Privacy Policy

Introduction

Chrono is a sleep tracking application designed to help you understand and improve your sleep patterns based on your chronotype (Bear, Lion, or Wolf). This Privacy Policy explains how we collect, use, and protect your information.

Information We Collect

Health Data

Chrono accesses the following data from Apple Health (HealthKit):

Sleep Analysis Data: Sleep duration, bedtime, wake time
Sleep Sessions: Manually logged sleep sessions

App Preferences

Your chosen chronotype (Bear, Lion, or Wolf)
Sleep schedule preferences
Notification settings
App configuration and preferences

Data We Do NOT Collect

❌ Personal identification information (name, email, phone)
❌ Location data
❌ Browsing history
❌ Social media information
❌ Payment information
❌ Any data from third-party apps

How We Use Your Data

Your sleep data is used exclusively to:

Calculate your daily sleep score
Provide personalized sleep insights based on your chronotype
Track your sleep consistency and patterns
Animate your sleep companion pet (Bear, Lion, or Wolf)
Generate sleep recommendations and tips
Display progress and statistics

Data Combination and Processing

We do NOT combine your sleep data with:

❌ Data from other apps on your device
❌ Data from other devices (Apple Watch, Fitbit, etc.)
❌ Data from external sources or databases
❌ Social media information
❌ Location tracking data

We ONLY process:

✅ Sleep Analysis data from Apple Health (HealthKit)
✅ In isolation, without cross-referencing external sources

This ensures your sleep data remains private and is used solely for the app's intended purpose.

Data Storage and Security

Local Storage

ALL your sleep data stays on your device. We do NOT:

❌ Upload data to external servers
❌ Store data in the cloud
❌ Transmit data over the internet
❌ Share data with third parties
❌ Sell your information to advertisers

Data Protection

All HealthKit data is protected by Apple's security measures
Your sleep data is encrypted and stored locally on your device
Only you have access to your data through the app

Data Processing Lifecycle

For transparency, here's how your sleep data flows through Chrono:

Collection: HealthKit permission requested → User grants access → App reads Sleep Analysis data
Processing: Data processed locally on your device to calculate sleep score and insights
Storage: Results stored locally using Apple's encrypted storage (no cloud sync)
Display: Information shown in Home, Stats, and Calendar screens
Retention: Data retained indefinitely until you uninstall the app
Deletion: Complete removal upon app uninstallation (no backups remain)

No external transmission occurs at any stage.

Third-Party Services

Chrono does NOT integrate with or share data with any third-party services, including:

Analytics platforms
Advertising networks
Social media platforms
Cloud storage services

Your Rights Under LGPD (Article 18)

As a Brazilian data subject, you have the following rights:

Confirmation (Confirmação): Confirm that we process your data
→ Answer: Yes, we process sleep data from HealthKit
Access (Acesso): View all your sleep data within the app
→ Available in: Stats screen and Calendar view
Correction (Correção): Update your chronotype and preferences anytime
→ Available in: Settings → Change Chronotype
Anonymization or Deletion (Anonimização/Eliminação):
→ Uninstalling the app removes all local data permanently
Portability (Portabilidade): Export your sleep data
→ Available through HealthKit → Health app → Export Data
Revocation (Revogação): Withdraw consent at any time
→ Go to: iOS Settings → Privacy & Security → Health → Chrono
Information about Sharing (Informação sobre Compartilhamento):
→ We share data with: ZERO third parties

How to Exercise Your Rights

Most rights can be exercised directly in the app (Settings screen)
For additional requests, contact: leonardobilhalva@icloud.com

HealthKit Permissions

What We Request

READ Permission: Access to Sleep Analysis data from Apple Health
WRITE Permission: Save manually logged sleep sessions to Apple Health

Why We Need It

To calculate your sleep score based on actual sleep data
To allow you to manually log sleep sessions when automatic tracking is unavailable
To provide accurate chronotype-based insights

Your Control

You can revoke these permissions at any time through iOS Settings without uninstalling the app.

Medical Disclaimer

Important: Chrono is NOT a medical device or healthcare service provider.

❌ Your data is NOT protected by medical secrecy (sigilo médico profissional)
❌ This app is NOT intended to diagnose, treat, cure, or prevent any medical condition
❌ Information provided should NOT replace professional medical advice
✅ This app is a wellness and educational tool only
✅ Always consult a qualified healthcare professional for medical concerns

Chrono is designed to help you understand your sleep patterns, not to provide medical treatment.

