Privacy Policy

Who this is about

Tracely ("the app", "we") is a voice-first health diary for iPhone, developed by Bjorn Schefzyk in Berlin, Germany. This policy explains what the app collects, how it collects it, and everything it is used for — including where data is shared with third-party services. See the Imprint for contact details.

At a glance: what leaves your phone

Your voice and the AI service

Speech stays on the device. When you speak into Tracely, the audio is turned into text on your iPhone by Apple's built-in on-device speech recognition. The recording itself never leaves your phone and is never sent to us or to anyone else.

What is sent, and when. Turning that text into a structured entry is done by an AI model. Each time you save an entry while AI use is switched on, the app sends exactly two things:

• the text of what you just said, and
• the names of the medications and symptoms already in your log, so the model spells them the way you do.

Nothing else is attached. AI use is off until you switch it on — you are asked during onboarding, and you can change your mind at any time in Settings → Privacy. With it off, entries are saved as plain transcripts and nothing is sent anywhere.

Who receives it. The request goes first to Tracely's own small proxy server (hosted by Railway Corp., US), which adds a fixed instruction prompt and forwards it to OpenRouter, Inc. (US), an AI model-routing API. OpenRouter runs it on the model configured on Tracely's server — currently OpenAI's GPT-5.6 Luna (OpenAI, L.L.C., US). If we change the model, we update the app and this page.

What it is used for. The text is used for one thing only: producing the structured entry that comes back to your phone. Tracely's proxy has no database and stores no entries; request and response logging is switched off, so Tracely's server does not keep a copy of your text. It does see your IP address, which is used only to enforce rate limits and is not stored. There are no user accounts, so nothing that is sent is linked to a name, an email address or a device identifier.

Training and retention. Tracely's server asks OpenRouter to route only to providers that do not use inputs for training (OpenRouter's data_collection: deny setting). According to OpenRouter's and OpenAI's published API terms, data sent through their APIs is not used to train their models. The model provider may retain API data for a limited period for abuse monitoring under its own policy — see OpenAI's API data usage policies and OpenRouter's privacy policy. According to those published terms and privacy policies, these providers process the data only to deliver the service and safeguard it to a standard equivalent to the protection described in this policy.

Never sent to the AI service: audio recordings, your name, your email address, your Apple ID, your contacts, your location, your photos, device identifiers, or anything from Apple Health.

Where it is processed. This processing takes place in the United States. Under the GDPR that is a transfer outside the EU; it happens on the basis of your explicit consent, given by the AI-use switch in the app (Art. 49(1)(a) GDPR). You can withdraw that consent at any time in Settings → Privacy, and the app keeps working without it.

Analysis

Analysis is the one feature that looks across your whole diary, and it runs only when you tap "Run analysis" — never in the background. When you do, the app sends your logged history over the same route as above (Tracely's proxy → OpenRouter → the model): for each entry its date, time and transcript text, and for each item within it the kind (symptom, medication, food & drink, mood, sleep), the name, whether it was a negation ("no heartburn"), the severity, dose, duration and time, and food attributes such as caffeine or alcohol.

What comes back is a short plain-language pattern report. It is stored on your device with the date it was run. Everything in the section above — no copy kept on Tracely's server, no training, no identity attached, US processing on the basis of your consent — applies here in exactly the same way.

Where your diary lives

Your entries — your transcripts and the structured data built from them — are stored on your device and in your own private iCloud (Apple CloudKit), under your Apple Account. There is no Tracely account and no Tracely database of your entries: the developer cannot read them. Syncing between your devices is handled by Apple under Apple's privacy policy, not by us.

Apple Health

Apple Health integration is optional and off by default. You turn it on in Settings → Apple Health, and iOS asks for your permission separately. When it is on, Tracely writes symptoms, moods, caffeine and alcohol from your entries into Apple Health on your device. Tracely never reads anything from Apple Health, and nothing from Apple Health is ever sent to the AI service, to the analytics service, or to us. You can switch it off at any time; what was already written stays in Apple Health, under your control, where you can delete it.

Usage analytics

Tracely sends anonymous usage analytics to PostHog, Inc., using PostHog's EU Cloud, so this data is hosted in the EU (eu.i.posthog.com). It is anonymous: no identity, no account, no person profile, and session replay and autocapture are switched off — the app never records your screen or captures what you type.

The events are things like "entry saved", "onboarding completed", screen views, which feature toggles are on, and the category of an error when something fails. They never include symptom, medication or food names, transcripts, or any other health content. They are used only to see which features people use and where the app breaks.

Analytics is on by default and you can switch it off at any time in Settings → Privacy → "Usage analytics".

Reminders and support email

Reminders are local notifications scheduled by iOS on your device; nothing about them leaves the phone. If you choose to write to support, your email reaches bjoern.schefzyk@gmail.com, a Gmail account operated by Google, and whatever you put in that message is kept only for as long as it takes to answer you.

What we don't do

• No advertising, no advertising identifier, no cross-app or cross-site tracking.
• No selling or sharing of your data with data brokers.
• No profiles built about you for marketing — analytics is anonymous and carries no health content.
• No health data, transcripts or entry contents sent to the analytics service, ever.
• No background uploads: the AI service is only contacted when you save an entry with AI use on, or when you tap "Run analysis".

This is not medical advice

Tracely is a diary and a pattern-spotting aid. It is not medical advice, not a medical device, and not a diagnosis. The AI can be wrong. For any medical concern, talk to a qualified clinician.

Your rights (GDPR)

The developer is based in the EU (Germany), so the GDPR applies. The legal bases are your consent for the AI processing of your entries, which are health data (Art. 6(1)(a) and Art. 9(2)(a) GDPR), given and withdrawable by the AI-use switch in the app, and our legitimate interest in improving the app for anonymous usage analytics (Art. 6(1)(f) GDPR), which you can opt out of.

• Access & export: your entries are already on your device and in your own iCloud, where you can view them at any time.
• Deletion: delete individual entries in the app, or remove everything by deleting the app and its iCloud data — anytime, without asking us.
• Withdraw consent: switch AI use off in Settings → Privacy; switch usage analytics off in the same place.
• Complaint: you can lodge a complaint with a data protection supervisory authority in your country.
• For privacy questions, or to exercise any GDPR right, email bjoern.schefzyk@gmail.com.

Children

Tracely is not intended for children under 16.

Changes

If this policy changes in a way that affects you — including a change of AI model or provider — we'll update this page and the "last updated" date above.

Questions? See Support or email bjoern.schefzyk@gmail.com · Berlin, Germany