Plena Privacy Policy

Introduction

Plena ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our meditation tracking application ("App") and related services.

Data Controller: Plena (Plenitudo.ai) acts as the data controller for personal data processed within the app.

Important: This app uses Apple's HealthKit framework to access health data. Your health information is sensitive, and we take its protection seriously.

Information We Collect

Health Data (via HealthKit)

Plena accesses the following health data types through Apple's HealthKit framework:

Device Information

We may collect information about your device, including:

• Device model and operating system version
• App version
• Anonymous device identifiers generated by the operating system (used solely for app functionality, not tracking or advertising)

Note: We do not use advertising identifiers (IDFA) or any tracking identifiers.

Usage Data

We may collect information about how you use the App, including:

• Session start and stop times
• Features used within the app
• Crash reports and performance data (automatically collected by Apple)

How We Use Your Information

Primary Uses

Health Data:

• Display real-time biometric readings during meditation sessions
• Calculate stress zone classifications
• Generate session summaries and statistics
• Create data visualizations and trend analysis
• Provide personalized insights about your meditation practice

Device Information:

• Ensure app compatibility
• Troubleshoot technical issues
• Improve app performance

Usage Data:

• Understand how features are used
• Improve user experience
• Identify and fix bugs

We Do NOT:

• Sell your data to third parties
• Share your health data with advertisers
• Use your data for marketing purposes without consent
• Access your data for purposes other than app functionality
• Store your data on our servers

Data Storage & Security

Local Storage

Primary Storage:

• Health data is stored locally on your device using CoreData
• All health data remains on your device unless you enable iCloud sync

What is Stored Locally:

• Session summaries and statistics
• App preferences and settings
• Historical data visualizations
• Cache and temporary files

iCloud Sync (Optional)

If You Enable CloudKit/iCloud:

• Data syncs between your iPhone and Apple Watch
• Data is stored in your personal iCloud account
• Sync is encrypted end-to-end by Apple
• You can disable iCloud sync anytime in Settings

What Syncs:

• Session data
• Statistics and summaries
• App settings and preferences

What Does NOT Sync:

• Raw HealthKit data (stays in HealthKit)
• Your HealthKit permissions (device-specific)

Security Measures

• HealthKit Integration: All health data access uses Apple's secure HealthKit framework
• Local Storage: Data is protected by iOS system-level encryption and your device's security features
• iCloud Encryption: If using iCloud, data is encrypted by Apple
• No Third-Party Servers: We do not transmit your health data to our servers
• Device Security: Your device's built-in security protects your data

Data Sharing

Third-Party Services

Apple HealthKit:

• We read and write data to HealthKit
• HealthKit is managed by Apple, not by us
• See Apple's Privacy Policy for HealthKit data handling
• You control HealthKit permissions in iOS Settings

Apple CloudKit (if enabled):

• Used for syncing data between your devices
• Managed by Apple
• Data remains in your iCloud account
• Encrypted by Apple

What We Do NOT Share

• We do NOT share your health data with third parties
• We do NOT sell your data
• We do NOT use analytics services that collect health data
• We do NOT share data with advertisers
• We do NOT share data with social media platforms

Legal Requirements

We may disclose your information if required by law, such as:

• To comply with legal obligations
• To respond to valid legal requests
• To protect our rights or the rights of others
• In emergency situations to protect health or safety (note: since Plena does not transmit health data to our servers, any such disclosure would only apply to non-health information if legally required)

Your Rights

Access to Your Data

View Your Health Data:

• Open the Health app on your iPhone
• Browse → View your heart rate, HRV, respiratory rate, etc.
• All health data is accessible in the Health app

View App Data:

• Open Plena app
• Go to Dashboard tab to view your statistics
• Go to Data tab to view historical visualizations

Data Deletion

Delete HealthKit Data:

