Privacy Policy
Effective date: 10 May 2026 · Last updated: 18 October 2026
1. Who We Are
FertOS is a fertility decision support application operated by Promotich OOD ("we", "us", or "our"). We are the data controller for personal data collected through the app and website at fertos.promotich.team.
Contact: support@promotich.team
2. Data We Collect
We collect the following categories of data:
Account data — email address, name, profile photo (from Google Sign-In or provided by you).
Health and fertility data — biological sex, fertility state, cycle length, period length, mood logs, lab results (PDF/photos you upload), onboarding questionnaire answers, AI conversation history.
Usage data — app interactions, screen views, session timestamps, device type.
Payment data — subscription tier, purchase timestamps. Payment card details are processed directly by Stripe or Apple/Google and are never stored by us.
Technical data — IP address, browser/device type, crash logs.
3. Legal Basis for Processing (GDPR)
We process your data under the following legal bases:
- Contract performance — to provide the FertOS service you signed up for (account management, AI features, roadmap). - Legitimate interests — product improvement, fraud prevention, security. - Explicit consent — for processing special category health data (Art. 9 GDPR). You provide this consent when you submit fertility and health information during onboarding and throughout app use. - Legal obligation — where required by applicable law.
You may withdraw consent for health data processing at any time by deleting your account. This will result in termination of the service.
4. How We Use Your Data
- Personalization — your fertility state, cycle data, and lab results are used to generate your personalized roadmap and AI responses. - AI processing — your messages and health context are sent to Anthropic's Claude API to generate AI advisor responses. Anthropic processes this data as a sub-processor under a data processing agreement. - Lab analysis — uploaded documents (PDFs, photos) are stored in AWS S3 and analyzed using Claude API. - Communication — we send magic link authentication emails via AWS SES. - Analytics — anonymized usage data helps us improve the product. - Subscription management — Stripe (web) and Apple/Google (mobile) process payments.
5. Sub-processors and Third Parties
We share data with the following processors:
| Processor | Purpose | Location |
|---|---|---|
| Anthropic | AI conversation and document analysis | USA |
| AWS (S3, SES) | File storage, email delivery | EU / USA |
| Authentication (Sign in with Google) | USA | |
| Apple | Authentication (Sign in with Apple) | USA |
| Stripe | Web payment processing | USA / EU |
| RevenueCat | Mobile subscription management | USA |
All processors are bound by data processing agreements and comply with GDPR where applicable (Standard Contractual Clauses for US transfers).
We do not sell your data. We do not share your health data with advertisers.
6. Data Retention
- Account and health data — retained for the duration of your account plus 30 days after deletion. - AI conversation history — retained for the duration of your account. You can delete individual threads at any time within the app. - Uploaded documents — retained until you delete them or your account. - Usage logs — retained for 90 days. - Payment records — retained for 7 years as required by financial regulations.
7. Your Rights (GDPR)
If you are located in the EU/EEA, you have the following rights:
- Access — request a copy of your personal data. - Rectification — correct inaccurate data. - Erasure — delete your account and all associated data (Settings → Delete account). - Portability — receive your data in a machine-readable format. - Restriction — request we limit processing in certain circumstances. - Objection — object to processing based on legitimate interests. - Withdraw consent — for health data processing (results in account deletion).
To exercise any right, email: support@promotich.team. We will respond within 30 days.
You also have the right to lodge a complaint with your local data protection authority.
8. Data Security
We implement appropriate technical and organizational measures:
- All data in transit is encrypted via TLS 1.2+. - Clinic account passwords are stored as secure hashes, never in plain text. Other sign-in methods use Google, Apple or email links. - Database access is restricted and monitored. - S3 files are encrypted at rest. - JWT tokens use short expiry (15 minutes for access tokens).
9. Children
FertOS is not intended for users under 18 years of age. We do not knowingly collect data from minors. If you believe a minor has provided data, contact us at support@promotich.team and we will delete it promptly.
10. Changes to This Policy
We may update this policy from time to time. We will notify you of material changes via email or in-app notification. Continued use after the change effective date constitutes acceptance.
11. Contact
Promotich OOD Data Controller
Email: support@promotich.team Website: fertos.promotich.team
12. Public website analytics
On fertos-portal.promotich.team, Google Analytics 4 is loaded only after you allow analytics cookies. It measures public page visits and technical browser/device information. We do not send your FertOS account, medical records, URL query strings or URL fragments to Google Analytics. Advertising personalization is disabled.
You can decline or withdraw your choice using Analytics settings on the public site. Withdrawal stops further collection and removes the analytics cookies set by this integration; it does not erase data already received by Google. Your choice is stored in this browser when storage is available. For questions or data requests, contact support@promotich.team.