Privacy Policy

Zeitarc is based outside the European Union. Under GDPR Article 27(2)(a), a representative in the EU is not required where processing is occasional, does not include large-scale processing of special categories of data, and is unlikely to result in a risk to the rights and freedoms of data subjects.

We believe this exemption applies to Zeitarc because:

• EU-hosted infrastructure: All personal data is stored on infrastructure located entirely within the EU (Germany). While our team in Pakistan may occasionally access this data for limited operational purposes such as customer support and maintenance, such access is occasional and restricted in scope.
• Limited special category data: Any processing of special category data (such as optional health milestones) is limited in scope, voluntarily provided by users, and is not conducted on a large scale.
• Low risk: The nature, context, and scope of our processing is unlikely to result in a risk to the rights and freedoms of data subjects, given the technical and organisational safeguards we have in place.

We keep this assessment under regular review. Should our processing activities change in nature or scale, we will appoint an EU representative and update this policy accordingly. In the meantime, you may contact us directly at privacy@zeitarc.com for any data protection matters.

When you create an account, we collect:

• Email address - Required for account creation, authentication, and communication
• Full name - Provided during registration
• Username - Chosen by you for identification within the App
• Profile photograph - Optional, uploaded by you
• Authentication tokens - Secure session tokens for login (we use passwordless one-time login codes sent to your email; we do not store passwords)

Content you voluntarily add to your timelines:

• Photographs and media files - Images and videos you upload
• Timeline entries - Text descriptions, dates, titles, and notes
• Milestone data - Birth information, growth measurements, vaccination records
• Names and biographical information - Names of children, pets, and family members

Automatically collected when you use the App:

• Device information - Device type, operating system, and version
• App version - Version of Zeitarc installed
• IP address - Collected for security and fraud prevention
• Crash reports and error logs - Collected via Sentry for error monitoring (technical data only, no personal content)

We use PostHog, a privacy-focused analytics platform, to collect anonymous usage data including:

• Features used - Which App features and screens you interact with
• Navigation flows - How you move through the App
• Performance metrics - App load times and responsiveness

Opt-out available: You can disable analytics at any time via Settings > Privacy & Data > Analytics toggle. When disabled, PostHog is fully deactivated and no usage data is collected or transmitted from your device.

If you choose to sign in with Google, we receive:

• Google account email - Your primary Google email address
• Google profile name - Your display name from Google
• Google profile picture - If available and permissions granted

We only receive data you authorize Google to share. We do not access your Google contacts, calendars, or other Google services.

Where we rely on legitimate interests, we have conducted a balancing test to ensure our interests do not override your fundamental rights:

• Security: Our interest in preventing fraud and unauthorized access is balanced against minimal privacy impact of technical data collection
• Improvement: Our interest in fixing bugs and improving the App uses anonymized/aggregated data where possible

You have the right to object to processing based on legitimate interests. See Section 8 for how to exercise this right.

When you create an account, you explicitly consent to our Terms of Service and this Privacy Policy by checking a consent checkbox. Your consent is recorded with a version number so we can track which version of our policies you agreed to.

When we make material changes to our Terms of Service or Privacy Policy, we will ask you to review and re-accept them before continuing to use the App. You will be shown a consent prompt on your next login after any policy update. This ensures you are always informed of and agree to the current version of our policies.

You can disable analytics data collection at any time by navigating to Settings > Privacy & Data and toggling off the Analytics switch. When analytics are disabled, PostHog is fully deactivated and no usage data is collected or transmitted from your device. Error tracking via Sentry remains active for crash reports to ensure App stability.

You may withdraw consent for any consent-based processing at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent for the core service, you may delete your account.

If you choose to record vaccination records, growth measurements, or health milestones, this may constitute health data. We process this data based on:

• Explicit consent (Art. 9(2)(a)) - You actively choose to enter this data
• Data manifestly made public by you (Art. 9(2)(e)) - If you choose to share it

You are never required to enter health data. All health-related fields are optional.

While Zeitarc stores information about children (names, birth dates, photos), this data is provided and controlled by parents/guardians - the actual users of the App. Parents retain full control over what information is recorded and can delete it at any time.

We do not process biometric data. Photographs are stored as regular image files and are not used for facial recognition or biometric identification.

We may share your data with the following categories of recipients:

Your data is primarily stored on servers located within the European Union (Germany). Where data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place:

• Adequacy decisions: Transfers to countries with EU adequacy decisions
• Standard Contractual Clauses (SCCs): EU-approved contract terms with recipients
• Supplementary measures: Additional technical and organizational safeguards where required

All personal data is stored on infrastructure located entirely within the European Union (Germany). Zeitarc is headquartered in Islamabad, Pakistan, which does not currently have an EU adequacy decision. Our team in Pakistan may occasionally access personal data for limited operational purposes. Where this occurs, we rely on the following safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Encryption in transit (TLS 1.2+) and at rest for all personal data
• Strict access controls limiting data access to authorised personnel on a need-to-know basis
• Confidentiality obligations for all team members with data access
• Occasional and limited access restricted to specific operational needs such as customer support and system maintenance, not routine or large-scale

You may request a copy of the safeguards in place by contacting us at privacy@zeitarc.com.

