This policy explains what data the Tomber Enceinte app and its website process, why, on what basis and for how long, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act (law no. 78-17 of 6 January 1978).
In short. No account, no ads, no data sold. Your cycle, your tests and your journal stay on your phone, in its encrypted storage: they are never sent to our servers. The questions you ask Pépin are sent without your identity, together with where you are in your cycle, just long enough for the artificial intelligence to write the answer, and we do not keep them. We measure how the app is used without ever knowing your cycle or your health. Payments go through Apple or Google.
1. Data controller
BAUGEY MATHEO, trading as DEVOLIM
248 rue de Bègles, 33800 Bordeaux, France
Company number (SIREN): 948 000 757
Email: contact.tomber-enceinte@devolim.fr
Given the nature and scale of the processing carried out, appointing a data protection officer is not required under Article 37 GDPR. Any request relating to personal data may be sent to the address above.
2. Principles
- No account to create; no email address or phone number requested.
- Your cycle, your tests and your journal stay on your phone.
- No cycle or health data is ever sent to usage measurement tools.
- No advertising, no ad tracking, no advertising identifier collected.
- No data sold, rented or transferred.
3. Data processed
3.1 Data kept on your device
Your period dates, your cycles, your morning check-ins (period, ovulation tests, cervical mucus, temperature, intercourse, mood), your settings and your reminders are stored only on your phone, in its encrypted storage. They are never sent to our servers and we make no online backup of them: we have no access to them. You can export or delete them at any time in the app (Me, My data); uninstalling the app also removes them.
When you share your fertile days with your partner, or create the report for your doctor, you choose the recipient and the app used to send it: this content does not go through our servers.
3.2 Data transmitted
Anonymous identifier. On first launch, the app creates a random technical identifier (Firebase Authentication anonymous sign-in). It contains neither your name, nor your email address, nor your phone number. It is used to link your purchases and to apply the usage limits that protect the service.
Questions to Pépin. With your consent, given at your first question, each question is sent, encrypted and without your identity, together with where you are in your cycle (cycle day, average length, estimated ovulation and test dates) and your 3 previous questions in the conversation, to our server function (Google Cloud Functions, europe-west1 region, in Belgium). The function checks your access, then passes the question to OpenAI, which writes the answer. We keep neither the questions nor the answers. OpenAI does not use them to train its models and may keep these exchanges for up to 30 days for safety reasons (abuse detection) before deleting them. A question may concern your health: do not write your name or anything that could identify you in it.
Question counters. On our servers (Google Cloud, in Europe), only counters are linked to your anonymous identifier: the number of questions asked per minute and per day (deleted automatically), and the number of free questions already used (kept as long as this identifier exists, so the offer stays the same for everyone). To check your Premium access, RevenueCat's answer is kept for 10 minutes at most.
"Write to us" messages. A message you send from the app goes without your name or email, with the app version and, if you gave one, your rating. It is stored on our servers (Google Cloud, in Europe) and deleted automatically after 12 months. Do not include health information.
Usage measurement and stability. Google Analytics for Firebase receives how the app is used: screens shown, buttons tapped and purchases. Firebase Crashlytics receives crash reports (device model, system version, app state at the time of the error). These tools never receive your cycle or health data: not your periods, your tests, your journal or your questions to Pépin.
Service protection. Every request to our servers carries a Firebase App Check attestation (Apple App Attest and DeviceCheck, Google Play Integrity) proving that it comes from the genuine app. We do not keep these attestations.
Purchases. See "Subscriptions and purchases".
Contact. If you email us, we use your address and your message to reply.
3.3 Your consent for health data
Information about your cycle is health data. Before storing it, the app asks for your explicit consent, in accordance with Article 9 GDPR.
