Last updated: 2026-07-25

Privacy Policy

We read your daily step count from Apple Health to check whether you hit your goal. That is the only thing we use it for. We never sell it, never use it for advertising, and never hand it to anyone for marketing.

1. Who is responsible

Pino Kokol s.p. is the controller of your personal data under the GDPR. Write to us at support@strutty.app.

2. What we collect

Your account

Name and email address, and whether the address is verified.
How you sign in: Apple, Google, or email and a password. Passwords are stored hashed, and we never see the one you typed.
Sign-in sessions, with the IP address and device string they were created from, so you can see and end them.
Short-lived codes we email you to reset a password or confirm an address.

Your steps

A daily step total, read from Apple Health. Read only. We ask for step count and nothing else: no workouts, no heart rate, no sleep, no weight, no location.
Every step figure your phone sends us, with the time it arrived, whether the app was open or in the background, and basic device information. We keep these as evidence, so a charge can always be explained.
The names of the apps or devices that wrote steps into Apple Health, so you can see where your numbers come from.
Once, during setup: your recent average step count, how many days it covered, and the moment you confirmed that history looked right.

Your commitment and your money

Your step target, stake, rest days and timezone, with a dated history of changes.
Each goal day: the target, the stake that applied, your synced steps and the outcome.
Your permission to charge: the exact wording you accepted, when you accepted it, how long you held the button, and the IP address you accepted from.
Each charge: the amount, currency, status, attempt number, any failure code, and the Stripe payment reference.
Anything you write in an appeal, and the note we write when we resolve it.

Payment details

Stripe handles your card. We store your Stripe customer reference and the reference of your saved payment method. We never see or store your card number, expiry date or security code.

Notifications and product use

A push token, if you allow notifications, so we can reach your phone.
Product analytics: which screens you opened and which steps of setup you finished, tied to your account. These events never carry a raw step count or Apple Health sample.
Crash and error reports, so we can fix what breaks. Personal data is switched off in these reports and health data is stripped before anything is sent.

3. Why we use it, and our legal basis

Step data (Article 9 health data): your explicit consent. You give it in setup, when you connect Apple Health and again when you commit to a goal. We store a record of that consent, including the wording you saw. You can withdraw it at any time, and withdrawing does not undo what we did while it was valid.
Running your account and your goal: performing our contract with you.
Charging a stake, refunding it, handling appeals: performing our contract, together with our legal duty to keep accounting records.
Fraud prevention and dispute evidence: our legitimate interest in a charging system that can prove what happened.
Product analytics and crash reports: our legitimate interest in a working app. No step counts go into either.

4. Apple Health, specifically

Apple sets rules for apps that read Health data. We follow them, and we mean them:

We read your step count. We never write anything into Apple Health.
We use it for one purpose: checking whether you hit your step goal.
We never use health data for advertising.
We never sell it, and never share it with anyone for marketing, advertising or profiling.
It never goes into analytics, crash reports or server logs.

You can revoke access at any time in iOS Settings, under Privacy & Security, Health, Strutty. Without it we cannot verify your days. We never charge an unverified day, so the practical result is that your goal pauses.

5. Who else handles your data

We keep the list short on purpose. Each of these does one job for us:

Stripe - payments, refunds and disputes. Stripe is its own controller for the payment records it keeps.
Hetzner - our servers, in Germany.
Cloudflare R2 - encrypted database backups, in an EU-jurisdiction bucket.
Resend - the emails we send you, such as reset and verification codes.
Expo and Apple Push Notification service - delivering push messages. A reminder can contain your step count for the day, because that is the point of the reminder.
PostHog - product analytics, on their EU cloud. No health data.
Sentry - crash and error reports, with personal data switched off.

Nobody else gets your data. We do not sell it, rent it or trade it. We share it with the authorities only where the law obliges us to.

6. Where your data lives

Your account, your steps and your goal history sit on servers in Germany, with backups in the EU. Some of the services above are based outside the EU or may process data there; where they do, the transfer relies on the European Commission’s standard contractual clauses.

7. How long we keep it

Your account, goal history and step reports: while your account exists.
Records of a payment method being saved: 30 days if unfinished, 90 days if finished.
Backups: up to 30 days. Data you delete can survive in a backup until that backup rolls off.
Payment records held by Stripe: for as long as Stripe’s own legal duties require, which is longer than your account lasts.

8. Deleting your account

You can delete your account in Settings, in the app. Deletion waits while money is in flight: a charge in progress, an open appeal or an open dispute. Once it runs, it removes our records of you - account, sign-in, sessions, profile, goals, settings history, consents, goal days, step reports, charges and resolved appeals. We delete them rather than anonymise them.

Stripe keeps its own record of payments it processed, and we cannot delete that for you. A dispute that arrives after you leave is handled from Stripe alone.

9. Your rights

Under the GDPR you can ask us to:

show you a copy of your data;
correct anything wrong;
delete it;
limit what we do with it;
hand it over in a portable form;
stop processing you object to;
withdraw a consent you gave.

Delete your account yourself in the app. For anything else write to support@strutty.app and we will answer within one month.

If you think we have handled your data badly, you can complain to a supervisory authority. In Slovenia that is the Information Commissioner (Informacijski pooblaščenec, www.ip-rs.si). You can also complain to the authority where you live.

10. Children

Strutty is not for anyone under 18. We do not knowingly collect data from children. If you believe a child has an account, tell us and we will remove it.

11. How we protect it

Traffic between your phone and our servers is encrypted.
Backups are encrypted and kept apart from the live database.
Card numbers never touch our servers.
Health data is kept out of analytics, logs and error reports.
Access to the production database is limited to people who need it.

12. Changes to this policy

We post changes here with a new date at the top. If a change matters to you, we tell you in the app or by email first. If it changes how we use health data, we ask for your consent again.

13. Contact

support@strutty.app. We answer every message.