Privacy Policy

Account information

When you create an account we collect your email address, your name if your sign-in provider shares it, the sign-in method you used (Sign in with Apple, Google, or email), and a user ID we assign. If you use Sign in with Apple and choose to hide your email, we receive an Apple relay address instead. You can also use the app without an email address, in which case your account is tied to your device.

Profile and onboarding answers

If you answer our onboarding questions or fill in your profile, we collect what you provide, which can include your first name, age, sex, height, weight, goals, experience level, timeline, concerns, and how you heard about Protokol.

Health and wellness information you enter

The core of the app is a record you keep for yourself. Depending on the features you use, this can include:

• The compounds in your stack, with the amounts, units, frequency, schedule and dates you enter.
• Dose logs, including the time, amount, site and any notes you add.
• Wellness entries, including mood, side effects and notes.
• Progress photos you choose to upload, with the pose, body weight and notes you attach.

Every amount and schedule in the app is entered by you. Protokol does not calculate or suggest doses.

Protokol AI

When you ask Protokol AI a question, the text of your question and the relevant context are sent to our AI provider to generate an answer (see section 5). For security, abuse prevention and cost control, our servers log technical details of each request, such as the time, a hashed version of your IP address, the number of tokens used and whether it succeeded.

Purchases

Subscriptions and lifetime purchases are processed by Apple. We do not receive your payment card details. Through our subscription provider we receive information about your purchase, such as the product, price, currency, whether you are in a free trial, renewal dates and whether auto-renew is on. If you redeem a partner or promo code, we record the code and when it was redeemed.

Device, usage and diagnostic information

When you use the app we automatically collect information such as your device model, iOS version, app version, language, time zone, IP address, crash reports, and in-app events such as which screens you open and which features you use. If you allow tracking under Apple's App Tracking Transparency, we also collect your device's advertising identifier (IDFA).

Device permissions

The app may ask for permission to send notifications (for dose reminders) and to access your camera or photo library (only if you add progress photos). You control these in iOS Settings, and you can use the app without granting them.

Website visits

When you visit protokolapp.com we record a pseudonymous visit event: the page, the referring site, any campaign tags in the link, your approximate country, and which app's in-app browser you arrived from if any. Instead of storing your IP address, we combine it with your browser's user agent and store a one-way hash of the two. The website does not set advertising cookies or load advertising pixels. Our hosting provider also keeps standard server logs.

Communications

If you email us, join a waitlist or sign up for updates, we collect your email address, your name if given, and the content of your messages. For emails we send, we collect delivery information and whether links were opened or clicked.

We use information to:

• Provide the app: create your account, store and sync your stack, logs, entries and photos, send the reminders you set up, and run Protokol AI.
• Manage subscriptions, free trials and codes.
• Respond to support requests and send service messages, such as changes to the app or to these terms.
• Send marketing emails about Protokol. You can unsubscribe at any time using the link in the email or by contacting us.
• Understand how the app and website are used so we can fix bugs and improve features.
• Measure how well our advertising on Meta, TikTok and Apple Search Ads works, as described in section 4.
• Keep the Services secure, prevent fraud and abuse, and enforce our Terms of Use.
• Comply with the law and respond to lawful requests.

We do not use your health and wellness information, progress photos or profile answers to target advertising, and we do not use them to make decisions that have legal or similarly significant effects on you.

We do not sell your personal information for money. We share information only in the following ways.

Service providers

We use companies that process information on our behalf, under contracts that limit how they can use it:

• Supabase: database, authentication and file storage for your account, logs and photos.
• Apple: Sign in with Apple, payments, push notifications, and Apple Search Ads attribution.
• Google: Sign in with Google, if you choose it.
• RevenueCat: subscription and purchase management.
• PostHog: product analytics for the app and website.
• Anthropic: the AI model behind Protokol AI.
• Resend: sending account and marketing emails.
• Vercel: hosting for protokolapp.com.

