KickMint Privacy Policy

Effective April 9, 2026 · Last updated September 2, 2026 · Version 2.2

What the app collects: nothing

KickMint keeps everything on your device. No account, no analytics, no ads, no sync. Your tasks, voice transcripts, AI prompts, AI outputs, cycle data, sleep data, medication timing, profile answers, and completion notes never leave your phone.

There is one exception, and it is not something the app does: a message you choose to write to us from your own mail app. The claim above is about what KickMint sends. It sends nothing. See section 9a for what is in a support email and how to remove any part of it before you press send.

The only thing that crosses our network is an optional one-time download of the on-device AI model from models.kick-mint.com on first launch. After that download finishes, the app is fully offline. We do not sell data. We do not profile you. We have no advertising business.

iCloud Backup of your task data (when enabled in iOS Settings) is encrypted by Apple and gated on your Apple ID. KickMint never sees those bytes either.

This is enforced in code, not just policy. iosApp/Sources/App/PrivacyInfo.xcprivacy declares NSPrivacyTracking=false and an empty NSPrivacyCollectedDataTypes, matching the App Store Connect "No, we do not collect data from this app" answer. Support mail sits outside that declaration because the app never transmits it: it hands a draft to your mail app and you send it, which is the case Apple's own guidance treats as optional to disclose. The sync subsystem ships dormant in the binary (no UI entry point, no automatic startup) and has no release date; if it ever ships, this policy changes first.

1. Who we are

KickMint is an iOS productivity app for adults with ADHD and similar executive-function differences, distributed worldwide via the Apple App Store and described at kick-mint.com.

In this policy, "we", "us", and "our" refer to:

• Controller / publisher: Povilas Konopackas, operating as an individual-activity practitioner (Individualios veiklos pažymėjimas) under Certificate No. 1503311, Republic of Lithuania.
• Registered address: Akacijų g. 14-2, Raudondvario k., LT-14258, Lietuva (Lithuania).
• Contact for privacy matters: [email protected]
• Contact for legal notices: [email protected]
• EU/EEA representative (Article 27 GDPR): Not required. The controller is established in the European Union (Republic of Lithuania), so the Article 27 representative-appointment requirement does not apply under GDPR Article 3(1).
• UK representative (UK GDPR Art. 27): Not appointed. We rely on the exemption in UK GDPR Article 27(2): our processing of UK residents' data is occasional, is not of a large scale, does not include large-scale processing of special categories of data under Article 9 or of criminal-offence data under Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons. We operate no application server and no user database: the only personal data we ever hold is support mail people choose to send us, described in section 9a.
• Data Protection Officer: Not appointed. We are not subject to the mandatory DPO requirement under GDPR Article 37(1) because (a) we are not a public authority, (b) our core activity does not require regular and systematic monitoring of data subjects on a large scale, and (c) our core activity does not involve large-scale processing of special categories of data under Article 9.
• Lead supervisory authority: Valstybinė duomenų apsaugos inspekcija (State Data Protection Inspectorate of the Republic of Lithuania), L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania. Website: https://vdai.lrv.lt. You may lodge a complaint with VDAI under GDPR Article 77.

2. Plain-language data summary

Statutory basis for this disclosure format: California Civil Code section 1798.100(a) requires a business to inform consumers of the categories of personal information collected at or before collection. Our answer to all enumerated CCPA categories is "not collected", so we list each category to make that affirmative claim verifiable. GDPR Article 13(1)(c) requires the purpose and lawful basis for each processing activity; where we do not collect data we have no Article 13 obligation for that category, but we list it for transparency.

3. The on-device AI

KickMint includes a Qwen 2.5 1.5B large language model in GGUF format, executed locally on your iPhone using llama.cpp. This model is downloaded from a Cloudflare R2 bucket on first launch (a one-time download of roughly 1 GB) and runs entirely on your device thereafter.

What this means in practice:

• Every AI feature (task breakdown, suggestion ranking, capture parsing) runs on your phone with no network call to us during inference.
• Your prompts, the model's intermediate state, and the model's outputs are never transmitted to any server we control.
• AI telemetry (latency, token counts, fallback rate) is stored in a local table named ai_telemetry, which never leaves the device.
• The model file itself is downloaded over HTTPS without authentication. Cloudflare's standard server logs may record the IP that requests the file. Those logs are operated by Cloudflare under their own privacy terms and are used for abuse prevention and content delivery, not user profiling.

