Privacy Policy

the Detoxer app and the detoxer.eu website

Version 2.0 · Effective from 1 November 2026

This is a translation for information only; the Czech version (Zásady ochrany osobních údajů) is decisive.

1. Who processes the data and a short summary

1.1 Controller: Tadeáš Koždoń, a self-employed natural person, with registered address at Uralská 689/7, 160 00 Praha 6 – Bubeneč, Company ID (IČO) 23827475 (the “controller” or “we”). Contact for personal data protection: info@detoxer.eu, phone +420 771 672 239. We have not appointed a data protection officer because Article 37 GDPR does not require us to.

1.2 This policy explains how we process personal data in the Detoxer mobile app (Android and iOS, the “App”) and on the detoxer.eu website. We follow Regulation (EU) 2016/679 (GDPR), Act No. 110/2019 Coll., on the processing of personal data, and Act No. 127/2005 Coll., on electronic communications. Capitalised terms have the same meaning as in the Terms and Conditions (https://detoxer.eu/vop).

1.3 In short:

• The App has no user accounts and no server of its own. We do not need your name, e-mail or phone number.
• In the App we do not use any analytics, advertising or tracking tools and no crash reporting tools.
• Your Detoxes, Plans, statistics and settings stay only on your phone.
  • If you have Google backup (Android) or iCloud (iPhone) turned on, some of this data is also in your backup. We have no access to it.
• The VPN does not send your internet traffic anywhere. It blocks it directly on the phone. We do not see where you go and we store nothing about it.
• Payments are handled by the App Store or Google Play. We do not see your payment details.
• Parental Mode (iOS only, not yet available) will transmit a few pieces of information about the status of the child’s phone via Apple’s iCloud.
• On the detoxer.eu website we use Google Analytics 4 and Meta Pixel only with your consent from the cookie bar.

2. The Detoxer App

2.1 Data that stays only on your Device. On your phone the App stores the history and length of Detoxes, Plans, streaks, levels and badges, the chosen theme, language and other settings, and data about the Guardian you have set up. This data does not go to us or to anyone else (except Parental Mode under Art. 3). We have no access to it, and therefore we cannot restore it for you, transfer it elsewhere or delete it remotely. You delete it by uninstalling the App or deleting its data. On Android, history, streaks, badges, settings and language are backed up to your Google backup (if you have it turned on) and are transferred when you switch to a new phone. On iPhone, some settings may be synchronised via iCloud storage in your Apple account. We have no access to your Google backup or your iCloud. Your consent to the terms (date, time and version) is stored on the Device, or also in your Google or iCloud backup. We have no access to it.

2.1a Screen time and attempts to open (Android). If you optionally grant the App Usage access, it will show you the screen time measured by Android (by apps, hours and days). During a Detox, the App remembers on the Device the aggregate number of attempts to open a locked app, including its name, for at most 30 days. This data stays only on the Device and is not sent anywhere.

2.2 VPN and internet traffic. During a Detox, the App intercepts the Device’s internet traffic via a local VPN profile and drops it directly on the Device. The traffic is not forwarded to any server, we do not record visited pages, IP addresses, DNS queries or the content of communications, and we keep no records (logs) of activity. Information about when a Detox started and ended stays only on your Device. On Android, the VPN lets the traffic of the default messaging app pass directly to the network, likewise without recording and without forwarding to us.

2.3 Lock permissions. The App uses the accessibility service and device administrator (Android) and the Screen Time interface (iOS) exclusively for the Lock: during a Detox it recognises which app is currently open, covers it and makes it harder to uninstall the App and change its settings. The accessibility service only monitors window changes and reads the name of the app in the foreground; it does not have permission to read screen content. Only the number of attempts under Art. 2.1a is stored. Through them the App does not read or store screen content, messages, passwords or entered text, and sends none of it anywhere. In addition, Apple’s Screen Time interface does not allow developers to find out which apps and websites you use.

2.4 Purchases and Subscription. Purchase, payment, trial period, renewals and refunds are processed by Apple (App Store) or Google (Google Play) as an independent controller under their privacy policies. We do not see your payment details. We receive transaction reports from the Store: country, product, price, date, order number and pseudonymous identifiers. They do not contain your name or e-mail. Verification of the Subscription and the App licence takes place on the Device via the Store’s interface. The Google Play Billing library and Google Play licence protection may send Google technical and diagnostic data about the course of the purchase and verification. Google processes these under its policies.