Children's Privacy

Chrono is not intended for children under 13 years of age. We do not knowingly collect data from children.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at leonardobilhalva@icloud.com so we can take appropriate action.

Data Retention

Sleep data is stored locally on your device indefinitely
Data is automatically deleted when you uninstall the app
You can manually reset all app data through Settings
No backups are created on external servers

Security Incidents and Data Breach Response

In the unlikely event of a data security incident:

Our Commitment

We will notify you as soon as reasonably possible upon discovering any breach, in compliance with LGPD requirements (typically within 72 hours)
We will notify ANPD (National Data Protection Authority) as required by LGPD
We will provide clear details about:
What happened
What data was affected
Steps we're taking to mitigate the issue
Actions you can take to protect yourself

Low Risk Profile

Since all your sleep data is stored locally on your device (protected by Apple's iOS encryption), the risk of a data breach through our app is minimal. We do not store your data on external servers.

Reporting Issues

If you suspect any security issue, contact us immediately at: leonardobilhalva@icloud.com

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be reflected by updating the "Last Updated" date at the top of this policy.

How we notify you:

Material changes will be announced within the app
Continued use of the app after changes constitutes acceptance of the updated policy
You can always find the latest version at: https://leonardobilhalva.github.io/chrono-legal-docs/

Data Protection Officer (Encarregado de Dados)

Under LGPD Article 41, we have designated a Data Protection Officer:

Name: Leonardo Bilhalva
Role: Data Protection Officer (DPO)
Email: leonardobilhalva@icloud.com

Responsibilities:

Receive and respond to data subject requests
Provide clarifications about data processing
Accept complaints and inquiries about your data
Serve as point of contact with ANPD (National Data Protection Authority)

Filing Complaints with ANPD

If you believe your data protection rights have been violated, you have the right to file a complaint with Brazil's data protection authority:

ANPD (Autoridade Nacional de Proteção de Dados)

Website: https://www.gov.br/anpd/
Email: anpd@anpd.gov.br
Phone: 0800-740-0606

You can also contact us first at leonardobilhalva@icloud.com to resolve any concerns directly.

Compliance

LGPD (Brazil)

Chrono complies with the Lei Geral de Proteção de Dados (LGPD - Law 13.709/2018) of Brazil:

Legal Basis: Specific and explicit consent for processing sensitive health data (you grant permission to access HealthKit sleep data via iOS authorization)
Data Minimization: We only collect essential sleep data (Article 6, VI)
Purpose Limitation: Data is used solely for sleep tracking features (Article 6, I)
Local Storage: All data remains in Brazil (on your device)
User Rights: Full access, correction, deletion, portability, and revocation rights (Article 18)
No International Transfer: Data never leaves your device (Article 33 does not apply)
DPO Appointed: Data Protection Officer designated (Article 41)
Transparency: Clear and accessible privacy policy (Article 9)

GDPR (European Union)

If you are in the EU, you have additional rights under GDPR:

Right to access your data
Right to rectify inaccurate data
Right to erase your data ("Right to be Forgotten")
Right to restrict processing
Right to data portability
Right to object to processing
Right not to be subject to automated decision-making

International Data Transfer

We do NOT transfer your data internationally because:

✅ All data stays on your device
✅ No cloud storage or external servers
✅ No third-party services outside Brazil
✅ Data never crosses national borders

Therefore, LGPD Article 33 safeguards for international transfer do not apply.

Contact Us

If you have questions about this Privacy Policy or how we handle your data:

Email: leonardobilhalva@icloud.com
Developer: Leonardo Bilhalva
Location: Brazil
Data Protection Officer: Leonardo Bilhalva
Response Time: We aim to respond to all inquiries within 5 business days.

Summary

In simple terms:

✅ We only access sleep data from Apple Health
✅ All data stays on your device (never uploaded anywhere)
✅ We don't sell, share, or transmit your data
✅ You can delete everything by uninstalling the app
✅ We comply with LGPD (Brazil) and GDPR (EU)
✅ You have a Data Protection Officer to contact
✅ This is NOT a medical device

Your privacy is our priority. 🔒

Acknowledgments

This Privacy Policy was created in compliance with:

LGPD (Lei Geral de Proteção de Dados - Brazil)
GDPR (General Data Protection Regulation - EU)
Apple App Store Review Guidelines
Apple HealthKit Framework Guidelines
Best practices for health and wellness applications