LEGAL · PRIVACY

Privacy policy.

We sell a coach, not your data. This page explains exactly what we collect, why, where it lives, and how you delete it. Written for humans, reviewed by lawyers.

EFFECTIVE 28 MAY 2026 · v2.4 · ENGLISH
§ 01

Who we are.

Ihmi Oy is a Finnish private company, registered in Helsinki, building a private AI performance coach for the App Store. We are the data controller for the personal data described below.

You can reach our data protection officer at dpo@ihmi.app for anything in this document.

§ 02

What we collect.

We only collect what the coach needs to work, and we say it out loud:

  • —Account: name, email, role, country, hashed password.
  • —Subscription: Apple In-App Purchase receipt, plan, renewal status. We never see card numbers.
  • —Health & training: anything you opt to sync from Apple Health, Oura, Whoop, Strava, Garmin. Heart rate variability, sleep stages, training load, steps, weight, workouts.
  • —Coach interactions: your journal entries, voice notes, chat with the coach. End-to-end encrypted.
  • —Device telemetry: app version, iOS version, crash reports. Anonymized.

We do not collect contacts, photos, location, microphone or camera unless you grant a specific permission, and we never collect them in the background.

§ 03

Why we collect it.

DataPurposeLegal basis
AccountOperate the appContract (GDPR 6(1)(b))
SubscriptionBill, support, accountingContract & legal obligation
Health & trainingPersonal coaching, recovery & training planExplicit consent (GDPR 9(2)(a))
Journal & chatProvide AI coachingExplicit consent
TelemetryFix crashes, improve qualityLegitimate interest
§ 04

How the AI coach works.

The coach is a large language model fine-tuned on coaching transcripts and journaling protocols. Three commitments, written into the architecture:

  • —Your data never trains a public model. Not ours, not anyone else’s.
  • —Per-request inference: your data is sent to the model only to answer your question, then dropped. No long-term provider retention.
  • —On-device first: summarization, baseline analysis and trend detection run on your iPhone. Only the question and minimal context reach the model.

We use OpenAI and Anthropic as sub-processors under data-processing agreements with zero-retention and no-training clauses.

§ 05

Where it lives.

Primary storage is in the EU — Frankfurt and Helsinki regions on Amazon Web Services. Backups are encrypted with customer-managed keys and stored in the same EU regions.

Health data is encrypted at rest with AES-256-GCM. Journal entries, voice notes and coach chats are end-to-end encrypted with a key derived from your device passcode; we cannot read them.

No transfers outside the EU/EEA except for App Store receipts handled by Apple under their own DPA.

§ 06

Who we share it with.

We share data with a small set of sub-processors under signed DPAs:

  • —Amazon Web Services (Ireland) — primary infrastructure.
  • —Apple (Ireland) — App Store payments and receipt validation.
  • —OpenAI Ireland Ltd — model inference for the coach, zero retention.
  • —Anthropic Ireland Ltd — model inference for the coach, zero retention.
  • —Stripe Payments Europe Ltd — for non-App-Store invoicing.
  • —Linear, Notion, Plain — for support tickets you write to us.

We never sell, rent or share your data with advertisers, data brokers, or affiliate networks. Full stop.

§ 07

Your rights.

Under GDPR you have the right to access, rectify, port, restrict and erase your data, and to object to processing. We also give you a one-tap export and a one-tap delete from inside the app.

  • —Export — Settings → Privacy → Export. JSON archive, ready in minutes.
  • —Delete — Settings → Privacy → Delete account. Health data is wiped within 24 hours; backups purge within 30 days.
  • —Revoke consent for AI processing without deleting the account — Settings → Privacy → AI Coach.

You can lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi) if you believe we got something wrong.

§ 08

How long we keep it.

DataRetained for
AccountWhile active, then 30 days
Health & trainingWhile active, then 30 days
Journal & chatWhile active, then 30 days
Subscription receipts6 years (Finnish accounting law)
Telemetry & crash reports90 days
§ 09

Children.

Ihmi is for adults. We do not knowingly collect data from anyone under 18, and the App Store rating reflects this.

§ 10

Data processing agreement.

If you are using Ihmi through a company subscription, your employer’s legal team can request a DPA at dpa@ihmi.app. We sign the SCCs and the EU Cloud Code of Conduct.

§ 11

Changes to this policy.

We will tell you at least 30 days before a material change, via email and in-app notice. Old versions remain at /privacy/history.

Ihmi Oy · 2906543-1 · Aleksanterinkatu 15, 00100 Helsinki, Finland.legal@ihmi.app