Privacy Policy

Effective Date: 20/04/2026  |  Last Updated: 20/04/2026

---

Before You Read

1. Boink does not sell your personal data and does not share your data with advertisers, marketing partners, or data brokers.
2. Boink does not track you across other apps or websites and does not use behavioural advertising.
3. Notes and images you create stay on your device. They are stored only on your device and are not transmitted to Boink's servers as part of normal app operation. Backups you create are encrypted with a passphrase you choose.
4. Boink handles sensitive personal data — including data concerning your sexual activity and, if you choose to provide it, your sexual orientation. This policy describes in plain language what we store, where, and under what legal basis, so you can make informed choices about what you enter.
5. Boink is free to use. We do not collect payment information and there is no financial relationship to manage.

---

1. Who We Are

Busyworks Unipessoal Lda is the data controller for the personal data processed in connection with Boink. We do not currently have a Data Protection Officer. We keep this requirement under review in line with GDPR Article 37 as the service evolves. For all privacy matters, use the contact address above.

2. Age Requirement

Boink is for users aged 18 or older. We do not knowingly collect information from anyone under 18. If we learn that we have collected data from someone under 18, we will delete it promptly. If you believe this has occurred, contact privacy@boink.app.

3. What Data We Collect

3.1 Data That Stays on Your Device

The following data is stored only on your device and is not transmitted to our servers as part of normal app operation:

• Notes — free-text entries you attach to records
• Images — photos you add within the app (other than your profile picture — see Section 3.5)

If your device is lost or damaged and you have not created a backup, this data is not recoverable by us. Backups you create within the app are encrypted with a passphrase you choose. We do not know your passphrase and cannot decrypt your backup.

3.2 Account Data We Can Access

When you create an account and use the app, we collect:

• Email address — required for account authentication and communication
• Display name — if you provide one
• Phone number — if you provide one (for example, for support via WhatsApp)
• Login history — when you access the app and session metadata
• Account dates — creation, last login, deletion if applicable

3.3 Optional Profile Information

You may optionally provide the following. All fields are voluntary and can be left blank without affecting app functionality:

• Age
• Gender
• Country
• Sexual orientation (special category data under GDPR Article 9 — see Section 4)

3.4 Activity Data on Our Servers

The following data is stored on our servers to enable syncing across sessions and devices, under the legal bases set out in Section 5:

• Partner entries (names or references, ages, genders, contact info you record, roles, ratings)
• Activity and encounter records and their details
• Tags and categories you create and use
• Financial tracking amounts
• Time tracking
• Places and locations you save
• Whether protection was used

3.5 Profile Pictures

If you choose to upload a profile picture, it is stored in Google Cloud Storage in US regions (us-central1 and us-west1). This is a separate service from the Firestore database that holds your other account and activity data (which is stored in the EU — see Section 13). Profile pictures are optional.

3.6 Third-Party Data You Enter ("Partners")

The activity data described in Section 3.4 often includes information about other people — Partners — who are not Boink users. This data may include names or references, ages, genders, and other details you choose to enter.

You are responsible for the lawfulness of entering information about third parties. Our Terms of Use (Section 7.2) set out your obligations in this regard, including the warranty that you will not upload identifying photographs or contact details of third parties without their knowledge and consent, and that you will use pseudonyms or initials wherever reasonably possible.

We acknowledge this is a category of data where the individual concerned has not consented to us directly. This is a known limitation of any private-journal service, and we are working to mitigate it by moving categories of partner data off our servers entirely. Until then, we rely on the contractual warranty in our Terms of Use and on the limitations you apply yourself when recording.

3.7 Data Collected Automatically

• Device type and operating system
• App version
• Crash reports and error logs
• Firebase authentication tokens

This data is used for app stability, bug fixing, and technical management.

3.8 Analytics and Usage Data

We collect data about how the app is used — session counts, feature usage, aggregate statistics, and related signals — to understand and improve the Service. Depending on implementation, this data may be linkable to your user account. We treat it as personal data processed under legitimate interests (see Section 5). You can object to this processing at any time by contacting privacy@boink.app.

3.9 Data We Do Not Collect

• We do not use cookies for tracking (the app operates on your device)
• We do not integrate with social media platforms and do not share data with them
• We do not collect payment or financial account information
• We do not use behavioural advertising networks

If you choose to share content from the app to third-party platforms, you do so under those platforms' terms and privacy policies.

4. Special Category Data (GDPR Article 9)

Boink processes data concerning sexual activity and, where you provide it, sexual orientation. Under GDPR, these are special category data and receive additional protection.

Our legal basis for processing special category data is your explicit consent under Article 9(2)(a) GDPR. We collect that consent through a dedicated consent flow when you set up the app. Each specific purpose (cloud sync of activity data; storage of orientation if provided; any other Article 9 processing) is presented as a separate, unbundled toggle that you actively enable.

