This Privacy Policy describes how the Nucleo Kegel application handles information relating to its users.
It explains which information is processed while using the application, for which purposes, how users can exercise their rights, and how to contact the developer.
This Policy applies exclusively to the Nucleo Kegel application, distributed through the Apple App Store.
By using the application, the user confirms that they have read this Privacy Policy.
The controller of the application is:
Controller: Everson José Pereira
Location: Joinville — Santa Catarina — Brazil
Support and privacy e-mail: [email protected]
The controller acts as the data controller for information processed directly by the application, to the extent applicable to the features provided.
This Policy applies exclusively to the processing of information carried out by the Nucleo Kegel application.
The application was designed to work on the device. Training, profile and wellness diary data are not sent to servers. There are four exceptions, all described in this Policy:
The application does not use third-party authentication, advertising or tracking services, and does not permit tracking across applications or websites. The only usage analytics performed is the one described in section 6.9, which is anonymous and not linked to the user's identity.
The third-party services used by the application are:
Each of these services has its own Terms of Use and Privacy Policy governing the data processing carried out by its providers.
To make this Policy easier to read, the terms below have the following meanings:
Application: Refers to the Nucleo Kegel software.
User: A person who uses the application.
Controller: The individual responsible for developing and distributing the application.
Personal data: Information relating to an identified or identifiable person, as defined by applicable law.
Sensitive personal data: A category of personal data that includes health information, as defined by applicable law.
Processing: Any operation performed on personal data, including collection, use, storage, consultation, deletion or any other operation provided for by applicable law.
Third-party services: Services provided by companies other than the application's controller and used to deliver specific features.
Nucleo Kegel is intended exclusively for people aged eighteen or older.
The application was not designed for use by minors.
If a user is found not to meet this requirement, access may be terminated in accordance with the Terms of Use.
Nucleo Kegel was designed to limit processing to the information required to provide its features. All processing described in this section takes place locally, on the user's device, with a single exception: the anonymous usage analytics described in section 6.9.
The user may optionally provide profile information used to personalise the experience:
Usage preferences are also stored, such as language, light or dark theme, sound, vibration, reminder time and the Health app integration setting.
While using Nucleo Kegel, the application records:
The application allows the voluntary recording of information about your intimate and pelvic floor health, through the symptom diary. This information may include:
This data is considered sensitive personal data under the LGPD and special category data under the GDPR. It remains stored exclusively on the user's device, is not transmitted to the controller, is not used for analytics, advertising or profiling purposes, and is not shared with third parties.
As currently implemented, Nucleo Kegel does not request or process:
The application does not create an account, does not require sign-in, and does not collect usernames, passwords or third-party account identifiers.
Notifications: used exclusively to display the reminders configured by the user. They can be disabled at any time in iOS Settings.
Apple HealthKit: when the user enables "Send sessions to Apple Health", the application saves each completed session as a workout in the Health app. Authorisation is requested by Apple when the option is enabled and can be revoked at any time in iOS Settings or in the Health app.
Photos: the profile photo is chosen by the user through the system photo picker. The application receives only the selected item and does not access the photo library as a whole.
Widget, Live Activity and Siri/Shortcuts: the application offers a Home Screen widget, a Live Activity shown during a session on the Lock Screen and in the Dynamic Island, and shortcuts that start the session of the day by voice or from the Shortcuts app. These extensions run on the device itself, as part of the same application, and use only information already stored locally: a summary of the day (title, description and number of sessions this week) in the widget, and the session state (current phase, time remaining, repetition and exercise) in the Live Activity. No information is sent to servers through these features.
The application offers, in its settings, the option to send a message to the developer. Sending is optional and only happens when the user writes a text and taps "Send".
In that case the following is transmitted:
No training, profile or wellness diary data is included in that message. The text is forwarded by e-mail to the developer through infrastructure and e-mail delivery providers and is not stored by the application.
When it receives a purchase transaction, the application sends the Nucleo Worker the data needed to validate the purchase with Apple and notify the developer by e-mail. The following is transmitted:
Apart from that optional display name, no profile, training or wellness diary data is included in that notification. The Worker discards automatic renewals and transactions it has already notified, and keeps the purchase identifiers it stores for this purpose for up to 400 days, after which they are automatically deleted.
