Who is responsible
Brombach Technologies GmbH
Rheintalbahnstraße 35, 68199 Mannheim, Germany
Represented by its managing director, Lukas Falk Brombach
Email: lukas@brombach-technologies.de
More details are in our legal notice (Impressum).
What stays on your iPhone
HeadUp processes the following only on your device. We don’t receive it and can’t access it. It’s gone when you delete the app.
- Head motion. With your permission for Motion & Fitness, HeadUp reads the tilt of your head from compatible AirPods or Beats. From it, the app notices when your head stays down too long and plays a tone.
- History and settings. Sessions, daily scores, streaks, your goal, calibration, sounds and your giraffe’s look.
- Your answers during setup. Your name if you give one, where and how long you look at screens, and whether you have complaints like neck pain or headaches. They only shape your plan.
- Widgets. Widgets read a copy of your daily scores from storage shared on the same iPhone.
- Notifications. With your permission, HeadUp schedules a local notification in case iOS stops a running session in the background.
- Photos. Only when you choose Save Image while sharing does HeadUp add the picture to your photo library. HeadUp never reads your photos.
- Clipboard. Only when you tap Paste invite link does HeadUp read the clipboard, to find an invite link.
Live Activity on your Lock Screen
During a session, HeadUp shows how it’s going on your Lock Screen and in the Dynamic Island. To keep that current while the app runs in the background, HeadUp sends the current values to our server: head tilt, head-up share, number of nudges, the giraffe’s mood, when the next nudge is due, the estimated neck load, and when the session started or paused, together with this Live Activity’s push token. The server passes them straight on to Apple Push Notification service, which updates the display.
We don’t store the values or the token, and they appear in no logs. The server uses your IP address only briefly, to fend off too many requests. It runs on Cloudflare, which operates it for us as our processor.
The legal basis is Art. 6(1)(b) GDPR, because you use the feature, and for fending off too many requests Art. 6(1)(f) GDPR, our legitimate interest in running the service safely. If you turn off Live Activities for HeadUp in your iPhone’s settings, HeadUp sends nothing to this server.
Herds with friends
Herds are optional. When you start or join one, HeadUp stores in iCloud (Apple CloudKit): your name, your giraffe’s look, your points and head-up share for this week and last week, your streak, whether your week counts for prizes, when you joined, and a pseudonymous iCloud identifier. Sessions, motion data, calibration, complaints and purchases are never part of it.
The herd lives in the private iCloud database of the person who started it and is shared with its members through an iCloud link. Every member sees these details. So friends can type a code instead, HeadUp keeps the code with the herd’s link in HeadUp’s public iCloud database until the herd stops sharing.
We have no access to a herd’s data. When you leave a herd, HeadUp deletes your entry; when the last member leaves, the herd is deleted. If the person who started the herd removes a member, that member’s pseudonymous identifier stays in the herd so they can’t rejoin.
HeadUp keeps your leaves balance in your iCloud key-value storage, so it’s the same on all your devices.
The legal basis is Art. 6(1)(b) GDPR. For iCloud, Apple’s privacy policy applies as well.
Purchases and subscriptions
Purchases go through Apple’s App Store. We never receive your payment details.
To check, unlock and restore purchases, we use RevenueCat (RevenueCat, Inc., USA) as our processor. RevenueCat receives a random, anonymous identifier, the purchase data from the App Store (product, price, currency, dates, transaction IDs), technical details such as device type and iOS and app version, and your IP address, from which it derives your country before discarding it. We also look at purchases in aggregate, for example how many subscriptions start or are cancelled.
The legal basis is Art. 6(1)(b) GDPR for handling your purchase and Art. 6(1)(f) GDPR for the aggregate figures, our legitimate interest in understanding our offer. We keep this data while you use your purchases and for as long as the law requires us to.
When you write to us
When you email us, we process your address, your message and anything you attach, to answer you. The legal basis is Art. 6(1)(b) GDPR, otherwise Art. 6(1)(f) GDPR. We delete your message once your request is settled, unless the law requires us to keep it.
This website
When you visit headupgiraffe.com, our host Cloudflare processes what’s technically needed: your IP address, the time, the page and your browser’s identifier. That’s necessary to deliver the site and protect it from attacks (Art. 6(1)(f) GDPR). The site sets no cookies, uses no analytics or tracking, and loads its fonts from its own server. The App Store button takes you to Apple.
Recipients and transfers
- Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA: hosting this website and running the Live Activity server.
- RevenueCat, Inc., USA: managing purchases.
- Apple: App Store, iCloud and push notifications, under Apple’s own privacy policy.
Cloudflare is certified under the EU-U.S. Data Privacy Framework, which the European Commission has found adequate (Art. 45 GDPR). With RevenueCat we have agreed the European Commission’s standard contractual clauses (Art. 46(2)(c) GDPR).
We don’t sell data, show ads or build profiles.
Your rights
You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You can object to processing based on our legitimate interest (Art. 21). Just write to lukas@brombach-technologies.de.
Because HeadUp has no accounts, we often can’t recognise you in our systems. For questions about purchases, the order ID from Apple’s receipt helps. To delete what’s on your iPhone, delete the app; to delete your entry in a herd, leave the herd.
You don’t have to give us any data, but without Motion & Fitness access HeadUp can’t measure your head posture. We make no automated decisions within the meaning of Art. 22 GDPR.
You can complain to a data protection authority (Art. 77 GDPR), for example the one responsible for us: Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg, Lautenschlagerstraße 20, 70173 Stuttgart, Germany.
Changes
When HeadUp changes, we update this policy. The version published here applies.