Privacy Policy

Effective date: 6 October 2026

1. Who we are and what this Policy covers

1. Ringostat LTD, a company incorporated under the laws of the Republic of Seychelles with a company registration number 177057, is the holder of the Apple App Store developer account through which the App "Tinsy" is distributed. Ringostat LTD does not collect, access, control or process any personal data of users of the App and is neither a data controller nor a data processor with respect to such data.
2. NarrativeLab OÜ, a company incorporated under the laws of the Republic of Estonia with a company number 17007093, develops the App and is the controller of personal data processed in connection with the App (collectively referred to as "we", "us" or "our").

This Privacy Policy explains what data we collect, why we collect it, on what legal grounds we process it, with whom we share it, how long we keep it, and which rights you have. It applies to the App, to the websites operated by us for the App and to any support communications you exchange with us.

Tinsy is a self-tracking and wellness tool. It allows you to log medication doses, injection sites, body weight, nutrition, hydration, symptoms and side effects, and to view your own history and trends. Tinsy is not a medical device, is not a healthcare provider, does not provide medical advice, diagnosis, treatment, prescriptions, dosing recommendations or clinical supervision, and does not create a doctor-patient relationship. Because we do not provide healthcare and do not act for or on behalf of a healthcare provider, insurer or clearinghouse, the data you enter into Tinsy is generally not "protected health information" governed by the United States Health Insurance Portability and Accountability Act, and we are neither a covered entity nor a business associate under that statute. The data is nevertheless sensitive, and we treat it as such under this Policy and under applicable data protection and consumer health data laws.

If you do not agree with this Policy, please do not install or use the App, or stop using it and delete it from your device.

1a. How the App stores your data

All tracker data you enter in the App (medication, doses, injection sites, weight, measurements, nutrition, symptoms, notes, photographs) is stored locally, in the App's own container on your device (SQLite database). We do not operate a backend server, we do not host any database on our side, and we do not have access to this data at any point, including when you contact support.

A backup of this local data is created only inside your own iCloud account (iCloud container associated with the App), where it counts against your personal iCloud storage space. This backup is controlled exclusively by Apple and by you, we have no access to it and cannot see, retrieve or delete it.

Where you enable Apple Health (HealthKit) integration, data is exchanged directly between the App and HealthKit locally on your device. This exchange never leaves your device and is never transmitted to us.

Where the App generates a PDF report for your doctor, that report is created locally on your device. You choose, through the system share sheet, whether and to whom to send it (for example, by email, messaging app or file storage). We do not receive, store or have visibility into that report or into where you choose to send it.

The App does not require you to create a Tinsy account, and no registration, login, sign-in or Tinsy account credentials are collected or processed by us.

2. Categories of data we process

We do not knowingly collect precise geolocation, contact lists, microphone recordings or advertising identifiers for cross-app tracking purposes, and we do not use Tinsy data to serve you targeted advertising.

3. Sources of data

All health, medication and body-measurement data originates from you and is entered directly into the App. The external parties involved in the handling of data are Apple (through StoreKit for in-app purchases, through iCloud for the user's own backup, through HealthKit where you enable that integration, and through anonymised crash reports if you opt in to "Share with App Developers"), Google (through Firebase Analytics and Firebase Crashlytics, as described in Section 6), and our support mailbox, if you choose to write to us. We do not collect or receive an IDFA or any advertising identifier, and health, medication or body-measurement entries are never included in analytics or crash-reporting events.

The list above concerns the App. The website operated by us for the App involves two further parties: Cloudflare, which hosts the website, through which every request to it passes, and which also measures in aggregate how the website is used, through Cloudflare Web Analytics, without storing anything on the visitor's device; and Google, through the Google Tag Manager container and the Google Analytics measurement it loads, which runs only where a visitor has consented to it. Nothing you enter in the App reaches the website, and the website receives no health, medication or body-measurement data. What the website stores on a visitor's device, and what is sent onward as a result, is described in full in our Cookie Policy.

