Privacy Policy - App

Only the German version is legally binding. Translations are provided for convenience and are not legally binding.

1. Information on the Collection of Personal Data

1.1 We offer a mobile app that you can download to your device (the "App"). This privacy policy describes how we collect, use, and share your personal data when you use the App. In this way, we want to inform you about our processing activities and comply with our legal obligations, in particular under the EU General Data Protection Regulation (GDPR).

1.2 Personal data is any information that can be related to you personally, e.g. user behavior, pseudonymized data, demographic data.

1.3 The controller pursuant to Art. 4(7) GDPR is Pyros Labs – Marijan Divkovic, Cotheniusstraße 4, 10407 Berlin, support@pyroslabs.com (see our imprint https://www.prayfocus.app/imprint) (hereinafter also referred to as "we," "us," or "our").

2. Your rights

2.1 You have the following rights with regard to your personal data processed by us:

2.1.1 Right of access (Art. 15 GDPR),

2.1.2 Right to rectification (Art. 16 GDPR),

2.1.3 Right to erasure (Art. 17 GDPR),

2.1.4 Right to restriction of processing (Art. 18 GDPR),

2.1.5 Right to data portability (Art. 20 GDPR),

2.1.6 Right to object to processing (Art. 21 GDPR),

2.1.7 Right to protection against automated decision-making (Art. 22 GDPR),

2.1.8 Right to withdraw your consent to data processing, and

2.1.9 Right to lodge a complaint with a supervisory authority about the processing of your data by us.

3. Processing of personal data when using the app

3.1 When downloading the app from the relevant app store (e.g. Apple App Store or Google Play Store), data such as your username, email address, customer number, time of download, payment information, and device identifier are transmitted to the respective app store. The app store collects and processes this data independently; we have no influence over this. Responsibility for data processing lies solely with the respective app store.

3.2 When using our app purely for informational purposes, i.e. when you use our app without registering or otherwise transmitting information to us, we automatically collect the following personal data that your device transmits to our server and store it in log files (so-called logfiles).

3.2.1 IP address,

3.2.2 date and time of the request,

3.2.3 time zone difference to Greenwich Mean Time (GMT),

3.2.4 requested file (page visited),

3.2.5 page from which the file was requested (previous page visited),

3.2.6 access status/HTTP status code,

3.2.7 amount of data transferred,

3.2.8 information about the browser type as well as the language and version of the browser software, and

3.2.9 your operating system.

3.3 This data is technically necessary in order to display our app to you and to ensure the stability and security of the system.

3.4 The legal basis for processing the aforementioned data is Art. 6(1) sentence 1 lit. f GDPR. Our legitimate interest lies in providing a functional and secure app.

4. App access permissions

4.1 To be able to use the app to its full extent, the app requires the following access permissions on your device:

4.1.1 Screen Time / Family Controls,

4.1.2 Notifications.

4.2 The legal basis for this data processing is our legitimate interest pursuant to Art. 6(1)(f) GDPR in providing a functional app, your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG, as well as the fulfillment of our contractual obligations pursuant to Art. 6(1)(b) GDPR (if a contract has been concluded).

4.3 The data will be deleted as soon as it is no longer required for the purpose for which it was collected.

5. Data Security

5.1 We implement appropriate technical and organizational measures to protect your data against manipulation, loss, destruction, or unauthorized access. In doing so, we take into account the state of the art, implementation costs, as well as the nature, scope, context, and purposes of processing. We also regularly assess the risks of potential data breaches, including their likelihood and impact. Our security measures are continuously adapted in line with technological progress.

6. Objection to or withdrawal of consent for data processing

6.1 If you have given your consent to the processing of your data, you may withdraw this consent at any time. The withdrawal takes effect from the time you notify us and applies to the future processing of your data. The lawfulness of processing carried out up to the time of your withdrawal remains unaffected.

6.2 If we process your personal data on the basis of a balancing of interests, you may object to this processing. We perform such a balancing in particular when we process your data in the public interest or on the basis of our legitimate interests. Please state the reasons in your objection why you consider the processing of your data in its current form to be unacceptable. We will review your objection and either stop or adjust the processing, or explain our compelling legitimate grounds that justify continuing the processing.

6.3 You may, of course, object at any time to the processing of your personal data for advertising and data analysis purposes.

6.4 To submit an objection or withdraw consent, please contact us at support@pyroslabs.com.

7. Storage period of your personal data

7.1 We store your personal data only for as long as is necessary to fulfill the purposes for which it was collected. This includes compliance with legal, tax, and accounting obligations. In determining the retention period, we take into account the scope, nature, and sensitivity of the data, the potential risk of unauthorized use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and applicable legal requirements.

7.2 In some cases, we will anonymize your personal data so that it can no longer be associated with you. In such cases, we may use this data without further notice to you.

