Privacy Policy

This is the privacy policy for Gem Habits, published by iMix Labs (Uppervox LLC). The same text is at gemhabits.com/privacy.

Effective 12 October 2026 · Last updated 13 October 2026

Privacy Policy

The short version: Gem Habits has no account, no analytics, no advertising and no tracking. We run no servers that receive your app data, and we treat everyone’s data to the GDPR standard, wherever you live.

1. Who is responsible for your data

The data controller for the Gem Habits app for iPhone and Apple Watch (the “app”) and this website is Alex Costa, a sole proprietor doing business as Uppervox, 1057 Saratoga St, Boston, MA 02128, United States, reachable at hello@uppervox.com (“we”). The operator works from the European Union; we therefore apply the EU General Data Protection Regulation (GDPR) as our baseline standard for every user, wherever you live, alongside the UK GDPR, the California Consumer Privacy Act and other laws that apply to you. We have not appointed a data protection officer because the law does not require one for this processing; write to the address above about anything in this policy.

2. What the app stores, and where

Your rituals live on your device and, if you use iCloud, in your own private iCloud, which Apple holds and we cannot read. We never receive any of the following.

• Rituals (name, icon, colour, schedule, daily target, reminder times, archived state): on your device, and in your iCloud private database if iCloud is on.

• Daily check-ins, rest days and one-line journal notes: same.

• Appointments you add (“bookings”: title, place, date, note): same.

• The Apple Health goal you set on a ritual (which measure and the threshold): same. It contains no Health readings.

• Your first name and personal intention, if you enter them: on your device only.

• App settings (appearance, morning line, when your day starts, quiet hours): on your device only.

• Premium status (yes or no): on your device, shared with the widget and Apple Watch.

The widgets and the Apple Watch app read the same data on your own devices through an App Group.

3. Apple Health

Health-linked rituals are optional and part of Premium. When you turn one on, Gem Habits asks to read these measures: steps, exercise minutes, workouts, sleep, mindful minutes, active energy, walking and running distance, and water. Gem Habits reads up to the last 400 days to work out which days met your goal.

• Gem Habits only reads. It never writes to Apple Health.

• Health data is processed on your device (iPhone and Apple Watch) only. It is not sent to us, not shared with anyone, and not used for advertising or marketing.

• The result (which days met your goal) is kept in a file on your device. It is not stored in iCloud and is excluded from device backups. Each device works it out again from its own Health data.

• The choice of measure and threshold for a ritual (for example “sleep, 7 hours”) is part of the ritual and syncs through iCloud like any ritual setting. It contains no Health readings.

• Data from other apps and devices (for example Oura, WHOOP or Fitbit) reaches Gem Habits only if you have those services write to Apple Health. We have no connection to them.

• Turn access off any time in Settings → Health → Data Access & Devices → Gem Habits, or in the Health app under your profile → Apps.

3a. Calendar

Apple Calendar is optional and part of Premium. Gem Habits asks for Calendar access only when you tap Connect Apple Calendar or turn on a Calendar switch in Settings, never at launch.

• What is read: the events in the calendars you tick, for the week you are looking at. They are shown beside your rituals and held in memory only. They are not stored, not sent to us, not shared, and not used for advertising.

• What is written: your bookings, and your daily and weekday rituals as all-day events, are added to a calendar named “Gem Habits”. Gem Habits never edits or deletes events in any other calendar. Changes you make to the Gem Habits calendar in Apple Calendar are overwritten at the next sync.

• Where it lives: the Gem Habits calendar is in Apple Calendar, under your control. If your Apple Account uses iCloud Calendar, Apple syncs it to your other devices under Apple’s terms; we cannot see it.

• How to remove it: turn off “Add to Apple Calendar” in Settings and choose Remove, or delete the Gem Habits calendar in the Calendar app. “Delete all my data” removes it too. You can withdraw access at any time in iOS Settings → Gem Habits → Calendars.

4. Why, and on what legal basis

• Running the app on your devices (rituals, check-ins, journal, bookings, reminders, widgets, Apple Watch, export and backup): performance of a contract, GDPR Art. 6(1)(b). This happens on your devices; we receive none of it.

• Apple Health: Health data is special-category data. It is read only with your explicit consent, Art. 9(2)(a) and Art. 6(1)(a), which you give in Apple’s Health permission screen and may withdraw at any time in Settings. It is processed on your device only.

• Apple Calendar: read and written only with your consent, Art. 6(1)(a), given in Apple’s Calendar permission screen and withdrawable at any time in Settings. It is processed on your device only.

• iCloud sync, if you turn it on: performance of a contract, Art. 6(1)(b). Apple stores the data in your own iCloud account under Apple’s terms.

• Subscriptions: performance of a contract, Art. 6(1)(b). Apple is the seller and handles payment as its own controller; we receive only anonymous sales reports.

• Answering your emails: legitimate interests, Art. 6(1)(f), in helping you; and, where relevant, legal obligation, Art. 6(1)(c).

