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Privacy Policy

Last updated: 20 October 2026 Applies to: the RecTake app (iOS and Android) and the website rectake.de

The short version

Your entries — what you take, what you eat, how you feel — live in a database on your phone. They are not transmitted to us. The voice recording stays there too: your phone turns it into text itself, using the speech recognition built into its operating system. Your account knows your email address, an account ID and your subscription status — not what you record.

No health data leaves your device.

The rest of this text explains that in detail, because it legally has to.

1. Controller

The controller within the meaning of Art. 4(7) GDPR is:

IT Consulting & Development Tino Sanchez Ross
Bismarckring 6
65185 Wiesbaden
Germany

Email: support@rectake.de

The second contact route is the contact form on the support page (section 2.7).

Data protection officer: none appointed.

2. What data is processed

2.1 Your entries — health data that stays on the device

This is what the app is actually about. The app knows exactly six kinds of entry:

Until 15 September 2026 there were separate kinds for caffeine and for symptoms. Both are gone; what they held now lives under drinks and in the note respectively. The level of protection for these details is unchanged.

In addition:

• History — every recorded day
• Routines — your recurring patterns
• Vocabulary — the supplement and food names you use
• the finished text of your entries
• photos — if you give a supplement or a food an image (section 2.6)
• voice notes and recorded reminders — if you keep a recording (section 2.6)

Medication and notes about complaints are the most sensitive items on that list. Someone who records which prescribed medicine they take and which complaints they have is disclosing their health at its core.

These entries do not leave the device — and neither does the voice recording they are made from. Anyone who speaks a medication or a complaint transmits nothing by doing so. How recognition works without any transmission is in the next section.

This is health data within the meaning of Art. 4(15) GDPR and therefore a special category of personal data under Art. 9(1) GDPR. It has the strongest protection the Regulation provides.

Where it lives: exclusively in a SQLite database in the app's private storage area on your device. There is no code path in the app that transmits entries to a server — not to us, not to anyone else. We have no access to this data: not on request, not with a court order. We simply do not have it.

What follows from that, and what you need to know: if you delete the app or lose the device, the entries are gone. There is no copy with us to restore from. You can export your entries yourself as a file (Settings → Your data). The export goes through your device’s share sheet; where the file ends up – e-mail, cloud storage, a messenger – is your choice, and that provider then processes it under its own terms. Nothing is transmitted to us.

2.2 The voice recording

To turn what you say into an entry, the recording has to be converted into text. This happens on your phone. It uses the speech recognition of the operating system — the same one that works when you tap the microphone on your keyboard. On iPhones that is Apple's Speech framework, on Android devices the recogniser the system ships with.

The app explicitly requires on-device recognition. It only starts if the operating system confirms that it can recognise your language without a network. If it does not confirm that, the app tries, on Android, a German language pack of its own that ships with the app and likewise works only on the device. If that is not available either — for another language, say — there is no speech recognition, and no silent fallback to a server. This mainly affects Android devices before version 13.

On Android the operating system may also need to download an offline language pack for your language first. The app then offers to trigger that download with the system. It runs through the operating system's recognition service, usually Google — not through us, and the app transmits nothing in the process.

What follows from that:

1. The recording exists in your phone's memory and becomes text there.
2. It is not transmitted — not to us, not to a third party.
3. Afterwards it is discarded. What is stored is only what you keep as an entry, and that lives in the database on the device. The one exception is your own choice: you can keep a note as a recording (section 2.6).

Your vocabulary — the supplement names you use — is given to the recogniser as a hint, so that "Elalanin" becomes "L-Alanine". It stays on the device as well.

What the operating system itself does is its maker's decision. Whoever makes your phone and its operating system is its supplier, not our processor. We explicitly ask for on-device recognition and do not start without it; what diagnostic data an operating system sends to its maker beyond that is governed by its own privacy terms and your system settings.

