Privacy Policy
Integro Last updated: 4 August 2026 · Version 1.1
The short version
Integro asks you a few questions each morning and gives you a reading of your day. To do that it holds what you tell it about your sleep, your body and your mind — which the law treats as health-related information, and which we therefore ask your explicit permission for, separately, before we ask you anything.
We do not sell your data. We do not advertise. There is no analytics service, no tracking, and no third party watching what you do in the app. Your history lives on your phone and in your own space on our servers in Germany, which nobody but you can open. You can take a copy of everything, or erase all of it, from inside the app at any time.
Three things we would rather you knew than discovered:
- Your voice leaves your phone to be transcribed. Turning speech into text is done by Google (on Android) or Apple (on iOS), not by us and not on the device.
- Your companion is an AI, and the words it says to you are generated by a language model run by Anthropic in the United States.
- Integro is not a medical service. It does not diagnose, treat, or give medical advice, and it is not a substitute for a clinician.
The rest of this policy is the detail behind those three sentences.
1 · Who is responsible for your data
The data controller is:
INTEGROHEALTH SAĞLIK DANIŞMANLIĞI VE BİLİŞİM TEKNOLOJİLERİ A.Ş. Maslak Mah. Sanatkarlar Sk. Eclipse Maslak Sitesi No: 2e, İç Kapı No: 9 Sarıyer / İstanbul, Türkiye MERSİS: 0465158799700001 · Trade registry no: 1080387 Privacy contact: [email protected]
You can reach us about anything in this policy at the address above.
2 · What we collect
2a · Your identity
| What | Where it comes from | Where it lives |
|---|---|---|
| An anonymous account (a random identifier) | Created silently the first time you open the app. No email, no name, no sign-up screen. | Our authentication service, hosted in Frankfurt, Germany |
| Your email address, or your Apple ID — optional | Only if you accept the offer to attach an account, which appears after your first reading | Same |
| The name you asked to be called | You tell the companion during the first conversation | Your phone, and your own space on our servers |
You can use Integro without ever giving us an email address. Attaching one exists for a single purpose: it is what makes your history recoverable if you lose your phone.
2b · What you tell us about your state special category data
This is the heart of the product and the most sensitive thing we hold. Under GDPR Article 9 and KVKK Article 6 it is special category / health-related data, and we ask for your explicit permission before collecting any of it.
- The four words you give each morning about your sleep, your body, your capacity and your mind
- What you actually said, kept in your own words rather than only as a score
- Hours of sleep, if you choose to say — never required
- Your answers in the first conversation: what you want to change, what a bad morning feels like, what loads you, when you wake naturally, and what you suspect is behind it
- One rotating question a morning about things that move how you feel — food, drink, training, the circumstances of your sleep
- Your answers to the companion’s follow-up after a reading
- Whether the day went the way the app predicted
- What we work out from all of this: your readiness score, its band, the directives you are given, and your personal baseline as it forms
2c · Your settings and records of your choices
The time you consented and to what, separately from your acceptance of the terms; whether you chose a nudge or an alarm and for what time; whether you allowed notifications; quiet mode; and small markers that stop the app repeating itself within a day.
2d · What we do not collect
No advertising identifiers. No analytics. No crash reporting. No location. No contacts, photos, or health-platform data. No third-party tracking of any kind. This is not a policy promise about the future — there is no such code in the app today.
3 · Why we hold it, and on what legal basis
| What | Why | Legal basis |
|---|---|---|
| Everything in §2b | To build your picture and give you your morning reading — the entire function of the app | Your explicit consent — GDPR Art. 9(2)(a) with Art. 6(1)(a); KVKK Art. 6 (açık rıza) |
| Your anonymous account, and your email if you attach one | To keep your history yours, to make it recoverable, and to run the subscription | Performance of a contract — GDPR Art. 6(1)(b) |
| Your settings and consent records | To do what you asked, and to be able to show when you agreed to what | Contract, and our legal obligation to evidence consent |
| Basic protection against abuse of our servers | To keep the service standing | Legitimate interests — GDPR Art. 6(1)(f) |
You can withdraw your consent at any time, and withdrawing it is not buried: “Your data” at the foot of the daytime home erases everything. Withdrawal does not undo processing that already lawfully happened before you withdrew.