You can review and withdraw your consent at any time in Settings → Privacy & Consent, or by deleting your account. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

5. Legal Basis for Each Purpose

We process personal data only for the specific purposes described below, using the legal bases set out in the table. Where special category data is processed, we rely on explicit consent (Article 9(2)(a)) in addition to the Article 6 basis.

Purpose	Data used	Legal basis
Provide the core app (account creation, sync)	Account info, activity records	Contract, Art. 6(1)(b)
Process special category data on our servers	Activity data, optional orientation field	Explicit consent, Art. 9(2)(a)
Account authentication and login security	Email, hashed password, auth tokens	Contract, Art. 6(1)(b)
Password recovery	Email	Contract, Art. 6(1)(b)
Respond to support requests	Email, phone (if given), support messages, screenshots you share	Contract, Art. 6(1)(b)
Send transactional service communications	Email, name	Contract, Art. 6(1)(b)
Send optional product updates and marketing	Email	Consent, Art. 6(1)(a)
Analytics and product improvement	Usage data (may be user-linked)	Legitimate interests, Art. 6(1)(f)
App stability and bug fixing	Device info, crash reports	Legitimate interests, Art. 6(1)(f)
Security and fraud prevention	Login data, device info	Legitimate interests, Art. 6(1)(f)
Legal compliance and defence of legal claims	Relevant records as required	Legal obligation / legitimate interests, Art. 6(1)(c)/(f)

Where we rely on legitimate interests, you have the right to object (Section 11). We do not use your data for selling to third parties, behavioural advertising, individual review of your activity records, or for building behavioural profiles of you.

6. Data Protection Impact Assessment

Because Boink processes special category data at the scale of a consumer application, we maintain a Data Protection Impact Assessment (DPIA) under GDPR Article 35. The DPIA describes the processing, the risks we have identified, and the measures we take to mitigate those risks. We review the DPIA when we make material changes to how we handle data.

7. Support System

When you contact our support team (via WhatsApp, email, in-app chat, or web form):

What support agents can see:

• Your email and phone number (for identification)
• Messages you send during the support conversation
• Any screenshots or images you choose to share
• Ticket status and conversation history

AI-assisted support. Support messages may be processed by a third-party AI provider to draft responses. The provider operates under a data processing agreement that prohibits use of your data for training models or for any purpose other than responding to your query. You may request a human agent at any time.

What support agents do not routinely access. Support agents do not open your activity records, Partner details, or other server-stored data in the ordinary course of responding to a ticket. Technical access is possible at the infrastructure level (see Section 3.4) and is restricted by internal policy to strictly necessary circumstances.

Third-party processing in support.

• If you contact us via WhatsApp, messages pass through Meta's servers under Meta's privacy policy
• Support images you send may be stored in Firebase Storage (see Section 13 for location)

8. Third-Party Processors

We use the following processors to operate the Service. We do not share your data with any third parties beyond these operational processors, other than as required by law or to defend legal claims.

Service	Provider	Purpose	Data involved
Firebase Authentication	Google	Account login	Email, hashed credentials, auth tokens
Cloud Firestore	Google	Data storage and sync	Account and activity data (Sections 3.2, 3.3, 3.4)
Firebase Cloud Messaging	Google	Push notifications	Device tokens
Google Cloud Storage	Google	Profile pictures, support-ticket images, app assets	Images you upload
WhatsApp Business	Meta	Support channel (optional)	Messages you choose to send
AI support provider	Third party under DPA	Drafting support responses	Support messages only; no training use

All processors operate under data processing agreements compliant with GDPR Article 28. Google services operate under Google's Cloud Data Processing Addendum and Standard Contractual Clauses.

9. Data Security

Technical and organisational measures we apply:

• Data in transit is encrypted using HTTPS/TLS
• Passwords are hashed — we do not store them in a form we can read
• Data at rest on our servers is encrypted using Google-managed encryption keys
• Backups you create on your device are encrypted with a passphrase you choose (we do not know it and cannot recover it)
• Access to production systems is restricted to authorised personnel and logged
• We use Firebase Authentication for account security
• We review our security posture periodically

Limitations you should understand:

• Activity data on our servers is not end-to-end encrypted. Staff have a technical ability to access it on our servers; our internal policy restricts that access to strictly necessary circumstances
• No system connected to the internet is perfectly secure. We advise discretion in what you record in any app, including Boink

10. Backups

You can create a backup of your on-device data (notes and images) at any time via Account → Backup & Restore.

• Backup files are stored on your device, not on our servers
• Backups are encrypted on your device using a passphrase you choose; the encryption key is derived from your passphrase and does not leave your device
• We do not know your passphrase and cannot recover it. If you lose it, no one — including us — can decrypt your backup
• You are responsible for keeping your backup file and passphrase safe and for storing them in separate secure locations
• On a new device, your account data and activity records sync from our servers after login; notes and images must be restored from your backup file

We are not liable for loss of on-device data, for lost passphrases, or for data you store outside the app.