If we ever change inference to a hybrid or cloud model, we will update this policy, notify users in-app at least 30 days before the change, and require explicit opt-in for any cloud inference.

4. Voice capture (on-device only)

When you use voice capture, KickMint uses Apple's SFSpeechRecognizer with the requiresOnDeviceRecognition = true flag set unconditionally. This forces speech recognition to run entirely on your iPhone using the on-device dictation model.

If your device or locale does not support on-device dictation (older hardware, an iOS version below 17, or a locale without an installed model), voice capture is disabled at the surface and the microphone button is hidden. We never fall back to Apple's cloud speech-recognition servers, even when the on-device path is unavailable. Audio never leaves your device. Raw audio is never written to disk.

The transcribed text becomes the task title or completion note you see on screen, identical to text you would have typed yourself.

5. Completion notes

You can attach an optional freeform note to any task when you finish it (typed or dictated). Notes are stored on-device in your task database and are visible in the Done segment of the task list and in the task detail sheet.

Notes are included in iCloud Backup with the rest of the main task DB when you have iCloud Backup enabled in iOS Settings, and in iTunes / Finder local backups if you make those. Apple's backup encryption protects them in transit and at rest. KickMint never reads completion notes (the app's logging discipline forbids interpolation of the field anywhere in the binary). If you write health, financial, or relationship details, treat the note like any other note on your phone.

You can erase any individual note at any time from the task detail sheet (Note section > Edit > Erase note). You can erase all task data by uninstalling KickMint.

6. iCloud Backup (cross-device continuity)

Your main task database (tasks, focus sessions, preferences, profile answers, body check-ins, journal entries, completion notes) is included in your iPhone's standard iCloud Backup if you have iCloud Backup enabled in iOS Settings. This is the path that lets "I got a new iPhone, restore from backup, all my tasks are there" actually work.

The backup is encrypted in transit and at rest with keys Apple manages on your behalf and gated on your Apple ID password plus two-factor authentication. KickMint never sees those bytes. If you opt into Apple's Advanced Data Protection, the backup is end-to-end encrypted with a key only you hold, so not even Apple can read it.

You can disable iCloud Backup for KickMint specifically in iOS Settings > [your name] > iCloud > iCloud Backup > Apps Backing Up to iCloud, and your data will then live only on the device.

The two analytics-only tables (ai_telemetry, onboarding_events) stay excluded from iCloud Backup regardless of your global setting. They contain only structural performance counters, never user content, and have no portability value to you.

7. Moving your data to another device

KickMint has no sync service and no account system. There is no KickMint server that holds your content, and the app has no code path that uploads a task, a note, a session, or any health context anywhere. Earlier versions of this policy described an opt-in end-to-end encrypted sync feature planned for the Pro tier. That feature was never released and the plan has been withdrawn. To be precise about the leftover: sync.kick-mint.com does exist and serves app configuration only, a feature-flag file, a model manifest and a healthcheck. It holds no user content and no accounts. The app in the App Store never calls it: the code that would is gated behind a pairing step, and no pairing screen ships, so the app makes no request to that host at all. If we ever build it, this policy will be updated before it ships and the feature will be off until you turn it on.

What this means in practice. Your data lives on the iPhone you use KickMint on. It does not appear on a second iPhone, an iPad, or a Mac, because nothing leaves the first device.

Getting to a new iPhone. The supported path is Apple's own: KickMint's database is included in your encrypted iPhone backup, so restoring a new iPhone from an iCloud or Finder backup brings your tasks, journal entries, breakdowns, and settings with it. That transfer happens entirely between you and Apple, under Apple's terms; we are not a party to it and never see the contents. Section 6 covers backup in detail.

7a. Optional iOS integrations added in V1.1.x (HealthKit, Calendar, Motion, Location)

Versions 1.1.4 through 1.1.5 added four optional iOS-system integrations that surface useful context inside KickMint. Each one is off by default, requires the standard iOS system permission prompt, and processes data entirely on your device. None of these integrations transmit any data to KickMint servers or any third party. They can each be revoked at any time from iOS Settings > Privacy & Security.