7.3 If you have any questions regarding the storage of your personal data, please feel free to contact us at support@pyroslabs.com.

8. Data processing by third parties

8.1 We may engage external service providers to process your data, e.g. service providers for operating the app, for data processing, or for handling payments. These service providers are carefully selected, bound by our instructions, and regularly monitored.

8.2 The legal basis for such disclosure is Art. 6(1)(b) or Art. 6(1)(f) GDPR, or, where consent has been obtained, your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time. The withdrawal takes effect from the time you notify us and applies to the future processing of your data. The lawfulness of processing carried out prior to your withdrawal remains unaffected.

8.3 With regard to the retention period, section 7 (Storage period) applies.

8.4 If our service providers are located outside the European Union (so-called third countries), we will inform you of this in the respective function description below. Some third countries are deemed by the European Commission to have an adequate level of data protection comparable to that of the EU. A list of these countries and copies of the adequacy decisions can be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. In other third countries to which personal data may be transferred, a consistently high level of data protection may not exist. In such cases, we ensure that data protection is adequately safeguarded, for example by means of the European Commission's Standard Contractual Clauses pursuant to Art. 46(1), (2)(c) GDPR.

9. Additional functions and features of our app

9.1 In addition to the purely informational use of our app, we offer further functions that you may use if you are interested, which we describe in more detail below. As a rule, you will need to provide additional personal data for this purpose, which we process in order to make these functions available. For such data processing, the general principles mentioned above (e.g. regarding storage period, your rights, and the right to object/withdraw consent) apply, unless expressly stated otherwise below.

10. Online marketing / analytics tools

10.1 We use analytics tools to tailor our app to user needs and to continuously improve it. The legal basis for this is our legitimate interest in a needs-based and functional design of our app pursuant to Art. 6(1)(f) GDPR. You can object to this processing at any time. Where data is transferred to a country outside the European Union (a third country), this only takes place where an adequate level of data protection is ensured, for example through an adequacy decision by the EU Commission or appropriate safeguards pursuant to Art. 44 et seq. GDPR.

10.2 Amplitude

10.2.1 In the app we use Amplitude, an analytics service provided by Amplitude Inc. For users in the EU, the EEA, and Switzerland, Amplitude is represented by Amplitude Germany GmbH, c/o Pramex International GmbH, Savignystraße 43, 60325 Frankfurt am Main, Germany.

10.2.2 Amplitude enables us to analyze the behavior of app visitors. In this context, we receive various usage data such as page views, length of stay, operating systems used, device information, and user origin. This data helps us to optimize our app and better adapt it to the needs of our users. Further information is available at https://amplitude.com/privacy.

10.2.3 The data collected by Amplitude is processed and stored on servers in Frankfurt am Main within the European Union (Amplitude EU Data Center). Thus, processing takes place exclusively within the EU/EEA without any data transfers to third countries such as the USA.

10.2.4 Amplitude uses anonymization and pseudonymization mechanisms to protect user privacy. Personal data such as IP addresses are not stored permanently or merged with other data sources.

10.2.5 The legal basis for this data processing is our legitimate interest pursuant to Art. 6(1)(f) GDPR.

10.2.6 You can object to this processing at any time with effect for the future. The objection takes effect from the time you notify us and applies to the future processing of your data.

10.2.7 Further information is available at https://amplitude.com/privacy.

10.3 Google Firebase Analytics

10.3.1 We also use Firebase Analytics, an analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

10.3.2 Firebase records standard app events (such as app opens, screen views, and purchases) and a limited set of usage properties, linked to a pseudonymous identifier, so that we can understand how the app is used and improve it.

10.3.3 This processing involves a transfer of data to Google LLC in the United States. Google is certified under the EU-US Data Privacy Framework, and we additionally rely on the European Commission's Standard Contractual Clauses as a safeguard for these transfers. Further information is available at https://firebase.google.com/support/privacy.

10.3.4 The legal basis for this data processing is our legitimate interest pursuant to Art. 6(1)(f) GDPR. You can object to this processing at any time with effect for the future.

11. Conclusion of a contractual relationship

11.1 When entering into a contractual relationship within our app, we do not collect any personally identifiable data. We use only a pseudonym for authentication.

11.2 The aforementioned data are processed for the purpose of concluding the contract. The processing of data is based on Art. 6(1) sentence 1 lit. b GDPR. The retention period is limited to the contract purpose and, if applicable, statutory and contractual retention obligations.

12. Use of payment service providers

12.1 For the payment of contracts concluded with us that are subject to a fee, we also work with the payment service provider RevenueCat, 1032 E Brandon Blvd #3003, Brandon, FL 33511. The actual payment processing, however, is carried out exclusively via the respective app store provider (e.g. Apple App Store or Google Play Store). We only pass on your payment data to the respective app store for the purpose of payment processing, insofar as this is necessary for payment processing. Through RevenueCat, only pseudonymous data is processed for the management of your subscriptions (e.g. App User ID, product ID, purchase date, subscription status). The legal basis for the transfer of data is Art. 6(1)(b) GDPR. Section 7 (Data Retention) applies to the storage period.

