on your phone. |
Health data, and conclusions about your health drawn by combining it with other data, are special category data under UK GDPR. We only process them with your explicit consent.
Why we use it, and our legal basis
- To provide nudg (your score, charts, insights and app limits): your explicit consent for health data and for combining it with spending and screen time, and our contract with you for everything else.
- To keep nudg secure and working (preventing abuse, fixing faults): our legitimate interests.
- To meet legal obligations, such as responding to a lawful request: legal obligation.
We do not use your data for advertising, sell it, or use it to train AI models. You can withdraw consent at any time by disconnecting a source in the app or deleting your account.
Ask nudg and AI
Ask nudg is an optional assistant. Before you first use it we ask whether you agree to share your data with our AI provider, [OpenAI, L.L.C.]. When you ask a question, the parts of your health and spending data needed to answer it, a short summary of your app limits and your last few messages are sent to answer that question. We ask the provider not to store these requests [and to apply zero data retention]. Ask nudg can suggest changes, such as a new limit, but never makes them without you tapping Confirm. It does not give medical advice.
Who we share it with
We share data only with providers who help us run nudg, under contracts that require them to protect it:
- Cloudflare: hosts our servers and stores your encrypted data.
- Open banking providers: [TrueLayer] in the UK, [Plaid] in the US and [Finverse] in Singapore connect to your bank under their own regulatory licences.
- [OpenAI]: answers Ask nudg questions, only if you turn it on.
- Open-Meteo: provides weather and air quality for your city. It receives a city location, not your identity.
- Apple: provides sign-in, Apple Health and Screen Time under Apple's own privacy terms.
We may disclose data if the law requires it. If nudg is ever sold or merged, your data would only move to the new owner under this policy, and we would tell you first.
Where it's stored and how it's protected
Your health and spending data and bank connection tokens are encrypted with keys held separately from the data, and stored on Cloudflare's network, which may include servers outside the UK. Data sent outside the UK is protected by [the UK International Data Transfer Addendum or the UK–US data bridge, as applicable]. Your session is protected by a token held in your iPhone's Keychain.
How long we keep it
- Health data: the most recent 92 days, replaced on each sync.
- Transactions: the most recent 180 days, replaced on each sync.
- Sign-in sessions: expire after 180 days.
- Everything above is deleted when you delete your account, and your bank connection is revoked.
Ask nudg chats and app limits are stored on your phone and are removed when you delete the app.
Your rights
You have the right to access your data, correct it, delete it, receive a copy in a portable format, object to or restrict how we use it, and withdraw consent. You can delete your account and data at any time from the You tab in the app. For anything else, email privacy@trynudg.app and we will reply within one month.
If you are unhappy with how we handle your data, you can complain to the UK Information Commissioner's Office at ico.org.uk. If you live in Singapore you can contact the Personal Data Protection Commission, and in the US your state's consumer protection authority.
Age limit
nudg is for adults aged 18 and over. We ask you to confirm your age when you start. If we learn that someone under 18 is using nudg, we will close the account and delete its data.
Changes to this policy
If we change this policy in a way that affects how we use your data, we will tell you in the app and ask for your agreement again where needed.
Contact
Questions about privacy: privacy@trynudg.app. Post: [registered address].