Terms & Privacy

By creating an account, signing in, or otherwise accessing the Service, the user accepts these Terms of Service. If the user does not accept them, they shall not use the Service.

The Service is intended for users aged 13 and older. The Provider does not knowingly process personal data of children under 13.

Okolee is an attention-training application providing short exercises that direct the user's attention to their physical surroundings, together with gamified progress mechanics including Growth Points, a virtual garden, and streaks.

The Service is:

• An application that uses the user's physical surroundings as the subject of short attention exercises
• A gamified tool intended to support a habit of present-moment attention
• A reflective journal (the Noticbook) for short personal notes
• A general wellbeing tool

The Service is not:

• A medical device or medical software within the meaning of Regulation (EU) 2017/745 or applicable national legislation
• A diagnostic, screening, or therapeutic tool
• A substitute for therapy, counselling, or any other form of professional mental-health care
• An emergency, crisis, or suicide-prevention service
• A meditation application or breath-work tool

The Service does not provide advice of any kind. The exercises, audio guidance, and any in-application recommendations are provided for general informational and self-reflective purposes only and do not constitute medical, psychological, legal, or other professional advice.

Access to the Service requires the creation of a user account in the application through Sign in with Apple or Sign in with Google; Sign in with Apple is offered in the iOS application and, solely for redeeming a promotional code with an existing account, on the website. An account can be created only in the application, never on the website. The Provider does not store user passwords; authentication is performed by the third-party identity provider.

The user undertakes to keep their account credentials confidential, to be responsible for all activity occurring under their account, and to notify the Provider promptly of any suspected unauthorised use.

Each natural person may register only one user account. Sharing, selling, or transferring an account, and impersonation of another person, are prohibited.

Subject to compliance with these Terms of Service and with the terms of the store from which the application was obtained - Apple's Licensed Application End User Licence Agreement for applications downloaded from the App Store, or the Google Play Terms of Service for applications downloaded from Google Play - the Provider grants the user a personal, non-exclusive, non-transferable, non-sublicensable, revocable licence to use the Service for the user's own non-commercial purposes.

The user shall not (a) copy, modify, distribute, sell, or rent the Service or any part of its content, (b) perform reverse engineering, decompilation, or any similar process intended to derive the source code, (c) remove or alter any proprietary notices, or (d) use the Service in a manner that infringes the rights of any person or that contravenes applicable law.

The Service is offered free of charge with optional paid features (Okolee Premium). Where paid features are offered on a given platform, Okolee Premium is provided as an auto-renewing subscription through the in-app purchase system of the store from which the application was obtained: Apple's In-App Purchase system on iOS, and Google Play Billing on Android. The subscription term and price are displayed within the application prior to purchase.

All payments are processed by the platform store, which charges the user's Apple ID or Google account and administers renewals. Subscriptions renew automatically at the end of each subscription period unless the user cancels at least 24 hours before the renewal date. Subscriptions may be managed and cancelled in the user's Apple ID account settings, or in the subscriptions section of Google Play.

Refunds are administered by the platform store in accordance with its standard refund process. The Provider cannot issue refunds directly. Refund requests shall be addressed to Apple Support or to Google Play Support, according to the store from which the subscription was purchased.

The Provider uses RevenueCat as a sub-processor for managing subscription state on the Provider's side (entitlement tracking and webhook events). RevenueCat does not charge users.

The Provider may change prices, the set of paid features, or the availability of Okolee Premium with reasonable prior notice. A change during an active subscription period shall not increase the price already paid for that period.

Promotional codes

The Provider, or a partner of the Provider such as an employer or another organisation, may distribute promotional codes that provide Okolee Premium free of charge for a stated period: one (1) month, one (1) year, or without a time limit, for as long as the Provider offers Okolee Premium. A promotional code is always free of charge to the user, including where it is received from a partner.

A promotional code is redeemed only on the Provider's website at okolee.app/redeem, by signing in with the same Sign in with Apple or Sign in with Google account that the user uses in the application. The website does not create accounts, so a code can be redeemed only for an existing account. Okolee Premium provided through a code belongs to that account and applies in the application on every platform on which the account is used.

Each code may be redeemed only once, by a single account, and not while that account already has Okolee Premium. Where a last day to redeem is stated for a code, the code cannot be redeemed after that day. The period begins upon redemption; Okolee Premium provided in this way cannot be transferred to another account, does not renew automatically, and no payment is charged when the period ends.