4 · Who else touches your data
We use a small number of service providers. They process data on our instructions and for no purpose of their own.
| Who | What they do | Where |
|---|---|---|
| Supabase | Hosts our database and authentication, and runs the small server function that talks to the language model | Frankfurt, Germany (EU) |
| Anthropic | Runs the language model that understands what you said and writes your reading in words | United States |
| Google (Android) / Apple (iOS) | Turn your speech into text; Google also provides the voice that speaks to you | Their own infrastructure |
| Apple / Google | Sell and manage the subscription. We never see your card. | Their own infrastructure |
4a · Your voice, specifically
When you speak to Integro, the audio is sent to Google’s (Android) or Apple’s (iOS) speech service to be turned into text. It does not stay on your phone, and we do not choose those companies’ retention terms — their own privacy policies govern what they do with it.
We want to be plain about why this matters: what you say to Integro is often about your sleep, your body and your mind, so the audio can carry health-related content. We use the network service deliberately, because the on-device alternative was tested on real hardware and failed to hear most of what people said, which made the product unusable rather than private.
If you would rather not send your voice anywhere, you can type instead. Every question in the app can be answered from the keyboard, and nothing is lost by doing so.
5 · The companion is an AI
You are talking to an artificial intelligence, not a person. The app says so, out loud and on screen, before it asks you anything.
The words your companion says are generated by a large language model (Anthropic’s Claude) running on servers in the United States. When it writes your reading, it receives your words for that morning, the scores our own engine calculated, and the rules we wrote for it — for the time it takes to answer, and no longer.
What you tell Integro is not used to train that model. Anthropic’s published position for its commercial products, including the API we use, is that inputs and outputs are not used to train their models by default. The exception in their terms is feedback a customer explicitly submits — a mechanism Integro does not use and does not have.
Your morning score and its band are calculated by our own code on your phone, not by the language model. The model puts them into words; it does not decide them.
5a · Automated analysis, and what it is not
Your readiness score, its band, and the directives you are given are produced automatically, by our own code, from the answers you give. Nobody reads your check-in and forms a view about you.
We want to be exact about what that does and does not amount to. It is automated analysis that produces a result about you, and you are entitled to know that. But it makes no decision about you: it does not determine what you may access, what you pay, or anything with a legal or similarly significant effect. It is information produced for you, about your own morning, which you are free to disregard entirely.
If you would rather a person looked at something the app concluded, or you want to contest a result, write to us at [email protected].
6 · Where your data lives, and when it crosses a border
Your history is stored in two places: on your phone, and in your own space in our database in Frankfurt, Germany.
That server copy is protected by a rule enforced by the database itself: each row is bound to the account that created it, and no other account can read it, even with a valid credential.
Data leaves the EU in two situations, both of them momentary rather than storage:
- To the United States, each time your reading is written, so the language model can turn your morning into sentences.
- To your phone’s maker — Google or Apple — each time you speak, so your voice can be transcribed.
The model-provider transfer is protected by the EU Standard Contractual Clauses incorporated into our agreement with the provider, which also participates in the EU-US Data Privacy Framework. Write to us at [email protected] for details of these safeguards.
7 · How long we keep it
| What | How long |
|---|---|
| Your history, on your phone and on our servers | Until you delete it. We do not expire it on our own — the point of the product is that it accumulates. |
| Your account | Until you delete it |
| The server function’s logs | Transient, and content-free |
| What the model provider holds | Their own retention window, set by their terms rather than by us |
8 · Your rights
You can, at any time:
- See and take a copy of everything we hold. “Your data” → Take a copy produces a complete file of every check-in, score and note. (Right of access; right to data portability.)
- Erase everything. “Your data” → Delete everything removes your rows from our servers, clears the database on your phone, and discards your account. The next time you open the app it is a genuine first run. It cannot be undone, and we tell you so before you confirm. If we cannot reach the server, nothing is deleted and the app says so plainly rather than pretending. (Right to erasure.)
