Privacy Policy

Franz is a mental performance coaching application developed and operated by Franz Health Ltd ("Franz", "we", "us", or "our"). We are committed to protecting the personal information you share with us.

Franz Health Ltd is the data controller for your personal data. Franz Health Ltd is registered in England and Wales, company number 17182431. We are registered with the Information Commissioner's Office (ICO), registration number ZC198020.

If you have questions about this policy, contact us at privacy@franz.health.

We collect information in the following ways:

• Account information. When you sign up, we collect your email address and a hashed password.
• Profile and onboarding data. Your primary stressor, personal goal, and why you chose Franz. You provide this voluntarily and can update or delete it at any time.
• Daily check-in data. Sleep scores, stress levels, emotions, triggers, and optional free-text notes you enter during morning check-ins and evening reflections.
• Coaching conversations. Messages you exchange with the Franz AI coach. These are stored so Franz can provide context-aware responses.
• Passive health data (optional). With your explicit permission, we read sleep duration and quality, heart rate variability (HRV), resting heart rate, blood oxygen saturation (SpO2), and step count from Apple Health (iOS) or Health Connect (Android). Permission is requested before any data is read, and granting it is entirely optional. You can disconnect at any time from Settings. Long-range health history charts are read directly from Apple Health or Health Connect on your device when you view them and are not stored on our servers. Only daily snapshot aggregates are stored in your account.
• Usage data. Aggregated, anonymised data about how features are used (page views, session length, feature interactions). We do not sell this data.
• Subscription information. Your subscription tier and status, managed via RevenueCat. We never store full payment card details — these are handled by your app store.

Your check-in data (stress, sleep, emotions, triggers, and notes), evening reflections, and coaching conversations reveal information about your mental health and wellbeing. Together with passive health data, we treat all of this as special category health data under the UK GDPR and the Data Protection Act 2018 (Article 9) and process it only with your explicit consent.

We use the information we collect to:

• Provide, personalise, and improve the Franz application
• Generate pattern detection insights and personalised coaching suggestions, including using passive health data where you have granted permission
• Send transactional emails (account confirmation, password reset)
• Manage your subscription and billing status
• Comply with legal obligations

We do not use your health-related check-in data for advertising and we do not sell it to third parties.

Legal bases. Under UK GDPR, we rely on the following legal bases for this processing:

• Performance of a contract (Article 6(1)(b)). Providing the service, account management, and transactional email.
• Your explicit consent (Article 6(1)(a) and Article 9(2)(a)). Processing your health data — check-ins, reflections, coaching conversations, and passive health data — including pattern detection and personalised coaching. You can withdraw consent at any time in Settings; withdrawal does not affect processing that happened before.
• Legitimate interests (Article 6(1)(f)). Security, fraud prevention, and anonymised product analytics.
• Legal obligation (Article 6(1)(c)). Tax, accounting, and legal compliance.

Franz uses Anthropic Claude to power the AI coach. When you send a coaching message, relevant context from your check-in history and profile is included in the request to Anthropic's API. Anthropic acts as our processor under a data processing agreement and does not use your data to train its models. You can review Anthropic's policy at anthropic.com/privacy.

The health information included in coaching requests is sent as derived indicators (for example, whether your HRV is above or below your baseline), not raw medical readings. Anthropic retains this data for a maximum of 7 days.

Franz treats passive health data as sensitive information and handles it with the following safeguards:

• Explicit permission only. We never read from Apple Health or Health Connect without first requesting your permission through the platform's standard permission dialogue. You can decline without affecting any other feature of the app.
• Revoke access at any time. You can disconnect health data from the Settings screen inside the app. Once disconnected, Franz stops reading new health data. You can also revoke access directly through iOS Settings or Android Health Connect settings.
• Secure storage. Health snapshots (daily aggregates of sleep, HRV, resting heart rate, SpO2, and steps) are stored in your account and protected with the same encryption and access controls as all other personal data.
• Never sold or shared for advertising. Your health data is never sold, rented, or shared with advertisers, data brokers, or any third party for commercial purposes.
• UK GDPR special category. Under UK GDPR, health data is a special category of personal data. We process it only on the basis of your explicit consent (Article 9(2)(a) UK GDPR). You may withdraw consent at any time by disconnecting health data in Settings, without this affecting the lawfulness of processing before withdrawal.

Your data is primarily stored on Replit's servers in the European Union. Replit, Inc. is a US company; where personal data is accessed from the United States, the safeguards described below apply.

Coaching requests are processed by Anthropic in the United States. Support enquiries submitted through our support form or sent to our support email are handled in our support mailbox, hosted by Namecheap, a US company; data processed this way is also transferred to the United States. Where any of our other service providers are based in the United States, the same safeguards apply.

These transfers are safeguarded by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. Anthropic is additionally certified under the EU-US Data Privacy Framework.

We share personal data only with the service providers (processors) we use to run Franz:

• Replit — hosting and database.
• Anthropic — AI coaching.
• Namecheap (Private Email) — support mailbox for customer enquiries.
• Google Analytics — website analytics (only with your consent).
• RevenueCat — subscription management.
• Apple App Store / Google Play — payments.
• Mailtrap — transactional email.

We never sell personal data and never share it for advertising.

We retain your account and check-in data for as long as your account is active. Daily health snapshots are retained on our servers for 180 days; your older health history stays in Apple Health or Health Connect on your device and is read from there when you view it.

If you delete your account, deletion starts a 24-hour grace window during which you can cancel it. After that window, your personal data is permanently deleted within 30 days, except where we are required to retain it by law. Data may persist in encrypted backups for up to 28 days after deletion, after which it is removed.

Anonymised, aggregated data (with no link back to you) may be retained indefinitely for product improvement purposes.

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data ("right to be forgotten")
• Export your data in a portable format
• Object to or restrict certain processing
• Withdraw consent at any time
• Lodge a complaint with the Information Commissioner's Office (ico.org.uk)

To exercise any of these rights, email privacy@franz.health. We will respond within one calendar month.

We use industry-standard measures to protect your data: encrypted connections (TLS), hashed passwords (bcrypt), and access controls limiting which team members can access production data. No system is perfectly secure, but we take reasonable precautions and will notify you promptly if we become aware of a breach that affects your data.

We use session cookies and browser local storage to keep you signed in and to remember your preferences.

On our marketing website we also use analytics cookies from Google Analytics, but only if you accept them through the cookie banner — no tracking script loads until you do. Your choice is stored in a first-party cookie for about six months, and you can change or withdraw it at any time via the "Cookie settings" link in the footer. We do not use third-party advertising cookies.

Franz is not intended for users under the age of 16. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

We may update this policy from time to time. If we make material changes, we will notify you by email or via an in-app notice at least 14 days before the changes take effect. Continued use of Franz after that date constitutes acceptance of the revised policy.