• Apple Health (Sleep Analysis + Menstrual Flow), V1.0+. Read-only on-demand reads, never persisted in the app's database, never transmitted. Sleep informs adaptive step pacing; cycle data informs the optional cycle-rhythm pill on the Today tab. GDPR Art. 9(2)(a) explicit-consent basis.
• Calendar (EventKit), V1.1.5. Reads only event start and end times (never titles, never attendees) to power the Waiting Mode Relief feature, which surfaces "you have a 17-minute window before your next meeting" suggestions. Zero persistence, zero network egress. GDPR Art. 6(1)(a) explicit-consent basis.
• Motion (CMMotionActivityManager), V1.1.5. Activity-change triggers for if-then plans ("when I stop walking, drink water"). Activity samples are evaluated transiently and discarded; nothing is persisted. GDPR Art. 6(1)(a) explicit-consent basis.
• Location (CoreLocation, significant-location-change), V1.1.5. Powers "when I get home" / "when I leave work" task triggers against places you set up yourself in Settings. The trigger evaluator only learns whether the device crossed a user-tagged region's boundary; precise coordinates are never logged. GDPR Art. 6(1)(a) explicit-consent basis.

Apple Privacy Nutrition Label note: under Apple's framework, "collected" means data the developer receives. Because these four integrations never reach KickMint's servers, none of them flip the App Store label answer. Nothing in any shipped version of KickMint does.

8. Lawful basis for processing (EU/UK GDPR)

Because KickMint processes no personal data on our servers, the only relevant Article 6 bases are:

• Performance of a contract under GDPR Article 6(1)(b) for the on-device app itself: when you install KickMint, we provide the productivity features the app advertises, all running on your device.
• Legitimate interests under Article 6(1)(f) for the optional one-time AI model download: we need to deliver the model file and Cloudflare needs minimal connection metadata (your IP, TLS handshake) to serve the request. The legitimate interest is delivering the feature you opted into; the impact is the standard CDN footprint of any HTTPS download.
• Legal obligation under Article 6(1)(c) for retaining purchase records to the extent required by Lithuanian tax and accounting law, typically 10 years under the Lithuanian Accounting Law and the Law on Tax Administration. Apple, as merchant of record for App Store in-app purchases, holds the authoritative transaction records; we hold no separate copy.

We do not rely on consent under Article 6(1)(a) for the core app because the app itself collects no personal data. There is no sync feature and no server-side processing of your content to find a lawful basis for. The one place a lawful basis is needed is support mail you choose to send us, covered in section 9a.

9. Third-party processors

If you never write to us, the only third party that receives any data related to your use of KickMint is Apple, and only in three contexts:

1. App Store distribution. Apple collects data about app downloads per their own privacy policies.
2. In-app purchases via StoreKit 2. Apple processes the payment transaction; KickMint receives only a transaction ID and receipt.
3. iCloud Backup of the main task database (if you have iCloud Backup enabled in iOS Settings). Apple stores the encrypted backup snapshot on your behalf, gated on your Apple ID password and two-factor authentication. KickMint never sees those bytes.

Apple Inc.

• What they do for us: App Store distribution, StoreKit 2 in-app purchase processing, iCloud Backup of the main task DB when you have it enabled, push notifications via APNs (if you enable them), device-level crash and performance reports if you have opted in via iOS Settings.
• What data they receive directly from you: payment information, App Store account identifier, device telemetry, iCloud Backup contents per Apple's policies. We never see any of this.
• Apple's privacy policy: apple.com/legal/privacy
• App Store data and privacy: apple.com/legal/privacy/data/en/app-store

Cloudflare, Inc. (CDN for the AI model download)

• What they do for us: Hosts the on-device AI model file as a static download from models.kick-mint.com, and serves this website. That is the entire relationship: we run no application server and no database with Cloudflare or anyone else.
• What data they process: standard HTTPS metadata (your public IP, TLS handshake, User-Agent) for the single optional first-launch model fetch, and the same for page views on this website. No application payload of yours is ever part of the request.
• Cloudflare's privacy policy: cloudflare.com/privacypolicy
• Cloudflare DPA: cloudflare.com/cloudflare-customer-dpa

We use no analytics SDK, no advertising SDK, no crash-reporting SDK other than Apple's built-in opt-in service, no attribution SDK, no fingerprinting library, no third-party tracking pixel, and no tag manager.

9a. When you write to support

KickMint has a "Help and feedback" section under the Me tab with two entries, "Suggest a feature" and "Report a bug". Tapping either opens your own mail app with a message already addressed to [email protected]. The app does not send anything: it hands the draft to your mail app, and you decide whether to press send.

