izmio Privacy Policy

Draft — requires review by a qualified attorney before publication

Effective date: [DATE] · Last updated: [DATE]

izmio is a mobile app for listening rituals: Solfeggio tones, 432 Hz tuning, binaural beats, isochronic tones, live global circles, journeys, a journal and animal modes. This policy explains what personal information we collect, why, who we share it with, how long we keep it and the choices you have.

Some of what you tell izmio, such as your mood, your intentions and your journal, may count as consumer health data under laws like the Washington My Health My Data Act. We give it extra protection and describe it in a separate Consumer Health Data Policy.

1. Who we are

izmio is operated by [COMPANY LEGAL NAME] Ltd. Şti., a limited liability company registered in Türkiye (trade registry no. [NUMBER], MERSİS no. [NUMBER]), with its registered address at [STREET ADDRESS, POSTAL CODE, CITY, Türkiye] ("izmio", "we", "us"). We are the controller (KVKK: veri sorumlusu) of the personal information described here.

Contact: [email protected] [VERIFY mailbox].

2. Summary

3. Information we collect

3.1 Account and device identifiers

• Anonymous account ID. On first launch the app creates a random user ID (via our database provider, Supabase). We use the same ID for your purchases (RevenueCat) and for product analytics (PostHog), so these records stay linked to one pseudonymous account rather than to your name.
• No sign-in in this version. izmio does not offer Sign in with Apple or Google yet, so we receive no name or email address from your app account. If a later version adds sign-in, we will update this policy before it ships.
• Profile settings. Language/locale, account creation date, reminder preferences and your chosen ritual time.
• Reminders. izmio's reminders are local notifications: the app schedules them on your device from your settings and your subscription status (Section 3.10). They are not sent from our servers, and no notification service receives your data.
• Device identifier for the founding offer. When the founding member offer is shown, the app sends a device identifier with the request so the 20-minute hold applies to your device as well as your account and a reinstall does not start a new one. On iPhone and iPad this is a random code the app creates and keeps in your device's Keychain, which can remain after you delete the app. On Android it is the Android ID that the system assigns to izmio on your device. Our server stores only a one-way hash of it (SHA-256), never the identifier itself. We use it only for the founding offer hold, never for advertising, analytics or tracking you across apps. The hash is kept after you delete your account (see Section 8).
• Device and app information, such as device model, operating system version, app version, time zone and crash data.

3.2 Wellness inputs (consumer health data)

Only with your consent, given on a separate screen before the onboarding questions, izmio asks for and stores:

• Intentions you choose during onboarding or later (for example, deeper sleep, inner peace, Body & Wellbeing, Renewal).
• Mood check-ins, in onboarding and in the optional daily check-in on the Today screen.

These answers stay on your device and are used only there, to suggest sessions and show support resources. If you skip the consent screen, izmio does not ask these questions.

izmio also handles:

• Journal entries, only when you choose to write one: your free text, with the date, session and mood attached.
• Listening history that may reveal health interests, such as sleep sessions, sleep timers and journey progress (for example, the Deep Rest journey).
• Personalization inferences: which sessions seem to suit you, derived from the inputs above. This learning happens on your device.

Withdrawing consent. You can withdraw your health-data consent at any time in You › Settings › Privacy › Health data. izmio then deletes the intention, mood and mood check-in answers stored on your device, records that you declined, stops asking for them and no longer uses intentions or mood to personalize your sessions. Withdrawing does not stop the journal or delete its server copy: journal sync is a separate choice with its own switch, and turning it off deletes the server copy. You can also delete entries in the journal at any time. [VERIFY with counsel: whether the journal and its moods need their own consent under the Washington My Health My Data Act]

Where it lives. By default, your journal entries, with the moods attached to them, are stored only on your device and encrypted there. They are copied to our servers only if you turn on Sync my journal at You › Settings › Privacy › Journal (backup). Sync works with the anonymous account izmio creates for you; you do not need to sign in or give us an email address, and the server copy is linked to your account ID. You can turn sync off at any time; we then delete the server copy. If you never turn on sync, deleting the app deletes your journal, and we cannot recover it. Details and your rights are in the Consumer Health Data Policy.