We do not sell, rent, or trade your personal data to third parties for marketing or any other purpose. Your family memories are not a product.

We may disclose your data if required by law:

• To comply with legal process or government requests
• To protect our rights, privacy, safety, or property
• To enforce our Terms of Service
• In connection with a merger, acquisition, or sale of assets (with notice to you)

When you request account deletion:

• Your account enters a 30-day grace period during which your data is preserved but your account is marked for deletion
• During this grace period, you can restore your account by logging back in and choosing "Restore My Account"
• After 30 days, your account and all associated data are permanently and irreversibly deleted from our active systems
• Backup copies are purged within 30 additional days
• Some anonymized, aggregated data may be retained for statistical analysis

To delete your account, use the "Delete Account" option in Settings > Privacy & Data, or email privacy@zeitarc.com.

You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data. You can request your data by using the "Request My Data" option in Settings > Privacy & Data, or by emailing us. This includes information about:

• The purposes of processing
• The categories of data processed
• Recipients of your data
• Retention periods
• The source of data (if not collected from you)

You can correct inaccurate personal data or complete incomplete data. You can update most data directly in the App, or contact us for assistance.

You can request deletion of your personal data. Use the "Delete Account" option in Settings > Privacy & Data to initiate a 30-day deletion process with a grace period for recovery. You may also email us. Deletion applies when:

• The data is no longer necessary for its original purpose
• You withdraw consent (where consent was the legal basis)
• You object to processing and there are no overriding legitimate grounds
• The data was unlawfully processed
• Deletion is required by law

Note: We may retain data where we have a legal obligation or legitimate need (e.g., legal claims, security records).

You can request that we limit how we use your data when:

• You contest the accuracy of the data (while we verify)
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data but you need it for legal claims
• You have objected to processing (pending verification)

You have the right to receive your personal data in a structured, commonly used, machine-readable format (e.g., JSON, CSV). This applies to data you provided to us and processed based on consent or contract.

Contact us at privacy@zeitarc.com to request a full data export.

You can object to processing based on legitimate interests or for direct marketing purposes. For legitimate interests, we will stop processing unless we demonstrate compelling legitimate grounds that override your interests.

Note: We do not use your data for direct marketing or profiling.

We do not make any decisions based solely on automated processing that produce legal or similarly significant effects on you. No profiling or automated decision-making is used in Zeitarc.

Where processing is based on consent, you can withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. For analytics, use the opt-out toggle in Settings > Privacy & Data. For the core service, you may delete your account.

To exercise any of these rights:

• Email: privacy@zeitarc.com
• Use in-App features: "Request My Data" and "Delete Account" in Settings > Privacy & Data
• Include your account email address for verification
• Specify which right(s) you wish to exercise
• We may request additional information to verify your identity

There is no fee for exercising your rights, unless requests are manifestly unfounded or excessive.

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher
• Encryption at rest: Sensitive data is encrypted on our servers
• Passwordless authentication: We use secure one-time login codes (OTP) sent to your email instead of stored passwords, eliminating password-related vulnerabilities
• Access controls: Strict role-based access to production systems on a need-to-know basis
• Secure session management: JWT tokens with appropriate expiration
• Regular updates: Security patches applied promptly

• Limited employee access to personal data (need-to-know basis)
• Security awareness and data protection practices
• Incident response procedures
• Regular security assessments

In the event of a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority within 72 hours (where required by GDPR Article 33)
• Notify affected users without undue delay if there is high risk to their rights and freedoms (GDPR Article 34)
• Document the breach and remedial actions taken

Zeitarc is intended for use by adults (parents, guardians, and caregivers) aged 16 years or older. We do not knowingly collect personal data directly from children under 16.

While the App is designed to help document children's lives, we recognize that this data requires special protection:

• Only parents/guardians control what information is entered
• Children's data is not shared with third parties for marketing
• Parents can delete all data about their children at any time
• We do not use children's data for profiling or analytics

As a parent using Zeitarc, you are the data controller for information you choose to enter about your children. We act as a data processor for this content, storing it securely on your behalf.

If we become aware that we have collected personal data from a child under 16 without parental consent, we will delete that data promptly. If you believe a child has provided us data directly, please contact us immediately.

The Zeitarc mobile app does not use cookies. We use the following local storage mechanisms:

• Secure storage: Authentication tokens (essential for login)
• Local preferences: App settings and user preferences
• Cache: Temporary storage for performance (images, data)

Our website uses only essential cookies necessary for the website to function. We do not use:

• Advertising or tracking cookies
• Third-party analytics cookies
• Social media tracking pixels

We honor Do Not Track browser signals. We do not track users across third-party websites or apps.

We will notify you of material changes by:

• Posting the updated policy with a new "Last updated" date
• Displaying a notice in the App for significant changes
• Requiring re-consent through our consent versioning system for material changes

For material changes, you will be asked to re-accept the updated policy before continuing to use the App. If you do not agree with changes, you should stop using the App and delete your account.

For any questions or requests regarding this Privacy Policy or your data:

• Standard requests: Within 1 month
• Complex requests: Up to 3 months (with notification within the first month)
• Urgent security matters: Within 72 hours

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a supervisory authority. We encourage you to contact us first so we can address your concerns.

You may contact your local Data Protection Authority (DPA). A list of EU DPAs is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en