GROW

Privacy policy

Last updated 29 September 2026

The short version. To use GROW Moment you give us an email address and pay for a membership, here or through the App Store. There is no face scan; the camera is used only if you choose to make your avatar from a selfie. After that, the data is what you write: a level and a note each day, and the body figures your protocol is computed from. Your notes and your body data are private by default. Your level and your index are visible to other members by default, and you can turn that off. We do not sell anything to anybody.

The rest of this page is the detail behind that, including the parts that are less comfortable — health data, third-party processors, and where the servers are. If you joined while signup still ran a face check, §2 says what is left of it and how to have it erased.

1Who is responsible for your data

The controller of the personal data described here is Kasparas Maniušis, at Vytauto Žalakevičiaus g. 13-13, LT-10109 Vilnius, Lithuania, operating growmoment.app.

For anything to do with your data, or anything else, write to info@growmoment.app or call +370 628 16971. Data protection contact: info@growmoment.app.

GROW Moment is for adults. You must be 18 or over to hold a membership, and we do not knowingly process the data of anyone younger.

2Your face: we no longer ask for it

There is no face scan. Signing up does not use your camera, and we do not collect, derive or store any biometric data about you. If you are joining now, this clause does not describe anything that will happen to you.

What this used to be

Earlier versions of the service ran a one-time liveness check at signup using Amazon Rekognition Face Liveness, and derived a face template from it so that one person could not hold several memberships. That step has been removed. Nothing in the product performs it any more, and the code that did has been deleted.

What we still hold, and for how long

Members who joined while that step existed have an enrolment record from it. Each one carries a deletion deadline stored on the record itself, and the images are deleted when it passes. We do not create new records, and nothing reads the existing ones to make decisions about you.

Having it removed now

If you were enrolled and want the remaining record erased before its deadline, write to info@growmoment.app and we will remove it. Because nothing depends on it any more, there is no consequence to your membership for asking.

3What else we hold

Your account

  • Email address and, if you sign in with a password, a password held in hashed form by Firebase Authentication. We never see the password itself.
  • Member number, allocated once and never reused.
  • Nickname and avatar. Both are generated for you: the nickname and its meaning, and the avatar image, are produced by a model from a prompt and a style you choose. Your stated gender is used to pick an avatar style and for nothing else.
  • A selfie, if you make your portrait from one. This is optional — you can always use one of the default avatars instead. The photo is sent to our server and on to OpenAI, whose image model draws your portrait from it. We keep the photo only while the portrait is being made and delete it as soon as it is done or the attempt fails; the portrait is what we store. The photo is not used to recognise you, and no face template is made from it. The iOS app asks before the first photo is sent.
  • “About me”, if you write one. It appears on your public profile and is given to Aris as standing context.
  • Your timezone, captured from your browser. It exists so the daily reminder lands at 22:00 where you are rather than at a random hour.

What you log

  • Check-ins. One per local day: a level from 0 to 5 and, optionally, a note. The note is private to you. To write his reply, Aris sends your level, your current streak and the note to our AI provider — see Your notes and AIbelow. His reply is stored so your history can show what he said.
  • Stories. If you publish a day, a single headline written by Aris from your note becomes visible to other members. That headline is a synthesis, not your note reproduced. A second, separate choice — made per day — decides whether the note behind the headline travels with it. Unpublishing removes both and leaves no record that a story existed.
  • Your protocol base. Sex, birth date, height, weight, how often you train, how the rest of your day moves, your bedtime and how long you intend to sleep. We store what you told us; every target is computed from it on read and none of the computed numbers are stored.
  • Your day. The schedule, targets and goals you keep, and which parts of the protocol you ticked off on a given day.
  • Forum activity. Posts, comments and votes, under your nickname and visible to other members.