Promotional codes have no cash value, cannot be exchanged for money, and may not be sold or resold, including by a partner. To prevent misuse, the number of unsuccessful redemption attempts per account is limited. The Provider may withdraw a code that has not yet been redeemed and may revoke Okolee Premium provided through a code obtained or used in breach of these Terms of Service.

Feedback is submitted entirely voluntarily; the user is under no obligation to submit any feedback in order to use the Service. The user retains ownership of content created by the user within the Service, including Noticbook entries (highlights, daily-presence entries, reflections), any images attached to them, a profile photo, a username, and voluntary feedback submissions. The user grants the Provider a worldwide, royalty-free, non-exclusive licence to host, store, back up, and process such content solely to the extent necessary to provide and operate the Service. This licence terminates upon deletion of the content or of the user's account.

Noticbook entries are not used for marketing or advertising purposes and are not shared with third parties for such purposes. Aggregated and anonymised feedback may be used by the Provider for the purpose of improving the Service and may be quoted in anonymised form in product communications.

The user is responsible for the content the user submits. The user shall not submit content that is unlawful, infringes third-party rights, contains malicious code, or that the user is not entitled to share.

The user shall not:

• Use the Service to cause harm to oneself or to any other person
• Circumvent or attempt to circumvent daily usage limits, paid-feature restrictions, anti-abuse mechanisms, or rate limits
• Guess, generate, collect or trade promotional codes, or attempt to redeem a code by automated means
• Scrape, mass-download, or systematically extract content from the Service
• Reverse-engineer, decompile, or otherwise attempt to derive the source code
• Impersonate any person or misrepresent any affiliation
• Upload or transmit malicious code, scripts, or other harmful content
• Submit content (in the Noticbook, as a profile photo, as a username, or in feedback) that is unlawful, harassing, defamatory, hateful, or sexually explicit material involving minors
• Use the Service for any commercial purpose without the Provider's prior written consent
• Interfere with the operation of the Service or its supporting infrastructure

The Provider may suspend or terminate accounts that violate the foregoing, with or without prior notice, depending on the severity of the violation.

The Service is a wellbeing tool. It is not a healthcare provider and is not intended to diagnose, treat, cure, or prevent any disease, mental-health condition, or other medical issue. The Service does not substitute professional advice, diagnosis, or treatment.

The user shall consult a physician, therapist, or other qualified healthcare professional in respect of any medical or mental-health concern. The user shall not disregard professional advice or delay seeking it on the basis of anything experienced through the Service.

In the event of a crisis, immediate danger, or thoughts of self-harm or harm to others, the user shall contact emergency services without delay. In the Czech Republic: emergency line 112; Linka první psychické pomoci 116 123 (free, anonymous, 24/7). International helplines are listed at findahelpline.com.

Certain exercises require the user to direct attention to their physical surroundings. The user shall not perform exercises while driving, operating machinery, crossing a road, or in any situation where directing attention away from the immediate task could be unsafe.

Okolee, the Okolee name and logo, the exercises, the guided-audio recordings, the plant illustrations, the gamification design, and all related content (the Materials) are protected by copyright and other applicable intellectual-property laws and are owned by the Provider or licensed to the Provider.

Save for the limited licence granted in Article 4, no use of the Materials is permitted without the Provider's prior written consent.

Notice of alleged copyright infringement may be submitted to [email protected], with sufficient information to identify the work and the alleged infringement.

To the maximum extent permitted by law, the Service is provided "as is" and "as available", with all faults, and without warranty of any kind, whether express or implied. The Provider does not warrant that the Service shall be uninterrupted, error-free, secure, accurate, current, or suitable for any particular purpose.

The Provider does not warrant any specific outcome from the use of the Service, including any improvement in mood, mental health, mindfulness, focus, or general wellbeing.

Mandatory consumer-protection rights under Czech and EU law shall not be affected by this Article.

To the maximum extent permitted by law, the Provider shall not be liable for any indirect, incidental, special, consequential, or punitive damages, nor for any loss of profits, data, goodwill, or other intangible losses arising out of or in connection with the use of, or inability to use, the Service.

