Privacy Policy

1. Introduction

This Privacy Policy explains how Miura cc LLC ("Thinkies," "we," "us," or "our") collects, uses, shares, and protects your personal data when you use the Thinkies mobile application (the "App").

Thinkies helps you receive personalized wellness suggestions based on the items you scan and the information you choose to provide. We are committed to handling your data responsibly, transparently, and in compliance with applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), and relevant U.S. state privacy laws.

The App is intended for users aged 16 and older. If you are under 16, please do not use the App.

2. The Data We Collect

We only collect the information necessary to operate the App and provide personalised wellness suggestions.

2.1 Information You Provide Directly

2.2 Information Processed Automatically

• Device details (model, operating system, language settings)
• Log data (session length, feature usage, crash reports)
• Security and diagnostic data
• A randomly generated user identifier assigned to your device. This identifier contains no personal information and cannot be used to identify you directly. It is used solely to associate your preferences and data within our systems.

We do not use advertising identifiers or behavioural ad tracking.

2.3 Payment Information

Subscription payments are processed securely by Apple through the App Store. Thinkies does not access or store your payment card details.

3. How We Use Your Data

We use your data to:

1. Provide personalised wellness suggestions based on the items you scan and the details you choose to share.
2. Operate and improve the App, including troubleshooting, analytics, and security.
3. Enable subscription access and purchase fulfilment through Apple's App Store In-App Purchase system.
4. Provide customer support when you contact us.

We do not use your data for advertising or to create marketing profiles.

4. AI and Automated Processing

Thinkies uses artificial intelligence to analyse your scans and profile details to generate personalised suggestions.

How it works:

• Your inputs (scan images, health goals, preferences) are processed automatically.
• Some data is sent securely to our AI provider, OpenAI, for analysis.
• Results are returned to you as personalized wellness recommendations.

Our commitments:

• AI suggestions are informational only and are not medical advice.
• You may contact us if you wish to question or challenge AI‑generated results.

Why we process this data:

AI‑based analysis is essential for the core functionality of the App.

5. Legal Bases for Processing (GDPR/FADP)

We process your data under the following bases:

Explicit Consent (Art. 9 GDPR)

For processing health-related information and for AI‑based automated analysis.

Contractual Necessity

To provide the App's core functionality and process payments.

Legitimate Interests

For security, diagnostics, and app improvement.

You may withdraw your consent at any time, but this may limit your ability to use the App.

6. Sharing Your Data

We share your data only with trusted service providers who enable the App to function.

We share data with:

• OpenAI (USA): AI processing of text and images
• Supabase (USA): database and storage
• AWS (USA): hosting infrastructure via Supabase
• Vercel (USA): backend and serverless functions
• Apple (USA): subscription and In-App Purchase processing (independent controller)

We do not sell your personal data.

All partners implement appropriate contractual, organisational, and technical safeguards.

7. International Data Transfers

Because our service providers are located in the United States, your data may be transferred outside your country.

We rely on:

• Standard Contractual Clauses (SCCs)
• Additional security measures (encryption, access controls)

By using the App, you acknowledge that your data may be processed in the United States.

8. Data Retention

We keep your data as long as your account is active.

If you delete your account:

• All profile, scan, and conversation data will be deleted.
• Backups may be retained briefly for security and audit purposes.

9. Your Rights

Depending on your location, you may have rights to:

• Access your data
• Correct your data
• Delete your data
• Withdraw consent
• Object to automated processing
• Request data portability

To exercise these rights, please contact us at the email listed in Section 13.

You also have the right to lodge a complaint with your local data protection authority.

10. Security

We use technical and organisational measures to protect your data, including encryption where possible. However, no method of transmission or storage is fully secure.

If a security incident occurs, we will notify you as required by law.

11. Children's Privacy

Thinkies is intended for users aged 16 and older. We do not knowingly collect data from children under 16.

If we learn that data from a child has been collected, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted within the App.

13. Contact

For any privacy questions or requests, please contact:

If required, we will appoint an EU/UK representative to handle GDPR inquiries.

14. U.S. Multistate Privacy Notice

For users residing in U.S. states with privacy laws (e.g., California, Colorado, Virginia, Connecticut, Texas), you have the rights to:

• Access your personal information
• Correct inaccuracies
• Delete your data
• Opt out of profiling in furtherance of significant decisions

We do not sell or share your data for advertising.

To exercise your rights, please contact us at the address in Section 13.