4. Purposes of processing and legal bases

We process your health, medication and body-measurement data solely to provide the tracking functionality, namely to store your entries locally on your device, display your history, calculate trends, averages and progress, generate reminders for upcoming doses, and create a backup of your data in your own iCloud account. Where the General Data Protection Regulation applies, this processing of special-category data is based on your explicit consent under Article 9(2)(a) GDPR, given when you enable tracking of health data and, separately, when you grant Apple Health permissions.

You may withdraw that consent at any time by disabling the relevant permission or deleting the entries concerned. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

We process device, subscription and support data to make the App available, to unlock and manage paid features, to respond to your requests and to provide customer support. The legal basis is performance of our contract with you and, for support records retained for evidentiary purposes and service operation, our legitimate interests.

We use Google Firebase Analytics and Firebase Crashlytics to understand how the App is used, to detect and fix defects, and to keep the App stable and secure. These tools are configured so that Advertising ID collection is disabled and no health, medication, body-measurement or other tracker content is included in analytics or crash events. Only the technical and usage information described in Section 2 is processed. In particular, we do not send, disclose or make available your health entries, medication names, doses, injection sites, weight or body measurements, symptoms, photographs, free-text notes or Apple Health data to Firebase Analytics, Firebase Crashlytics, any attribution provider or any advertising technology provider. Additionally, basic anonymised, aggregated crash reports may be generated by Apple itself where you have separately enabled "Share with App Developers" in your iOS settings. The legal basis is our legitimate interest in operating a functioning and secure product and, where required by applicable law, your consent, which you may withdraw at any time in the App settings.

On the website operated by us for the App, we load a Google Tag Manager container and, through it, Google Analytics measurement, and we store a record of your cookie choice in your browser. The Google measurement, and the reading and writing of the cookies it uses, are carried out only where you have consented on the banner shown to every visitor, and you may withdraw that consent at any time; the legal basis is your consent. The record of your own choice is stored because a refusal that is not remembered cannot be honoured, and keeping it rests on our legitimate interest in giving effect to the answer you gave. The receipt of your internet address by Cloudflare, which hosts the website, is necessary to deliver the pages to you and to keep the service secure, and rests on our legitimate interests. Cloudflare also measures, through Cloudflare Web Analytics, how much the website is visited and how quickly its pages load, and shows us the results only as totals; because it stores nothing on your device and reads nothing from it, this measurement is not covered by the banner and rests on our legitimate interest in understanding, in aggregate, how the website is used. All of this is described in full in our Cookie Policy.

We process data to comply with legal obligations, including accounting, consumer protection, sanctions and export control obligations, and to establish, exercise or defend legal claims. The applicable legal bases are compliance with a legal obligation, our legitimate interests, and, where applicable to special-category data, the establishment, exercise or defence of legal claims.

Health data is never used for marketing, advertising, advertising profiling, credit or insurance decisions, or for sale to third parties.

5. Apple Health and Apple platform commitments

Where you connect Tinsy to Apple Health, the data exchange with HealthKit takes place exclusively and locally on your device; the App reads and, where applicable, writes only the specific HealthKit data types for which you grant permission, and this data is never transmitted to us or to any server. Data obtained through the HealthKit API is used only to provide the tracking functionality inside the App on your device. It is never used or disclosed for advertising, marketing, remarketing or use-based data mining, is never sold, rented or licensed to data brokers, and is not stored by us in iCloud or on any backend, because we do not operate one. You may review, change or withdraw HealthKit permissions at any time in the iOS Settings or in the Health app.

6. Disclosure of data / third-party services

Your tracker and health data, including medication, doses, injection sites, weight, measurements, nutrition, symptoms, notes and photographs, is stored only locally on your device and is never transmitted by us to any processor, vendor or affiliate, including Firebase. We do not send, disclose or make available your health entries, medication names, doses, injection sites, weight or body measurements, symptoms, photographs, free-text notes or Apple Health data to Firebase Analytics, Firebase Crashlytics, any attribution provider or any advertising technology provider. The external recipients involved in the operation of the App, and what each receives, are set out below.

Actual data recipients:

Website recipients:

The recipients above relate to the App. The website operated by us for the App has its own, which receive no data from the App and no health, medication or body-measurement data of any kind.

Should we integrate additional third-party tools beyond those listed in the tables above, we will update this Section 6 before such integration takes effect.

