Privacy Policy

1. Who is responsible for your data

The data controller is:

Controller	Eulogi Bordas Casas, sole trader established in Spain
Address	Passeig de Gràcia 74, 4th floor, 08008 Barcelona, Spain
Email	hello@reedbreathworks.com
Telephone	+34 649 450 624

This policy covers the Reed iPhone app, the Reed Pro subscription, and the website at reedbreathworks.com.

Reed is not required to appoint a Data Protection Officer, and has not appointed one. Write to the address above with any question about your data and it will reach the person responsible.

2. What stays on your device

The following never leaves your phone. It is written to a database inside Reed's own app storage, protected by iOS, and is not backed up to any server we operate:

• Your check-ins — the before and after ratings you give on the five-point scale
• Your session history — which sessions you practised, when, and for how long
• Your shift figures and the trends built from them
• Health information you provide during setup — the conditions you flag on the health screen, such as pregnancy, a cardiovascular condition, epilepsy, or any of the others listed there
• Safety acknowledgements — a timestamped record of the safety information you confirmed before starting certain sessions, including which conditions you had flagged at the time
• Your settings — theme, tones, pinned sessions, home session, custom patterns, and reminder times

We do not receive any of this. It is not transmitted, not synchronised, not backed up to us, and not included in anything we can access. Because we never obtain it, we are not processing it as a controller, and there is nothing for us to disclose, sell, or lose.

Two consequences worth being clear about:

• If you delete Reed or reset your phone, this data is gone permanently. We cannot restore it. There is no cloud copy.
• If your device is backed up through iCloud or a computer, Reed's data may be included in that backup, under Apple's terms and your own backup settings, not ours.

The health information and safety records deserve a specific note, because health data is sensitive. Reed asks about your health for one reason: to decide which sessions to close to you and which warnings to show. That decision is made on the device, by the app, using data that stays on the device. It is never sent to us and never shared with anyone.

3. What we actually receive

3.1 Your subscription status

If you subscribe to Reed Pro, we need to know that you did, so the app can unlock and later restore it.

Purchases are processed by Apple. We never see your name, card details, or billing address. Apple provides us with anonymised sales and payout reporting, which does not identify you.

We use RevenueCat to manage entitlements. When Reed checks or restores your subscription, RevenueCat processes:

• an anonymous app user ID generated by the SDK, which is not your name, email, or Apple ID
• your purchase and subscription status, product, and renewal or expiry dates
• basic technical information about the device and app version
• an IP address, from which an approximate country is derived

RevenueCat acts as our processor under a data processing agreement. We do not use it to identify you personally, and we do not combine it with anything else.

3.2 If you write to us

If you email hello@reedbreathworks.com, we receive your email address and whatever you choose to put in the message. We use it to answer you and keep it only as long as needed for that, and for any record we are legally required to keep.

3.3 The website

reedbreathworks.com is hosted by Vercel. Vercel processes standard server request data, including IP address, browser type, and pages requested, to serve and secure the site.

The website runs no analytics. We do not use Vercel Analytics, Google Analytics, or any comparable tool. We do not build visitor profiles, and we do not know who visits the site or what they read beyond the server request data described above, which Vercel processes to serve and secure the site.

The website does not use advertising or cross-site tracking cookies, and sets no cookie that is not strictly necessary to serve the page.

4. Why we are allowed to process it (legal bases)

What	Purpose	Legal basis (GDPR Art. 6)
Subscription and entitlement data	To provide Reed Pro and restore it across your devices	Performance of a contract, Art. 6(1)(b)
Emails you send us	To answer you	Legitimate interests, Art. 6(1)(f) — responding to people who contact us
Website server logs	To operate and secure the site	Legitimate interests, Art. 6(1)(f) — security and availability

Health information is a special category of data under Art. 9. Because it never leaves your device and we never receive it, we do not process it and no Art. 9 condition is engaged on our side.

5. Who else sees your data

Recipient	Role	What for
Apple	Independent controller	Payment, App Store distribution
RevenueCat, Inc.	Our processor	Subscription entitlement management
Vercel Inc.	Our processor	Website hosting

We do not sell personal data. We do not share it with advertisers or data brokers. We do not use it to train any model.

We may disclose data if we are legally required to, or to establish or defend a legal claim — but note that for the on-device data in section 2, we have nothing to disclose, because we do not hold it.

6. Transfers outside the EEA

RevenueCat and Vercel are established in the United States. Where personal data is transferred there, the transfer is made under the European Commission's Standard Contractual Clauses, together with the supplementary measures each provider applies.

You can ask us for information about these safeguards at hello@reedbreathworks.com.

7. How long we keep it

• On-device data — for as long as Reed is installed, until you delete it. Under your control, not ours.
• Subscription records — for as long as your subscription is active, and afterwards for as long as needed for accounting, tax, and legal purposes. Spanish law generally requires commercial records to be kept for six years.
• Emails — for as long as needed to deal with your enquiry, and any period we are required to keep them.
• Website logs — for the short retention periods Vercel applies.

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you
• rectify it if it is inaccurate
• erase it, in the circumstances the law provides
• restrict or object to our processing of it
• portability — receive it in a machine-readable format
• withdraw consent, where we rely on consent
• not be subject to a decision based solely on automated processing with legal or similarly significant effects. Reed makes no such decisions.

To exercise any of these, write to hello@reedbreathworks.com. We will respond within one month.

Please note what we can and cannot do. For subscription data we can act on all of these. For the data described in section 2, we cannot — not because we refuse, but because we do not have it. You already hold it, and you can erase all of it by deleting the app. We would rather say this plainly than imply a control we do not have.

If you are unhappy with how we have handled your data, you may complain to the Spanish supervisory authority:

Agencia Española de Protección de Datos (AEPD) C/ Jorge Juan, 6, 28001 Madrid www.aepd.es

If you live in another EEA country, you may complain to your own national supervisory authority instead.

9. Children

Reed is for adults. Our Terms of Use require you to be 18 or older. We do not knowingly collect data from anyone under 18. If you believe a minor has used Reed, write to hello@reedbreathworks.com.

10. Security

On-device data is stored inside Reed's app container and protected by iOS, including device encryption when you have a passcode set. Data in transit to Apple and RevenueCat uses TLS provided by the operating system.

No system is perfectly secure. But the strongest protection here is structural rather than technical: the sensitive data — your check-ins, your health flags, your history — is not on any server we run, so there is no central store of it to breach.

11. Changes to this policy

We will post any updated policy here with a new date, and where a change materially affects you we will say so in the app before it takes effect.

12. Contact

Eulogi Bordas Casas Passeig de Gràcia 74, 4th floor, 08008 Barcelona, Spain hello@reedbreathworks.com +34 649 450 624