Body and health figures. Your height, weight, date of birth, sleep and training load can amount to data concerning health. We treat them as special-category data and process them on the basis of your explicit consent, given at checkout and again when you set up your base — or, in the iOS app, when you choose to save your base. You can withdraw that consent or delete the base entirely, without giving up the rest of the membership. Apart from Apple Health, below, we do not connect to fitness trackers or wearables, and we do not collect step counts or heart-rate data.

Apple Health (iOS app)

If you connect Apple Health, the app reads your sex, date of birth, height, weight, sleep (the last 14 nights) and workouts (the last 28 days) — nothing else — and never writes to Health. On your phone it works out a usual bedtime, a usual sleep length and how many days a week you train. Those figures leave your phone only if you agree to save them as your base, and then they are handled exactly like a base you typed in.

Data from Apple Health is never sold, never used for advertising or marketing, and never used for anything but your base and the protocol built from it. You can say no and type your numbers yourself, and you can turn off access at any time in the Health app.

Your notes and AI

Your daily note is a free-text field, so what goes in it is entirely yours to decide — and people write about their health, their moods, their treatment and their setbacks. We do not ask for any of that, and no part of the product looks for it. But we do have to say plainly what happens to a note once you save it.

Where it goes. The note is stored in our database in Frankfurt. To write his reply, Aris sends the text of that note, with your level and your current streak, to OpenAI in the United States; to write a story headline if you ask for one, he sends the note. It is sent without your name, your email or your account id — the provider receives the words and nothing that identifies who wrote them. We ask the provider not to store it, and it is not used to train their models. Like any API customer we cannot rule out a short abuse-monitoring window on their side; what we control is that nothing we send links those words to you.

The basis for it. Because a note can contain data concerning health, we treat it as special-category data and rely on the explicit consent you give at checkout, which names your notes and this transfer — or, in the iOS app, the one it asks for before Aris’s first reply, which names OpenAI. You can withdraw that consent at any time (in the app, under Settings); the practical effect is that Aris stops replying, because a reply to a note requires sending the note.

What stays private. Notes are private by default and no other member can read one. Publishing a day as a story is a separate choice you make per day, and it publishes a one-line headline rather than the note; releasing the note behind it is a further, separate choice. Nothing is inherited from one day to the next.

If you would rather Aris never saw a particular day, leave the note empty — the check-in still counts, and your streak is unaffected.

Your weekly and monthly report

The GROW report shows you your own week or month — or, when your first two weeks as a member end, those two weeks: its GROW %, what each day contributed to it, and which patterns held in your levels and, if you allow it, in your notes. A day without a check-in scores 0%, and the report shows it that way. The numbers and patterns are computed in your browser, from the check-ins the app has already shown you on your calendar, and nothing about them is stored (see lib/aris/report/). A report is made only when you ask for one.

Your notes are read only if you say so. Because a note can concern your health, the report leaves notes out until you switch on “Find patterns in my notes”, and it rests on that explicit consent (Article 9(2)(a)). That switch works on your device only.

Aris’s read is AI, and only on request. When you generate a report and have agreed to Aris’s read (you are asked the first time, and can generate a report without it), our server recomputes that period’s facts from your check-ins and sends them to OpenAI in the United States so Aris can write the read: one line per day (day of the month, weekday, level, the day’s score, how it compared with your own normal and your streak day), the period’s GROW % and the patterns that held — and that period’s notes only if you switched on note patterns, with email addresses, links, handles and phone numbers removed first. It is sent without your name, your email, your account id or the year; we ask OpenAI not to store it and it is not used to train their models. We do not store the request or Aris’s reply either: the read is shown to you and discarded when you leave. This rests on your explicit consent (Article 9(2)(a)), which you can withdraw at any time under “Your data & privacy” in the report (see app/api/aris/report/read/route.ts and lib/aris/report/aiPayload.ts).

On the preview site only, anyone can ask Aris to read the invented sample month without an account. Nothing personal is involved: the sample contains no member’s data, and that route does not exist on growmoment.app.

Your controls. You can leave any day out of the report, download everything it read and concluded as a file, and see the method behind every number. The report describes your week or month and decides nothing: it does not change your index, your membership or anything else about your account, and no other member can see it.