11. Your Rights (GDPR)

Under GDPR and Portuguese data protection law, you have the following rights:

Access. Request a copy of the personal data we hold about you, or download your data directly via Account → Privacy & Data → Download my data.

Rectification. Request correction of inaccurate data.

Erasure. Delete your account and all server-stored data via Account → Privacy & Data → Delete Account. Server-side deletion, including from routine backups, completes within 30 days. Local data on your device remains until you delete it or uninstall the app. We may retain limited data where required by law or for defence of legal claims.

Restriction. Request that we restrict processing of your data in specific circumstances (for example, while accuracy is being verified).

Portability. Receive your data in a structured, machine-readable format. Use the in-app download feature for server-stored data and the backup feature for local data.

Object. Object to processing based on legitimate interests where your rights outweigh ours — this covers analytics, stability data, and security processing as listed in Section 5.

Withdraw consent. Withdraw consent for processing of special category data at any time in Settings. Also applies to any optional marketing emails.

How to exercise your rights. Contact privacy@boink.app or use the in-app tools. We respond within 30 days, extendable by up to 60 further days for complex requests (with notice to you). If you use the in-app deletion or download tools, actions complete on the timelines shown there.

12. Data Retention

Category	Retention
Active account data (activity records, account info)	For as long as the account is active
Inactive account data	Up to 24 months of inactivity, then account may be deleted after notice
Deleted account data on servers	Deleted within 30 days of deletion request, including from backups
On-device data (notes, images, backups)	Retained until you delete them or uninstall the app; we have no ability to delete data on your device
Support conversations	Up to 12 months after ticket closure, then deleted
Consent records	Life of the account plus the statutory limitation period under Portuguese law, as proof of consent
Account deletion logs	Up to 30 days for audit, then deleted
Records required for legal compliance	For the period required by applicable law

13. International Data Transfers

Different Boink data is processed in different locations:

• Account and activity data (Cloud Firestore) — stored in the European Union (eur3 multi-region, comprising data centres in Belgium and the Netherlands). No international transfer.
• Profile pictures and support-ticket images (Google Cloud Storage) — stored in the United States (us-central1 and us-west1). Transfer of this limited data to the US relies on Google's certification under the EU-US Data Privacy Framework and on the Standard Contractual Clauses incorporated in Google's Cloud Data Processing Addendum.
• Firebase Authentication — processed on Google's global infrastructure, which may include US data centres. This transfer relies on the same mechanisms as above. The data involved is limited to email addresses, authentication tokens, and sign-in metadata — not the special category data referenced in Section 4.
• Firebase Cloud Messaging — operates on Google's global infrastructure. Data involved is limited to device tokens for the purpose of delivering push notifications.
• WhatsApp (if used for support) — messages pass through Meta's infrastructure, which includes processing outside the EU. Use of WhatsApp for support is optional; you may contact us by email instead.

Where data is transferred outside the European Economic Area, we rely on the safeguards listed above, which are recognised under GDPR Chapter V. Google's Data Privacy Framework certification is available at dataprivacyframework.gov.

14. Data Sharing

We do not sell, rent, trade, or share your personal data with third parties for their own purposes.

We may disclose data only:

• To the processors listed in Section 8, who process data on our behalf under data processing agreements
• When required by law or in response to valid legal process from competent authorities
• To protect rights, property, or safety where strictly necessary
• In a business transfer such as a merger, acquisition, or sale of assets — with advance notice to you and preservation of your rights under this policy

15. Breach Notification

If a personal data breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay under GDPR Article 34, using the email address on file. We will also notify the Portuguese supervisory authority where required by Article 33.

16. Changes to This Policy

We may update this policy from time to time. For material changes, we will:

• Post the updated policy in the App and on our website
• Update the "Last Updated" date
• Notify you in advance by email or in-app notification
• Where the change materially affects consent for special category data, ask for fresh explicit consent before continuing to process that data under the new terms

If you do not agree with a change, you may stop using the App and delete your account. Changes do not apply retroactively to processing you did not consent to.

17. Contact and Complaints

18. Governing Law and Jurisdiction

This policy is governed by the laws of Portugal, including the General Data Protection Regulation as it applies in Portugal. If you are a consumer resident in another EU/EEA country, you retain the protections of the mandatory consumer and data protection law of your country of residence.

Any disputes arising in connection with this policy may be brought before the competent Portuguese courts. If you are a consumer, this does not remove any right you may have to bring proceedings in the courts of your country of habitual residence, or to be sued only in those courts, where mandatory EU law so provides.

---

This Privacy Policy is provided in English. In case of any discrepancy between translated versions, the English version prevails, except where mandatory law of your country of residence requires otherwise.