Privacy Policy

Effective: 2026-08-09

This Privacy Policy explains how ZenThoughts handles personal data. It is a privacy notice, not a request for blanket consent and not a waiver of your rights.

1. Who We Are

The controller responsible for ZenThoughts is:

• Kanstantsin Ausianovich
• Individual developer, Republic of Lithuania
• Email: zenthoughtsapp@gmail.com

In this Policy, “ZenThoughts,” “I,” and “my” refer to the service and its developer, as applicable.

2. Scope

This Policy applies to the ZenThoughts mobile application, its account and backend services, and the website pages that publish this Policy and the Terms of Use. ZenThoughts is offered globally, including in the European Union and European Economic Area (“EU/EEA”), the United Kingdom, and the United States.

The legal website is static and does not use JavaScript, analytics, advertising, tracking pixels, or cookies. Third-party sites linked from ZenThoughts have their own privacy practices.

3. Age Eligibility

ZenThoughts is intended for people aged 13 and older. It is not directed to children under 13, and I do not knowingly allow a child under 13 to create an account or submit personal data.

If you are 13 or older but below the age at which you may consent to relevant data processing or enter into these Terms by yourself under local law, use ZenThoughts only with the involvement and authorization of a parent or legal guardian where required.

If you believe a child provided personal data contrary to these rules, contact zenthoughtsapp@gmail.com. I will investigate and delete the data where required.

4. Information We Process

Persistent identifiers described below are pseudonymous rather than truly anonymous when they can distinguish a device, installation, or customer record.

I receive data directly from you, automatically from the app and device when you use a feature, from Apple or Google during authentication, from Apple and RevenueCat for purchases, and from service providers acting for the purposes described here.

Comments are public. Do not include your own or another person’s contact details, health data, precise location, financial information, credentials, or other sensitive or private information in a comment. If you choose to publish such information, other users may see it, and ZenThoughts may process it to host or moderate the comment.

5. How We Use Information and Legal Bases

Depending on your location and the feature involved, I rely on the following legal bases:

Acknowledging this Policy does not constitute consent for every processing activity. Where consent is the legal basis, the app requests it separately and you may withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal.

I do not use personal data for advertising, sell it, disclose it to data brokers, or track you across apps or websites owned by other companies. I do not use the information described here for solely automated decisions that produce legal or similarly significant effects.

6. Analytics and Diagnostics Choices

ZenThoughts uses PostHog Cloud EU in Frankfurt for product analytics and error/crash reporting only after you opt in. Both purposes use a random analytics identifier. ZenThoughts does not send PostHog your name, email address, ZenThoughts server user ID, RevenueCat App User ID, comments, other user-entered content, or deliberately selected sensitive data.

Session replay is disabled. The PostHog project is configured not to capture or retain raw IP addresses as event properties. Event and error properties must be reviewed so that direct identifiers, user content, authentication values, and sensitive information are not included.

You can decline analytics and diagnostics or turn them off later in ZenThoughts settings without losing paid access or core app functionality. Opting out stops future PostHog capture from the app. It does not automatically delete data already processed; use the privacy-request process below if you also want existing provider data deleted.

7. Push Notifications

ZenThoughts requests Apple notification authorization and registers with APNs only as needed to deliver reminders you enable. The server uses your random installation ID, APNs token, locale, time zone, and schedule to request delivery through Apple Push Notification service.

You may change the schedule or disable notifications in ZenThoughts. You may also withdraw system permission in Apple Settings. Disabling system permission prevents notification display, but the saved schedule or device registration may remain until you disable the feature in the app, delete your account, or ask for deletion, as applicable.

Notification permission is optional and is not required to access paid or core app functionality.

8. Subscriptions and Purchases

Apple processes payment, billing, and the underlying App Store transaction records. RevenueCat receives its generated anonymous App User ID and receipt-derived purchase and subscription information to validate entitlements and restore purchases. ZenThoughts does not use your name, email address, or internal server user ID as the RevenueCat App User ID, and the ZenThoughts server does not store purchase records.

“Anonymous App User ID” is RevenueCat’s name for its randomly generated identifier; it may still be personal data because it distinguishes a customer record and is associated with purchase history.

Deleting your ZenThoughts account or asking RevenueCat to delete a customer record does not cancel an Apple subscription or delete Apple’s transaction records. Manage or cancel Apple subscriptions at Apple’s subscription management page.

9. Service Providers and Recipients

I disclose data only as needed for the purposes in this Policy:

Providers process data under their own legal obligations and applicable agreements with the controller. I may also disclose information when required by law, to protect users or the service, to investigate fraud or security incidents, or in connection with a lawful transfer of the service, subject to applicable notice and data-protection requirements.

10. International Transfers

Primary ZenThoughts backend data and PostHog Cloud EU data are hosted in Frankfurt, Germany. Apple, Google, DigitalOcean, PostHog, and RevenueCat may process limited operational, support, security, or transaction data in other countries where they or their subprocessors operate.

Where cross-border transfer rules apply, I rely on an adequacy decision, contractual safeguards made available by the provider, or another lawful transfer mechanism, as applicable. For transfers handled by PostHog outside the applicable protected area, the signed data processing agreement incorporates the EU controller-to-processor Standard Contractual Clauses (Module 2) and requires equivalent data-protection duties from subprocessors; PostHog remains responsible for their performance. EU hosting does not mean that support or operational access can never occur from outside the EU/EEA.

