Underthink

Underthink

Privacy Policy

Underthink

Operated by Sagiware (individual developer)

Poland, European Union

Effective Date: June 2, 2026

Last Updated: June 6, 2026

1. Who We Are and How to Contact Us

Underthink is an iOS application for self-reflection and daily journaling. It is operated by an individual developer trading as Sagiware, based in Poland, European Union.

Data Controller: Sagiware (individual developer), Poland, European Union

Email: d.trafalski.dev@gmail.com

Privacy-specific enquiries: d.trafalski.dev@gmail.com

Because Sagiware is based in Poland, all personal data processing activities are subject to the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Polish data protection law.

Data Protection Officer: As a small-scale individual developer, Sagiware is not legally required to appoint a Data Protection Officer under Article 37 GDPR. For all privacy enquiries and data subject requests, please contact us directly at d.trafalski.dev@gmail.com. We will respond within 30 days.

2. Our Commitment

We do not sell your personal data. We do not share your personal data with advertisers, data brokers, or any third party for commercial purposes unrelated to operating the app. We do not use your journal content or emotional profile for advertising or for training AI models.

Your reflection content exists to serve you. It is never used for any purpose other than delivering the service you have requested.

3. Data We Collect and Why

3.1 Account Information

If you choose to sign in using Sign In With Apple, we receive from Apple:

  • A unique, anonymised Apple user identifier
  • Your email address (only if you choose to share it; Apple may provide a privacy-relay address)
  • Your display name (only if you choose to share it; fully optional)

You may use Underthink without creating an account. Without an account, data is stored only on your device and is never transmitted to our servers.

3.2 Emotional Profile and Onboarding Data

When you complete the onboarding process, you provide responses to a structured questionnaire covering:

  • Emotional challenges you selected (from a fixed list, such as anxiety, stress, overthinking, and burnout)
  • Emotional triggers you identified (such as work, relationships, family, social situations)
  • Your coping style and behavioural patterns (selected from a fixed list)
  • Your level of prior engagement with self-reflection practices
  • Your personal goals and stated reasons for using the app (free-text entry)
  • Your preferred session duration and reflection style

This data is used to generate a personalised onboarding profile that determines the framing and content of your experience within the app. It is not used for any other purpose.

3.3 Reflection Session Data

During reflection sessions, you provide:

  • Written answers to guided reflection questions (free-text)
  • An emotion label selected from a fixed list at the end of each session
  • The session category chosen (e.g., gratitude, stress, confidence)
  • Timestamps for when each session started and was completed

3.4 Progress and Usage Data

The app tracks the following statistics to display your progress:

  • Current and longest daily reflection streak
  • Total number of reflection sessions completed
  • Total gratitude moments logged
  • Total stress-processing sessions completed
  • Date of your most recent session

Storage: When you are signed in, this data is synchronised to our server (Supabase) so that it is accessible across devices and is not lost if you reinstall the app. Without an account, this data is stored locally on your device only.

3.5 Notification Preferences

If you grant notification permission, we store:

  • Whether daily reminders are enabled
  • Your chosen reminder time (hour and minute)

Local notifications are scheduled and delivered entirely on your device. No notification content is transmitted to our servers or any third party. We do not use Apple Push Notification Service (APNs) for delivering Underthink's reminder notifications.

3.6 Application Preferences

  • Whether haptic feedback is enabled
  • Onboarding completion status

3.7 Subscription and Entitlement Data

We use RevenueCat to manage in-app subscriptions. When you subscribe:

  • RevenueCat receives a user identifier (either your account ID if signed in, or an anonymous device identifier)
  • RevenueCat processes your App Store receipt with Apple to verify subscription status
  • We receive from RevenueCat: your current subscription status (active/inactive), the plan type (monthly or annual), and the entitlement expiry date

We do not receive, store, or process your payment card details, Apple ID password, or any financial information. All payment processing is handled exclusively by Apple via the App Store.