The Provider's total cumulative liability for any claim arising out of or in connection with the Service shall not exceed the greater of (a) the amount paid by the user for Okolee Premium during the twelve (12) months preceding the event giving rise to the claim, or (b) one hundred euros (EUR 100).

The foregoing limitations shall not apply to (a) liability that cannot be excluded or limited by law, including liability for gross negligence, wilful misconduct, death or personal injury caused by negligence, or fraud, and (b) mandatory consumer-protection rights.

By accepting these Terms of Service, the user expressly acknowledges and agrees to the limitation of liability set out in this Article, and confirms that the user was informed of this limitation in advance of contract formation.

Where the user's use of the Service in breach of these Terms of Service gives rise to a claim, fine, or loss asserted by a third party against the Provider, the user shall indemnify the Provider against such claim, including reasonable legal costs. This Article shall not apply where the loss results from the Provider's own breach of these Terms or from the Provider's wilful misconduct.

The user may terminate the use of the Service at any time. Permanent deletion of the user's account may be requested through the Preferences screen of the application, by selecting Delete Account.

Upon a deletion request submitted by the user (self-deletion), the user's Firebase Authentication record is removed without delay. Personal data stored in the Provider's database (Firestore) is retained for a grace period of thirty (30) days, after which it is permanently deleted by an automated scheduled process in the following order: (1) an audit row is written to a deletion log containing only a former account identifier and the date (no personal data); (2) any feedback submitted by the user is anonymised by stripping the e-mail address and account reference, while the textual content is retained, and any answers to the optional demographic questionnaire and any promotional codes redeemed by the user are de-linked from the account; (3) the corresponding RevenueCat customer record is requested to be deleted; (4) any images the user attached to Noticbook entries, and the user's profile photo where one was set, are permanently deleted from file storage; (5) the user's Firestore user document and all subcollections (activity, exercise runs, Noticbook entries, garden state, garden sessions) are permanently deleted. Self-deletion is irreversible. The 30-day retention period serves solely to permit operational recovery in the event of error and shall not be relied upon by the user to reverse a deletion request.

Automatic deletion of inactive accounts: in order to minimise the volume of personal data retained, the Provider automatically deletes accounts that have been inactive for two (2) years (730 days). "Inactive" means that the user has not opened the application or otherwise used the account during the foregoing period. The Provider sends a push notification thirty (30) days before the deletion is processed. If the user signs in to the Service before the expiry of the 30-day grace period, the deletion is cancelled and the account is preserved. Otherwise, the account is processed in the same manner as set out above for self-deletion.

Reuse of e-mail address: following deletion, the e-mail address previously associated with the deleted account may be used to register a new account. The new account is independent of the deleted account and contains none of the deleted account's data.

The Provider may suspend or terminate a user account in the event of a material or repeated breach of these Terms of Service. Where reasonably practicable, the Provider shall give the user prior notice and an opportunity to remedy the breach.

The Provider may amend these Terms of Service from time to time. The "Last updated" date at the top of this page shall always reflect the latest version. Material amendments may be communicated by an in-application message, push notification, or e-mail. Continued use of the Service following the entry into force of an amendment shall constitute acceptance of the amended Terms; a user who does not accept the amendment shall delete the user's account.

These Terms of Service are governed by the laws of the Czech Republic, without regard to its conflict-of-laws rules. Mandatory consumer-protection rules of the country in which the user resides as a consumer shall continue to apply in parallel with Czech law.

Disputes arising out of or in connection with these Terms of Service shall be resolved by the competent courts of the Czech Republic, save where mandatory EU consumer-protection rules provide otherwise. Consumers resident in the European Union may also access the European Commission's Online Dispute Resolution platform at ec.europa.eu/consumers/odr.

If any provision of these Terms of Service is found to be unenforceable, the remaining provisions shall continue in full force and effect. A failure by the Provider to enforce any right or provision shall not constitute a waiver of such right or provision.

The controller of personal data processed in connection with the Service is Petr Jelínek, a sole trader registered in the Czech Republic under IČO 17347661, contactable at [email protected].

The Provider is not obliged to designate a Data Protection Officer at the present scale of operations. All privacy-related correspondence shall be addressed to [email protected].

