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Gailuh Privacy Policy

This policy explains what personal data we process when you use Gailuh —the iPhone and Apple Watch app, its widgets and complications— and the gailuh.com website, what for, who we share it with, how long we keep it and how to exercise your rights. If anything is unclear, write to us.

Last updated: 14 October 2026 · Version 2.2


1. The essentials

Controller Irakai Studio SL (Spanish tax ID B95935615) · hola@gailuh.com
What for To provide the service (your account and your records, synced across your devices), to manage your Pro subscription, to protect the service, to fix errors and, unless you turn it off, to measure app usage in pseudonymised form so we can improve it; we also count website visits, without cookies.
Why we may Contract, to provide the service you ask for; legitimate interest, which you can object to, for security, error diagnostics and analytics.
Who else processes it Providers working on our behalf (hosting, sync, subscriptions, email, analytics and diagnostics). We do not sell your data or use it for advertising.
Outside the EU RevenueCat and Resend process data in the United States and Google uses its worldwide network; the others host your data in the EU, although they may access it from outside. Always under standard contractual clauses or an adequacy decision of the European Commission (section 9).
Your rights Access, rectification, erasure, objection, restriction and portability, and the right to complain to the Spanish Data Protection Agency (AEPD) or the authority in your country. You can delete your account from within the app. If you live outside the EU, see also section 19.

2. Who the controller is

Data Protection Officer: we have not appointed one because none of the cases that require one applies (Article 37 of the General Data Protection Regulation, GDPR, and Article 34 of Spain’s Organic Law 3/2018, LOPDGDD). For any privacy matter, write to the contact email.


3. What data we process

3.1. Your account data

3.2. What you record in the app

Your beauty devices (catalogue model or the name, brand and technology you type, body zones and their labels, duration and status), your fitness and supplement routines (name, category, duration, zones and notes), your schedules and reminders (weekly goal, days and time, and their change history) and your usage records: when you mark something as done and where from (app, widget, Apple Watch or notification), pauses, freezes and counters. Streaks are calculated on your device.

3.3. Data about your photos (without the image)

For each progress photo, only the date, the body zone and the device or routine it belongs to, to order your series and apply your plan’s limits; and your save a copy to Photos preference and the date we suggested turning it on, so your choice is respected on all your devices.

3.4. Suggestions for the device catalogue

If you manually add a device that is not in the catalogue, we keep its name, brand and technologies as a suggestion to grow the shared catalogue. Only the generic product listing goes into the catalogue, never who suggested it.

3.5. Purchases and subscription

3.6. Apple Watch

So that the watch has its own session, we process a watch identifier (the vendor identifier iOS assigns to Gailuh on that Apple Watch), its session credentials (on the server, only as a hash) and, if you sign in on the watch with a code, your email to send it to you.

3.7. Service security

To prevent abuse we keep attempt counters linked to a fingerprint of the IP address or of the watch (computed with a secret key, so the IP cannot be derived from it) or to your internal identifier, and a record of each account deletion process with the status of its steps. Our server providers also log the IP address and technical data of each connection.

3.8. Product analytics (PostHog)

Unless you turn it off (section 13), the app sends usage events (for example, whether a sign-in worked and with which method, whether a purchase completed or whether a use was marked) and the analytics component adds automatic events, such as the app being opened, installed or updated, or repeated taps on a screen, with its technical name. Our server also records, with the same identifier and only if you have not turned analytics off, the outcome of some Apple Watch session operations. A filter drops device and routine names, text you type, photos, emails and names before sending. The events carry:

3.9. Error diagnostics (Sentry)

When the app or our server hits an error, we send a technical report: type of error, where in the code it happened, device model and system and app versions; for app errors, also a pseudonym of your account (a fragment of a salted hash of your internal identifier). Before sending, we remove or mask messages, text and identifiers that could contain personal data. For iPhone errors, the report includes a screen replay of the moments before and, where applicable, the rest of that usage session, configured to mask all text and all images. It does not depend on the analytics setting (section 13).

3.10. Communicating with you

3.11. The gailuh.com website

3.12. Data that never reaches our servers

Your progress photos, the share cards (which only go to the app or contact you choose), your Face ID, appearance and analytics preferences and your scheduled reminders never reach our servers or our providers’ servers: they stay on your iPhone or Apple Watch and, if it is on, in your iPhone’s iCloud Backup (section 4). The app also keeps a copy of your data on the device so it can work offline and show it in widgets and on the watch.

