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 through Sign in with Apple or Sign in with Google. 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 Apple's Licensed Application End User Licence Agreement (which applies to all applications downloaded from the App Store), 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). Okolee Premium is provided as an auto-renewing subscription through Apple's In-App Purchase system. The subscription term and price are displayed within the application prior to purchase.

All payments are processed by Apple. Apple charges the user's Apple ID 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.

Refunds are administered by Apple in accordance with its standard refund process. The Provider cannot issue refunds directly. Refund requests shall be addressed to Apple Support.

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.

The user retains ownership of content created by the user within the Service, including Noticbook entries (highlights, daily-presence entries, reflections) and 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 Service includes an exercise-recommendation feature powered by a third-party large-language model (currently Google Gemini). When the user submits a free-text query, that query is transmitted to the model together with a coarse time-of-day indicator derived from the user's timezone and the public catalogue of exercises. The model returns one or more recommended exercises.

The Provider does not transmit personal identifiers (such as the user's name, e-mail address, or account identifier) to the model. The scope of data transmitted may evolve as the feature is developed; any such change shall be reflected in this Privacy Policy.

AI-generated suggestions are non-binding suggestions. They do not constitute medical, psychological, or any other professional advice. The model may produce inaccurate, incomplete, or unexpected output.

The third-party AI provider may retain submitted prompts under its own terms for abuse-prevention or service-improvement purposes. The Provider endeavours to use an API tier that excludes prompts from model training but cannot guarantee the internal processes of the third-party provider. A user concerned by this may refrain from using the AI matching feature; the remainder of the Service operates independently of it.

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
• 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, feedback, or AI prompts) 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.

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 iOS 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; (3) the corresponding RevenueCat customer record is requested to be deleted; (4) 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 the 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, and feedback submissions
• AI input data: when the AI exercise-matching feature is used, the free-text query submitted (see Article 7)
• Subscription data: receipts and subscription state received from Apple via RevenueCat, including current entitlement status and the timestamp of the latest event
• Device and diagnostic data: device platform and application version; a Firebase Cloud Messaging token for delivering push notifications to which the user has consented
• Timezone snapshot: a record of the user's timezone at the moment of each activity, exercise, or Noticbook entry
• iOS application and website analytics: anonymous events processed via Firebase Analytics (Google) - on the iOS application 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 both cases without advertising identifiers, without cross-application tracking, and not connected to the user's account, name, e-mail, or any content created in the application or on the website

The Provider does not process: precise device location, contacts, photo library, microphone audio, camera images, HealthKit data on the Provider's servers (where the HealthKit 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
• AI-assisted exercise matching: transmission of the user's query to the third-party AI provider (see Article 7)
• Detection of crisis indicators: queries submitted to the AI matching feature are automatically checked for indicators of immediate crisis in order to redirect the user to appropriate professional resources
• Delivery of push notifications to which the user has consented (reminders, streak warnings, the inactivity-deletion warning)
• Subscription processing: validation of Apple receipts and reconciliation of entitlement state with RevenueCat
• Service improvement: aggregated, anonymous patterns of usage and, subject to the user's cookies consent, website analytics
• Abuse prevention: enforcement of usage limits, detection of timezone or quota manipulation, and enforcement of these Terms
• Legal compliance: response to lawful requests from public authorities where required by law

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)
• Consent (Article 6(1)(a)): for push notifications, the HealthKit integration on iOS, the AI exercise-matching feature, 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, and improving the Service in aggregated form; the data subject may object to processing based on legitimate interests
• 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 Functions, Cloud Messaging, Remote Config, Analytics, Crashlytics): hosting of the backend, processing of anonymous iOS application and website analytics, and crash diagnostics; primary region europe-west3 (Belgium). Firebase Analytics is configured without IDFA, Google Signals, or advertising features; on iOS it is opt-out through the application's Preferences screen, on the okolee.app website it is opt-in through the cookies banner. Privacy: firebase.google.com/support/privacy
• Google Gemini API: large-language model for the AI exercise-matching feature; processes only the data set out in Article 7. Terms: ai.google.dev/gemini-api/terms
• RevenueCat: subscription state management; processes the account identifier and Apple 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

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, Gemini API, 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].

Where the user invokes the AI exercise-matching feature, the Provider transmits the following to the third-party AI provider:

• The free-text query submitted by the user
• A coarse time-of-day indicator (for example, "morning" or "evening") derived from the user's timezone
• The Provider's public catalogue of exercises (titles, descriptions, durations, categories)

The Provider does not transmit personal identifiers (such as the user's name, e-mail address, or account identifier). The scope of data transmitted may evolve as the feature is developed; any such change shall be reflected in this Privacy Policy.

The third-party AI provider may, in accordance with its own terms, retain submitted prompts for abuse-prevention purposes and (depending on the API tier) for model improvement. The Provider endeavours to use an API tier that excludes prompts from model training but cannot guarantee the third party's internal processes. A user who does not wish to share even anonymous query text with the third party may refrain from using the AI matching feature; the remainder of the Service operates independently of it.

AI-generated suggestions do not constitute advice. The output is a non-binding recommendation.

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

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, in the order set out in Part A, Article 14. 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 only 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 submitted by the user 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.

Subscription events received from RevenueCat are retained for two (2) years for accounting and reconciliation purposes.

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 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.

The Okolee iOS application does not use cookies. The application uses Firebase Analytics (Google) to record anonymous events about how the application is used (for example, which exercises are started, completed, or skipped). Collection is enabled by default on the legal basis of the Provider's legitimate interest in improving the Service (Article 6(1)(f) GDPR) and may be disabled by the user at any time through the application's Preferences screen. The application does not use the Apple advertising identifier (IDFA), does not enable Google Signals or any other advertising feature, and does not collect data for the purpose of advertising or cross-application tracking. Event-level retention in Firebase Analytics is set to the shortest available period.

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 anonymous 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 on iOS 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 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].