2.5 Statistics and error reports from the Store. Apple and Google may provide us with aggregated statistics (number of downloads, installations, countries, system versions) and technical reports on crashes and performance of the App. For Apple, only from users who have allowed sharing with developers in their iPhone settings. For Google, according to the Google Play settings (Android Vitals). This data does not reveal your identity to us and we use it only to improve the App.

2.6 Guardian. Invitations, requests and the Guardian Code are sent by SMS or call directly between you and the Guardian via your mobile operator. We do not see or store them. The link in the invitation (https://detoxer.eu/s/…) opens in the App. If it opens in a browser, our web hosting records the usual technical access data (Art. 4.2). By using the Guardian’s phone number, you are responsible for the Guardian agreeing to it.

2.7 The “Rate” button (iOS). The App sends one anonymous query to Apple’s server (itunes.apple.com) to find the link to the App Store rating. It transmits no data about you. As with any connection, Apple sees the IP address of the Device.

2.8 Notifications (end of a Detox, Plans, end of the Trial Period) are created by the App directly on the Device. We do not use server push notifications.

2.9 When you write to us. If you contact us (question, complaint, withdrawal, exercise of rights), we process your e-mail, name, the content of the message and the data you send us yourself (e.g. order number, screenshots).

2.10 Purposes, legal bases and retention periods:

2.11 We do not use profiling or automated decision-making with legal or similarly significant effects (Art. 22 GDPR). We do not sell data and do not use it for advertising. We do not process special categories of data (e.g. health data). The App does not ask about your health and infers nothing about it.

3. Parental Mode and children

3.1 What is transmitted. Parental Mode is not yet available in the App. This article will apply after it is made available. In Parental Mode (iOS only), only the following is transmitted between the child’s Device and the Parent’s Device:

• when the child’s Device was last active,
• until when the Device is locked (Detox) and until when it has internet,
• whether the permissions needed for Detox have been granted on the Device,
• technical identifiers needed to pair the two Devices.

Not transmitted are the child’s name, their Apple ID, location, contacts, communication content, browsing history, list of apps used or other Device content.

3.2 Where the data will be stored. Parental Mode data will be stored in Apple’s iCloud (CloudKit) service under a randomly generated code, without name and Apple ID. The data is encrypted in transit and at rest and may be stored in data centres in the EU and the USA.

3.3 Legal basis and retention period. We will process the data to provide the Parent with the Parental Mode they requested (performance of a contract, Art. 6(1)(b) GDPR). We will add details on the protection of records and their retention period to this policy before Parental Mode is made available.

3.4 Responsibility of the Parent. The Parent declares that they are the child’s legal guardian or are entitled to set up Parental Mode. The Parent should explain to the child, appropriately to their age, what Parental Mode does and what data about their Device they can see. The child’s rights under the GDPR are exercised by their legal guardian. A child who is capable of it given their age and maturity may also contact us themselves.

3.5 Children in general. The App does not require any personal data, and therefore we do not determine the age of Users. Users under 15 may use the App only with the consent and under the supervision of a Parent (under the Terms and Conditions, Art. 3.7). If we find that we have obtained data of a child under 15 without the Parent’s consent (e.g. in an e-mail), we will delete it without undue delay.

4. The detoxer.eu website and cookies

4.1 You can visit the detoxer.eu website without registration. We have no user accounts on it. If we introduce a contact form or a newsletter subscription, we will update this policy in advance.

4.2 Hosting technical logs. On every visit to the website, the server records the usual technical data: IP address, date and time, the address visited, browser and device data and the referring page. We process it to ensure the operation and security of the website (legitimate interest, Art. 6(1)(f) GDPR). The website is hosted by WEDOS Internet, a.s., Company ID 28115708, Masarykova 1230, 373 41 Hluboká nad Vltavou, as a processor in data centres in the Czech Republic. The logs are kept only for as long as necessary to ensure the operation and security of the website according to the hosting provider’s settings.

4.3 Cookies. Cookies are small files that a website stores in your browser. We use three groups:

• Necessary – ensure the functioning of the website and remember your choice in the cookie bar. They do not require consent (Section 89(3) of Act No. 127/2005 Coll.).
• Analytics – Google Analytics 4. Only with your consent.
• Marketing – Meta Pixel. Only with your consent.

Without consent, the analytics and marketing tools are not loaded at all.