For the recognition itself this means: Apple or Google provides it as a function of the operating system, on its own responsibility and under the maker's own privacy terms. There is no data processing agreement for it, and none is needed: the app asks for on-device recognition and only starts it if the system has your language installed offline. A language pack your device downloads from its maker is a separate thing — the system downloads it, not the app, and your recording plays no part in it.

2.3 Your account

The account is not there to store your entries. It exists for one reason: a subscription has to be recognisable on a new phone, and that needs something that recognises you.

So exactly this is stored:

No name, no date of birth, no address, no entries.

Accounts from the test phase also carry an old, non-functional counter of recording seconds; it is deleted along with the account.

There are three ways to sign in: Google, Apple, or email with a six-digit code. With Google and Apple we learn only the email address and an identifier from them — not your address book, not your profile. Conversely, Google or Apple learns that you signed in to RecTake; see section 4.

Do you have to provide this? Without an email address there is no account, and so no subscription that can be recognised on a new phone — everything else in the app works without an account. You are under no legal obligation to provide anything, and the waiting list on the website is voluntary as well.

2.4 The website rectake.de

The website counts visits with Google Analytics — but only if you agree (section 2.4a). Without your consent it sets no cookies and loads nothing from third-party servers.

Server access logs are produced on request, as with any web server: IP address, timestamp, page requested, browser type submitted. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure operation). On our plan the host keeps these runtime logs for one day; after that they are gone.

The website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. Vercel has certified to the U.S. Department of Commerce under the EU-US Data Privacy Framework (Vercel privacy policy, last updated 1 June 2026); its data processing agreement (version of 17 March 2026) additionally incorporates the European Commission's standard contractual clauses and forms part of its terms of service. While you read it, the site transmits no personal data to us. The one exception is the waiting list you can add yourself to (section 13a) — and it transmits only what you type, and only when you press send.

Domain, name resolution and email sit with a German provider instead, see section 4.6. Anyone opening rectake.de asks there first where the address points.

2.4a Visit measurement with Google Analytics

The website only, not the app. The app still measures nothing (section 4.7).

If you choose “Yes, count” in the notice at the bottom of the page, the website loads Google Analytics 4. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google processes the data as our processor (Art. 28 GDPR).

What is recorded: which pages you open and for how long, which page you came from, approximate location (country, region — derived from the IP address; Google Analytics 4 does not store the IP address itself), device type, browser, operating system, screen size, language, and individual actions on the page: scrolling, clicks on outbound links, and the fact that you joined the waiting list — without your address. For this Google sets the cookies _ga and _ga_<ID>, which carry a random identifier for your browser.

Switched off are Google Signals, personalised advertising and any link to Google Ads. We only see aggregated numbers, never individual people.

Purpose: to understand how many people find the site, by which routes, and which texts are read.

Legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act). Without consent Google Analytics is not loaded at all.

Withdrawal: at any time via “Change analytics consent” in the footer of every page. If you choose “No” there, we delete the cookies immediately and nothing more is sent.

Your answer is remembered by your browser in its local storage (rectake-messung). This is technically necessary so the question does not reappear on every page (§ 25(2) no. 2 TDDDG), and it does not leave your device.

Retention: the cookies expire after 13 months at most. The analytics data at Google is deleted after 2 months.

Third country: Google may also transfer data to the USA (Google LLC). Google is certified under the EU-US Data Privacy Framework; the standard contractual clauses in Google's data processing terms apply in addition.

2.5 Purchases and subscription

Processing runs through the App Store or Google Play. We learn from them whether a purchase is valid — no payment data, no card number, no billing address. Apple and Google are responsible for payment processing in their own right; their privacy notices apply in addition. Validation of purchases is handled by RevenueCat, see section 4.5.