4. Legal bases
| Purpose | Legal basis |
|---|---|
| Health data logged in the app and questions to Pépin | Explicit consent (Articles 6(1)(a) and 9(2)(a) GDPR), which can be withdrawn at any time |
| Providing the app and the Premium offer (anonymous identifier, purchases) | Performance of the contract (terms of use and sale) |
| Usage limits, App Check, abuse prevention | Legitimate interest: ensuring the service and its security |
| Usage measurement and crash reports | Legitimate interest: improving the app and fixing errors |
| Replying to your messages | Legitimate interest: answering your requests |
| Keeping purchase records | Legal obligation |
5. Recipients and processors
| Provider | Role | Data concerned |
|---|---|---|
| Google Ireland Limited (Firebase, Google Cloud), Gordon House, Barrow Street, Dublin 4, Ireland | Anonymous sign-in, server function, question counter, App Check, Analytics, Crashlytics | Anonymous identifier, questions passed on (not stored), counter, usage and crash data |
| OpenAI Ireland Ltd (Dublin, Ireland) and OpenAI, L.L.C. (San Francisco, United States) | Writing Pépin's answers | Question asked and where you are in your cycle, without your identity |
| RevenueCat, Inc. (United States) | Subscription and Premium access management | Anonymous identifier, transaction information sent by the store |
| Apple and Google | Sale and payment on their stores, as controllers of their own processing | Your Apple or Google account data |
| OVH SAS, 2 rue Kellermann, 59100 Roubaix, France | Website hosting | Website technical logs |
Each of these providers is contractually required to provide a level of data protection at least equivalent to the one described in this policy.
No data is sold, rented or otherwise transferred to third parties for commercial purposes.
6. Transfers outside the European Union
Some data may be processed in the United States (OpenAI, RevenueCat, and Google for some services). These transfers are covered by the EU-U.S. Data Privacy Framework where the recipient is certified, and otherwise by the standard contractual clauses adopted by the European Commission.
7. Retention periods
| Data | Period |
|---|---|
| Cycle, journal, settings and reminders (on the phone) | Until deleted in the app or the app is uninstalled |
| Pépin's questions and answers (server) | Not kept by us; up to 30 days at OpenAI |
| Question counter (server) | Per minute and per day counters: deleted automatically. Free questions used: as long as the anonymous identifier exists |
| Usage data linked to a device (Analytics) | 2 months |
| Crash reports (Crashlytics) | 90 days |
| Transaction information (RevenueCat) | Duration of the relationship, then legal time limits |
| "Write to us" messages sent from the app | 12 months, then deleted automatically |
| Emails sent to support | 3 years after the last exchange |
8. Advertising and tracking
Tomber Enceinte shows no advertising and does no ad tracking. Your phone's advertising identifier is not collected, and the app does not ask for Apple's tracking permission (App Tracking Transparency), which it does not need.
9. Subscriptions and purchases
Payments are collected by Apple (App Store) or Google (Google Play): the publisher sees neither your identity nor your bank details. RevenueCat, our subscription management provider, receives your anonymous identifier and the transaction information sent by the store (product, dates, country, currency, receipt) in order to unlock your Premium access.
10. Security
Your cycle and journal are stored in your phone's encrypted storage and never leave it. Exchanges with our servers are encrypted (HTTPS), the server only accepts requests from the genuine app (App Check), secret keys stay on the server, usage limits protect the service and access to admin tools is restricted to the publisher.
11. Website
This website sets no cookies and uses no audience measurement tool. Fonts are hosted on our own servers: no request is made to a third party during your visit. The host (OVH) keeps technical logs (IP address, pages requested) for security, for a limited time.
12. Your rights
Under Articles 15 to 22 GDPR, you have the right to access, rectify, erase, restrict, object to and port your data, as well as the right to give instructions concerning your data after your death (Article 85 of the French Data Protection Act). These rights can be exercised by email at contact.tomber-enceinte@devolim.fr. We reply within one month, extendable by two further months for complex requests.
As we do not know your identity and your cycle is not on our servers, your data is exported (portability) and deleted directly from the app: Me, My data. You can withdraw your consent at any time: for Pépin, by turning off "Pépin's AI answers" in Me, My data; for everything else, by deleting your data; withdrawal does not affect what was done before. The question counter linked to your anonymous identifier deletes itself.
13. Complaint to the CNIL
If, after contacting us, you consider that your rights have not been respected, you may lodge a complaint with the French data protection authority: CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or online at cnil.fr.
14. Minimum age
The app is for adults only: 18, or the age of majority in your country if it is higher.
15. Changes
This policy may be amended to reflect legal or technical developments. The last update date appears at the top of this page; substantial changes are notified within the app.
This is a translation provided for convenience. In the event of any discrepancy, the French version prevails.