4.4 Google Analytics 4. With your consent we measure traffic: pages visited, source of the visit, approximate location (country, city), device and browser type and a pseudonymous browser identifier. We use the data to evaluate which parts of the website work and where people come from. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acting as a processor. According to its statement, Google does not store IP addresses in GA4. We retain data in GA4 for at most 14 months. The legal basis is your consent (Art. 6(1)(a) GDPR and Section 89(3) of Act No. 127/2005 Coll.). Google’s policy: https://policies.google.com/privacy.

4.5 Meta Pixel. With your consent we use Meta Pixel on the website. It helps us measure the effectiveness of ads on Facebook and Instagram, show ads to people who have visited the website and find similar audiences. The Pixel transmits to Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland, in particular data about pages visited and actions taken (e.g. clicking a link to a Store), a browser identifier (cookie _fbp, _fbc), IP address and browser data. If you are logged in to Facebook or Instagram, Meta may link this data to your profile.

For the collection and transmission of this data we are joint controllers with Meta (Art. 26 GDPR, CJEU judgment C-40/17 Fashion ID) under the Meta Controller Addendum (https://www.facebook.com/legal/controller_addendum). For further processing after transmission (displaying ads, Meta’s own purposes), Meta is responsible as an independent controller: https://www.facebook.com/privacy/policy. You can exercise your rights with us as well as with Meta. We do not use the automatic advanced matching feature. The legal basis is your consent (Art. 6(1)(a) GDPR and Section 89(3) of Act No. 127/2005 Coll.). Pixel data is retained at Meta according to Meta’s policies, cookies according to the table below.

4.6 Consent and its withdrawal. On your first visit, the cookie bar asks for your consent. The options “Accept all” and “Reject all” are equally available on the first screen. In “Settings” you can consent to only some of the groups. You can withdraw or change your consent at any time via the “Cookie settings” link in the website footer. Withdrawing is as easy as giving consent and does not affect the lawfulness of processing before it. We remember your choice for 6 months, after which we will ask you again. You can also delete or block cookies in your browser settings.

4.7 Overview of cookies:

4.8 Social media profiles. We operate a Detoxer page on Facebook and a profile on Instagram, which the App also links to. Meta processes the data of page visitors under its policies. For page statistics (Page Insights) we are joint controllers with Meta under the Page Insights Controller Addendum. We see only aggregated statistics and public interactions (comments, messages you send us).

4.9 Links to the Stores. Download links lead to the App Store and Google Play. There, the policies of Apple and Google apply.

5. Recipients, transfers outside the EU and your rights

5.1 Recipients. Personal data may be processed by:

We do not sell data and do not pass it on to anyone else for their own marketing.

5.2 Transfers outside the EU. Apple, Google and Meta may also process data in the USA. The transfer is based on the European Commission’s adequacy decision under the EU–US Data Privacy Framework, under which these companies are certified, and further on the European Commission’s standard contractual clauses (Art. 46(2)(c) GDPR). We will provide you with a copy of the safeguards on request.

5.3 Your rights. You have the right:

• of access to your data and to a copy (Art. 15 GDPR),
• to rectification of inaccurate data (Art. 16),
• to erasure (Art. 17),
• to restriction of processing (Art. 18),
• to portability of the data you have provided to us (Art. 20),
• to object to processing based on legitimate interest (Art. 21),
• to withdraw consent at any time (cookies in the website footer), without affecting the lawfulness of earlier processing,
• to lodge a complaint with the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Praha 7, www.uoou.gov.cz, or with the supervisory authority of the country of your residence.

5.4 How to exercise your rights. Write to us at info@detoxer.eu. We will reply without undue delay, at the latest within 1 month. In complex cases we may extend the period by a further 2 months, of which we will inform you. To avoid releasing data to someone else, we may verify your identity. Please note that we do not have the data stored only on your Device (Art. 2.1). You manage it yourself in the App or by uninstalling it. Purchase data is managed by Apple or Google. For deletion of your Store account, please contact them.

5.5 Security. We protect data with appropriate technical and organisational measures: data in the App stays on the Device under the protection of its system, communication with the Stores and iCloud is encrypted, the website runs over HTTPS, access to developer consoles is protected by two-factor authentication and only authorised persons bound by confidentiality have it. We will notify a security breach that would pose a risk to your rights to the Office for Personal Data Protection within 72 hours, and to you without undue delay if the risk were high.

5.6 Changes to the policy. We update the policy when the App, the website or legal regulations change. We will inform you of material changes in advance in the App or on the website. The current version is always available at https://detoxer.eu/soukromi and in the App (Settings → Privacy).

5.7 This policy in version 2.0 is effective from 1 November 2026 and replaces the previous version of the policy (version 1.1).