2.6 Photos, voice notes, reminders and notifications

Four things the app keeps on your device that appear in none of the tables above, because they are not entries:

• Product photos. You can give a supplement or a food an image — from the camera or from your gallery. The app scales it down and stores it in its private storage area; location and other metadata of the photo are not carried over. The image does not leave the device.
• Voice notes. You can keep a note as the original recording. The file sits next to the database on the device until you delete it — on its own or together with everything else.
• Recorded reminders. You can record a reminder in your own voice, a few seconds long. That recording stays on the device too.
• Notifications. Reminders and the mood follow-up are notifications the app schedules on your device itself. There is no push server: the notification is created on the device and shown there by the operating system; nothing goes to us. On iPhone the notification does not name your supplements.

Everything in this section is removed by Delete all entries on this device in the settings — and likewise by uninstalling the app.

2.7 Contact form

On the support page you can write to us without opening a mail app. What happens, step by step:

1. You type your email address, your message and, if you like, your name. Nothing more is collected — no IP address, no cookie, no identifier; only the language of the page, so that the reply comes in your language.
2. When you send, this goes to a function on our server at Supabase in Frankfurt (section 4.1). It checks the form, stores nothing, and sends two emails through our mail server at Serverprofis (section 4.6): your message to us, and an automatic confirmation of receipt to you.
3. Your message lands in our mailbox at Serverprofis in Germany (section 4.6). It stays there until your request is settled (section 6).

Legal basis: Art. 6(1)(b) GDPR where it concerns your account or subscription, otherwise our legitimate interest in answering your request, Art. 6(1)(f) GDPR. For requests under the GDPR itself — access, erasure — Art. 6(1)(c) GDPR.

Please, no health details. We never need them to resolve a request, and a mailbox is no place for them.

3. Legal bases

No health data reaches us. What we process is an account and a subscription status. That is not a special category of personal data under Art. 9 GDPR.

4. Who receives data

We do not pass data on for advertising, sale or profiling — to anyone. The recipients below are processors under Art. 28 GDPR, or independent controllers where that is stated explicitly.

4.1 Supabase — account and sign-in

Supabase Pte. Ltd.
65 Chulia Street #38-02/03, OCBC Centre
Singapore 049513
Place of processing for the database: Frankfurt am Main (eu-central-1)

Our contracting party is the Singapore company, not the US-based Supabase, Inc. The latter acts as a sub-processor for support.

What goes there: email address, account ID, subscription status. Nothing else.

A list we maintain ourselves: for test phases we can unlock individual email addresses in advance. They then sit in a table next to the accounts, with a short note on what for. If you were never on such a list, this does not concern you — and if you are, you know, because you gave us the address for it.

What goes there without us controlling it: the sign-in service records the IP address, your device or browser identifier and the time of every sign-in. These logs sit with a sub-processor (Google BigQuery); there is no assurance that this storage is located in the EU.

What does not go there: your entries, your voice recordings, your vocabulary.

Processing agreement: in place. Under the terms of service it applies automatically on entering into the contract, without separate signature (version of 1 August 2026). The European Commission's standard contractual clauses (implementing decision 2021/914, module 2) are incorporated.

4.2 The recognition service — there is none

There is no processor for voice recordings. Recognition is done by your phone’s operating system (section 2.2); the recording does not leave the device.

Why we do not use one. We asked two providers in writing whether their recognition service may carry health data under Art. 9 GDPR. Both answers were no: the certification for hosting health data under French law (HDS) covers servers, storage and networking — not the recognition service. That left two options: keep looking, or build without the transmission. We build without.

What this means: no contract, no transmission, no exception for fault cases, no open question under Art. 9 — not in France, not anywhere.

4.3 Google — Google Sign-In

Google Ireland Limited
Gordon House, Barrow Street
Dublin 4, Ireland

Only if you choose this sign-in path. Google learns that you are signing in to RecTake and transmits an identifier and your email address to us. Google processes the sign-in in its own right; Google's own privacy notices apply to that.

Google does not learn your entries. They do not leave the device.

4.4 Apple — Sign in with Apple

Apple Distribution International Ltd.
Hollyhill Industrial Estate, Hollyhill
Cork, Ireland

As with Google, only if you choose this path. Apple offers to hide your email address; in that case we receive a relay address instead of your real one. Apple also asks you for your name when signing in; we do not read that value and do not store it. Here too: no entries.

