Privacy Policy

Who is responsible

Romain Anezo, who publishes Malvea, is the controller for all the processing described on this page. For any question or request: contact@malvea.app.

The challenge stays on your phone

Everything about the challenge stays on your device: your answers to the entry questionnaire, the content of your daily check-ins, your score and your history. The Malvea app has no account and no syncing, and this data is sent nowhere. It includes no ad network, no attribution tool and no third-party analytics tool. Uninstalling the app erases this data for good.

If you finish the entry questionnaire without subscribing, your answers stay on your phone, so you can pick up where you left off. They never leave it. The app erases them the first time it opens after 30 days, and you can erase them yourself from the subscription screen, or by uninstalling it.

This information falls under Article 9 of the GDPR, which protects health data. That is precisely why it is not hosted.

The only thing the app sends is usage statistics, described just below, which you can turn off.

The app's usage statistics

• Data collected: the screens viewed, taken from a fixed list (never a screen that only appears depending on your answers), and for those of the entry questionnaire, their place in its list of screens, the same for everyone; the features used, such as doing your daily check-in (only the fact that it was logged, once a day, never what it contains), opening a card, choosing a plan, buying or restoring a purchase (with its outcome), accepting reminders or not, opening a reminder; the state of the challenge (ongoing, paused, finished, maintenance) and its progress by range of days (day 8 to 14, for example, never the exact day); the subscription state (none, trial, active, expired); the install week, and the time since install, also by range (4 to 7 days, for example, never the exact number), reported once per range, on your first return to the app; the date and time of each event (during the entry questionnaire, only their order, never their time, so that its length cannot be read; for opening a reminder, only the day, and it is only sent on a later day, so that neither its time nor the time of sending reveals the reminder time you chose); a session identifier, drawn at the start of each session, kept in memory and never saved on the phone, except the one specific to opening a reminder, which waits there at most three days to be sent; the app version and the system's major version. Never your answers to the entry questionnaire, nor the content of your check-ins, nor anything derived from them (habits kept, a good day, your streak or its milestones), nor your habit score, nor your challenge's levers, nor a device or purchase identifier, nor a location. Your IP address is read by our relay, at Vercel, to limit the number of sends per minute: it serves as the key of a counter of those sends, held in memory only, is never written by us and is not passed on to PostHog; our host Vercel keeps technical access logs on its side that contain it.
• Purpose: understanding how the app is used in order to improve it, and nothing else. Measuring its usage and performance, spotting the screens where people drop off, making it simpler to use. Aggregated statistics only, never tracking a person; no advertising, no profiling, no matching with an email address or a reservation.
• Legal basis: our legitimate interest in improving the app (Article 6(1)(f) of the GDPR). This audience measurement falls within the consent exemption of Article 82 of the French Data Protection Act, under the conditions set by the CNIL: that is why it is on by default, and why you can object to it at any time, with no effect on the app.
• Retention period: the identifier only lasts for a session and is never saved; no lasting identifier exists. Events are kept for one year at PostHog.
• Objecting: in the app, the “Usage statistics” switch, in Settings, “Your data” section. When it is off, whatever was waiting to be sent is erased, a send in progress is stopped, and nothing leaves any more; turning it off is not itself reported, and the app works exactly the same, subscription included.

If you leave your email address on this site

• Data stored: your email address, the page you left it on (home page or the “Aider mon conjoint” page), the exact text of the consent you accepted and the date of that consent. Your IP address is read to limit the number of sends per minute: it serves as the key of a counter of those sends, held in memory only, and is never written by us, in a database or anywhere else; our host Vercel keeps technical access logs on its side that contain it.
• Purpose: letting you know when the app is released, and nothing else. No newsletter, no sharing, no resale.
• Legal basis: your consent, given through an unticked box. The exact text you accepted is stored with your address, so that we can prove what you consented to.
• Retention period: twelve months at most, then automatic deletion.

Consent text, as shown on the site (in French): « J'accepte de recevoir un email quand Malvea sort, et rien d'autre. Mon adresse est conservée douze mois au maximum, hébergée dans l'Union européenne, et je peux demander sa suppression à tout moment. »

If you reserve the first year

• Data stored: your email address, the customer identifier and the payment mandate identifier created by Stripe, the Stripe event identifier and the reservation status. Never your card number, which does not leave Stripe.
• Purpose: keeping your reservation, notifying you before the charge, charging €19 including VAT when the app is released and sending you your code.
• Legal basis: performance of the reservation contract and pre-contractual steps taken at your request (Article 6(1)(b) of the GDPR). It is not consent, so you cannot withdraw it; you can, however, cancel the reservation at any time before the charge, which amounts to the same.
• Retention period: a reservation is kept while it is ongoing, then automatically deleted twelve months after it ends, that is, after its cancellation, its charge or its refund. Accounting records linked to a charge are kept for ten years (Article L.123-22 of the French Commercial Code).

Recipients and hosting

Database: Supabase, eu-west-3 region, in Paris. Site hosting and relaying statistics to PostHog: Vercel, cdg1 region, in Paris. Card registration, if you make a reservation: Stripe. App usage statistics and site audience measurement: PostHog, hosted in the European Union, in Frankfurt. Vercel and PostHog act there as processors.

Transfers outside the European Union

The servers that serve this site and the database are in Paris, and PostHog's in Frankfurt. Three of our processors are, however, American companies: Vercel Inc. for site hosting and relaying statistics, Stripe for card registration, and PostHog Inc. for usage statistics and audience measurement. Their teams, and some of their own processors, may access data from the United States for operations and support. These companies state that they govern this access through the European Commission's standard contractual clauses and, for those certified under it, the EU-U.S. Data Privacy Framework. You can ask for a copy of the applicable safeguards at contact@malvea.app.

Cookies and storage on your device

This site sets no cookie and writes no identifier on your device. The only information it keeps there, and only if you ask, is your objection to audience measurement, under the key malvea.analytics: its value is “non”, it contains no identifier and is never sent to a server. If you had answered the former consent banner, a “Non merci” remains an objection, and a “D'accord” is erased, along with the identifier the measurement of that time had set. Our team's browsers also carry the key malvea.interne, which excludes their own visits from the statistics.

Your rights

You have the right of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time, without affecting what was done before. Write to contact@malvea.app: requests are handled within one month, in accordance with Article 12(3) of the GDPR. If you are not satisfied with the answer, you can contact the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or at www.cnil.fr, or the data protection authority of your country.

For usage statistics and audience measurement, no lasting identifier exists: we cannot find the events that concern you, and therefore cannot send them to you or erase them one by one (Article 11 of the GDPR). Your right to object, however, is exercised directly, without having to ask us anything: the “Usage statistics” switch in the app's Settings, and the button in the audience measurement section of this site.