3.3 Mosquito Watch

Mosquito Watch plays a sound lure on your device: a tone between 484 and 650 Hz, 2 minutes on and 2 minutes off. It does not use the microphone, does not record sound, does not use your location and sends us no observations. A future version may offer an optional community map; we will update this policy and ask for your consent before collecting any such data.

3.4 Live circles

• When you join a live circle, the app sends a "heartbeat" (circle ID, your account ID and time) so we can count how many distinct people are listening. The counter shows people whose heartbeat arrived in the last 90 seconds. We never inflate it. Heartbeat records are deleted automatically after 24 hours.
• Reactions you tap during a circle are shown to other listeners without your name.
• Circles show only the number of people listening. We do not show or count where listeners are.
• There is no audio streaming and no chat in this version. Every phone plays the same session at the same server time.

3.5 Purchases

• Purchases are processed by Apple (App Store) or Google (Google Play). We never receive your payment card details.
• RevenueCat receives purchase receipts and tells us your entitlement status (product, purchase and renewal dates, trial status, store, country/currency, transaction IDs).
• Founding offer records. When you first see the founding member offer, we store your account ID, a hash of the device identifier described in 3.1, the time the offer was first shown and when your 20-minute hold expires. For founding lifetime purchases we store the transaction ID, your account ID, the product and the purchase time, which we need to count the 1,000 founding spots. The device hash and the purchase records are kept after you delete your account, so the founding price is never offered to the same device again and to meet tax-record duties (Section 8). See Founding Offer Terms.
• Consent records. We keep a record that you agreed to subscription terms (what was shown, when) as required by state automatic-renewal laws.

3.6 Usage analytics and crash reports

• Product analytics (PostHog, US cloud): app events such as screens viewed, sessions started and completed, live circle joins, paywall views, trial starts and purchases, linked to your pseudonymous account ID. Analytics events carry only IDs and counts (for example, which session was played and for how long). The app does not record session replays.
• Your choice: "Share anonymous usage counts." This switch is in the app at You › Settings › Privacy › Usage counts and is on by default. Turn it off and the app stops sending product analytics events and deletes the events it has not sent yet; turn it back on and only new events are sent. The switch covers product analytics only: purchases, live circle listener counts and your account keep working as before. On or off, analytics events carry only IDs and counts, linked to your pseudonymous account ID and never to your name or email, and never include your mood, intentions or journal.
• Crash reporting (Sentry): crash reports, error logs, device model, OS and app version.
• Never sent to analytics, crash-reporting or advertising tools: your mood check-ins, intentions and journal content or your email address.

3.7 Waitlist, email and support

• Waitlist (izmio.com): your email address, the page or campaign you came from and the sign-up time.
• Email: if you give us your email (waitlist or support), we use it to send the messages you signed up for and to answer you. Our email provider may record whether an email was delivered or opened. [VERIFY provider] The app does not send trial or renewal reminders by email. [VERIFY with counsel: whether email notices are required in addition to the in-app reminders in Section 3.10]
• Support: anything you send us when you contact support.

3.8 Age signals

To meet app-store age laws (for example in Texas, Utah and Louisiana) we may receive an age range or age-verification status from Apple's Declared Age Range API or Google Play's Age Signals API, and we may ask for your birth month and year in a neutral way. We use this only to apply age-appropriate settings and meet legal duties, never for advertising, analytics or profiling, and we delete verification data when the law requires.

3.9 Attribution

If you arrive through a creator's link or code, or through our own ads on other platforms, we may record the campaign or creator code so we can pay creators and understand which channels work. Ad-platform attribution uses privacy-preserving, aggregated tools provided by Apple and Google (such as Apple Ads attribution and the Google Play Install Referrer). [VERIFY: final attribution stack; if a mobile measurement partner or Meta/TikTok SDK is added, update Sections 6–7 and add opt-out/consent flows before release.]