4.5 RevenueCat — subscription management

RevenueCat, Inc.
1032 E Brandon Blvd #3003
Brandon, FL 33511, USA

If you take out a subscription, this service validates the purchase. It is the party that knows, towards the App Store and Google Play, whether your subscription is valid.

What goes there: your RecTake account ID, the store receipts and technical details of your device that the embedded module sends along.

What does not go there: your entries, your voice recordings, your vocabulary. And no payment data — neither we nor this service see a card number or a billing address. Payment is handled solely by Apple and Google.

Place of processing: United States. That is a third country. The transfer relies on the European Commission's standard contractual clauses. The processing agreement forms part of the terms of service and does not need to be signed separately.

Why we transmit your account ID and not your email address: the service needs to attach the purchase to an account. The identifier is enough. The email address stays with us.

When you delete your account: the customer record at RevenueCat — your account ID and the store receipts — is not deleted automatically along with it. We delete it as part of your account deletion, within 30 days at the latest (Art. 17 GDPR). How that works is described under Delete account.

4.6 Serverprofis — domain, name resolution and email

Serverprofis GmbH
Otto-Lilienthal-Ring 34-36
85622 Feldkirchen
Germany

This is where the address rectake.de is registered, where name queries for it are answered, and where our two mailboxes sit (support@rectake.de and kontakt@rectake.de).

What goes there: your emails to us — support requests and anything you ask for under the GDPR, such as access or erasure. Our contact form sends its two emails through the same mail server (section 2.7). Plus the technical data of every name query, when your device wants to know where rectake.de points.

What does not go there: your entries, your voice recordings, your account.

Place of processing: Germany. No third-country transfer.

Which is why the deletion page and this page both say: do not send us health details by email. We never need them to resolve a request, and an email does sit on a mail server.

4.7 Nobody else

There are no further recipients. The one exception concerns the website: Google Analytics counts visits there if you agree (section 2.4a). For the app:

• no analytics SDK (no Firebase Analytics, no Amplitude, nothing comparable)
• no advertising IDs, no tracking, no sharing with ad networks
• no crash reports containing content
• no sharing with health insurers, insurance companies, employers or any other third party — under no circumstances

5. Third-country transfers

Speech recognition is not a transmission at all — it runs on your phone. Of the processing that does reach us, the database sits in Frankfurt am Main.

There is a third-country element nonetheless, in four places:

1. Account and sign-in (Supabase, section 4.1). The contracting party is established in Singapore, its support provider in the United States. There is no adequacy decision of the European Commission for Singapore, and Supabase does not participate in the EU-US Data Privacy Framework. The transfer therefore relies on the European Commission's standard contractual clauses under Art. 46(2)(c) GDPR, supplemented by the provider's transfer impact assessment of 14 March 2025.
2. Subscription validation (RevenueCat, section 4.5). Processing in the United States on the basis of the standard contractual clauses.
3. Website hosting (Vercel, section 2.4). Processing in the United States; Vercel is certified under the EU-US Data Privacy Framework (adequacy decision of 10 July 2023), and the standard contractual clauses in its data processing agreement apply in addition.
4. Visit measurement (Google Analytics, section 2.4a) — only with your consent. Google is certified under the EU-US Data Privacy Framework; standard contractual clauses apply in addition.

This concerns your account data, the sign-in logs, the account ID held by the subscription service and the website access logs. Not affected are your entries and your voice recordings — they do not leave the device at all. Domain, name resolution and email are not affected either; those sit in Germany (section 4.6).

For the sign-in paths via Google and Apple, see 4.3 and 4.4; both companies act as controllers in their own right.

6. How long data is kept

Tax and commercial retention obligations may bind individual invoice data for longer (§ 147 AO, § 257 HGB). Invoices are issued by the stores, not by us; none arise with us.