The draft has a short block at the end, shown to you in full before your mail app opens. It contains a Support ID, the app version and build, your iOS version, your device family (the word "iPhone", not a hardware identifier), and whether the on-device AI model is downloaded. Nothing you have written in KickMint is attached: no tasks, no notes, no AI prompts, no answers from setup.

The Support ID is a random identifier generated on your device. It exists so that if you write to us twice about the same problem we can tell it is the same installation, which is the difference between support and a suggestion box. It is not derived from your hardware, your Apple Account, or anything about you, and it is not the identifier the optional device-sync feature uses. On its own it says nothing about who you are; in your email it sits next to your email address, which does. Nothing is stored until you actually use the support screen: opening it shows you an ID, and we only keep that ID if you copy it or open your mail app. Deleting KickMint deletes it, and a fresh install produces a new one, though restoring an iCloud Backup would carry the old one across. It is shown to you on screen and you can copy it on its own. If you would rather not send it, delete that line from the draft before you press send, or write to us directly at [email protected] instead.

What we then hold is the message you wrote and the email address you sent it from. We use it to answer you and to fix what you reported, and for nothing else: no marketing list, no profiling, no sale, no transfer to advertisers. The lawful basis is Article 6(1)(b) and 6(1)(f) GDPR, our legitimate interest in supporting the product you use.

Because KickMint is an app for ADHD and AuDHD adults, a support message may contain health-related detail if you choose to include it. You are not required to, and we ask you not to send more than the problem needs. Where you do include it, that is special-category data under Article 9(2)(a) processed on the basis of your explicit consent, given by choosing to send that message.

Our support mailbox is routed by Cloudflare, Inc. and hosted by Google LLC. We keep support mail for 24 months from the last message in the thread, and then delete it. You can ask us to delete your correspondence sooner at [email protected].

10. International data transfers

The app transmits no personal data off your device. The one exception is not a transmission by the app at all: it is an email you choose to send from your own mail app. That message travels to our support mailbox, which is operated by Cloudflare (email routing) and Google (mailbox hosting), both of which process it in the United States among other locations. Sending it is your decision, made message by message, and nothing in the app sends anything on its own.

The optional AI model download from models.kick-mint.com may be served from Cloudflare edge nodes worldwide, including US points of presence. The request carries only standard HTTPS connection metadata (IP, TLS handshake) and no application payload, so the transfer is not personal-data-intensive in the GDPR sense.

11. Your rights

All users

• Delete the app to delete the data. Because all data is on your device, uninstalling KickMint deletes it. iCloud Backup snapshots are then aged out by Apple per your iCloud Backup settings.
• Export. Me tab > Privacy & Data > Export my data creates a JSON file you can save anywhere.
• Erase a single completion note. Tap the completed task in the Done segment > Edit > Erase note. Confirms before deleting.
• Wipe onboarding answers / analytics. Me tab > Settings > Privacy > Delete my onboarding answers / Delete my analytics history.
• Disable iCloud Backup for KickMint. iOS Settings > [your name] > iCloud > iCloud Backup > Apps Backing Up to iCloud > toggle KickMint off.

EU/EEA, UK, and other GDPR-style users

Under GDPR Articles 15-22 and equivalent UK provisions, you have the rights of access, rectification, erasure, restriction, portability, and objection.

• Right of access (Art. 15): because all data is stored on your device, you can view it directly within the app, or use the built-in data export to receive a JSON copy. We hold nothing on our servers that is associable with your account.
• Right to rectification (Art. 16): you can correct or update any data in the app at any time, tasks, preferences, and settings are all editable directly.
• Right to erasure (Art. 17, "right to be forgotten"): the in-app deletion controls listed above plus uninstall together cover the full erasure surface that we control. If you have iCloud Backup enabled, the most recent backup snapshot may still contain a copy until iOS overwrites it. Apple controls iCloud Backup retention; you can wipe the snapshot via iOS Settings > Apple ID > iCloud > Manage Storage.
• Right to portability (Art. 20): the in-app Export creates a JSON file containing your tasks, focus sessions, and preferences.
• Right to restriction (Art. 18) and objection (Art. 21): because processing happens exclusively on your device, you control processing directly, you can pause, limit, or stop using any feature at any time.
• Right to lodge a complaint (Art. 77): you may complain to any supervisory authority. Our lead supervisory authority is the State Data Protection Inspectorate of the Republic of Lithuania (VDAI), vdai.lrv.lt. You may also complain to your own national authority, for example the UK ICO at ico.org.uk, the Irish DPC at dataprotection.ie, or any other EU/EEA national authority.