13. Registration for our newsletter

13.1 If you have expressly consented pursuant to Art. 6(1)(a) GDPR, we will use your email address to regularly send you our newsletter offered in the app.

13.2 Your email address will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Accordingly, your email address will be stored for as long as the newsletter subscription remains active.

13.3 You may unsubscribe at any time, for example via a link at the end of each newsletter.

13.4 You can manage which of our emails you receive at any time via the "Manage preferences" link in any of our emails, which opens a secure preference center where you can turn each type of email on or off.

14. Contacting us by email

14.1 When contacting us from within the app (e.g., by email or via a contact form), the data you provide (your email address and, if applicable, your name and telephone number) will be stored by us to answer your questions. The data processing for the purpose of contacting us is carried out in accordance with Art. 6(1) sentence 1 lit. a GDPR on the basis of your voluntarily given consent. The data arising in this context will be deleted if the request is assigned to a contract, after the periods for the contract term; otherwise, after storage is no longer necessary, or the processing will be restricted if statutory retention obligations exist.

15. Artificial intelligence features

15.1 The app offers optional features powered by artificial intelligence: Scripture Guide (an AI chat that answers your questions with responses grounded in the Bible) and Daily Insight (a short, AI-generated reflection based on your prayer activity).

15.2 To provide these features, we use Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA, and its "Claude" AI models as a processor. Data is transmitted to Anthropic over an encrypted connection through our own secure backend; we do not share your name or contact details with the AI provider.

15.3 For Scripture Guide, when you send a message we transmit the text of your message, a limited amount of recent conversation history, any Bible references detected in your text, your app language, and your country (used only to show the correct crisis helpline where relevant). Your conversations are stored only on your device; we do not keep a copy on our servers.

15.4 For Daily Insight, we transmit aggregated statistics about your prayer activity (for example your streak length, number of sessions, and mood trends). We do not transmit the text of your prayers or journal entries.

15.5 Anthropic processes this data solely to generate a response and does not use it to train its models. As Anthropic is based in the United States, using these features involves a transfer of data to a third country, safeguarded by the European Commission’s Standard Contractual Clauses. The legal basis is your explicit consent pursuant to Art. 6(1)(a) and, insofar as spiritual content may reveal religious beliefs, Art. 9(2)(a) GDPR, which you give by choosing to use the feature. These features are provided for spiritual encouragement and study only; their responses are generated automatically, may be inaccurate, and are not a substitute for pastoral, medical, psychological, legal, or financial advice.

16. Referral program

16.1 If you take part in our referral program, we process a randomly generated device identifier (stored securely on your device), the invite codes you create or redeem, the platform you use (iOS or Android), and, if you have enabled notifications, a push notification token so that we can tell you when a friend accepts your invitation. On Android, when the app is installed from a shared invite link, Google Play may pass us the referral information from that link so that we can credit the invitation.

16.2 This data is processed to operate the referral program and to prevent abuse. We do not link it to your name or email address. The legal basis is the performance of the referral program you chose to join (Art. 6(1)(b) GDPR) and our legitimate interest in preventing fraud (Art. 6(1)(f) GDPR).

17. Backend services, app stores and backups

17.1 Backend services. The app uses Supabase for anonymous authentication and to store referral and reward information under a pseudonymous identifier. Supabase is operated by Supabase, Inc.; the data for our project is hosted within the European Union.

17.2 App stores. The app is distributed through the Apple App Store (Apple) and Google Play (Google). When you download, install, or update the app, or make a purchase, the respective store processes data under its own privacy policy. On Android, we may receive install attribution data (such as campaign parameters) from the Google Play Install Referrer.

17.3 Optional cloud backup. If you choose to back up your prayer history, the backup is stored in your own iCloud account (Apple) or Google Drive account (Google), depending on your device. These backups are controlled by you and governed by Apple's and Google's terms; we do not have access to them. On Android, your device's automatic backup may also include app data unless you disable it in your device settings.

17.4 Managing and deleting your data. Most of your personal content (prayers, journal entries, moods, and prayer history) is stored only on your device and is removed when you delete the app. To exercise your rights of access, correction, or erasure regarding data we process on our servers (for example referral or subscription data), or to withdraw a consent, please contact us at support@pyroslabs.com.

18. Updates and changes to this privacy policy

18.1 As our app and the services we offer continue to develop, or due to changes in legal or regulatory requirements, it may become necessary to amend this privacy policy.

Last updated: August 7, 2026

Contact Information:
Pyros Labs – Marijan Divkovic
Cotheniusstraße 4, 10407 Berlin, Germany
Email: support@pyroslabs.com