This policy explains what data Amicacciu handles, how, and your rights. It mirrors the policy available inside the app.
Amicacciu is operated by SDR Digital Solutions, a sole proprietorship registered in the Netherlands (KVK 42080349). Registered address: Frankenslag 67, 2582HD The Hague, Netherlands. SDR Digital Solutions is the data controller responsible for your personal data under GDPR. Contact: [email protected].
Competent supervisory authority: Autoriteit Persoonsgegevens (AP), the Dutch Data Protection Authority. Website: autoriteitpersoonsgegevens.nl.
The categories of personal data Amicacciu handles are summarised here and described in full in the lettered paragraphs below.
a) Locally stored data: Your daily check-ins, mood scores, stress and sleep ratings, activity logs, domain selections, free-text notes, and full check-in history are stored in your browser's localStorage on this device. Amicacciu does not transmit this data to its own servers. However, when you use an AI feature, this locally stored data — including prior check-in history, notes, and inferred patterns — is transmitted to Anthropic as described in section 2b. Local storage is therefore not a guarantee that data will never leave your device.
b) Data transmitted to Anthropic, PBC for AI processing: When you use any AI feature — daily check-in response, mid-day update, pattern analysis, perspective check, reframe, chat, weekly reflection, or message check — the following personal data is transmitted to Anthropic, PBC (USA) solely to generate a response:
Amicacciu does not log, store, or retain this data on its own servers after the response is delivered. Note: requests are routed through Cloudflare's edge infrastructure, which may process data in transit in accordance with Cloudflare's Data Processing Addendum. Anthropic processes this data as a sub-processor under a Data Processing Agreement. Anthropic's own data practices are governed by their Privacy Policy at anthropic.com/privacy.
Amicacciu does not use your personal data to train any AI model. Anthropic's policy on the use of data for model training is available at anthropic.com/privacy.
c) Subscription email: Amicacciu does not require or maintain user accounts. If you subscribe to Amicacciu Plus via the web, or restore an existing subscription, you provide an email address. This email is stored locally on your device. Each time the app starts, if a subscription email is stored, it is sent to Amicacciu's server function and used solely to look up whether your subscription is active with the payment provider. The server function does not store or log it. Subscriptions purchased through the Apple App Store do not require an email at all: Apple and RevenueCat identify your subscription without one.
d) Payment and subscription data: If you subscribe to Amicacciu Plus, payment is handled differently depending on where you purchased:
Purchases made through the Apple App Store (iOS app): Payment is processed by Apple Inc. under your Apple ID. Amicacciu never receives your card details or billing address. Apple acts as an independent data controller for payment data under its own privacy policy (apple.com/legal/privacy). To manage your subscription entitlement, Amicacciu uses RevenueCat, Inc., which processes an anonymous app user identifier, purchase receipts, and subscription status on our behalf as a data processor. RevenueCat does not receive your name, email address, or payment details.
Purchases made through the web (amicacciu.com): Payment is processed by Stripe, Inc. Amicacciu does not store your card details. Stripe processes payment data as an independent data controller under their own privacy policy.
All processing of your personal data falls under one of the following legal bases:
The data described in Section 2 falls under those bases as follows:
Amicacciu is a wellbeing app. You may voluntarily enter information that constitutes health-related or sensitive personal data under GDPR Article 9, including mood, stress, illness flags, and free-text descriptions of personal situations. This information is self-reported — your own subjective ratings on sliders and free-text notes — not clinically measured, physiologically recorded, biometric, or medical-device data; Amicacciu collects no sensor or device measurements. It is nonetheless treated as special category data, and processed only on the basis of your explicit consent. This data is stored locally on your device. When you use an AI feature, this data — including health indicators and free-text notes — is transmitted to Anthropic, PBC as part of the AI context described in Section 2b. You provide this data voluntarily. The legal basis for processing special category data is your explicit consent (GDPR Article 9(2)(a)), given at onboarding and reaffirmed each time you use an AI feature. You may withdraw consent at any time by turning AI features off in Settings.
Anthropic, PBC is based in the United States. Transmission of AI feature inputs to Anthropic constitutes an international transfer of personal data outside the European Economic Area (EEA). This transfer is governed by Standard Contractual Clauses (SCCs) Module Two (controller to processor), incorporated into Anthropic's Data Processing Addendum (effective February 24, 2025), available at anthropic.com/legal/data-processing-addendum. Governing law for the SCCs is Ireland. By using AI features, you acknowledge this transfer.
RevenueCat, Stripe, Apple, and Cloudflare are also United States-based providers. Transfers of personal data to these providers are safeguarded by Standard Contractual Clauses and/or the EU–US Data Privacy Framework, as set out in each provider's data processing terms.
The competent supervisory authority for SDR Digital Solutions is the Autoriteit Persoonsgegevens (AP), the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).
Local data: Stored on your device until you clear your browser data or use the in-app reset function. Amicacciu has no control over or access to this data.
AI-processed inputs: Amicacciu does not store AI inputs on its own servers after the response is delivered. Requests are routed via Cloudflare's edge infrastructure, which may process data in transit per their Data Processing Addendum. Anthropic's own retention policies apply to processing on their systems — see anthropic.com/privacy.
Subscription email: Stored locally on your device until you clear app data. It is sent to Amicacciu's server function each time the app starts, solely to verify your subscription status, and is not stored or logged there. Stripe retains it as part of your customer record under its own policies.
