Privacy Policy

1. Data Controller

Johannes Kropatschek
Vienna, Austria
Email: office@hydrapt.com

2. Scope and Purpose

This policy applies to the use of the App on iOS/iPadOS. The App provides cognitive training and self-assessment features for informational and entertainment purposes.

3. What Data Does the App Process?

The following data is processed exclusively on your device and is never transmitted to the developer:

• Usage and performance data (on-device): Test progress, answers, scores, timer states, local result overviews.
• App settings (on-device): e.g., light/dark mode, UI preferences.
• No special categories: No health or biometric data in the legal sense is collected or transmitted.
• No advertising IDs or analytics SDKs.

When you install Hydra Trainer from the App Store, Apple collects and aggregates telemetry data and provides it to us. This information includes the number of people who downloaded the app, the number of people who used it on a given day, and the total number of users per country. Apple does not share information about specific users with us.

3a. Leaderboard (Optional Server-Side Processing)

If you choose to participate in the leaderboard, the App transmits the following data to a server operated by the developer:

• Your self-chosen, anonymous username.
• Test scores and associated timestamps.

No other personal data is transmitted. In particular, no IP addresses are logged by the application, no device identifiers are collected, and no tracking takes place.

Server location: The leaderboard server is hosted by Hetzner Online GmbH, Nuremberg, Germany (EU). A data processing agreement (AVV/DPA) is in place with Hetzner.

Purpose: The data is processed solely to provide the leaderboard functionality, allowing you to compare your results with other users.

Voluntary participation: Leaderboard participation is entirely optional. You can use all App features without submitting any data to the server.

4. Purposes and Legal Bases (GDPR)

• Provision of the App (Art. 6(1)(b) GDPR): Processing of the above-mentioned on-device data is necessary to provide the app features (tests, results, settings).
• Consent (Art. 6(1)(a) GDPR): When you actively choose to participate in the leaderboard by creating a username, the transmission of your username and scores to our server is based on your consent. You can withdraw consent at any time by deleting your username in the App, which also removes your data from the server.
• Legitimate interest (Art. 6(1)(f) GDPR): General app security and stability on your device.

5. Retention and Deletion

• On the device: Data remains stored until you reset it in the App (if a reset function is available) or uninstall the App.
• Leaderboard data on the server: Your username and scores are stored on the server until you delete your username in the App. Deleting your username removes all associated data from the server. Uninstalling the App alone does not automatically delete server-side leaderboard data. To ensure deletion, please remove your username in the App before uninstalling, or contact office@hydrapt.com.

6. Recipients and Disclosure

Leaderboard data is hosted on servers provided by Hetzner Online GmbH (Nuremberg, Germany). Hetzner acts as a data processor under a data processing agreement (AVV/DPA). No data is shared with other third parties.

No international data transfers. All server-side processing takes place within the EU.

7. App Permissions

The App does not use any sensitive device permissions such as camera, microphone, contacts, calendar, photos, location, or HealthKit. Should this change in the future, you will be asked for consent before use, and this policy will be updated.

8. Your Rights (Art. 12-23 GDPR)

You have the right to access, rectification, erasure, restriction of processing, data portability, and objection.

For on-device data, these rights can be exercised by you directly (reset function or uninstallation).

For server-side leaderboard data, you can exercise your right to erasure by deleting your username in the App, which removes all associated data from the server. For all other rights regarding server-stored data (e.g., access, rectification, data portability), please contact office@hydrapt.com.

9. Minors

The App is not specifically aimed at children. No tracking or collection of personal data by the developer takes place.

10. Data Security

On-device data processing is subject to the security mechanisms of iOS/iPadOS. Please protect your device (e.g., device passcode, Face/Touch ID).

Server-side leaderboard data is transmitted over encrypted connections (TLS) and stored on servers within the EU operated by Hetzner Online GmbH, which maintains appropriate technical and organizational security measures.

11. External Services

The App does not integrate any external analytics services, ad networks, or social plugins. The only external connection made by the App is to the developer's leaderboard server (hosted by Hetzner in Germany), and only if you choose to participate in the leaderboard. Any operating system functions (e.g., system-wide crash reports to Apple, if enabled by you) are Apple's responsibility.

12. Changes to This Policy

We may update this privacy policy if features or legal requirements change. The current version is always available in the app or via the linked notice. See date above.

13. Contact & Right to Complain

Privacy questions: office@hydrapt.com

You also have the right to lodge a complaint with a data protection supervisory authority. In Austria: Austrian Data Protection Authority (dsb.gv.at).

Disclaimer (Not a Medical Device)

The App serves training, information, and entertainment purposes. It is not a medical or psychological diagnostic or therapeutic tool and does not replace professional advice, diagnosis, or treatment.