The Provider processes only such personal data as is necessary for the provision of the Service. The following categories are processed:

• Account data: e-mail address, display name, and avatar URL obtained from Sign in with Apple or Sign in with Google; selected language and timezone
• Usage data: in-application activity, including exercises completed, Noticbook entries created, daily-limit counters, streak progression, Growth Points balance, virtual-garden state, premium status, and share events
• User-generated content: Noticbook highlights, daily-presence entries, reflections (including answers about how the user feels), personal goals, any images the user attaches to a highlight (a paid feature), an optional profile photo, an optional username, and feedback submissions (with an optional e-mail address for a reply)
• Optional questionnaire data: where the user chooses to answer the optional onboarding questionnaire, self-reported information about who they are and what they hope to get from Okolee. The questionnaire is fully optional and skippable, and no question requires an answer. These answers are stored separately from the user profile, keyed by a pseudonymous account identifier, and are not shared with third parties. The specific questions may change over time as the questionnaire is refined
• Subscription data: receipts and subscription state received from the platform store (Apple, or Google Play) via RevenueCat, including current entitlement status and the timestamp of the latest event; where the user redeems or attempts to redeem a promotional code, also the code redeemed, the date and time of redemption, the period of Okolee Premium it provides, and the number of recent unsuccessful redemption attempts
• Device and diagnostic data: device platform and application version; an app instance identifier assigned by Firebase; a Firebase Cloud Messaging token for delivering push notifications to which the user has consented; crash reports processed via Firebase Crashlytics (Google), which carry the pseudonymous account identifier
• Timezone snapshot: a record of the user's timezone at the moment of each activity, exercise, or Noticbook entry
• Application and website analytics: events about how the Service is used, processed via Firebase Analytics (Google) - in the mobile applications enabled by default and opt-out through the application's Preferences screen, on the okolee.app website only where the user has provided consent through the cookies banner. In the mobile applications the events are linked to a pseudonymous account identifier, so that usage can be measured per user across devices and reinstallations; on the website they are not linked to any account. In both cases without advertising identifiers, without cross-application tracking, and without the user's name, e-mail, or any content created in the application or on the website

Where the user redeems a promotional code on the okolee.app website, the user signs in with the same Sign in with Apple or Sign in with Google account as in the application. The website does not use Firebase Authentication: Apple or Google confirms the sign-in directly to the website, which passes that signed confirmation to the Provider's server together with the code, and the server uses the account identifier contained in it to find the user's existing account; the e-mail address in it is used only to tell the user, where no account matches, that the address signs in to Okolee another way. The confirmation is held only in the browser's memory, for the length of the redemption and at most five minutes, nothing is stored in the browser, no authentication record and no account is created, and the Provider receives no data beyond the account data listed above.

Where the user sets a profile photo, the image is cropped and re-encoded on the user's device before it is uploaded, so that no metadata of the original file - including any location information - is transmitted. The profile photo is visible only to the user and is not shown to other users. Where the user sets a username, it is likewise visible only to the user and is not shown to other users; it is not required in order to use the Service and may be removed at any time.

The Provider does not process: precise device location, contacts, microphone audio, the user's photo library or camera other than for an image that the user expressly provides (only an individual image that the user selects as a Noticbook attachment, or selects or takes with the camera as a profile photo, is uploaded; the library itself is never accessed, scanned, or indexed, and the camera is opened only when the user chooses to take a profile photo), health data from the health integrations on the Provider's servers (where the HealthKit or Health Connect integration is enabled, the relevant data remains on the user's device), advertising identifiers, or any behaviour from outside the Service.

Personal data is processed solely for the following purposes:

• Operation of the Service: authentication, persistence of progress, enforcement of premium gating and daily limits, calculation of streaks and Growth Points, virtual-garden state management, and display of the profile photo the user has chosen
• Delivery of push notifications to which the user has consented (reminders, streak warnings, the inactivity-deletion warning)
• Subscription processing: validation of store receipts, redemption of promotional codes, reconciliation of entitlement state with RevenueCat and subscription statistics
• Feedback: replying where an e-mail address for a reply is included
• Service improvement and diagnostics: usage analytics in the mobile applications, linked to a pseudonymous account identifier, crash reports, and, subject to the user's cookies consent, website analytics
• Pilot research: where the user has answered the optional demographic questionnaire, the responses are used in aggregate to understand who the Service reaches and to improve it
• Abuse prevention: enforcement of usage limits, detection of timezone or quota manipulation, protection of promotional-code redemption against automated abuse, and enforcement of these Terms
• Legal compliance: response to lawful requests from public authorities where required by law

Where promotional codes are distributed by a partner, the Provider may provide that partner only with aggregate figures about its codes, such as how many have been redeemed. The Provider does not disclose to a partner which user redeemed a code, nor any other information about the user or the user's use of the Service.