Payment records: For App Store purchases, transaction records are held by Apple; Amicacciu retains only subscription status records (via RevenueCat) and payout and accounting records. For web purchases via Stripe, and for all payout and accounting records, the following applies: records are retained for 7 years from the date of the transaction. This retention is mandatory under Dutch tax law (Article 52, Algemene wet inzake rijksbelastingen) and applicable EU financial regulations, which require businesses to maintain financial records for this period regardless of subscription status. This data is retained solely for legal compliance and is not used for any commercial purpose. This retention obligation overrides any erasure request under GDPR Article 17(3)(b) — see Section 7.
If you are in the EU/EEA, the rights below apply to you under the GDPR. If you are outside the EU/EEA, we extend the same rights to you as a matter of policy, together with the additional right noted at the end of this section. To exercise any right, contact [email protected] — we do not require you to hold an account, so please write from the email address you used to subscribe where the request concerns a subscription.
To exercise any right, contact: [email protected]. We will acknowledge your request within 5 business days and respond in full within 30 days. If we cannot fulfil a request, we will explain why in writing.
Amicacciu may share your personal information with the following categories of recipient, and no others:
Service providers: third-party vendors who perform services for us, such as hosting, AI response generation, subscription management and payment processing. These are our sub-processors and independent controllers, listed below.
Professional advisers: lawyers, auditors, accountants and insurers, where necessary and only to the extent required for them to advise us. In practice this is limited to payment and accounting records.
Legal authorities: regulators, courts or law enforcement, where we are required to disclose by law or where disclosure is necessary to establish, exercise or defend legal claims. Your journal data is stored on your device and is not in our possession, so we cannot disclose it.
US-specific disclosure: We do not "sell" your personal information for monetary compensation, and we do not share it for cross-contextual behavioural advertising. Amicacciu contains no advertising software and no advertising partners.
Amicacciu uses the following sub-processors:
The following parties process data as independent data controllers, not sub-processors:
You have the right to object to any new sub-processor added by Anthropic within 15 days of notice, per the Anthropic DPA Section C.3.
All data transmitted between your device and Amicacciu's infrastructure, and between Amicacciu's infrastructure and sub-processors, is encrypted in transit using TLS 1.2 or higher, enforced by Cloudflare's edge network. Data stored locally on your device is subject to your device's own operating system security controls. Amicacciu does not operate its own servers storing your personal data and therefore does not hold encryption keys to your journal data. Access to payment and subscription data held by Apple, Stripe, and RevenueCat is governed by those providers' own security programmes, details of which are available in their respective security documentation.
Amicacciu uses browser localStorage and IndexedDB to store your journal data locally on this device. IndexedDB serves as a resilient backup that allows data recovery if localStorage is cleared. No advertising cookies are set. No third-party tracking or advertising cookies are used.
Amicacciu is not intended for use by persons under the age of 16. We do not knowingly collect data from minors. If you believe a minor has used this service, contact [email protected].
We may update this policy. Material changes will be notified via the app. The current version is always available in the About section. Last updated: 7 August 2026.
Amicacciu Plus is a recurring subscription billed monthly or annually. Cancellation and refunds work differently depending on where you purchased.
Cancellation: Your subscription is managed entirely by Apple. To cancel, open Settings on your iPhone or iPad, tap your name, tap Subscriptions, select Amicacciu, and tap Cancel Subscription. Amicacciu cannot cancel an App Store subscription on your behalf. Cancellation takes effect at the end of the current paid billing period; you retain full Plus access until that date.
Free trial: If your subscription began with a free trial, you will not be charged if you cancel at least 24 hours before the trial ends. If you do not cancel, the subscription converts automatically to a paid subscription at the price shown at purchase.
Refunds: Refunds for App Store purchases are granted or declined by Apple, not by Amicacciu. To request a refund, visit reportaproblem.apple.com and sign in with your Apple ID, or contact Apple Support. Amicacciu has no ability to issue refunds for App Store transactions.
Right of withdrawal (EU): For purchases made through the App Store, your statutory 14-day right of withdrawal under Directive 2011/83/EU is exercised through Apple's refund process described above, in accordance with Apple's Media Services Terms and Conditions.
Cancellation: You may cancel at any time via the Manage Subscription link in the About screen, or by contacting [email protected]. Cancellation takes effect at the end of the current paid billing period. You retain full Plus access until that date. No further charges are made after cancellation.
Right of withdrawal (EU Consumer Rights Directive 2011/83/EU): As a consumer in the EU/EEA, you have the right to withdraw from a digital service contract within 14 days of purchase without giving a reason, provided the service has not yet commenced. By subscribing to Amicacciu Plus and immediately accessing AI features, you expressly consent to the service commencing before the 14-day withdrawal period expires, and acknowledge that your right of withdrawal is thereby waived once the service has commenced, in accordance with Article 16(m) of Directive 2011/83/EU.
Refunds: If you cancel within 14 days of your first subscription payment and have not used any Plus features, you may request a full refund by contacting [email protected] within that period. Refunds for subsequent billing periods are not provided except where required by applicable law. Partial-period refunds are not issued.
Annual subscriptions: Cancellation stops renewal at the end of the annual period. No pro-rata refund is issued for unused months except where required by applicable law.
Data on cancellation: Your journal data is stored locally on your device and is not affected by cancellation. Cancellation does not delete your data. If you wish to delete your data, use the in-app reset function; for deletion of your Stripe customer record, contact [email protected].
Data controller contact: [email protected]
You have the right to lodge a complaint with your national supervisory authority. In the Netherlands: Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).
Amicacciu is operated by SDR Digital Solutions (KVK 42080349), The Hague, Netherlands. Contact: [email protected]