3.8 What We Do Not Collect

We do not collect:

  • Precise GPS or location data of any kind
  • Contacts, address book, or phone number data
  • Camera or microphone input
  • Browsing history outside the app
  • Data from other apps on your device
  • Advertising identifiers (IDFA or IDFV)
  • Biometric data
  • Web cookies or web tracking technologies (the app does not embed a web browser or web-based tracking)

4. Legal Basis for Processing (GDPR)

| Purpose | Data Used | Legal Basis |

|---|---|---|

| Creating and managing your account | Apple ID identifier, email, display name | Art. 6(1)(b) — Contract performance |

| Generating your personalised onboarding plan | Emotional profile, goals, challenges | Art. 6(1)(a) and Art. 9(2)(a) — Explicit consent |

| Providing reflection sessions | Session answers, emotion labels, timestamps | Art. 6(1)(a) and Art. 9(2)(a) — Explicit consent |

| Displaying your progress across sessions | Streak data, session statistics | Art. 6(1)(b) — Contract performance |

| Delivering daily reminders | Notification time preference | Art. 6(1)(a) — Consent |

| Processing your subscription | RevenueCat user ID, entitlement status | Art. 6(1)(b) — Contract performance |

| Preventing fraud and abuse | Account identifiers, session data | Art. 6(1)(f) — Legitimate interests |

| Maintaining technical security | Authentication tokens | Art. 6(1)(f) — Legitimate interests |

| Complying with legal obligations | Financial records as required by law | Art. 6(1)(c) — Legal obligation |

5. Special Category Data: Emotional and Mental Health Information

Information you enter into the app's reflection features — including free-text journal entries, the emotional challenges and coping patterns you identified during onboarding, and your personal reasons for using the app — constitutes data concerning health within the meaning of GDPR Article 4(15) and falls within the special categories of personal data set out in GDPR Article 9.

We process this data exclusively because you choose to provide it as an integral part of using the service. By entering this information, you provide your explicit consent under Article 9(2)(a) GDPR for us to process it for the sole purpose of delivering Underthink's personalised reflection experience.

You may withdraw this consent at any time by ceasing to input such information and by requesting deletion of your data (see Section 10 below). Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

This data is never:

  • Used for advertising or commercial profiling
  • Shared with third parties for their own purposes
  • Used to train machine learning models or AI systems
  • Disclosed to employers, insurers, or healthcare providers

6. Where Your Data Is Stored

On Your Device

The following data is stored locally on your device using iOS standard storage mechanisms:

  • Your emotional profile and onboarding selections
  • Your reflection sessions and answers (when not signed in)
  • Your streak and progress data (when not signed in)
  • Your app preferences and notification settings
  • Your Supabase authentication tokens (stored in the iOS Keychain, encrypted by the operating system and tied to device authentication)

If you sign in and then sign out, locally stored data is not automatically deleted from your device. Use the account deletion function to remove all data from our servers (see Section 10).

On Our Servers (Supabase)

If you sign in with Sign In With Apple, the following data is synchronised to our cloud database hosted by Supabase:

  • Your user account (identifier, email if shared, display name if shared)
  • Your emotional profile and onboarding selections
  • Your reflection sessions and answers
  • Your streak and progress statistics

Data is not transmitted to our servers for users who do not create an account.

7. Third-Party Service Providers

We share data only with the following processors, strictly for the purposes described. All processors are bound by applicable data protection law and contractual data processing agreements.

7.1 Supabase (Supabase Inc., United States)

Purpose: Cloud database storage and authentication token verification

Data shared: User account data, reflection sessions and answers, streak data, emotional profile

Legal safeguard for EEA transfers: Standard Contractual Clauses (SCCs) approved by the European Commission

Privacy policy: https://supabase.com/privacy

7.2 RevenueCat (RevenueCat Inc., United States)

Purpose: In-app subscription and entitlement management

Data shared: Anonymous or named user identifier, App Store receipt data, subscription status

Legal safeguard for EEA transfers: Standard Contractual Clauses (SCCs)

Privacy policy: https://www.revenuecat.com/privacy

7.3 Apple Inc. (United States)

Purpose: Authentication (Sign In With Apple), payment processing (App Store In-App Purchases), app distribution

Data shared: Authentication tokens (Sign In With Apple), purchase receipts

Note: Apple's processing of payment and authentication data is governed solely by Apple's Privacy Policy. We do not control Apple's data practices. Additionally, Apple may independently collect usage or crash data through App Store systems (e.g., App Store Connect analytics, TestFlight) pursuant to Apple's own privacy policy, independently of this policy.