The Provider does not sell personal data and does not process personal data for third-party advertising purposes.

The Provider processes personal data on the following legal bases under Article 6(1) GDPR:

• Performance of a contract (Article 6(1)(b)): for the provision of the core functionality of the Service (authentication, synchronisation of activity, premium gating, redemption of promotional codes, and the profile photo where the user sets one)
• Consent (Article 6(1)(a)): for push notifications, the health integrations (HealthKit on iOS and Health Connect on Android), the optional demographic questionnaire (which is fully optional and skippable), and website analytics cookies; consent may be withdrawn at any time, without affecting the lawfulness of processing carried out prior to withdrawal
• Legitimate interests (Article 6(1)(f)): for maintaining the security and integrity of the Service, preventing abuse, debugging (including crash reports), and improving the Service through usage analytics in the mobile applications; the data subject may object to processing based on legitimate interests, and may object to usage analytics at any time by turning it off in the application's Preferences screen
• Legal obligation (Article 6(1)(c)): where processing is necessary to comply with an applicable legal obligation

The Provider uses the following sub-processors, each processing personal data solely on the Provider's instructions and in accordance with the sub-processor's own published privacy commitments:

• Google Firebase (Authentication, Firestore, Cloud Storage, Cloud Functions, Cloud Messaging, Remote Config, Analytics, Crashlytics, App Check): hosting of the backend, processing of mobile application and website analytics, and crash diagnostics; primary region europe-west3 (Frankfurt, Germany). Firebase Analytics is configured without IDFA, Google Signals, or advertising features; in the mobile applications it is opt-out through the Preferences screen, on the okolee.app website it is opt-in through the cookies banner. Privacy: firebase.google.com/support/privacy
• RevenueCat: subscription state management; processes the account identifier and store receipt data. Privacy: revenuecat.com/privacy
• Apple: Sign in with Apple, App Store payments, and (on the user's device only) HealthKit. Privacy: apple.com/legal/privacy
• Google: Sign in with Google, Google Play payments, and (on the user's device only) Health Connect. Privacy: policies.google.com/privacy

Personal data is primarily stored within the European Union (Firebase europe-west3 region). Certain sub-processors are based or operate infrastructure outside the European Economic Area, including Google (Firebase Analytics and parts of Google's global infrastructure), RevenueCat, and Apple.

Where personal data is transferred outside the EEA, the Provider relies on the safeguards put in place by the relevant sub-processor, including the European Commission's Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework. Further details may be requested at [email protected].

Personal data of an active account is retained for as long as the account is active.

A profile photo is retained until the user removes or replaces it through the Preferences screen, whereupon the previous image is permanently deleted from file storage. A username is retained until the user changes or clears it through the same screen, and in either case the previous value is not kept.

Where the user requests the deletion of the account through the application, the Firebase Authentication record is removed without delay. Personal data stored in the Provider's database is retained for a thirty (30) day grace period for operational-recovery purposes and is thereafter permanently deleted, together with any images attached to Noticbook entries and the user's profile photo, in the order set out in Part A, Article 13. Self-deletion is irreversible.

Where an account has been inactive for two (2) years, the Provider sends a push notification and marks the account for deletion thirty (30) days later. The deletion is cancelled if the user signs in to the Service before the expiry of the 30-day grace period.

Following permanent deletion of an account, the Provider retains a minimal audit log entry (a former account identifier and the date of deletion - no personal data) for the purpose of demonstrating compliance with deletion obligations. This audit entry is retained indefinitely.

Feedback voluntarily submitted by the user (free-text content, star rating, and source) is retained following deletion of the account in anonymised form: the e-mail address and account reference are stripped, while the textual content, star rating, and source are retained for the purpose of product development. The user is not required to submit feedback to use the Service.

Where the user has answered the optional demographic questionnaire, the responses are not deleted but anonymised upon deletion of the account: the account identifier is stripped (replaced with "deleted"), severing the link to the user, and a de-linked copy is retained only in aggregate, non-identifying form for pilot research. The user-linked record is removed.