7. Your rights

Under the GDPR you have the following rights against us:

• Access (Art. 15) — which data we hold about you. With us that is a short list, because your entries are not part of it.
• Rectification (Art. 16)
• Erasure (Art. 17) — see Delete account
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Objection to processing based on legitimate interests (Art. 21)
• Withdrawal of consent (Art. 7(3)) — for the waiting list see section 13a

An informal message to support@rectake.de is enough for all of it. We reply within one month (Art. 12(3) GDPR). It costs you nothing.

An honest note on access requests: we cannot hand you your entries, because we do not have them. They are on your device. You can, however, export them yourself as a file at any time (Settings → Your data).

8. Consent

At present two processing operations rely on consent, both on the website: the waiting list (section 13a) and visit measurement with Google Analytics (section 2.4a). You can withdraw either at any time — the measurement via the button in the footer, the waiting list informally; the lawfulness of processing up to the withdrawal is unaffected (Art. 7(3) GDPR).

Speech recognition needs none. It runs on your device, the recording never reaches us, and so there is nothing on our side to consent to (section 2.2). The microphone and speech recognition are released by your operating system, not by the app: you grant and revoke those permissions in your device settings.

9. Right to lodge a complaint

You can lodge a complaint with a data protection supervisory authority if you believe we are infringing the GDPR (Art. 77 GDPR). The competent authority is the one where you live, where you work, or where the alleged infringement took place.

The authority competent for us is:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
(Hessian Commissioner for Data Protection and Freedom of Information)
Gustav-Stresemann-Ring 1
65189 Wiesbaden
Germany

https://datenschutz.hessen.de

This authority is competent because the controller is established in Wiesbaden, in the German federal state of Hesse.

10. Security

• The safest path is the one that does not exist. Voice recordings, transcripts and vocabulary are never transmitted, so they can never be intercepted, stored or logged anywhere.
• The connection between app and account endpoint is TLS-encrypted end to end.
• Your session lives in the operating system's keychain, not in a file next to the entries.
• Account data is locked down row by row on the server: a signed-in user can read their own row and no one else's, and can write none.

11. No automated decision-making, no profiling

There is no automated decision-making within the meaning of Art. 22 GDPR. We do not build profiles and do not derive any assessment of you from your data.

12. Children

The app is not directed at children. You must be at least 16 years old to use it. This matches Art. 8 GDPR on consent in information society services as applied in Germany, and the age ratings in both stores.

13. Not a medical application

RecTake is a diary, not a medical device. It gives no diagnosis and no treatment recommendation. See the disclaimer.

13a. Waiting list on this website

While the app is not in the store yet, you can leave your email address on the home page. It is used for exactly one purpose: to send you a single message — the one saying RecTake is available. No newsletter, no advertising, no sharing with third parties.

What is stored: your address, whether you are waiting for iPhone or Android, the time, the language of the page and the fact that the entry came from the website. No cookie, no identifier. We store no IP address with it; the database provider may record the request in its technical logs with an IP address, for at most seven days (section 4.1). Nothing leaves your browser until you tap “Join the list” — simply reading the page transmits nothing.

Where it is stored: in the same database as the app accounts, at Supabase in Frankfurt. The table is set up so that the website can only write to it and never read from it.

Legal basis: your consent (Art. 6(1)(a) GDPR), given the moment you submit the address. Withdrawal: any time, informally, to support@rectake.de or via the unsubscribe route contained in every message from us — we delete the entry. Leaving is no harder than joining. At the latest, we delete the entire list once the launch message has been sent.

Before the launch message goes out, we email you once to ask whether the address really is yours. Only after you confirm do we send it; if no confirmation comes, we delete the entry. We keep the time of your sign-up and your reply to the confirmation email as our record of consent (§ 7(2) no. 2 of the German Unfair Competition Act, UWG).

14. Changes to this policy

If processing changes — for instance because a new service provider is added — we change this text and update the date at the top. For material changes that require consent, we obtain it explicitly.

15. Contact

Questions about data protection, access requests, deletion: support@rectake.de

Legal notice: Legal notice · Impressum (deutsch, maßgeblich)