3.10 Permissions summary

izmio asks for notification permission only after you finish your first session, never during onboarding. If a trial or renewal reminder would arrive between 9 pm and 9 am your local time, the app schedules it earlier instead: at 6 pm that evening, or the evening before if it would fall after midnight. It never moves a reminder later. Reminders contain no mood, intention or journal content. You can turn off the daily reminder and circle reminders in the app, or all notifications in your device settings. izmio does not ask for microphone or location access. Paid features never depend on granting notification access.

4. How we use information

We do not use your information for automated decisions that have legal or similarly significant effects on you.

5. Consumer health data: extra protections

• We ask for your consent before asking about your intentions and mood, separately from accepting our terms. You can use izmio's sounds without giving this consent, and you can withdraw it at any time in You › Settings › Privacy › Health data, which deletes those answers from your device (Section 3.2). Withdrawal does not affect your journal, which has its own sync switch.
• Your journal is written only when you choose to write in it.
• We use this data only to provide and personalize izmio for you.
• Your journal stays on your device, encrypted, unless you turn on sync.
• We never sell it, never send it to analytics, crash-reporting or advertising tools, and never use it to target ads.
• We share it only with service providers that store or process it for us under contract (for example, our database host when sync is on).
• We do not set up geofences around health care facilities.
• See the Consumer Health Data Policy for categories, rights and how to withdraw consent.

6. How we share information

We share personal information only as described here.

Service providers (processors). They act on our instructions under written contracts and may not use your data for their own purposes. [VERIFY final list and data processing agreements]

Apple and Google process purchases and app distribution under their own privacy policies.

People you choose to share with. Share cards you post to Instagram, TikTok or other apps leave izmio and are governed by those platforms' policies. A card may include journal text only if you add it.

Founding Guides. If you sign up with a creator's code, the creator sees only aggregated counts of sign-ups and paying users, never your identity. [VERIFY with program setup]

Legal and safety. When required by law, court order or a valid government request, or to protect the rights, safety and property of izmio, our users or others.

Business transfers. If izmio is involved in a merger, acquisition or sale of assets, personal information may be transferred under this policy, and we will notify you of any change in who controls it.

What we don't do: we do not sell personal information, we do not "share" it for cross-context behavioral advertising, we do not use it for targeted advertising and we do not give it to data brokers.

7. Advertising

izmio has no ads, including on the free plan, and the app contains no third-party advertising SDKs at launch. [VERIFY at each release] We may advertise izmio on other platforms (for example Apple Ads, Instagram or TikTok). Those campaigns are measured with aggregated, privacy-preserving tools and never receive your health data.

8. How long we keep information

When you delete your account, we delete or de-identify your personal information and ask RevenueCat to delete your subscriber record, except the records listed above that we keep: purchase and transaction records (including founding purchase records), the founding offer device hash, consent records and records of your requests. Purchases themselves remain with Apple or Google, and deleting your account does not cancel a subscription. Step-by-step instructions and the full list of what we delete and keep are on our account deletion page.

9. Security

We use encryption in transit, encryption at rest provided by our hosting partners, on-device encryption for the journal, row-level access controls so each account can reach only its own records, and access limits for our team. No system is perfectly secure. If a breach affects your personal information, we will notify you and the authorities as the law requires (including, where applicable, under the FTC Health Breach Notification Rule, US state breach laws and within 72 hours under KVKK).

10. Children and teens

• izmio is a general-audience app for people aged 13 and over. We do not knowingly collect personal information from children under 13.
• We use a neutral age screen and the age signals described in Section 3.8. If we learn a user is under 13, or we cannot determine age where the law requires it, izmio switches to a mode that does not collect personal information (no account or journal sync), or we delete the data. [VERIFY with workstream A]
• If you are 13–17, please use izmio with your parent's or guardian's permission. A parent who believes a child under 13 has given us information can contact [email protected] and we will delete it.