- Withdraw your consent, which is the same action as erasing.
- Object to, or ask us to restrict, our processing.
- Complain to a supervisory authority — in the EU, the authority where you live; in Türkiye, the Kişisel Verileri Koruma Kurumu (see §12 for your rights under Turkish law specifically).
Deleting your data does not cancel your subscription. Only the App Store or Google Play can do that, from your own account settings — we have no power over it, and we say so on the deletion screen too.
9 · Age
You must be 18 or over to use Integro. It is not built for children or teenagers, and we do not knowingly collect anything from them.
This is not about what the app shows — there is nothing in Integro unsuitable for any age. It is about two things. What you tell Integro is health-related information, and the law is careful about whether a person under 18 can meaningfully agree to that being collected. And the product itself reasons about adult sleep, adult training and adult working days; its judgements are not built for a body that is still growing.
If you believe someone under 18 has been using Integro, write to us at [email protected] and we will delete their data.
10 · Security
Your data is protected in transit and at rest by our hosting provider. Access to the server copy is enforced by the database on a per-account basis, not by application code that could be bypassed. On Android, we have deliberately excluded the app from Google’s automatic backup and from phone-to-phone transfer, so that your history is not copied to a cloud drive or a new device without your involvement — attaching an account is the one recovery path we can describe honestly.
No system is perfectly secure, and we will not claim otherwise.
11 · Changes to this policy
If we change how we handle your data, we will update this policy and, where the change is significant, tell you inside the app. The version and date at the top will always say which text you are reading.
12 · For users in Türkiye — KVKK
Integro is operated by a Turkish company, so Law No. 6698 on the Protection of Personal Data (KVKK) applies to everything described above, whoever you are and wherever you are. This section states, in the form KVKK Article 10 requires, what the rest of this policy already describes.
Data controller (veri sorumlusu). INTEGROHEALTH SAĞLIK DANIŞMANLIĞI VE BİLİŞİM TEKNOLOJİLERİ A.Ş., MERSİS 0465158799700001, at the address in §1. Contact: [email protected].
What is processed, and why. The categories in §2 — your identity, what you tell us about your state, and your settings — for the purposes in §3: building your picture and giving you your morning reading, running your account and subscription, and keeping the service standing.
How it is collected, and on what ground. Everything is collected through the app itself, from what you type or say. Data about your sleep, body and mind is special category data (özel nitelikli kişisel veri) and is processed on the basis of your explicit consent (açık rıza) under KVKK Article 6, taken as its own separate action before anything is asked. Your account and settings are processed on the basis of contract performance under Article 5.
Who it is transferred to, and abroad. The recipients in §4: Supabase, Anthropic, and Apple or Google. Because we are established in Türkiye, all of these are transfers abroad under KVKK Article 9 — including the data stored in Germany. These transfers rest on your explicit consent (açık rıza), which you give as its own separate action in the app, informed on that same screen that your words cross a border — the storage in Germany, the model in the United States, and the speech service — before anything is asked of you.
Your rights under KVKK Article 11. You may apply to us to:
- learn whether your personal data is processed;
- request information about it if it has been;
- learn its purpose of processing, and whether it is used accordingly;
- know the third parties to whom it is transferred, in Türkiye or abroad;
- have it corrected if it is incomplete or inaccurate, and have that correction notified to those third parties;
- have it erased or destroyed where the grounds for processing have fallen away, and have that notified to those third parties;
- object to a result reached about you exclusively by automated analysis — see §5a, since that is what the app does;
- claim compensation for damage arising from unlawful processing.
Most of these you can exercise yourself, immediately, without writing to anyone: “Your data” in the app takes a full copy or erases everything. For anything else, write to [email protected]. We answer within thirty days, which is the period KVKK allows.
13 · Getting in touch
Write to [email protected] with anything about this policy, or to exercise any of the rights in §8. We answer within one month, which is the period the law allows us.