Advertising partners

If you allow tracking, Meta and TikTok receive information as described in section 4. They receive your advertising identifier and events such as app installs, sign-ups, trial starts and purchases. They do not receive your dose logs, wellness entries, progress photos or profile answers.

Partners and promo codes

If you redeem a code associated with a partner, we may tell that partner that their code was used and whether a purchase followed, so we can pay any commission owed. We do not give partners your name, email address or health information.

Legal and safety reasons

We may disclose information if we believe in good faith that it is required by law, subpoena or court order, or needed to protect the rights, property or safety of Protokol, our users or others.

Business transfers

If we are involved in a merger, acquisition, financing or sale of assets, information may be transferred as part of that transaction. We will require the recipient to honor this Privacy Policy.

With your permission

We may share information for other purposes if you ask us to or agree to it.

When you first open the app, iOS asks whether Protokol may track your activity across other companies' apps and websites. This is Apple's App Tracking Transparency prompt.

• If you allow it, the Meta and TikTok software in our app can access your device's advertising identifier and send events such as installs, sign-ups, trial starts and purchases to those companies. This tells us which ads led people to Protokol. Meta and TikTok handle that information under their own privacy policies.
• If you ask the app not to track, we do not access your advertising identifier and do not share it with Meta or TikTok.
• Apple Search Ads attribution uses Apple's own attribution service, which tells us whether an install came from a Search Ads campaign without using your advertising identifier.

You can change your choice at any time in iOS Settings under Privacy & Security, then Tracking.

Under some U.S. state laws, sharing an advertising identifier and app events with ad platforms can count as a "sale" or "sharing" of personal information, or as "targeted advertising." Declining or turning off tracking in iOS is how you opt out in the app. You can also email support@protokolapp.net and we will honor the request for your account. Our website does not use advertising pixels, so there is nothing to opt out of there, and we treat a Global Privacy Control signal as an opt-out request.

Protokol AI is powered by Anthropic's Claude models. Your questions and the context needed to answer them are sent to Anthropic for processing. Under its commercial terms, Anthropic does not use this data to train its models.

Protokol AI is an educational research assistant. It cites sources, does not discuss doses, amounts or schedules, and is not medical advice. Please do not enter information you do not want processed this way, such as other people's personal details.

We keep your account information and the content you create for as long as your account exists.

When you delete your account in the app, we delete your account, profile, stack, logs, wellness entries and photos from our active systems. Copies in routine backups are overwritten on their normal schedule, generally within 30 days. We may keep a limited record that a deletion happened, with a hashed IP address, for security and fraud prevention.

We may keep some information longer where we need it to comply with the law, resolve disputes, prevent fraud or enforce our terms. For example, purchase records may be kept for tax and accounting purposes, and if you unsubscribe from emails we keep your address on a suppression list so we do not email you again.

Aggregated or de-identified information that can no longer reasonably be linked to you may be kept and used without limit.

• Delete your account: use the delete account option in the app's settings. This deletes your data as described in section 6. Deleting your account does not cancel an Apple subscription. Cancel that in your Apple account settings.
• Edit your information: update your profile, stack and logs in the app at any time.
• Tracking: allow or deny tracking in iOS Settings under Privacy & Security, then Tracking.
• Notifications and photos: turn these permissions on or off in iOS Settings.
• Marketing email: click unsubscribe in any marketing email, or email us. We will still send service messages about your account.

Depending on where you live, you may have the right to:

• Know what personal information we have about you and get a copy of it in a portable format.
• Correct inaccurate information.
• Delete your information.
• Opt out of the sale or sharing of personal information, targeted advertising, and profiling.
• Limit the use of sensitive personal information. We only use sensitive information to provide the Services you ask for, so this right is already reflected in how we operate.
• Withdraw consent you have given, without affecting processing that happened before.
• Not be discriminated against for exercising these rights.