3.13. What we do not process

We do not access your GPS location, contacts, calendar, microphone or Apple Health (HealthKit), or process data about your menstrual cycle (section 4). We do not use the advertising identifier (IDFA), our providers do not receive it, and we do not track you across other companies’ apps or websites; that is why the app does not show you Apple’s tracking request.

3.14. Is this health data?

Gailuh does not ask about illnesses, diagnoses, medication, weight or your menstrual cycle, and we do not infer information about your health from your records or build profiles with them. That is why we treat them as ordinary personal data, with the same safeguards as everything else, and never for advertising or marketing. Please do not write information about your health in the free-text fields (names, zone labels and notes); if you do, that text is only stored, synced and shown to you, without being analysed or sent to analytics or error diagnostics.


4. Your progress photos, Face ID and backups


Purpose Data Legal basis (GDPR)
Your account: creating it, signing in, recovering access and deleting it, including revoking Gailuh’s access to your Apple Account 3.1, 3.10 Performance of the contract (Art. 6(1)(b))
Providing the service: storing and syncing your records across iPhone, Apple Watch and widgets, calculating your progress and scheduling reminders 3.2, 3.3, 3.6 Performance of the contract (Art. 6(1)(b))
Pro subscription: each plan’s limits, restoring purchases and billing issues 3.5 Performance of the contract (Art. 6(1)(b)); for purchase notifications not linked to an account, legitimate interest in resolving billing issues and defending ourselves against claims (Art. 6(1)(f))
Growing the shared catalogue with your suggestions 3.4 Legitimate interest in improving the catalogue for all users (Art. 6(1)(f))
Security: watch sessions, attempt limits, recording account deletions 3.6, 3.7 Legitimate interest in the security of the service (Art. 6(1)(f))
Detecting and fixing errors (Sentry) 3.9 Legitimate interest in the app working in a stable and secure way (Art. 6(1)(f))
Pseudonymised analytics to improve the app (PostHog) 3.8 Legitimate interest in improving the product (Art. 6(1)(f)); you can turn it off in Settings
Helping you when you write to us 3.10 Performance of the contract (Art. 6(1)(b)) or, if you are not a user, legitimate interest in replying (Art. 6(1)(f))
Sending you advertising or newsletters, only if we turn this on (we do not today) Your email (3.1) Consent (Art. 6(1)(a)), which we will ask for first and you can withdraw at any time
Serving and protecting the website 3.11 Legitimate interest (Art. 6(1)(f))
Measuring website visits and the use of its buttons, without cookies (PostHog) 3.11 Legitimate interest in knowing what works on the website (Art. 6(1)(f)); we do not measure when your browser sends Global Privacy Control or Do Not Track
Complying with legal obligations and defending ourselves against claims Whatever is needed in each case Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f))

About legitimate interest. We have weighed each case (you can ask us for the detail): security and error diagnostics are essential for the service, and analytics carries no content, uses a pseudonymised identifier and is hosted in the EU, with no advertising purposes. You can object (section 12).

Which data is required. Only an email (or your Apple or Google account) to create the account, without which we cannot sync your data or provide the service. Everything else is up to you. Using Pro does not depend on accepting analytics.

No new uses. We do not use your data for other purposes without telling you first and, where the law requires it, asking for your consent.


6. iPhone permissions

The app asks for each permission only when it needs it, and you can withdraw it in iOS Settings → Gailuh: Camera, for your progress photos; Photos, to pick a photo and, only if you turn on copies or recovery, to use the “Gailuh” album; Face ID, to protect your photos; and Notifications, for your reminders. Without a permission, the rest of the app keeps working.


7. Notifications, widgets, Apple Watch and complications


8. Who we share your data with

8.1. Providers that process data on our behalf

They are processors: they only use your data to provide their service to us, following our instructions, and their processing contract (Art. 28 GDPR) obliges them to protect it, keep it confidential, help us with your rights, tell us about any breach and delete it when the service ends. None of them receives your progress photos.

