Kopfwolke Privacy Policy

Effective 2 October 2026 · Version 1.1

Summary

Your headache diary stays on your iPhone. Attacks, symptoms, medication and notes are health information. We never receive them. There is no account, no server and no iCloud sync.
Weather: the App sends a location rounded to about 1 km to Apple WeatherKit. Apple states that these requests are not linked to you.
Notify on attack (optional): contacts and templates stay on your iPhone and Apple Watch. Kopfwolke never sends anything itself.
No ads, no tracking, no analytics, no sale or sharing of data.

1. Who is responsible

Patrick Böttge, Ferdinand-Rhode-Str. 5, 04107 Leipzig, Germany, [email protected] (“we”). Legal notice: in the App under Settings › Impressum.

2. Data stored only on your device

attacks: start, end, intensity, location on the head, type, aura, symptoms (including nausea/vomiting), daily factors (e.g. sleep, stress, alcohol), notes (health data under Art. 9 GDPR; consumer health data under Washington and Nevada law);
medications with drug class, intakes and how well they worked;
daily entries such as stress and caffeine;
optionally a name for the doctor PDF;
optionally the contacts you want to notify (name, phone number or email address, channel, order) and your message templates, weekdays and time windows, and a local record of which contact was already notified for an attack;
the last rounded location used for the pressure heads-up;
settings, purchase status, the paywall version and time of your purchase, and the version of the Terms of Use shown to you.

In the United States the App asks Apple’s Declared Age Range API for an age range; it is evaluated on your device only and not stored.

Storing this data on your device is strictly necessary to provide the service you asked for (§ 25(2) no. 2 TDDDG). It is protected by iOS data protection and, if you turn it on, Face ID. Kopfwolke does not store it in iCloud. We cannot see, restore or share it. You can delete it with “Delete all data” (Alle Daten löschen) or by deleting the App.

3. Apple Health (optional)

If you allow it, Kopfwolke reads sleep analysis, menstrual cycle and steps from Apple Health. It does not write to Apple Health. The values are used only on your device to display them in charts and the calendar, are not stored in iCloud by Kopfwolke, not shared and never used for advertising or marketing. You can change access at any time in the Health app.

4. Weather and barometric pressure (Apple WeatherKit)

To show pressure and weather and to send pressure heads-ups, the App requests weather data from Apple WeatherKit. It sends your location rounded to two decimal places (about 1 km). For heads-ups in the background it uses the last rounded location, cached only on your iPhone, or a place you chose. Apple states that WeatherKit requests are not associated with personal information and not tracked across requests (https://developer.apple.com/weatherkit/). Weather data is kept only briefly and fetched again when needed. Legal basis: Art. 6(1)(b) GDPR (providing the weather feature you use) and Art. 6(1)(f) GDPR. Without location access you can choose a place manually or leave the weather feature off. Weather data: Weather; legal attribution: https://developer.apple.com/weatherkit/data-source-attribution/.

5. Doctor PDF and CSV export

The PDF and CSV files are created on your device. You decide whether and with whom you share them. After you share them, the recipient’s privacy practices apply.

6. Notify on attack (optional)

Choosing contacts: you pick single contacts with the iOS contact picker. Kopfwolke gets no access to your address book, only the name and number or email address you tap.
Storage: contacts and templates stay on your iPhone and, if you use the Watch app, on your paired Apple Watch. They are synced directly between both devices (WatchConnectivity), not via iCloud or a server.
Manual sending: Kopfwolke fills in the template and opens the iOS Messages or Mail compose sheet or the share sheet. Nothing is sent until you tap Send. The message then travels through the service you use (iMessage/SMS via Apple or your carrier, email via your provider, WhatsApp or Signal via the share sheet) under that provider’s privacy policy. Kopfwolke does not receive the sent text or a delivery confirmation; it only remembers locally whom you have already messaged for an attack.
Health information in messages: a message like “I’m having a migraine attack” contains information about your health. Whether and to whom you send it is your decision. The employer template contains no diagnosis.
Location (optional): only if you switch on “Attach location” for a contact does the App request your precise location once when the message is prepared and add it as an Apple Maps link. It is not stored and not sent to us. Not available for employer templates.
Not an emergency service. In an emergency, call your local emergency number.

7. Apple Watch, widgets and Control Center

The Watch app, widgets and the Control Center control start and end attacks and show pressure. Entries are stored on the device and synced directly with your iPhone (WatchConnectivity or the shared app container), not via iCloud. Lock Screen widgets show no health data, only pressure.

8. Purchases

Apple processes purchases. We do not receive your name, email address or payment details, only aggregated sales reports. Your purchase status is checked on your device.

9. When you contact us

If you email us, we process your email address and your message to answer you (Art. 6(1)(b) and (f) GDPR). Please do not send us health information. We delete emails when your request is closed, unless the law requires us to keep them longer. Our email provider: Apple (iCloud Mail), Apple Distribution International Ltd., Ireland. We never use support emails for marketing.

10. No tracking, analytics or advertising

Kopfwolke contains no analytics, crash-reporting, advertising or tracking technology. We do not sell or share personal information and do not use it for targeted advertising. There is nothing to opt out of, so we do not respond to “Do Not Track” or Global Privacy Control signals separately.

11. Children

Kopfwolke is not directed at children under 13. Teenagers should use it with a parent.

12. Your rights and international transfers

You can view, export and delete your data in the App at any time. If you are in the EU/EEA or the UK, you have the right to access, rectification, erasure, restriction, data portability and objection regarding any personal data we process (in practice: your emails). You may complain to a supervisory authority, for example the Saxon Data Protection and Transparency Commissioner (Sächsische Datenschutz- und Transparenzbeauftragte, SDTB), Devrientstraße 1, 01067 Dresden, Germany, https://www.sdtb.sachsen.de or, in the UK, the Information Commissioner’s Office. US residents may contact us with any privacy request; we will answer even where a state law does not apply to us. If you email us from outside the EU, your email is transferred to us in Germany. Apple (App Store, WeatherKit, Messages) may process data in the United States under its own privacy policy.

13. Consumer Health Data Privacy Policy (Washington, Nevada and other US states)

This section describes how we handle “consumer health data” as defined in the Washington My Health My Data Act and Nevada law.

Categories. Headache and attack entries, symptoms, medications and their effect, daily factors, sleep/cycle/steps read from Apple Health, and the text of messages prepared for your contacts.
Source. You, by entering them in the App, and Apple Health, if you allow it.
Purpose. Only to provide the diary, charts, heads-ups, exports and messages you request, on your device.
Where it is processed. Only on your device (and your paired Apple Watch). We do not receive, collect on our servers, share or sell consumer health data. The rounded location sent to Apple WeatherKit contains no health data.
Sharing. None by us. You may share exports or send messages yourself.
Your rights. You can access, export and delete all consumer health data in the App at any time (“Alle Daten löschen” deletes it permanently). You can also contact us at [email protected]; because we hold no such data, we will confirm that we have none. If we ever deny a request, you may appeal by replying to our answer; if the appeal is denied, you may contact the Washington State Attorney General (https://www.atg.wa.gov/file-complaint) or the Nevada Attorney General.
Consent. We do not collect or share consumer health data, so we do not ask for consent to do so. If this ever changes, we will ask for your separate consent first.

14. Changes

We will update this policy when the App changes and show the new effective date. Material changes are announced in the App.

15. Contact

Patrick Böttge · Ferdinand-Rhode-Str. 5 · 04107 Leipzig · Germany · [email protected]