Promotional codes redeemed by the user are retained after deletion of the account as used codes, so that they cannot be redeemed again, but the account identifier is stripped from them (replaced with "deleted"), severing the link to the user.

A counter of recent unsuccessful attempts to redeem a promotional code is kept with the account, counting only attempts within the last hour, and is deleted together with the account.

Subscription events received from RevenueCat are retained for accounting and reconciliation purposes. Following deletion of the account these records are no longer linked to any identifiable person: they contain no name, e-mail address, or other contact detail - only an account identifier that no longer resolves to a user, the product purchased, and the store transaction reference.

Analytics events and crash reports are not deleted together with the account. Analytics events are retained in Firebase Analytics for fourteen (14) months from collection and crash reports in Firebase Crashlytics for ninety (90) days; statistics aggregated from them contain no identifier and are retained without time limit. Once an account has been permanently deleted, the account identifier these records carry no longer resolves to any person, as the account record, the e-mail address, and all other data linking the identifier to the user have been deleted.

Following permanent deletion of an account, the e-mail address previously associated with that account becomes available for use in registering a new account. Any new account is independent of the deleted account and contains none of the previous account's data.

Under the GDPR, the data subject has the following rights in respect of personal data processed by the Provider:

• Right of access (Article 15): to obtain a copy of the personal data processed
• Right to rectification (Article 16): to obtain correction of inaccurate or incomplete personal data
• Right to erasure (Article 17): to request deletion of personal data; deletion may also be initiated by the user from within the application
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20): to receive personal data in a structured, commonly used, and machine-readable format
• Right to object (Article 21): to object to processing based on legitimate interests
• Right to withdraw consent (Article 7(3)): where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of prior processing
• Right to lodge a complaint (Article 77): with the Czech supervisory authority - Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Praha 7, www.uoou.cz - or with the supervisory authority in the EU country of the data subject's residence

Requests in connection with the foregoing rights shall be addressed to [email protected]. The Provider shall respond within thirty (30) days. The Provider may request verification of identity in order to protect the data subject's personal data.

Push notifications are dispatched only on the basis of the user's consent. Consent may be withdrawn at any time through the application's Preferences screen or through the iOS or Android system settings.

The HealthKit integration is offered on an opt-in basis. Where enabled, the Service writes Mindful Session entries to the iOS Health application corresponding to the time spent on the beyond-the-screen portion of each exercise. When the user manually triggers a backfill sync of past exercises, the Service additionally reads the external identifiers of Mindful Session entries previously written by Okolee (and only those entries) in order to avoid creating duplicate writes; no other HealthKit data is read, and the read result is held only in device memory. HealthKit data remains on the user's device; the Provider does not transmit any HealthKit data to the Provider's servers.

On Android, the Health Connect integration is offered on an opt-in basis and additionally requires a permission granted within Health Connect itself, which may be withdrawn there at any time. Where enabled, the Service writes Mindfulness Session entries to Health Connect corresponding to the time spent on the beyond-the-screen portion of each exercise. The Service requests and holds the permission to write only; it does not request or hold any permission to read health data. In order to avoid creating duplicate entries, the Service reads back the identifiers of Mindfulness Session entries previously written by Okolee, and only those entries - a read that Health Connect permits to an application in respect of its own entries without a read permission; the read result is held only in device memory. Health Connect data remains on the user's device; the Provider does not transmit any Health Connect data to the Provider's servers.

The Okolee mobile applications do not use cookies. They use Firebase Analytics (Google) to record events about how the applications are used (for example, which exercises are started, completed, or skipped). These events are linked to a pseudonymous account identifier - a randomly generated identifier of the account, never the user's name or e-mail address - so that usage can be measured per user across devices and reinstallations and problems can be diagnosed; they never contain content created by the user. Google Analytics derives an approximate location (at city level) from the device's IP address and does not store the IP address itself. Collection is enabled by default on the legal basis of the Provider's legitimate interest in diagnosing problems and improving the Service (Article 6(1)(f) GDPR). The user may object to this processing at any time by turning off "Help Improve Okolee" in the application's Preferences screen, after which no further analytics events are collected from that device. The applications do not use advertising identifiers (the Apple IDFA or the Google Advertising ID), do not enable Google Signals or any other advertising feature, and do not collect data for the purpose of advertising or cross-application tracking. Event-level retention in Firebase Analytics is set to fourteen (14) months.

