Privacy Policy

This privacy policy describes how BAUGEY MATHEO (DEVOLIM) processes personal data within the Rupture mobile app and the https://rupture.devolim.fr website. It complies with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) and the French Data Protection Act of 6 January 1978 as amended.

1. Data controller

The controller of personal data is:

BAUGEY MATHEO (DEVOLIM)
248 rue de Bègles, 33800 Bordeaux, France
Business ID (SIREN): 948 000 757
Email: [email protected]

Given the volume and nature of the processing, appointing a Data Protection Officer (DPO) is not mandatory. For any question about your data, write to the address above.

2. Data processed and purposes

2.1 Data stored locally on your device

The app stores exclusively on your phone, with no transmission to a DEVOLIM server:

• Your journal, letters and notes (text, associated mood, date).
• Your progress through the path and exercises.
• Your preferences: notifications, daily check-in time, sounds, display settings.
• The app lock passcode, if any: it is never stored in clear text — only a hash (SHA-256 with a random salt) is kept.
• Your Rupture+ status (member or not) and the subscription metadata needed to display it.

This data is stored via the native secure APIs of iOS and Android (Keychain / EncryptedSharedPreferences, encrypted storage for sensitive data). It is permanently deleted when you uninstall the app or via “Erase everything” in the settings. The passcode, Face ID, Touch ID or fingerprint lock lets you protect access to this space. You remain responsible for the content you enter in the app; please avoid including sensitive information about identifiable third parties without their consent.

2.2 Conversations with Glow (AI companion)

Glow relies on a conversational AI model. When you write to it, the content of your message (and the current conversation thread) is sent, via our secure server (Google Cloud Functions), to our AI provider OpenAI to generate a response, which is then returned to you.

• These exchanges are transmitted solely to produce Glow's response (service performance).
• They are not tied to your identity (no name or email is sent) and are not used for advertising.
• In accordance with OpenAI's API terms, content sent via the API is not used to train OpenAI's models.
• We do not build a named history of your conversations on our servers; the thread is kept locally on your device.

Progress analysis (Rupture+): if you are a Rupture+ member and use the progress-analysis feature, elements of your progress and recent entries are likewise sent to OpenAI for the time needed to produce the analysis shown to you. You may choose not to use this feature.

Important: Glow is not a healthcare professional. See § 11 “Disclaimer”.

2.3 Anonymous technical account and Firebase services

To manage the Rupture+ subscription and keep the app working, Rupture uses several Google Firebase services:

• Firebase Authentication (anonymous): an anonymous technical identifier is created for your device. It contains no name, email or phone number. It is only used to attach your Rupture+ status and to prevent sharing of a single purchase across multiple accounts.
• Cloud Functions / Firestore: our servers verify the validity of your purchases (Apple/Google receipts) and store, linked to your anonymous identifier, the subscription expiry date and a hash of the purchase receipt for fraud prevention. None of your journal data is stored there.
• Firebase App Check: secures access to our servers by verifying that requests come from the genuine app.
• Firebase Crashlytics (with consent): automatic technical crash reports (anonymized trace, device model, OS version) to fix bugs. No personal data.

2.4 In-app purchases (Apple / Google)

The app offers the Rupture+ subscription in three plans:

• Weekly — auto-renewing;
• Monthly — auto-renewing;
• Quarterly — auto-renewing.

All transactions are handled by Apple StoreKit (iOS) or Google Play Billing (Android). DEVOLIM receives neither your identity, nor your payment details, nor your postal address. Only a signed purchase receipt is verified (server-side) to confirm your subscription's validity.

• Apple Privacy Policy
• Google Privacy Policy

2.5 Advertising (free version only, with consent)

The free version of Rupture shows, in discreet placements, ads provided by Google AdMob:

• banners and in-content rectangles;
• interstitial (full-screen) ads at transition points, frequency-limited;
• app open ads;
• rewarded ads, triggered only by your explicit action (e.g. unlocking a step).

Out of respect, no ads are shown in the most sensitive contexts (while writing in the journal, or chatting with Glow).

AdMob may process certain technical identifiers (advertising ID — IDFA on iOS / AAID on Android, device type, OS version, language, IP address, impression and click events) for measurement and personalization.

Prior consent required: at first launch (EU, EEA, UK, Switzerland), a Google UMP (User Messaging Platform) consent form collects your choice. Until consent is granted, no ads are served and no advertising ID is transmitted. On iOS, Apple's App Tracking Transparency (ATT) adds a separate authorization prompt before any tracking; if you decline, your IDFA is not shared.

