1. Who is responsible (controller)
Anjuli Denise Hertle, Otto-Hahn-Str. 2, 72622 Nuertingen, Germany. Contact: breaking.life.patterns@gmail.com or the contact form on this site. There is no statutory requirement for a Data Protection Officer for a business of this size; if that changes we will name one here.
2. What this service is, in one line
A fully self-guided digital "Pattern Analysis", sold as the Catchself membership and, where offered, as a one-off digital service. You answer questions over several sessions and an AI creates a personal written report and a Pattern Map. No human ever reads your answers or your report.
3. What data we process
- Your answers (free text and scales) about your life, feelings, relationships and wellbeing. These can reveal information about your mental health, which is special-category data under Art 9 GDPR.
- The report and Pattern Map the AI generates from your answers.
- Account and contact data: your email, login details, language preference, your age confirmation, and records of the consents you gave.
- Payment data: handled only by our payment provider (Stripe). We never see or store your card details.
- Free quiz completion records: a pseudonymous hash of the submitted email, product, completion time, whether a marketing confirmation was requested, and whether the email provider accepted the result email. These records contain no answers or scores. They are kept for 90 days to measure use and repeat completions. A hash is still personal data; it is not an anonymous marketing permission.
- For optional marketing follow-ups, we check your confirmed subscription, unsubscribe status and whether you already have a CatchSelf account. We keep a pseudonymous email hash, sequence step, language, timestamp and provider message reference for up to one year to prevent duplicate messages and investigate delivery failures. No answers or scores enter this record. Account deletion removes our matching follow-up records; you can also request deletion using the contact address above.
- Consent proof for the free quiz and free Mind Read: when you submit either free tool, we keep a record of the door used, the language, the wording version of the consent text you saw, and a one-way HMAC-SHA256 of your email address (not your email itself, and not reversible back to it). We never store your plain email or name for this proof unless you separately confirm a marketing subscription (below). This record is kept for 3 years, then automatically deleted, matching the EDPB's guidance that consent proof is kept no longer than strictly necessary.
- Only after you click the double opt-in confirmation link do we create a marketing contact (your email and first name) with our email provider, Brevo; a ticked box alone never creates one.
- Technical and usage data with no answer content: how far through the analysis you are, session counts, timestamps, crisis-pause status, and usage counts we use to prevent abuse.
4. Why we process it, and the legal basis
- To deliver the analysis and your report: to perform our contract with you (Art 6(1)(b)) and, because your answers can be special-category data, your explicit consent (Art 9(2)(a)). We do not rely on any health-care exception, because we are not a health-care provider and this is not treatment.
- To run your account, save and resume your progress: to perform our contract (Art 6(1)(b)). In the installed app, an optional personal-device preference can suppress inactivity sign-out for up to 30 days. It stores only your account ID and expiry time on that device, not your password or answers. Sign out to remove it.
- To measure free quiz completion and repeat use without storing answers in business reports: our legitimate interest in operating and improving the service (Art 6(1)(f)). You can object or request deletion through the contact address above. Marketing uses separate, confirmed opt-in; participation alone is not permission.
- To issue and keep invoices: legal obligation (Art 6(1)(c)) with German tax law (sec 147 AO, sec 257 HGB).
- To keep the service secure and prevent abuse, and to run the crisis-pause safety feature: our legitimate interest and duty of care (Art 6(1)(f)).
- To prevent abuse and fraud and keep the service secure, we keep a short record of when usage limits are hit: our legitimate interest (Art 6(1)(f), Recital 49). This uses technical usage metadata only (counts, timing, limit-hit events), with no answer content and no IP address or user-agent stored at launch.
- To send you launch or marketing emails (only if you separately opt in): your consent (Art 6(1)(a)), which you can withdraw any time.
5. The AI, and no human reading
Your report and Pattern Map are generated by an AI system. You are interacting with AI. No human reads your answers or your report in normal operation. The report is a reflective, non-clinical aid. It is not a medical diagnosis or treatment, and it is not an automated decision that has legal or similarly significant effects on you (Art 22 does not apply); we still tell you openly that AI produces it.
6. Who else processes your data (our processors)
- Supabase (servers in Frankfurt, EU): stores your answers and report, encrypted.
- Vercel (EU): runs and serves the app.
- Anthropic (AI provider): processes your answers to generate the questions and your report. The signed terms confirm Standard Contractual Clauses as the transfer mechanism, that your answers are not used to train any AI model, and that the provider retains them only briefly to process your request and then deletes them.
- Brevo (EU): sends the app's emails (purchase confirmation, withdrawal receipt, account and safety emails). Account and billing emails contain no answer content. For the free quizzes, a result is emailed at your explicit request; the input answers are not saved to your account. A marketing contact (email and first name) is created only after double opt-in confirmation, never from the checkbox alone; Brevo keeps its own send and delivery logs for the retention period set in our Brevo account, which we keep to the minimum the provider allows.
- Stripe: processes your payment as a separate controller for that payment data.
We have data processing agreements (Art 28) with our processors. Where data is transferred outside the EEA, it is protected by Standard Contractual Clauses or an adequacy framework; you can ask us for a copy of the safeguard.
7. How long we keep it
- Your answers and results, membership: kept while your membership runs and for at least one full year from the day you joined, even if you cancel inside that year. After the membership has ended and that year has passed, we send you a notice giving you at least 30 days to download everything, and only then do we delete our copy (Terms of Service, 3.3b). One-off purchase: kept for the 12-month access window from purchase; we delete on your request, and a deletion we start ourselves is always preceded by a notice. You can ask us to delete sooner at any time. If your account is paused under the crisis-safety feature, the data needed to resume is kept for the pause and, for a one-off purchase, for the 12-month goodwill extension.
- Invoices and tax records: 8 to 10 years, as German tax law requires, kept separately and containing only billing data, not your answers.
- Consent records: kept as long as needed to prove we had your consent. For the free quiz and free Mind Read specifically, the pseudonymous consent-proof record described in section 3 is deleted automatically after 3 years.
- General security and usage logs: a short period (about 30 to 90 days); they never contain your answers.
- Abuse-evidence records (counts, timing, and limit-hit events only, never any content): kept up to 12 months and then deleted, or for as long as needed to pursue or defend a specific case.
8. Your rights
You have the right to access your data and get a copy (Art 15), to correct it (Art 16), to have it deleted (Art 17), to restrict processing (Art 18), to data portability (Art 20), and to object (Art 21). The copy and portability rights cover your own answers and your own report; they do not extend to our question bank, prompts, scoring logic or methodology, which are our protected materials (Art 15(4), Recital 63). You can withdraw any consent at any time with future effect (Art 7(3)); for the special-category consent, withdrawing it normally means we can no longer provide the analysis. You also have the right to complain to a data protection supervisory authority (Art 13(2)(d)); the competent one for us is Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW).
9. Is providing data required?
Yes, to use the service: without your answers and the explicit consent, the analysis cannot be created. You are never required to give more than the service needs.
10. When you write about other people
Sometimes you may write about other people in your answers, for example a partner, a parent or a friend. We only ever receive that information through what you choose to write, and we use it only to create your own private reflection. No human reads it, we never contact or build a profile of anyone you mention, we never share it, and it is deleted when your data is deleted. To help keep this to a minimum, the app reminds you at the start that you do not need to use other people's real names or details. If you believe someone has written about you here and you have a concern, contact us at hello@catchself.co and we will look into it.
11. Changes
We update this policy if the service or our processors change. The current version is shown with its date on this page.