To make a request, email support@protokolapp.net with the subject line "Privacy Request" from the email address on your account. If your account has no email, tell us that and we will explain how to verify it from your device. We will verify your request before acting on it and respond within the time required by law, generally 45 days. You may use an authorized agent, who must provide proof of their authority.

If we deny your request, you can appeal by replying to our response with the subject line "Privacy Appeal." We will respond in writing within the time required by law. If you are not satisfied, you may contact your state attorney general.

California residents

In the past 12 months we have collected the following categories of personal information, for the purposes described in section 2: identifiers (name, email, user ID, IP address, advertising identifier); customer records and commercial information (purchase and subscription history); characteristics such as age and sex; internet or other electronic activity (app and website usage); approximate location derived from IP address; photos you upload; inferences from onboarding answers such as goals and experience level; and sensitive personal information (health information and account login). We collect this from you, from your device, and from Apple, Google and our subscription provider.

We disclose identifiers, commercial information and internet activity to the service providers listed in section 3. With your permission under App Tracking Transparency, we share identifiers and app activity with Meta and TikTok for ad measurement, which may be considered "sharing" under California law. We do not sell or share sensitive personal information, and we do not knowingly sell or share the personal information of anyone under 16.

California's "Shine the Light" law lets California residents ask once a year about personal information disclosed to third parties for their own direct marketing. We do not make those disclosures.

Users in the EEA, UK and Switzerland

Protokol is operated from the United States and your information is processed there. We rely on these legal bases: performance of our contract with you (to provide the app), your explicit consent (for the health information you choose to record and for tracking), our legitimate interests (security, analytics and improving the Services, balanced against your rights), and legal obligations. You also have the right to object to processing based on legitimate interests and to complain to your local data protection authority.

This section is our consumer health data privacy policy for purposes of the Washington My Health My Data Act, Nevada's consumer health data law, Connecticut's data privacy law and similar laws. It applies to consumer health data we collect from anyone covered by those laws.

• What we collect: the compounds, amounts, schedules, dose logs and sites, wellness entries (mood and side effects), progress photos, body weight, height, age, sex, goals and concerns you enter, plus Protokol AI questions that relate to your health.
• Where it comes from: directly from you, when you enter it in the app.
• Why we collect and use it: only to provide the features you use: storing and syncing your records, reminders, your history, and Protokol AI answers. We do not use it for advertising.
• Who we share it with: only the service providers that store and process it for us, which are Supabase (storage), Anthropic (for AI questions you ask) and PostHog (limited feature-usage events, not the content of your logs). We do not sell consumer health data, and we do not share it with advertising platforms or partners.
• Consent: we collect this data when you choose to enter it. You can stop at any time and delete what you have entered.
• Your rights: you can confirm whether we collect your consumer health data, access it, get a list of the third parties and affiliates we share it with, withdraw consent, and delete it. Deleting your account in the app deletes it. For anything else, email support@protokolapp.net with the subject line "Health Data Request."
• Appeals: if we decline your request you can appeal by replying to our response. If your appeal is denied, Washington residents may contact the Washington State Attorney General, and residents of other states may contact their attorney general.

We use reasonable technical and organizational measures to protect your information, including encryption in transit, access controls, and database rules that limit each account to its own data. No system is completely secure, so we cannot guarantee that information will never be accessed without authorization. If we learn of a breach that affects you, we will notify you as required by law.

Protokol is only for people who are 18 or older. We do not knowingly collect information from anyone under 18. If we learn that we have, we will delete the account and its data. If you believe a minor is using Protokol, email support@protokolapp.net.

We may update this Privacy Policy. When we do, we will change the effective date at the top. If a change is material, we will tell you in the app or by email before it takes effect. If a change would let us use health information in a materially different way, we will ask for your consent first.

Email: support@protokolapp.net

Mail: Cisco & LeChau LLC, 7932 Dunbarton Ave, Los Angeles, CA 90045, United States