• Delivering and protecting this website: legitimate interests, Art. 6(1)(f), in keeping the site available and secure.

No decision with legal or similarly significant effect is made about you by automated means, and we do no profiling.

5. Notifications

Ritual reminders, appointment reminders and the optional daily “morning line” are local notifications scheduled on your device. No push service or third party is involved. Turn them off in Settings → Notifications → Gem Habits.

6. Purchases

Subscriptions are handled by Apple through the App Store. We do not receive your name, email or payment details. The app asks Apple, on your device, whether your subscription is active. Apple’s privacy policy applies to the purchase.

7. Analytics, advertising and tracking

None. The app contains no analytics, advertising, crash-reporting or tracking software, and does not track you across other companies’ apps or websites. The app does not need the internet to work; it opens web links (this policy, support, App Store review) only when you tap them.

8. This website

The Gem Habits site uses no cookies and no analytics scripts, so there is nothing to consent to. It is served by Cloudflare, which processes standard request data such as IP address to deliver and protect the site. If you email us, we receive your email address and message and use them only to reply.

9. Who receives data

We do not sell, rent or share personal data. The only providers involved are:

• Apple: App Store purchases, iCloud sync in your own account, and Apple Health on your device.

• Cloudflare: hosting and security for this website.

• Zoho: our email provider, which holds support emails you send us.

10. International transfers

Our providers are established in the United States, so if you are in the EEA, UK or Switzerland, website request data and any email you send us are transferred there. Your app data is not transferred by us; iCloud data is handled by Apple, which may process it in several countries under its own terms. Apple and Cloudflare are certified under the EU–US Data Privacy Framework (and its UK and Swiss extensions); for every transfer, including to Zoho, we additionally rely on the European Commission’s Standard Contractual Clauses and the equivalent UK and Swiss clauses. You can ask us for a copy of the safeguards in place.

11. How long we keep it

• Everything on your devices (rituals, history, notes, bookings, settings, Health results): until you delete it in the app or delete the app.

• Your iCloud copy: until you delete it in the app or in iCloud settings.

• Support emails: 24 months after our last exchange, then deleted.

• Website request data: kept by Cloudflare under its own retention for delivery and security; we do not export or store it.

12. Your rights

Wherever you live, you can exercise every right below; we do not limit them to any region. Under the GDPR and UK GDPR these are legal rights; elsewhere we honour them as a matter of policy. Because your app data stays on your devices, most rights work directly in the app.

• Access and portability: Settings → About → Export your history (CSV) or Back up everything (JSON). The file is saved or shared wherever you choose; it is never sent to us.

• Rectification: edit any ritual, note, booking or setting in the app.

• Erasure: Edit ritual → Delete ritual and its history removes it everywhere, including iCloud. Deleting the app removes its local data. Remove the iCloud copy in Settings → [your name] → iCloud → Manage Account Storage → Gem Habits. For support emails, ask us and we delete them.

• Withdraw consent: turn off Health access in Settings → Health → Data Access & Devices → Gem Habits. Withdrawal does not affect processing before it.

• Object or restrict: object to processing based on our legitimate interests, or ask us to restrict it, by email; we will stop unless we have compelling grounds that override your interests.

• Complain to your local data-protection authority. In the EU you can find yours at edpb.europa.eu; in Portugal it is the CNPD; in the UK the ICO. We would appreciate the chance to resolve it with you first.

Email requests to hello@uppervox.com. We answer within 30 days, free of charge.

13. United States residents

Residents of California (CCPA/CPRA) and other states with privacy laws have the right to know, access, correct and delete personal information, to obtain a portable copy, to opt out of sale, sharing and targeted advertising, to limit the use of sensitive personal information, and not to be discriminated against for exercising any right. We do not sell or share personal information as those laws define it, do not use it for targeted advertising, and do not use sensitive personal information beyond giving you the feature you turned on, so there is nothing to opt out of. We honour Global Privacy Control signals as a matter of course.

14. Children

Gem Habits is not directed to children under 13 (or under 16 where local law sets that age) and we do not knowingly collect information from anyone.

15. Security

Your data on your devices is protected by iOS and watchOS security; iCloud data is encrypted by Apple; this website is served only over TLS. If a breach ever affects personal data we hold, we will notify you and the relevant authority as the law requires, normally within 72 hours of becoming aware of it.

16. Apple’s privacy label, in plain words

The App Store privacy label for Gem Habits says Data Not Collected. That is accurate because nothing the app handles is sent to us or to any third party: Health data stays on your device, and synced data goes only to your own iCloud. Whenever the app changes, we update the label and this policy together.

17. Not medical advice

Gem Habits is a wellness and habit tool. It is not a medical device and does not give medical advice. See the Terms of Use.

18. Changes

If this policy changes we will update this page and its dates. Material changes will also be noted in the app’s release notes.

19. Contact and complaints

Alex Costa (doing business as Uppervox) Attn: Privacy 1057 Saratoga St Boston, MA 02128 United States Email: hello@uppervox.com