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Grounded Privacy Policy

Grounded: Daily Affirmations – Privacy Policy

Last updated: 14.02.2026

1. Who We Are

Grounded: Daily Affirmations (“Grounded,” “we,” “us,” or “our”) is a mobile application developed and operated by BPA TARGET SRL.

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), we act as the data controller of the data described in this Privacy Policy.

Grounded is designed as a local-first wellness app. All user-generated content remains stored locally on the user’s device and is not transmitted to us.

Limited technical and subscription-related metadata may be processed by third-party providers such as Mixpanel and RevenueCat solely for analytics and subscription validation.

If you have questions regarding this Privacy Policy, you may contact us at: support@bpatarget.com.

By using the app, you agree to this Privacy Policy and our Terms of Use.

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store, and safeguard information when you use the Grounded mobile application.

Grounded is a personal development application that provides affirmations and allows users to personalize certain preferences.

Grounded is not a medical, psychological, therapeutic, or healthcare service.

By using the application, you acknowledge that information may be processed as described in this Privacy Policy.

3. Information We Process

3.1 Optional Information Provided During Onboarding

Grounded does not require account registration. However, during onboarding you may optionally provide information such as:

• Name or nickname (optional)

• Gender selection (optional)

• Age group (18+ categories)

• Selected goals

• Preferred affirmation categories

• Mood selections

• Notification preferences

This information is associated with a pseudonymous app-generated identifier and is not used to directly identify you.

3.2 Technical and Usage Data

Certain technical data may be processed automatically when you use the app, including:

• Pseudonymous app user identifier

• Device model

• Operating system version

• App version and build number

• Timezone

• Country or region derived from device settings

• Session counts and timestamps

• Subscription status and storefront country

We do not collect:

• Precise GPS location

• Contacts or messages

• Photos or media files

• Health records

• Payment card details

All purchases are processed directly by Apple through the App Store.

Important Note: Deleting the app permanently removes all locally stored data from your device.

4. Analytics (Mixpanel)

We use Mixpanel to process limited analytics data to understand onboarding completion, subscription trends, app performance, and stability.

Mixpanel may process:

• Pseudonymous identifiers

• Device information

• App version

• Timezone and region

• Onboarding selections

• Limited session metadata

Analytics are processed in pseudonymous form and are not used to directly identify individuals.

Mixpanel is headquartered in the United States and data may be transferred outside the European Union under appropriate safeguards, including Standard Contractual Clauses or the EU–US Data Privacy Framework.

5. Subscription Management (RevenueCat)

We use RevenueCat to manage in-app subscriptions and validate premium access.

RevenueCat may process:

• App user identifier

• Subscription status

• Transaction metadata

• Storefront country

• IP address for fraud prevention

RevenueCat does not receive onboarding preferences, mood selections, or other personalization data.

6. Advertising

Grounded does not sell personal data and does not share personal data with advertising networks.

We do not perform cross-app tracking and we do not upload user identifiers to advertising platforms.

Marketing decisions are based only on aggregated, non-identifiable information.

7. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area, processing is based on:

• Contractual necessity to provide app functionality and subscriptions

• Legitimate interests to improve performance, reliability, and security

• Consent where applicable (for example push notifications)

8. Data Retention

• Local app data remains on your device until the app is deleted

• Analytics data is retained only as long as necessary for service improvement

• Subscription-related metadata is retained according to service provider requirements

Important Note: Deleting the app permanently removes all locally stored data from your device.

9. International Data Transfers

Grounded is operated from Romania but is available globally via the Apple App Store.

Some service providers may process data outside the European Economic Area, including the United States.

We rely on legally recognized safeguards such as Standard Contractual Clauses and the EU–US Data Privacy Framework.

By using the application, you acknowledge that your data may be processed internationally subject to these safeguards.

10. Your Data Protection Rights

If you are located in the European Economic Area, you may have the right to:

• Access your data

• Request correction of inaccurate data

• Request deletion of data

• Restrict processing

• Object to processing

• Request data portability

Because Grounded operates without account registration, we may not be able to identify you unless you provide the app-generated identifier.

To exercise your rights, contact: support@bpatarget.com.

11. Children

Grounded is intended for users aged 18 and older.

We do not knowingly collect data from individuals under 18.

If you believe a minor has used the app, please contact us.

12. Security

We implement reasonable technical and organizational safeguards including encrypted transmission, pseudonymization of identifiers, and restricted access to analytics systems.

However, no digital system can guarantee absolute security.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in legal requirements, infrastructure, or data processing practices.

The most recent version will always include the latest revision date.

Continued use of the application constitutes acceptance of any updates.

14. Limitation of Liability

To the maximum extent permitted by law, Grounded is provided on an “as is” and “as available” basis.

We are not liable for indirect, incidental, or consequential damages arising from the use or inability to use the application, except where such limitation is prohibited by law.

15. Contact & Effective Date

support@bpatarget.com

Effective Date: 14.02.2026

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