Privacy policy: https://www.apple.com/privacy/

7.4 PostHog (PostHog Inc., United States) — **Currently Inactive**

Purpose (if activated): Product analytics — event tracking and usage analysis

Status: The PostHog SDK is integrated into the app, but no API key is configured in the production build. PostHog is currently receiving no data.

Activation notice: If PostHog is activated in a future release, this Privacy Policy will be updated before activation. Where required by applicable law, we will seek your consent prior to enabling analytics collection.

Privacy policy: https://posthog.com/privacy

7.5 Sentry (Functional Software Inc., United States) — **Currently Inactive**

Purpose (if activated): Crash reporting and error diagnostics

Status: The Sentry SDK is integrated into the app, but no DSN is configured in the production build. Sentry is currently receiving no data.

Activation notice: If Sentry is activated in a future release, this Privacy Policy will be updated before activation.

Privacy policy: https://sentry.io/privacy/

We do not share your data with advertising networks, data brokers, marketing platforms, or any party for purposes unrelated to operating the app.

8. International Data Transfers

Sagiware is based in Poland, within the European Economic Area (EEA). Supabase and RevenueCat are companies based in the United States.

Transfers of personal data to the United States are governed by Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to GDPR Article 46(2)(c), incorporated into our data processing agreements with these providers. These clauses provide equivalent protections required under GDPR Chapter V.

Apple's processing of Sign In With Apple and App Store data is subject to Apple's own compliance mechanisms.

9. Data Retention

| Data Category | Retention Period |

|---|---|

| Reflection sessions and answers (server) | Retained while your account exists; permanently deleted upon account deletion |

| Emotional profile (server) | Retained while your account exists; permanently deleted upon account deletion |

| Streak and progress data (server) | Retained while your account exists; permanently deleted upon account deletion |

| User account profile (server) | Permanently deleted immediately upon account deletion |

| Authentication tokens (device Keychain) | Deleted from your device when you sign out |

| Locally stored app data (device) | Retained on your device until you delete the app or request deletion |

| Subscription and financial records | Retained for the period required by applicable law for financial record-keeping (minimum 5 years under Polish accounting law) |

| RevenueCat subscription data | Subject to RevenueCat's own retention policy |

When you delete your account through the app, all personal data stored on our servers is deleted immediately and permanently. This action cannot be undone.

Certain anonymised, aggregate, or de-identified data derived from your usage (e.g. aggregate feature usage counts) may be retained after account deletion, as such data cannot be used to identify you.

10. Your Rights

Rights Under the GDPR

As a data subject located in the EEA, you have the following rights. To exercise any of these rights, contact us at d.trafalski.dev@gmail.com. We will respond within 30 days; in complex cases, this may be extended by a further 60 days, and we will inform you of any extension.

Right of Access (Article 15): You may request a copy of all personal data we hold about you.

Right to Rectification (Article 16): You may request correction of inaccurate or incomplete data.

Right to Erasure (Article 17): You may request deletion of your data. You can delete your account and all associated server-side data directly within the app at Profile → Account → Delete Account, which triggers immediate permanent deletion.

Right to Restriction of Processing (Article 18): You may request that we restrict processing of your data in certain circumstances (for example, while the accuracy of data is contested).

Right to Data Portability (Article 20): You may request a copy of data you have provided to us in a structured, commonly used, machine-readable format. You can export your data directly within the app at Profile → Export My Data, which generates a JSON file containing your reflection sessions and profile data. You may also contact us at d.trafalski.dev@gmail.com to request an export.

Right to Object (Article 21): You may object to processing based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

Right to Withdraw Consent (Article 7(3)): Where processing is based on your consent — including the processing of your emotional and reflection data under Article 9(2)(a) — you may withdraw consent at any time by deleting your data and ceasing use of those features. Withdrawal does not affect the lawfulness of processing before withdrawal.