We may also disclose your data where we are legally required to do so, in response to a valid and binding request from a competent public authority or court, to comply with sanctions and export control rules, or where disclosure is necessary to protect our rights, the safety of users or the security of the App, and to establish, exercise or defend legal claims. If our business or the App is transferred in whole or in part, for example in a merger, acquisition, reorganisation or sale of assets, data may be transferred to the acquirer, which will remain bound by this Policy for the data concerned.

In any case we do not sell your personal data, we do not share it for cross-context behavioural advertising, and we do not disclose health or medication data to advertisers, data brokers, employers or insurers.

7. International transfers

Because your tracker and health data is stored only locally on your device and is never transmitted to us, there is no international transfer of that data by us. Technical and usage data processed through Firebase Analytics and Firebase Crashlytics, and data that leaves your device to Apple (for StoreKit purchases, iCloud backup and, if enabled, crash reports), may be transferred to and processed in the United States or other countries where Apple and Google operate, under their respective privacy terms and the safeguards described below.

Website usage data processed through Google Tag Manager, Google Analytics and Cloudflare Web Analytics, and the request data necessarily received by Cloudflare as the website's host, may likewise be transferred to and processed in the United States or other countries where those providers operate. For transfers to the United States, Google and Cloudflare each state that they rely on the EU-U.S. Data Privacy Framework, together with the Swiss-U.S. Data Privacy Framework and the UK Extension to it, and on the European Commission's Standard Contractual Clauses where no such framework applies.

Should we integrate any of the additional third-party services described in Section 6, some of which may be based in or transfer data to the United States or other countries, we will rely on the safeguards described below and update this Policy accordingly before such integration takes effect.

• Adequacy Decisions: Where applicable, we rely on countries or recipients that the European Commission have recognized as providing an adequate level of data protection. For instance, if a service provider is certified under a framework like the EU-U.S. Data Privacy Framework or if they operate in a jurisdiction with an adequacy decision, your data is afforded protection deemed equivalent to EU standards.
• Standard Contractual Clauses (SCCs): For transfers to countries without an adequacy decision (for example, Ukraine or the United States, if the provider is not certified under an approved framework), we use the European Commission’s Standard Contractual Clauses (SCCs) or the UK’s International Data Transfer Addendum as part of our contracts with those service providers. These are legally binding commitments that require the recipient to protect your data according to EU/UK privacy standards.
• Additional Safeguards: In addition to SCCs, we assess each transfer to determine if additional technical or organizational measures are needed. This may include end-to-end encryption of data, strict access controls, and routine audits. For example, sensitive data may be encrypted in transit and at rest, and only stored in cloud environments with robust security certifications. We also monitor developments in privacy law and guidance. If new transfer mechanisms become available or if legal conditions change, we will adapt our practices accordingly.
• Transparency: You can contact us (see Section 14) for more information about the international transfer safeguards we have in place. Our goal is to ensure that your personal information enjoys a high standard of protection wherever it is processed.

Please note that if you use the "Share with App Developers" crash-reporting feature or use the system share sheet to send your PDF report through a third-party app (for example, email or messaging), your data is transmitted to and handled according to the privacy practices of that third party, which we do not control.

8. Retention

We keep the data you enter into the App for as long as it remains stored locally on your device, because the purpose of the App is to maintain your own longitudinal history. You may delete individual entries at any time, and deletion in the App removes the entry from your local dataset. Because we do not hold your data on any server, we cannot delete it remotely; deleting the App or its data from your device, and separately from your own iCloud backup, is entirely within your control.

Because your tracker data is stored only locally on your device and backed up only within your own iCloud account, we do not control or set any retention or rotation period for that backup; retention is governed by your own device and iCloud settings. Support correspondence is retained for 6 months from the closure of the request. Subscription and transaction records available to us are limited to Apple's aggregated sales reports and are retained for the period required by accounting, tax and consumer protection law in the relevant jurisdiction. Usage data processed through Firebase Analytics is retained in accordance with the retention setting configured on the linked analytics property, currently 2 months, after which it is deleted or retained only in aggregated form that cannot be linked to you or to your device. Crash data processed through Firebase Crashlytics is retained for 90 days, a period fixed by Google and not configurable by us.