Payment

Payments on this website run through Stripe. We hold a Stripe customer id, a subscription id and status, the price, the amount, the currency, the billing interval, the renewal date and invoice records. We never receive or store your card number.

In the iOS app, you pay Apple. A membership bought there is an App Store subscription: Apple takes the payment under its own terms and privacy policy, and renewal and cancellation are managed in your Apple ID settings. RevenueCat checks the purchase for us. We receive which plan you bought, the transaction and subscription ids, the store environment, and when it renews or ends — never your payment details, and not your Apple ID.

Collected automatically

  • Request data — IP address, user agent, the page requested, and the time — logged by our hosting provider for security and diagnostics.
  • Error reports — when something breaks, a stack trace and the account id associated with the failing request go to our monitoring service.
  • Page-timing measurements — anonymous loading and responsiveness figures. They carry no identifier and are used to find slow pages.
  • Cookies. Only the ones that keep you signed in, carry an in-progress signup, and remember your cookie choice. See the cookie policy.

4What we do with it, and on what legal basis

PurposeLegal basis
Running the check-in, the protocol, the feed and the forumPerformance of the contract — Article 6(1)(b)
Historical: verifying a joining member was a real person and not already a member. No longer carried out; the enrolments it produced are held under the consent given at the time, until the deletion deadline on each recordExplicit consent — Articles 6(1)(a) and 9(2)(a)
Your protocol base — body and health figures — and the targets computed from itExplicit consent — Article 9(2)(a)
Sending your daily note, level and streak to our AI provider so Aris can replyExplicit consent — Article 9(2)(a), and Article 6(1)(b) for the reply itself
Your weekly and monthly report: your levels and dates, analysed in your browser to show you your week or monthPerformance of the contract — Article 6(1)(b)
Reading your notes for patterns in that report, in your browser, if you switch it onExplicit consent — Article 9(2)(a)
Sending a summary of one week or month (and its notes, if note patterns are on) to our AI provider so Aris can read it, when you askExplicit consent — Article 9(2)(a)
Sending your selfie to our AI provider to make your portrait, if you choose toConsent — Article 6(1)(a)
Taking payment and keeping invoicesContract, and legal obligation for accounting records
The daily reminder and the streak emailContract; you can switch the reminder off at any time
Security, abuse prevention, and keeping the service upLegitimate interests — Article 6(1)(f)
Answering a legal request or a tax auditLegal obligation — Article 6(1)(c)

There is no advertising, no profiling for advertising, and no sale of personal data. No third-party advertising or cross-site tracking network is loaded by this product.

5What other members can see

The defaults are these, and every one of them is yours to change:

  • Shown by default: your nickname, your avatar, your member number, your daily level, and your index.
  • Hidden by default: your notes, and your base — body composition, sleep and training load.
  • Only ever shown by a deliberate act: a story headline, and separately the note behind it. Both are decided per day.
  • Leaving entirely: one switch removes you from the feed and from search.

Anything you post in the forum is visible to other members under your nickname. Treat it as published.

6Who processes it for us

The following processors act on our instructions under written agreements meeting Article 28 GDPR. Where a transfer outside the EEA is involved, it is covered by the European Commission’s Standard Contractual Clauses together with encryption in transit and at rest.