The application can generate a PDF report from the user's own records, summarising training and the wellness diary, intended to be shown to a health professional.
The report is assembled on the device. It only leaves the application when the user chooses to share it, through the system share sheet, with whomever and by whatever means they decide (for example e-mail, a messaging app or printing). That choice is always individual and revocable, and the controller neither receives nor stores the report or a copy of it.
Because it contains health data, the user should share the report only with whom they wish. The content sent is then handled by the recipient and by the service used to share it, under those third parties' own policies.
The application uses Google Analytics for Firebase, a Google service, to measure how its features perform — that is, to learn which screens and features are used, how long sessions last and where users get stuck. This analysis is anonymous and aggregated: the information is not linked to the user's identity and does not allow the user to be identified.
Only usage and non-identifying technical data are sent:
The application never sends to that service:
Configuration: usage analytics runs without ad personalisation and without ad storage, and the application does not use Apple's advertising identifier or track users across third-party applications or websites.
User control: the user can turn usage analytics off at any time in the "Profile" section of the application, under "Anonymous usage analytics". The "Delete all my data" feature also turns this collection off.
Provider: processing is carried out by Google (Google Analytics for Firebase) under Google's Privacy Policy, available at https://policies.google.com/privacy. Retention of analytics data follows the service's own retention setting.
Nucleo Kegel processes only the information required to provide the application's features. The purposes of processing are:
Nucleo Kegel does not use locally stored content (profile, wellness diary and notes) for advertising, commercial profiling, data sales or training automated systems, nor does it use it for the usage analytics described in section 6.9.
Where Lei nº 13.709/2018 (the Brazilian General Data Protection Law – LGPD) applies to the processing carried out by Nucleo Kegel, processing may be based on one or more of the following legal bases.
Processing is necessary to provide the features requested by the user, including:
Recording the wellness data described in section 6.3 and saving workouts to the Health app as described in section 9 depend on the user's own action and authorisation. These choices can be reversed at any time: records can be deleted in the application, and Health write permission can be revoked in iOS Settings.
Where required by applicable law, certain information may be processed to comply with legal obligations.
The anonymous usage analytics described in section 6.9 is based on the controller's legitimate interest in maintaining and improving the application (art. 7, IX, of the LGPD and art. 6(1)(f) of the GDPR). The processing is limited to non-identifying usage data, does not involve health data, is not used for advertising or commercial profiling, and can be turned off by the user at any time in the application's Profile.
Nucleo Kegel offers an optional Apple HealthKit integration. When enabled by the user, the application saves each completed session as a workout in the Health app.
The application requests write permission only. Workouts it saves remain under the user's control in the Health app and can be deleted there at any time.
The application does not read the user's health data, does not use HealthKit data for advertising or any similar purpose, and does not transmit it to third parties.
When the user uses "Delete all my data", the application also requests deletion of the workouts it saved to the Health app.
All information related to the use of the application is stored locally on the user's device, in a single file inside the application's own data directory. This information includes:
That file is written with iOS data protection, which keeps it encrypted at rest, and is excluded from iCloud and computer backups.
For the widget and the Live Activity to work, the application publishes a reduced summary of the day and the session state into a shared container on the device itself (App Group), accessible only to the application and its own extensions. That summary is limited to title, description, number of sessions this week and session state — it does not include the wellness diary, the profile or the history. The main file holding all the data remains exclusive to the application.
This information is not synchronised with servers, is not accessed by the controller and is not shared with third parties by the application. The only exception is the anonymous usage analytics described in section 6.9, which includes neither the main file nor the content of the wellness diary.
Nucleo Kegel does not sell or rent users' personal information. Profile and wellness diary data are not sent to servers or to analytics, advertising or tracking services. Training data leaves the device only in aggregated, non-identifying form, in the usage analytics described in section 6.9.
Sharing with third parties is limited to what the features described in this Policy require:
These services process information in accordance with their own privacy policies.
In addition, the user may, at their own discretion and at any time, share the PDF report with third parties of their choosing through the system share sheet. That sharing comes exclusively from the user, who chooses the recipient and the means used; the application never sends the report to anyone automatically.
Training, profile and wellness diary data do not leave the user's device. The usage analytics described in section 6.9 sends only anonymous, aggregated data, which may be processed by Google outside the user's country of residence.