Provider What for Data Where it is processed Contract
Supabase (Supabase Pte. Ltd., Singapore) Database, authentication and server functions Account and everything you record (3.1 to 3.7) EU: Ireland (AWS eu-west-1) DPA
PowerSync (Journey Mobile, Inc., US) Sync between your iPhone, your Apple Watch and the server The data that is synced (3.2, 3.3, 3.5) EU: Ireland (AWS eu-west-1), with possible access from the US DPA · sub-processors
RevenueCat, Inc. Managing purchases and subscriptions Your internal identifier, purchases and subscription status (3.5) United States DPA
PostHog, Inc. Product analytics and website measurement Pseudonymised usage events (3.8) and website visits, without cookies (3.11) EU: Germany (PostHog EU Cloud) DPA · sub-processors
Sentry (Functional Software, Inc.) Error diagnostics Pseudonymised technical reports (3.9) EU: Germany (Frankfurt) DPA · sub-processors
Resend (Plus Five Five, Inc.) Sending service emails Your email and the message content (3.10) United States (sends from Ireland, but stores messages and logs in the US) DPA · sub-processors
Google (Firebase Hosting) Hosting gailuh.com IP and technical data of the visit (3.11) Google’s global network Firebase data processing terms · Firebase privacy
Google (Google Workspace) Irakai’s email, including the support and privacy mailbox What you write to us and your email address (3.10) Google’s worldwide network of data centres Google Cloud Data Processing Addendum

The safeguards for each transfer are in section 9. These providers in turn rely on sub-processors (for example, Amazon Web Services), listed in the links in the table.

8.2. Companies that process data as independent controllers

These companies process your data under their own policies when you use their services:

8.3. Other recipients

We will only disclose your data to authorities, judges or courts when a law requires us to. We do not sell your data, we do not share it with third parties for advertising and we do not work with data brokers.


9. International transfers

We host data in the European Union with every provider that allows it. Even so, there are international transfers, because some providers are outside the EU and may access the data from there, or process it outside the European Economic Area. Each one has its safeguard, incorporated into the provider’s contract (section 8.1):

Provider Why there is a transfer Safeguard
Supabase Singapore company (data in Ireland) The European Commission’s standard contractual clauses (Implementing Decision (EU) 2021/914)
PowerSync Its staff and infrastructure may access the data from the US, for example to provide support (data in Ireland) Standard contractual clauses (Decision 2021/914)
PostHog and Sentry US companies (data in Germany) EU-US Data Privacy Framework (Implementing Decision (EU) 2023/1795), under which both are certified, and standard contractual clauses
RevenueCat Subscription data in the US Standard contractual clauses (Decision 2021/914)
Resend Service emails and sending logs stored in the US Standard contractual clauses and the EU-US Data Privacy Framework, under which it is certified
Google Worldwide network: website (Firebase Hosting) and our email, including the support mailbox (Google Workspace) EU-US Data Privacy Framework, under which it is certified, and, as a fallback, standard contractual clauses

You can ask us for a copy of the safeguards at hola@gailuh.com.


10. How long we keep your data

Data Period
Account and everything you record While you have the account; deleted when you delete it (section 11).
Items you delete in the app They disappear from view immediately and are kept marked as deleted until you delete the account, so the deletion reaches all your devices. If you want us to erase them sooner, write to us.
Subscription and purchase notifications for your account While you have the account; deleted when you delete it, including at RevenueCat. If another account’s notification mentions you (for example, because of a purchase transfer), it is kept for that account with your identifier replaced by a “deleted account” marker.
Purchase notifications the store does not link to an account (for example, a transfer) Full content, 30 days, to resolve billing issues; after that, a minimal record with none of your data (identifier, type, environment and date) so it is not processed twice. If it mentions your account and you delete it, its content is erased at that moment.
Apple token Encrypted, while you have the account; when you delete it, it is revoked with Apple and erased (if revocation remains pending, once it completes).
Record of each account deletion 7 days after it completes or fails without having erased anything. If a step remains pending, it is kept meanwhile and retried every hour for 7 days and daily after that; if the only pending step is revoking Apple access and there is no token, it is treated as complete.
Attempt counters 1 day (only fingerprint or identifier, time window and number of attempts); those for your account, also when you delete it.
Apple Watch sessions One-time codes, 1 day after expiry; credentials, 30 days after expiry or revocation; everything, when you delete the account.
Providers’ technical logs (connections, website visits, email sending) The limited time each keeps them to operate and protect its service; website logs (Google), a few months.
Analytics (PostHog) When you delete your account we ask PostHog to delete your profile and events, which it completes shortly afterwards; the event recording that deletion carries no identifier. Turning analytics off does not erase what was already sent: if you want us to erase it, write to us.
Website visits (PostHog) Nothing that can recognise you: the temporary identifier changes every day and is not linked to your account. Kept as visit statistics for at most 24 months.
Error diagnostics (Sentry) Deleted automatically after 90 days at most.
Support conversations As long as needed to help you and, afterwards, while related claims may arise.
Requests to exercise rights and our reply Up to 3 years, as proof (limitation period for infringements, Art. 72 LOPDGDD).
Database backups Daily, overwritten within about 7 days; deleted data disappears with them and is not restored.
Content on your iPhone Until you delete it, delete the account or uninstall the app; your photos may remain in iCloud Backup until it is updated (section 4).