ProcessorWhat it doesWhat it seesWhere
Amazon Web ServicesStorage of the face images produced by the liveness check that used to run at signup. No new images are created — the check has been removed from the productFor members who joined while the check existed: the reference and audit images it produced, and a numeric face template. Nothing is captured nowEuropean Union — Frankfurt (AWS eu-central-1)
Shared face registerHistorical. This product no longer enrols or matches faces — the check was removed. Templates enrolled while it ran remain in a register that is shared with sibling products rather than copied per product, which is why the entry stays until they are erasedFor members enrolled while the check ran: the numeric face template derived from it. Not the images — those stay in this product’s own storage. Nothing new is enrolled.European Union — Frankfurt (AWS eu-central-1), processed under a Joint Controller Agreement (Art. 26 GDPR)
NeonManaged PostgreSQL — the application databaseEverything the product stores: account, check-ins, notes, protocol, forum posts, billing referencesEuropean Union — Frankfurt (AWS eu-central-1)
Google (Firebase Authentication)Sign-in, password handling and email verificationEmail address, password (hashed by Firebase — never seen by us), sign-in metadataGoogle infrastructure, subject to Google’s regional terms
StripePayment processing and subscription managementName and email you give at checkout, card details (handled entirely by Stripe), billing country, invoicesIreland and the United States
OpenAIGenerating the coach reply, the story headline, Aris’s read of your week or month when you ask for it, your nickname and your avatar, and checking forum posts, comments and stories for harmful content before they are publishedThe content of the note you are sending with your level and streak, the context Aris is given with it, your avatar prompt, a summary of one week’s or month’s check-ins (and, if you allowed note patterns, that period’s notes with contact details removed) when you ask Aris to read it, the text of a post, comment or story you publish, and — if you make your portrait from one — your selfie. Unaccompanied by your name, email or account idUnited States
RevenueCatChecking and tracking App Store subscriptions bought in the iOS appYour account id, the App Store transaction and subscription records, and basic device and app information. Never your payment detailsUnited States
Cloudflare (R2)Object storage for avatar and profile imagesYour avatar image and its style asset, and — only while your portrait is being made — the selfie it is made fromCloudflare’s network
VercelHosting, edge routing and Speed InsightsRequest metadata — IP address, user agent, the URL requested, and anonymous page-timing measurementsGlobal edge network
Amazon Web Services (Amazon SES)Sending the reminder, streak, verification and billing emailsYour email address and the content of the message sent to youEuropean Union — Frankfurt (AWS eu-central-1)

Beyond these, we disclose personal data only where the law requires it, to establish or defend a legal claim, or — with notice to you — if the service is transferred to another owner.

7How long we keep things

  • Your account and everything in it — for as long as the membership exists. Deleting your account deletes the profile, the check-ins, the notes, the protocol and the forum content attached to it.
  • Liveness images and face templates — historical only; nothing new is created. Each existing enrolment is held until the deletion deadline on its own record. See §2.
  • A minimal archive of deleted accounts — after deletion we keep a small record: the email address, the member number and the payment references. It exists to answer a chargeback and satisfy a tax audit. Nothing you wrote is in it.
  • Invoices and payment records — for the period accounting law requires, 10 years (or as mandated by applicable statutory accounting and tax laws).
  • Error reports and request logs — a rolling window measured in weeks, not years.
  • Abandoned signups — a signup you never finished leaves no account and no charge, only a short-lived session record which expires on its own.

Deletions propagate to encrypted backups as those backups roll over, within 30 days.

8Your rights

Under the GDPR you can ask us to:

  • give you a copy of your data, in a portable format;
  • correct anything wrong;
  • delete your account and its contents;
  • restrict or object to a particular use;
  • withdraw a consent — health data, or the reminder email — at any time.

Write to info@growmoment.app. We answer within one month. If you think we have handled your data badly, you can complain to a supervisory authority; ours is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), Lithuania, and you may also complain to the authority where you live.

9Security

Everything travels over HTTPS. The session cookie is host-scoped, signed, HTTP-only and not readable by scripts. Access to production data is limited to the people who need it. Backups are encrypted. API routes are closed by default at the edge and opened only where a route is deliberately public.

None of that makes a system unbreakable, and we will not pretend otherwise. If a breach affects your data we will act under Articles 33 and 34 — notifying the supervisory authority within 72 hours and telling you directly where the risk to you is high.

10Changes

If this policy changes materially we will update the date at the top and tell you directly before the change takes effect. A change that widens what we do with data you have already given us will ask for your consent rather than assume it.

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