Any international transfers arise only from the features described in this Policy: the Apple services mentioned in section 11, Google Analytics for Firebase (section 6.9), and feedback submission, whose infrastructure and e-mail providers may process the message outside the user's country of residence.
Information remains stored exclusively on the user's device for as long as the application is installed and the user does not remove it.
The user can delete all data at any time using the "Delete all my data" feature available in the application. Removing the application from the device also erases the locally stored data.
Information that may be processed by Apple is subject to the retention periods defined by Apple. Usage analytics data (section 6.9) follows the retention setting of Google Analytics for Firebase.
Nucleo Kegel provides the "Delete all my data" feature inside the application. Upon confirming deletion:
Deletion is permanent and irreversible. The application does not send training data to any server, so the training history cannot be recovered once removed. Purchase identifiers already sent for validation follow the retention described in section 6.7.
Deleting the application's data does not affect the purchased subscription, which is managed by Apple and must be cancelled in the user's Apple Account settings.
The controller of Nucleo Kegel adopts measures appropriate to the nature of the application to reduce risks related to the handling of information. Because data stays on the device, security also depends on the protections offered by iOS itself.
Users also play an important role in protecting their information and should:
No computer system can offer an absolute guarantee of security.
Depending on the legislation applicable in the user's place of residence, they may exercise rights relating to their personal data.
Because Nucleo Kegel stores all information exclusively on the user's device, most of these rights can be exercised directly by the user through the application's features: viewing, correcting and deleting data. Where applicable, requests may also be sent to the controller at the e-mail address provided in this Policy.
Where the LGPD applies to the processing carried out by Nucleo Kegel, the user may exercise, subject to legal limitations, rights such as:
Exercising these rights may depend on confirming the requester's identity and on the existence of data effectively processed by the controller.
Where processing is subject to Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), the user may exercise the rights provided for in that legislation, including, where applicable:
Exercising these rights depends on the applicability of the GDPR to the specific case and on the nature of the information processed by the application.
Where applicable, the privacy laws of the State of California, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), may grant additional rights to residents of that State.
Given the current implementation of Nucleo Kegel: the controller does not sell or share users' personal information, does not use sensitive personal information for purposes other than providing the service, and does not carry out behavioural advertising. A California resident wishing to exercise rights that may be granted by applicable legislation may contact the address provided in this Policy.
Where applicable, this Policy aims to provide transparent information about: which information may be processed by the application, how that information is used, how the user can contact the controller, and how changes to this Policy will be communicated.
Nucleo Kegel does not display ads, does not use advertising identifiers and does not track users across third-party applications or websites.
The usage analytics described in section 6.9 is not tracking: it is anonymous, is not linked to the user's identity, is not used for advertising or profiling, and can be turned off in the application's Profile. The application does not include attribution, crash-reporting or social media SDKs. For this reason, no App Tracking Transparency prompt is presented.
The privacy labels published on the App Store correspondingly declare the data collected by the developer: device identifiers and anonymous usage data (analytics), in addition to the data already described in this Policy (purchases, user content and user-generated content).
This Policy may be updated periodically to reflect legal, regulatory, technical or operational changes, or changes related to the evolution of the application. The date of the last update will be indicated at the top of this document. The most recent version replaces any previous versions in full.
If you have questions about this Privacy Policy or about the handling of information related to Nucleo Kegel, please contact:
Controller: Everson José Pereira
E-mail: [email protected]
This Policy shall be interpreted in accordance with Brazilian law. Where mandatory data protection rules of other jurisdictions apply to the processing carried out by the application, those rules shall prevail to the extent required by the corresponding legislation. Nothing in this Policy is intended to limit rights guaranteed by mandatory legislation applicable to the user.
To the extent permitted by applicable law, the courts of the District of Joinville, State of Santa Catarina, Brazil, are elected to settle disputes arising from this Policy. Where mandatory legislation assigns jurisdiction elsewhere for certain disputes, that legislation shall prevail.
If any provision of this Policy is held invalid, illegal or unenforceable by a competent authority, the remaining provisions shall remain valid and effective.
Any tolerance by the controller regarding non-compliance with any provision of this Policy shall not constitute a waiver of rights nor prevent its later enforcement.
This Policy constitutes the official privacy document of the Nucleo Kegel application and must be read together with the application's Terms of Use.