Where the law requires us to keep some data for longer (for example, following a court order), we will keep it blocked, only for that purpose and period.


11. Deleting your account

In Settings → Delete account. It is permanent. When you confirm, we erase from our database everything linked to your account (devices, routines, records, photo data, preferences, subscription and purchase notifications), delete your customer record at RevenueCat, ask PostHog to delete your profile and events, revoke with Apple Gailuh’s access to your Apple Account if you signed in with Apple on your iPhone, delete your account and close your sessions (including the watch one) and erase the app’s content, photos included, on the iPhone you delete it from.

Please note:

Signing out is not deleting your account: your data stays on our servers, and the local copy and your photos on your iPhone, inaccessible to any other account, until you sign in again.


12. Your rights and how to exercise them

You have the right to:

How: write to hola@gailuh.com from your account’s email or telling us which it is. We will reply at no cost (Art. 12(5) GDPR) within one month, which may be extended by two further months in complex cases, in which case we will let you know. If we have reasonable doubts about your identity, we may ask you to prove it. We prepare access and portability copies on request; there is no automatic download in the app today.

If you believe we have not handled your rights properly, you can lodge a complaint with the Spanish Data Protection Agency or with the authority in your country (sections 18 and 19).


13. Analytics and error diagnostics in detail


14. Automated decisions

We do not make automated decisions that produce legal effects on you or similarly significantly affect you, and we do not profile you for such purposes. The app automatically applies your plan’s limits (Free or Pro); if you think they have been applied wrongly, write to us and a person will review it.


15. Minors

You must be at least 18 years old to use Gailuh (see the Terms and Conditions). We do not knowingly collect data from minors and, if we find that an account belongs to someone under 18, we will delete it. If you are a parent or guardian and believe a minor has given us their data, write to us.


16. How we protect your data

Encryption in transit (HTTPS/TLS) and at rest; per-account isolation on the server (row-level security and sync filtered by account) and on the device; sessions in the iOS keychain, watch credentials only as a hash and the Apple token encrypted; minimisation (photos never reach our servers, and analytics and diagnostics contain neither your name nor your email); and restricted access to production systems. No system is infallible: if a breach were likely to result in a high risk to you, we would tell you without undue delay and notify the AEPD where required.


17. Cookies and website

gailuh.com uses no cookies and stores nothing in your browser (no local storage or similar technologies), uses no advertising tools and loads no fonts or scripts from third-party servers: everything the page loads, including PostHog’s measurement component, is served from gailuh.com. To measure the visit, the page reads the technical data from your browser described in section 3.11, unless it sends Global Privacy Control or Do Not Track. We count visits without cookies with PostHog (section 3.11), and Google Firebase Hosting, our hosting provider, processes your IP address and technical browser data to serve the page, prevent abuse and give us aggregated statistics. The third-party sites we link to (App Store, Google Play, Instagram, our providers) have their own policies.


18. Complaints to the supervisory authority

If you believe we are not handling your data properly, you can complain to the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) through its electronic office or at www.aepd.es. If you live in another EU country, you can also complain to the data protection authority of your country; outside the EU, see section 19. We would be grateful if you told us first, in case we can solve it.


19. If you live outside the European Union

Gailuh is available worldwide. Wherever you live, we process your data from the EU, with the providers in sections 8 and 9 and the GDPR safeguards described in this policy, and we recognise the rights in section 12, which you exercise through the same channel: hola@gailuh.com. In addition:


20. Changes to this policy

We may update this policy when the app, our providers or the law change. The date and version at the top show when it was last changed. If the change is significant (for example, a new use of your data or a new provider outside the EU), we will write to your account email before it applies and, where needed, ask for your consent.


21. Contact

For any question about this policy or your data:


Last updated: 14 October 2026 · Version 2.2