The okolee.app website uses cookies only where the user has provided express consent through the cookies banner. Upon acceptance, the Provider initialises Firebase Analytics (Google) for the collection of product-analytics events about how the website is used; this includes Google Analytics 4 cookies (such as _ga and _ga_*) used solely for measuring usage. Upon refusal, Firebase Analytics is not initialised and any pre-existing analytics cookies are cleared. The same configuration as in the mobile applications applies: no advertising identifiers, no Google Signals, no advertising features, and event-level retention set to fourteen (14) months.

The user may modify the cookies preference at any time through the "Cookie Settings" link in the website footer.

The website's code redemption page loads no analytics and sets no analytics cookies, whatever the choice made in the cookies banner, and stores nothing in the browser beyond the site-wide language and appearance preferences.

The Service is not directed at children under the age of 13. The Provider does not knowingly process personal data of children under 13. Where a parent or legal guardian becomes aware that personal data of such a child has been provided to the Provider, the Provider shall delete such personal data upon notification at [email protected].

The Provider protects personal data through industry-standard measures, including encryption in transit (TLS), encryption at rest in Firebase, server-side access controls (Firestore security rules block client-side writes to sensitive fields including premium status; only the backend may update such fields), authenticated callable functions for all sensitive operations, secrets management via Firebase Functions secrets, and limited human access on a need-to-know basis.

In the event of a personal-data breach within the meaning of Article 33 GDPR, the Provider shall notify the Czech supervisory authority (Úřad pro ochranu osobních údajů) without undue delay and, where feasible, within 72 hours, and shall notify the data subject directly where the breach is likely to result in a high risk to the rights and freedoms of natural persons (Article 34 GDPR).

The Provider may amend this Privacy Policy from time to time. The "Last updated" date at the top of this page shall always reflect the latest version. Material amendments may be communicated by an in-application message, push notification, or e-mail.

All enquiries, requests, and complaints shall be addressed to [email protected].

An Okolee account and the personal data associated with it may be deleted at any time, by either of the two routes set out below. Both result in the same deletion, which is irreversible.

Within the application

Open the Preferences screen and select Delete Account. Signing in again is required before the deletion is carried out, as a safeguard against an accidental or unauthorised request.

Without the application

Where Okolee is no longer installed, a request may be sent to [email protected] from the e-mail address associated with the account. The sending address is used to identify the account, and the request must therefore be sent from that address. Receipt is confirmed by reply. No further information is required, and neither the application nor an active session is needed in order to make the request.

Data that is deleted

• The Firebase Authentication record and the ability to sign in
• The profile photo and the username
• All Noticbook entries, together with any images attached to them
• All reflections and the answers given in them
• The record of completed exercises
• The garden, its plants and its planting history
• Goals and streak data
• The customer record held with the payment provider
• All remaining files stored under the account in file storage

Data that is retained

• A minimal audit entry (a former account identifier and the date of deletion, containing no personal data), retained indefinitely in order to demonstrate compliance with deletion obligations
• Feedback, retained in anonymised form with the account reference and any e-mail address removed
• Responses to the optional demographic questionnaire, retained in anonymised form with no link to the account
• Promotional codes redeemed by the user, retained as used codes with no link to the account
• Records of subscription transactions required for accounting and tax purposes, retained for the period prescribed by law; these contain no name, e-mail address or contact details
• Analytics and crash reports, which are no longer linked to the account following its deletion

Deleting individual content without deleting the account

Individual items of content may be removed without deleting the account. A Noticbook highlight or daily-presence entry may be deleted from its detail screen, together with any images attached to it, and the profile photo and the username may be removed or replaced from the Preferences screen. A reflection recorded after an exercise forms part of the record of that exercise and is removed with the account. A request for the deletion of specific data may also be sent to [email protected], subject to the same identification requirement set out above.

Timing

The Firebase Authentication record is removed without delay, after which it is no longer possible to sign in. The remaining personal data is retained for a thirty (30) day grace period and permanently deleted thereafter, in any event no later than forty-five (45) days from the request.

Data held on the device itself, such as reminders and cached files, is not held by the Provider and is removed when the application is uninstalled. Article 7 above sets out the applicable retention periods in full, and Article 9 the further rights of the data subject.