11. Retention

I retain data only as long as reasonably necessary for the purposes described above:

• Account-linked data is retained while your account is active.
• After account deletion, account data, public comments, and synchronized app state are deleted without undue delay unless limited retention is required for legal obligations, security, fraud prevention, dispute resolution, or establishing, exercising, or defending legal claims.
• Data in backups is removed as backups are overwritten through the normal backup cycle and is not restored to active systems except for disaster recovery, subject to applicable legal requirements.
• Minimal security and operational logs are retained only while needed for security, abuse prevention, troubleshooting, and legal obligations.
• Terms/EULA acceptance evidence is retained only while needed to establish the applicable agreement or resolve a legal claim.
• On-device data remains until you use an available reset or deletion control, clear app data, or remove the app, subject to synchronization already completed.
• PostHog and RevenueCat records follow the provider and verified controller-deletion processes described below. Apple retains App Store transaction records under its own policy and legal obligations.

Retention may vary because the criterion depends on account status, feature use, security needs, provider behavior, backup replacement, and applicable law. I do not use an unsupported fixed retention period where those facts control the appropriate duration.

12. Account Deletion and Privacy Requests

If you created a ZenThoughts account, you may initiate permanent account deletion from the account settings in the app. All users with accounts may use this control regardless of location. Account deletion removes the account and associated personal data controlled by ZenThoughts, including public comments, except for narrowly limited information that must lawfully be retained. When applicable, ZenThoughts also requests revocation of the Sign in with Apple credential associated with the deleted account.

Before deleting an account, cancel any Apple subscription you no longer want. Account deletion does not cancel billing, and deleting an account immediately may remove access to features while Apple billing continues.

You may also email zenthoughtsapp@gmail.com to request access, correction, deletion, restriction, portability, or objection where applicable. Describe the request and the account or device context needed to locate the data. I may ask for information reasonably necessary to verify that you are the relevant user and to prevent unauthorized disclosure or deletion.

Requests are handled without undue delay and within the period required by applicable law. A request may be limited or refused only where the law permits, such as when identity cannot reasonably be verified, the request adversely affects another person’s rights, or retention is legally required. I will explain an applicable refusal unless the law prevents that explanation.

13. Provider Data Requests

ZenThoughts provides one Contact Privacy Support action. It opens an email addressed to zenthoughtsapp@gmail.com and prefills the random PostHog analytics ID and RevenueCat anonymous App User ID currently available on your device. You can review, edit, or cancel the email before sending it. The IDs are not sent to me merely because you open the action.

These IDs help locate pseudonymous provider records without exposing your name, email address, or ZenThoughts server user ID to PostHog or RevenueCat. After verifying the request as reasonably necessary, I will use the providers’ administrative tools or APIs to request deletion of records controlled through those services where applicable.

Deleting a RevenueCat customer record clears that provider record but does not cancel an Apple subscription or delete Apple’s transaction history. If you continue using purchase features, make a new purchase, or restore purchases, RevenueCat may create or restore a customer record so that the entitlement can function. You may make another deletion request when appropriate.

14. Your Regional Rights

EU/EEA and United Kingdom

Where the GDPR or UK GDPR applies, you may have rights to access, correct, erase, restrict, or receive a portable copy of personal data; object to processing based on legitimate interests; withdraw consent; and complain to a supervisory authority. These rights are subject to statutory conditions and exceptions.

You may complain to the State Data Protection Inspectorate of the Republic of Lithuania, another competent EU/EEA supervisory authority, or the competent UK authority.

United States

Depending on your state and whether the relevant law applies to this service, you may have rights to know, access, correct, delete, or obtain a copy of personal data and to appeal certain decisions. Some state privacy statutes apply only when business or processing thresholds are met. This Policy does not claim that every statute applies, but you may contact me and I will respond as required by applicable law.

ZenThoughts does not sell personal data, share it for cross-context behavioral advertising, use it for targeted advertising, or process it for profiling that produces legal or similarly significant effects.

15. Security

I use reasonable technical and organizational measures appropriate to the service, including secure transport, access restrictions, limited provider access, and secure on-device session storage. No transmission or storage system is completely secure, so absolute security cannot be guaranteed.

If a personal-data breach creates a notification obligation, I will notify the competent authority and affected users as required by applicable law.

16. Third-Party Services and Links

ZenThoughts may link to Apple subscription management, authentication providers, service-provider policies, or other external resources. Those services are operated by third parties and their own terms and privacy policies apply. I am not responsible for independent third-party content or practices, except to the extent applicable law makes me responsible for selecting, instructing, or overseeing a processor or otherwise prohibits that limitation.

17. Changes to This Policy

I may update this Policy when the app, providers, processing purposes, legal requirements, or user controls change. The updated document will show a new effective date. Material changes will receive an in-app or other prominent notice where appropriate, and renewed consent will be requested when required by law.

18. Contact

For privacy questions or requests, contact:

• Kanstantsin Ausianovich
• Republic of Lithuania
• zenthoughtsapp@gmail.com