Right Not to Be Subject to Solely Automated Decision-Making (Article 22): The personalised plan and prompts shown in the app are generated algorithmically from your onboarding inputs using deterministic, rule-based logic within the app. This does not constitute automated decision-making producing legal effects or similarly significant effects within the meaning of Article 22.

Rights Under the CCPA (California Residents)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the purposes of collection, and the categories of third parties with whom it is shared.

Right to Delete: You may request deletion of your personal information, subject to certain exceptions.

Right to Correct: You may request correction of inaccurate personal information.

Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information with third parties for cross-context behavioural advertising. There is nothing to opt out of.

Right to Limit Use of Sensitive Personal Information: Information about your emotional and mental wellbeing constitutes "sensitive personal information" under the CPRA. We use this data solely to provide the core service you have requested and for no secondary purpose.

Non-Discrimination: We will not discriminate against you for exercising any CCPA rights.

To exercise California rights, contact us at d.trafalski.dev@gmail.com. We do not respond to browser "Do Not Track" signals, as the app does not use browser-based tracking technologies.

11. Security

We implement the following security measures appropriate to the sensitivity of the data processed:

  • Keychain encryption: Authentication tokens are stored in the iOS Keychain, which is encrypted by the operating system and tied to device authentication (Face ID / passcode)
  • TLS in transit: All data transmitted between the app and Supabase is encrypted using Transport Layer Security (TLS)
  • Row Level Security: Our Supabase database is configured with Row Level Security (RLS) policies, ensuring users can only access their own data
  • No advertising SDKs: No advertising, behavioural tracking, or fingerprinting SDKs are present in the app

No method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we take precautions commensurate with the sensitivity of the information involved. In the event of a personal data breach affecting your rights, we will notify you and the relevant supervisory authority as required by GDPR Article 33 and 34.

12. Children's Privacy

Underthink is not directed at children under 13. We do not knowingly collect personal data from individuals under the age of 13. If you are a parent or guardian and believe your child under 13 has provided personal data to us, please contact us at d.trafalski.dev@gmail.com and we will delete such data promptly.

EU/EEA users: Under GDPR Article 8 and applicable Polish data protection law, the minimum age for processing personal data in the context of information society services without parental consent is 16 years. If you are under 16 and located in the EU/EEA, you must not use this app without obtaining verifiable parental or guardian consent. We cannot technically verify age at sign-up; we rely on users and parents to comply with this requirement.

13. Local Notifications

Underthink may request permission to deliver local notifications on your device for daily reflection reminders. These notifications are:

  • Scheduled and delivered entirely on your device using iOS's local notification system
  • Not transmitted through Apple's Push Notification Service (APNs)
  • Not used to deliver advertising or third-party marketing content
  • Cancellable at any time within the app (Profile → Settings → Notifications) or via iOS Settings → Underthink → Notifications

14. Subscriptions and Payments

In-app subscriptions are processed through Apple's App Store. When you subscribe:

  • Payment is charged to your Apple ID account by Apple
  • Subscription management (cancellation, renewal settings) is handled through Apple ID Settings or the App Store on your device
  • We use RevenueCat solely to verify your subscription entitlement status; we do not receive or store your payment instrument details, billing address, or any financial credentials

We do not store payment card details or financial information on our servers.

15. Changes to This Privacy Policy

We may update this policy when the app's data practices change. Material changes will be communicated via a notice within the app before the changes take effect. Where required by applicable law, we will seek renewed consent before processing your data under materially changed terms.

The current version of this policy is always available at https://underthink.app/privacy. The "Last Updated" date at the top of this document indicates when the policy was most recently revised.

16. Contact and Complaints

For any privacy-related request, question, or concern, contact:

Sagiware (Underthink)

Email: d.trafalski.dev@gmail.com

We will acknowledge your request within 72 hours and provide a full response within 30 days.

Right to Lodge a Complaint

If you are located in the EEA and believe we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority. The lead supervisory authority for Sagiware is:

Urząd Ochrony Danych Osobowych (UODO)

Polish Office for Personal Data Protection

ul. Stawki 2, 00-193 Warsaw, Poland

Website: https://uodo.gov.pl/

Email: kancelaria@uodo.gov.pl

You may also contact the supervisory authority in the EU member state of your habitual residence or place of work.