11. Your choices and rights

11.1 Everyone

• Get a copy of your information, or correct it: email [email protected] [VERIFY mailbox]. The app has no export feature; after we verify the request, we send you a copy by email. You can edit or delete your own journal entries in the app at any time.
• Delete your account in the app at You › Settings › Account › Delete account, or by following the steps at izmio.com/delete-account. Deleting the app does not delete your account or cancel a subscription.
• Withdraw consent for health data at any time in You › Settings › Privacy › Health data. izmio then deletes the intention, mood and mood check-in answers stored on your device and stops personalizing with them; your journal is managed separately (Section 3.2). Withdrawal does not affect processing that already happened.
• Stop product analytics with the "Share anonymous usage counts" switch at You › Settings › Privacy › Usage counts (Section 3.6).
• Turn off the daily reminder and circle reminders in the app, or all notifications in your device settings. With notifications off, the app shows trial and renewal reminders on screen instead (Section 3.10).
• Unsubscribe from marketing email using the link in every email.

11.2 United States

Depending on where you live (including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), you may have the right to:

• know and access the personal information we hold about you, and get a portable copy;
• correct inaccurate information;
• delete your information;
• opt out of the sale of personal information, targeted advertising and profiling with legal or similarly significant effects (we do none of these);
• limit the use of sensitive personal information (we use it only to provide the service you asked for);
• not be discriminated against for exercising your rights;
• appeal our decision on your request.

We offer these rights to all US users, whatever their state. Send requests to [email protected] (copies of your information are sent by email) or use the in-app tools for deletion, health-data consent and journal sync. We verify your request by confirming you control the account (for example, from inside the app). You may use an authorized agent with written permission. We respond within 45 days and may extend once by 45 days where permitted, telling you why. To appeal a decision, reply with "Appeal" in the subject line; we answer within the period your state requires (generally 45–60 days). If we deny your appeal, you can contact your state attorney general.

California. Categories collected in the last 12 months: identifiers (account ID, a hash of the device identifier used for the founding offer, email if provided); commercial information (purchases); internet or electronic activity (app usage); sensitive personal information (health-related wellness inputs, with consent). Sources, purposes and recipients are described above. We have not sold or shared personal information for cross-context behavioral advertising. izmio.com uses no advertising or analytics cookies and loads no third-party trackers; we treat a Global Privacy Control signal as a valid request to opt out. We do not respond differently to "Do Not Track" because we do not track you across other sites. Under California's "Shine the Light" law, we do not share personal information with third parties for their direct marketing.

Washington, Nevada and Connecticut consumer health data: see the Consumer Health Data Policy.

11.3 European Economic Area and United Kingdom

If you are in the EEA or UK, you also have the right to object to processing based on legitimate interests, to restrict processing, and to lodge a complaint with your local data protection authority. Our EU representative: [NAME, ADDRESS] · UK representative: [NAME, ADDRESS]. [VERIFY: GDPR Art. 27 representative is likely required if izmio is offered in EU/UK storefronts]

11.4 Türkiye (KVKK)

Under Article 11 of the Personal Data Protection Law No. 6698, you may ask whether your data is processed, request information, learn the purpose and whether it is used accordingly, learn the recipients in Türkiye or abroad, request correction or deletion, request that recipients be notified, object to results produced solely by automated analysis, and claim compensation for unlawful processing. Send requests in writing to our registered address, by registered electronic mail (KEP) to [KEP ADDRESS], or from an email address registered with us to [email protected]. We respond within 30 days. A Turkish-language information notice (Aydınlatma Metni) and explicit consent text will be provided in the app for users in Türkiye. [VERIFY before TR launch]

12. International transfers

We are based in Türkiye and our main service providers store data in the United States. When we transfer personal information abroad we use the safeguards the law requires, such as the KVKK standard contracts (notified to the Personal Data Protection Authority within five business days of signing), the European Commission's Standard Contractual Clauses or the EU–US Data Privacy Framework where a provider is certified. [VERIFY that each provider signs the unmodified KVKK standard contract]

13. Changes to this policy

We will post any changes here and update the date above. If a change materially affects how we use personal information, especially health data, we will tell you in the app or by email before it takes effect and ask for your consent where the law requires.

14. Contact

[COMPANY LEGAL NAME] Ltd. Şti. (izmio) · [STREET ADDRESS, POSTAL CODE, CITY, Türkiye] · [email protected] · Account deletion: izmio.com/delete-account · Help: izmio.com/support