1. Open Health app on iPhone
2. Browse → Find the data type (e.g., Heart Rate)
3. Tap "Show All Data"
4. Tap "Edit" → Delete specific entries or all data

Delete App Data:

• Delete the Plena app from your device
• This removes local app data
• HealthKit data remains (delete separately if desired)
• iCloud data may remain (delete in iCloud settings)

HealthKit Permissions

Manage Permissions:

1. Settings → Privacy & Security → Health
2. Tap "Plena"
3. Toggle ON/OFF for each data type
4. Changes take effect immediately

Revoke All Permissions:

• Turn OFF all data types in Settings
• App will not be able to access health data
• App functionality will be limited

Health Data Specific Information

HealthKit Integration

What is HealthKit?

• HealthKit is Apple's secure framework for health data
• It acts as a central repository for health information
• Apps can read and write data with your permission
• All HealthKit data is encrypted and secure

Our Use of HealthKit:

• We read biometric data during meditation sessions
• We write meditation session data back to HealthKit
• We do not read or write data outside of app usage
• We only access data types necessary for app functionality
• Health data obtained through HealthKit is not used for advertising, marketing, or tracking, and is not shared with analytics services

Health Data Privacy

Your Health Data is Private:

• Stored securely on your device or in your iCloud account
• Encrypted by Apple's security systems
• Not transmitted to our servers
• Not shared with third parties
• Under your control at all times

Medical Disclaimer

Important: Plena is not a medical device and does not provide medical advice, diagnosis, or treatment. The information provided by Plena is for wellness and self-improvement purposes only.

• Do not use Plena data to diagnose, treat, or prevent any disease
• Consult healthcare professionals for medical advice
• Do not rely on Plena data for medical decisions
• Plena data is not a substitute for professional medical care

Children's Privacy

Plena is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian:

• HealthKit requires users to be 13+ to use health apps
• Children's health data should be managed through Family Sharing features
• Contact us if you believe we have inadvertently collected data from a child under 13

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective when posted in the app or on our website.

We will notify you of significant changes by:

• Posting the updated policy in the app
• Updating the "Last Updated" date
• Providing notification through the app (for major changes)

Continued use of the app after changes constitutes acceptance of the updated policy.

Data Retention

Local Data:

• Stored on your device until you delete the app
• You can delete data anytime by deleting the app

iCloud Data:

• Stored in your iCloud account until you delete it
• Follows your iCloud storage settings
• Can be deleted in iCloud settings

HealthKit Data:

• Managed by Apple's HealthKit system
• Follows your Health app settings
• You control retention in the Health app

International Users

If you are using Plena outside the United States:

• Your data may be processed and stored in your country or region
• iCloud data is stored according to your iCloud account region
• HealthKit data is stored according to Apple's regional policies
• We comply with applicable data protection laws

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data:

California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale of personal information (we do not sell data)
• Right to non-discrimination for exercising privacy rights

Note: We do not sell personal information. We do not share health data with third parties for commercial purposes.

European Union (GDPR) Rights

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

To exercise these rights, contact us at info@plenitudo.ai.

Legal Basis for Processing (GDPR Article 6)

We process health data based on your explicit consent, which you grant through Apple HealthKit permissions. You may withdraw consent at any time through iOS settings. This consent is the lawful basis for processing your health data under GDPR Article 6(1)(a).

Consent

By using Plena, you consent to:

• The collection and use of information as described in this Privacy Policy
• HealthKit data access as described
• Local storage of session data on your device
• Optional iCloud sync (if enabled)

You can withdraw consent by:

• Revoking HealthKit permissions in Settings
• Disabling iCloud sync
• Deleting the app

Summary

In Simple Terms:

• We only access health data you explicitly permit
• Your data stays on your device or in your iCloud account
• We don't share your data with anyone
• You control all permissions
• You can delete your data anytime

Your Privacy Matters: We built Plena with privacy in mind. Your health data is yours, and we're just here to help you understand it better.