Privacy Policy
Section 1 — What is Tiia
Tiia is a personal skin diary app that helps you track your skin condition, log how your skin feels day to day, and understand patterns over time. Tiia is not a medical device and does not provide medical advice, diagnosis, or treatment.
Section 2 — What data we collect
We collect two categories of personal data:
Account data: Your email address and password, collected when you create an account, and the name you enter in your Profile, if you enter one. If you sign in with Apple, Apple sends us an identifier for you and your email address, which can be a private relay address Apple creates. We do not ask Apple for your name, and Apple sends no password. If you sign in with Google, Google sends us an identifier for you, your email address, your name and a link to your profile picture. We do not use the name or picture Google sends; they stay with your account until you delete it. Google sends no password.
Health data: Information about your skin condition, daily skin state check-ins, products you use and their ingredients, and the content of your conversations with Tiia. This is special category data under GDPR Article 9.
Section 3 — Why we collect it and our legal basis
Account data: We collect account data to provide you with access to Tiia and to manage your account. The legal basis is performance of a contract (GDPR Article 6(1)(b)).
Health data: We process health data on the basis of your explicit consent under GDPR Article 6(1)(a) and GDPR Article 9(2)(a), split into two separate choices:
- Diary storage consent — lets Tiia store your skin check-ins, shelf, and journal. This is required to use the app, since it's the core function Tiia provides.
- AI companion consent — lets Tiia send your journal text to our AI service provider (currently Anthropic, see Section 5) to generate companion responses, emotional tone analysis, and pattern insights. This is optional — the journal works completely without it.
You may withdraw your consent at any time, from Profile → Data & Privacy.
Withdrawing AI companion consent turns off the companion and switches you to journal-only mode. Your check-ins, shelf, and account stay exactly as they are — nothing is deleted.
Withdrawing diary storage consent is only possible by deleting your account entirely, since diary storage is the core function the app provides. See Section 8 for how to delete your account.
Section 4 — How your data is processed
Your account data and health data are stored securely in a database hosted in the EU (Frankfurt, Germany). Our database provider's staff in the United States and Singapore can access it remotely to operate and support the service, under the safeguards in Section 5.
When you send a message to Tiia, the content of that message and relevant context from your history is sent to our AI service provider (currently Anthropic's Claude API) to generate Tiia's response. This processing currently occurs outside the EU — see Section 5 for details.
What "Tiia remembers" means: Tiia's memory of your skin history is based entirely on what you have logged in the app. It is the result of algorithmic correlation of your own entries — not a clinical assessment, medical diagnosis, or professional opinion of any kind.
Section 5 — Your data processors
We use the following third-party processors to operate Tiia. No other company has access to your health data, apart from the sub-processors these processors use, such as the cloud companies whose servers they run on. Our contracts require each processor to bind its sub-processors to the same data protection obligations.
| Processor | Function | Location | Transfer mechanism |
|---|---|---|---|
| Supabase | Database storage, sign-in and the app's server functions | EU, Frankfurt; remote access for operations and support from the United States and Singapore | Standard Contractual Clauses (SCCs) |
| Anthropic | AI response generation (our current AI service provider) | United States; responses can also be generated in other countries where Anthropic's cloud providers operate | Standard Contractual Clauses (SCCs) |
| Scaleway | Sending account emails (sign-in codes, password reset) | EU, Paris | Within EU — no transfer required |
| Cloudflare | Checking that a sign-up, sign-in or password-reset request comes from a person, not a script | USA (global network) | EU-US Data Privacy Framework; Standard Contractual Clauses |
No EU adequacy decision covers the transfers to Supabase and Anthropic, so they rely on the Standard Contractual Clauses adopted by the European Commission (Implementing Decision (EU) 2021/914); you can ask us for a copy at tiia.privacy@gmail.com. Supabase, Anthropic and Scaleway are contractually prohibited from selling your data or using it for advertising purposes. Scaleway receives only your email address and the email we send you, never your journal.
Cloudflare receives only technical details of your connection (IP address, device and browser type), never your email address or your journal, and also uses them to improve its detection of automated traffic. For that improvement Cloudflare decides how the details are used, under its own privacy policy.
If we replace our AI service provider, we will update this table and tell you in the app before the new provider receives any of your data. A replacement is bound by the same terms: no selling your data, no advertising, no training on your data, and EU safeguards for any transfer outside the EU.
Section 6 — How long we keep your data
We retain your data for as long as your account is active. If you delete your account, all personal data is permanently deleted within 30 days. We do not retain any data beyond what is necessary to provide the service.
Section 7 — Your rights
Under GDPR you have the following rights regarding your personal data:
- Access — request a copy of the data we hold about you
- Rectification — request correction of inaccurate data
- Erasure — request deletion of your data
- Portability — request your data in a machine-readable format
- Withdrawal of consent — withdraw your consent to AI processing at any time without affecting your account or diary (see Section 3); withdrawing consent to diary storage requires deleting your account (see Section 8)
- Lodge a complaint — with the Polish Data Protection Authority (UODO) at uodo.gov.pl
To exercise any of these rights, contact us at tiia.privacy@gmail.com. We will respond within 30 days.
Section 8 — How to delete your data
You do not need to delete your account just to stop the AI companion — see Section 3 for how to turn that off on its own, with your diary kept intact.
To delete your entire account and all associated data, go to:
Profile → Data & Privacy → "Delete My Entire Profile and History"
This action permanently deletes all your skin entries, conversation history, shelf data, and account information. Deletion is complete within 30 days. This action cannot be undone.
Deleting your account also withdraws all consent described in Section 3.
Section 9 — Changes to this policy
We may update this policy from time to time. If we make material changes to how we process your health data, we will request your explicit consent within the app before those changes take effect. For other minor adjustments, we will notify you in-app before they go live. Replacing an AI service provider in Section 5 with one bound by the exact same terms is not a material change requiring a new consent prompt. However, we will notify you in the app before the new provider receives any data, giving you the opportunity to turn off the AI companion if you choose. The effective date at the top of this policy will always reflect the most recent version.
Section 10 — Controller details
Tiia is built and operated by the Tiia Team. The data controller responsible for your personal data is the Tiia Team, operating under the trading name Tiia, based in Warsaw, Poland. For privacy-related questions or to exercise your rights, contact us at tiia.privacy@gmail.com.