Website measurement data processed through Google Analytics is retained in accordance with the retention setting configured on the property, currently 2 months, after which it is deleted or retained only in aggregated form. The analytics cookies described in our Cookie Policy expire as stated there, and the record of your cookie choice remains in your browser until you clear this site's data. Neither is held by us on any server.

9. Security

We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption of data in transit using TLS, encryption at rest, authentication and role-based access control, the principle of least privilege for personnel access, logging of administrative access, segregation of production and development environments, secure software development and dependency review practices, and periodic review of our security controls and of those of our processors. Health entries stored on your device are protected by the security features of iOS, including device passcode and file-level encryption. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please protect your device and your device passcode and inform us without delay at the address in Section 14 if you believe the security of your device or data has been compromised. Where a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, you, within the deadlines set by applicable law.

10. Your rights

Subject to the conditions and exceptions of the law applicable to you, you may have the following rights in relation to personal data that we process or control:

1. the right to request access to that data;
2. the right to request rectification of inaccurate or incomplete data;
3. the right to request erasure of data from our systems;
4. the right to request restriction of processing;
5. the right to data portability, where applicable;
6. the right to object to processing based on our legitimate interests; and
7. where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

Health and tracker entries are stored locally on your device and, where applicable, in your own iCloud backup. We do not hold or control those entries and cannot access, correct, export or delete them for you. You can view, edit and delete such entries directly in the App and manage Apple Health permissions in iOS Settings or in the Health app. The App may generate a PDF report locally on your device; it does not provide a general export of the underlying tracker database.

Your statutory rights may apply to support, technical, usage and subscription-related data that we process or control. To exercise a right, please contact us using the contact details in Section 14. We will respond without undue delay and, where the GDPR applies, normally within one month of receiving your request. We may extend that period by up to two further months where permitted by law and where necessary because of the complexity or number of requests; if so, we will inform you of the extension and the reasons for it within the initial one-month period.

We may ask for information reasonably necessary to verify your identity and will not use that information for any other purpose. Exercising your rights is free of charge unless a request is manifestly unfounded or excessive. You may use an authorised agent where the law allows it, provided that the agent submits evidence of authorisation.

We do not sell personal information, do not share it for cross-context behavioural advertising and use sensitive personal information, including health and medication information, only to provide the Services you request, to secure the Services and to comply with law.

If we deny a request, you may appeal by writing to the address stated in Section 14 with the subject line "Privacy Appeal". We will inform you of the outcome and the reasons within the period prescribed by applicable law.

If you are in the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with the data-protection supervisory authority in the country of your habitual residence, place of work or the place of the alleged infringement. The supervisory authority of NarrativeLab OÜ is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). If you are in the United Kingdom, you may also lodge a complaint with the Information Commissioner's Office.

11. Children’s privacy

Tinsy is intended for adults and is not directed at children. We do not knowingly collect personal data from persons under the age of eighteen or under the minimum age required in the user's jurisdiction for the provision of the App without parental consent. If you believe that a minor has provided us with personal data, please contact us at the address in Section 14 and we will delete the data without undue delay.

12. Geographic availability and restrictions

Tinsy is distributed worldwide through the Apple App Store with the exceptions determined by us and by applicable law, and it is not offered in mainland China, in the territories of Ukraine temporarily occupied by the Russian Federation, or in countries and territories subject to comprehensive sanctions or embargoes administered by the Office of Foreign Assets Control of the United States Department of the Treasury, the European Union or the United Kingdom. Where you access the App from such a location, we may be legally required to refuse or terminate service, and we may process the country information described in Section 2 for that purpose.

13. Changes to this Policy

We may update this Policy to reflect changes in the App, in our processing operations or in applicable law. The current version is always available in the App and at https://tinsy.app/privacy-policy.

14. Contact

For any question relating to this Policy or to exercise your rights, contact us at support@tinsy.app.

Company name: NarrativeLab OÜ

Post address: Estonia, Harju maakond, Tallinn, Lasnamäe linnaosa, Valukoja tn 8/2, 11415

Phone: + 372 (61) 04186