There is no account
The app has no sign-up and no login. We never receive your name, your email address or your payment details. Purchases are handled by Apple, and Apple tells us only that a subscription exists, not who bought it.
What stays on your phone
Your questionnaire answers, the profile calculated from them, the countries you compare, the role you read advice in, and your conversation with the Coach are stored on your device. They are not uploaded, and deleting the app deletes them.
What leaves your phone, and when
- When you ask the Coach a question: To answer it, we send your question, recent conversation history, and profile context (such as your dimension score bands and role) to our Coach service on Google Cloud in Belgium, and to Google's Gemini model on Google Cloud in the European Union. We do not store your questions or answers. Google processes them strictly under Google Cloud's terms and does not use them to train its AI models. Transient logging of prompts and responses may be maintained by Google Cloud for up to 30 days solely for safety, abuse monitoring, and operational integrity, after which it is automatically deleted.
- An install identifier: The first time the Coach is used, the app creates a random identifier and keeps it in the device keychain. It lets our service count the free messages belonging to one installation. It is random, it is not derived from your device or your Apple Account, and it tells us nothing about you.
- Your subscription identifier, if you subscribe: Apple gives the app a signed receipt. Our service verifies it and keeps only the subscription identifier, which is what your monthly message count is stored against.
- Message counters: We keep the number of messages and the amount of model usage for each installation or subscription, in Google Cloud's database in the European Union. They exist to enforce the free-message limit and the monthly allowance, and to stop runaway costs.
- A security check: Each request carries an attestation from Apple's App Attest service, through Firebase App Check, proving that it came from a genuine installation of this app and not from a script. It is used for security only.
What we never do
We do not track you. The app contains no advertising, no analytics and no third-party tracking code of any kind. We do not sell or share your information, and we do not combine anything from the app with data from other apps or websites.
International Data Transfers
While our primary Coach service and database run on Google Cloud servers located within the European Union, data processing by our third-party infrastructure providers (Google Cloud and Apple) may involve limited administrative or operational transfers outside the European Economic Area (EEA). Such transfers are safeguarded under the European Commission’s Standard Contractual Clauses (SCCs) and Data Privacy Framework frameworks to ensure your data receives EU-equivalent protection.
Other connections the app makes
The app fetches our published articles from news.theculturefactor.com, and opens links in your browser when you tap them. Country data, the questionnaire and the offline articles ship inside the app and need no connection.
Why we are allowed to process this
Answering your questions is what you asked the app to do, so that processing is necessary to provide the service you chose. Keeping the security check and the message counters rests on our legitimate interest in preventing abuse and controlling the cost of a service we provide at a fixed price.
How long we keep it
We keep the counters for as long as the installation or subscription is in use, and delete them on request. We hold nothing else about you.
Your rights
For any data protection inquiries, you can reach our team or data protection contact directly at privacy@theculturefactor.com. You can ask us what data we hold, request its deletion, or object to processing by emailing privacy@theculturefactor.com. Because all server-side records (message usage counters) are attached only to a random installation identifier stored in your device keychain — and not to your personal identity — uninstalling the app automatically deletes your local data and severs any link to our server records, fulfilling your right to erasure directly.
You may also complain to your data protection authority. In Finland that is the Office of the Data Protection Ombudsman.
Children
The app is meant for adults at work and is not directed at children.
Changes
If this policy changes, the date above changes with it, and material changes will be announced in the app.