Revocation: you can change your preferences anytime in the app Settings, or via your system's ad settings. By subscribing to Rupture+, all ads are disabled and no further advertising data is sent to AdMob.

More information: Google advertising policy.

2.6 Local notifications

If you enable them, Rupture schedules reminders (e.g. the daily check-in or a morning thought). These notifications are 100% local: handled by your phone's operating system, with no push server.

2.7 Website https://rupture.devolim.fr

The website is static and uses no analytics cookie, no advertising pixel, no tracking tool. When you email us at [email protected], we process your email address and message solely to reply; these exchanges are kept for a maximum of 3 years from the last contact.

3. Legal bases

• Local storage (journal, progress, preferences, passcode): performance of the contract — Art. 6.1.b GDPR.
• Conversations with Glow and progress analysis: performance of the contract (delivery of the requested feature) — Art. 6.1.b GDPR.
• Subscription management and anti-fraud (Firebase, receipts): performance of the contract and legitimate interest in fraud prevention — Art. 6.1.b and 6.1.f GDPR.
• Advertising (AdMob): consent — Art. 6.1.a GDPR (revocable anytime).
• Crash reports (Crashlytics): consent — Art. 6.1.a GDPR.
• Replying to your emails: legitimate interest in communication — Art. 6.1.f GDPR.

4. Data recipients (processors)

Apart from yourself, the third parties that may process technical data related to your use of the app are:

• Apple Inc. (One Apple Park Way, Cupertino, CA 95014, USA) — iOS distribution, App Store purchases.
• Google LLC (1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA) — Android distribution, Google Play purchases, Firebase infrastructure (anonymous auth, Cloud Functions, Firestore, App Check, Crashlytics) and the AdMob ad network (free version, with consent).
• OpenAI, L.L.C. (3180 18th Street, San Francisco, CA 94110, USA) — provision of the AI model that generates Glow's responses and the progress analysis.

These providers act as processors under Article 28 GDPR for the described purposes, and as independent controllers for distribution and payment. DEVOLIM has no access to any personally identifying data about you.

5. Transfers outside the European Union

Apple, Google and OpenAI may process some technical data in the United States. These transfers rely on the EU-US Data Privacy Framework (adequacy decision of 10 July 2023) and/or the Standard Contractual Clauses adopted by the European Commission.

6. Retention periods

• Data stored in the app (journal, progress, preferences, passcode): as long as the app is installed; deleted upon uninstall.
• Messages sent to the AI: processed for the time needed to generate the response. Under OpenAI's policy for API requests, they may be kept for a short period for safety/abuse purposes, then deleted, and are not used to train the models.
• Subscription expiry date and receipt hash (Firestore): kept for the duration of the subscription relationship, for management and anti-fraud.
• Crashlytics reports (with consent): kept by Google for about 90 days.
• Contact emails: 3 years from the last exchange.

7. Your GDPR rights

Under Articles 15 to 22 of the GDPR, you have the following rights:

• Right of access, rectification, erasure, restriction, objection and data portability.
• Right to withdraw your consent at any time (advertising, crash reports), from the app Settings.
• Erasure of your local data: simply uninstalling the app permanently deletes your journal and the data stored on the device.
• Full deletion from within the app: at any time, from Settings → "Erase everything and start over", you can permanently erase all of your data — both what is stored on your device and the data tied to your anonymous identifier on our servers (subscription expiry date). Only a hash of the purchase receipt is kept, for fraud prevention and to let you restore a still-active subscription.

To exercise these rights, write to [email protected]. We will respond within one month at most.

8. Complaint to the CNIL

If you believe your rights are not respected, you may lodge a complaint with the French data protection authority (CNIL):

CNIL — 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France
www.cnil.fr

9. Security

Data stored on your phone benefits from the native security of iOS and Android (encryption, app sandbox, Keychain). Exchanges with our servers are encrypted (HTTPS) and protected by Firebase App Check. We do not centralize any journal content on a server, greatly reducing exposure.

10. Minors

The app is intended for people aged at least 15. It is not intended for children and does not knowingly collect any data about a minor under 15 without the authorization of a holder of parental authority. If you are a parent or guardian and believe your child has provided us with data, please write to us: we will delete it immediately.

11. Disclaimer

Rupture is an emotional wellbeing and support tool. It is not a medical device, not psychological advice, and not a substitute for a healthcare professional. Glow is a generative companion and can be wrong. If you're going through a hard time, we encourage you to reach out to someone you trust or a healthcare professional.

12. Changes

This policy may be updated to reflect changes to the app or to regulations. The last-updated date appears at the top of this page. Any material change will be signaled to you in the app.