California users (CCPA / CPRA)

Under California Civil Code section 1798.100 et seq., you have the rights of access, deletion, correction, opt-out of sale or sharing for cross-context behavioral advertising, and limit on use of sensitive personal information.

• Right to know (1798.110, 1798.115): ask [email protected]. We hold no personal information on our servers. We have no source from which we sold or shared personal information because we do not sell or share.
• Right to delete (1798.105): see the in-app deletion controls and uninstall path above.
• Right to opt out of sale or sharing (1798.120): N/A. We do not sell or share personal information for cross-context behavioral advertising as those terms are defined in 1798.140.
• Right to limit use of sensitive personal information (1798.121): N/A. We do not collect sensitive personal information as defined in 1798.140(ae). All cycle, health, sleep, and medication data stays on your device.
• No discrimination (1798.125): we do not discriminate against you for exercising any of these rights. Pricing and features do not depend on whether you exercise rights.
• Authorized agent requests: you may designate an agent under California Code of Regulations Title 11 section 7063 by emailing [email protected] with written authorization signed by you.

We are required to disclose retention periods (1798.100(a)(3)). Because KickMint collects nothing on our servers, the only retention period that applies is your device's local storage, which lasts until you delete it or uninstall the app.

Brazil users (LGPD)

Under Lei nº 13.709/2018, particularly Article 18, you have the rights of confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing, and revocation of consent. Use the same email mechanism as above. ANPD complaints: gov.br/anpd.

Canada users (PIPEDA)

PIPEDA Principle 9 (Individual Access) and Principle 8 (Openness) apply. Contact [email protected]. The Office of the Privacy Commissioner of Canada accepts complaints at priv.gc.ca.

Australia users (Privacy Act 1988)

Australian Privacy Principles 5, 6, 12, and 13 apply to the extent they are applicable to us. We currently operate below the small-business turnover threshold of AUD 3 million under Privacy Act section 6D and therefore rely on the small-business exemption. We nevertheless follow the Australian Privacy Principles as a voluntary matter of practice given we collect almost nothing. Contact [email protected]. The Office of the Australian Information Commissioner accepts complaints at oaic.gov.au.

12. Security

• Local data: stored in the iOS app sandbox using SQLite, automatically protected by iOS Data Protection (NSFileProtectionCompleteUntilFirstUserAuthentication), encrypted at rest with a key derived from your device passcode.
• Cryptographic keys: KickMint stores no Keychain material at runtime. There are no device keys, signing keys, or group credentials, because there is no account and no server to authenticate to.
• SQLCipher database-level encryption: not active in any shipped version. iOS file-level Data Protection provides equivalent security for the device-unlock threat model.
• No network transmission of personal data: the strongest guarantee is that your task content never travels over a network, eliminating a broad class of interception risks.
• No third-party SDKs with data access: no third-party code in the app has access to your task data.
• Breach notification: if we discover a breach involving personal data, we will notify the Lithuanian State Data Protection Inspectorate (VDAI) within 72 hours of becoming aware where required by GDPR Article 33, notify affected users without undue delay where required by GDPR Article 34, and meet the corresponding windows under CCPA, LGPD, PIPEDA, and Australia's Notifiable Data Breaches scheme.

13. Retention

14. Children's privacy

KickMint is rated 13+ on the App Store and built for adult users. We do not direct the app at children under 13 (United States COPPA, 15 U.S.C. sections 6501-6506) and we do not knowingly collect data from children under 13. Because KickMint requires no account creation and stores all data locally on the user's own device, it does not collect personal information through any mechanism we control.

If you are a parent or guardian and you believe a child under 13 has used KickMint, contact [email protected].

15. Changes to this policy

If we make material changes, we will:

1. Update the "Last updated" date at the top.
2. Notify users inside the app the next time they open it after the change.
3. For changes that broaden processing (which we do not anticipate), we will give 30 days' advance notice and, where required, request fresh consent.

16. Contact

• Privacy questions, rights requests, or breach reports: [email protected]
• Legal notices: [email protected]
• Postal address: Povilas Konopackas, Akacijų g. 14-2, Raudondvario k., LT-14258, Lietuva (Lithuania).

If you do not receive a response within 30 days, you may escalate to your data protection authority. See section 8 for the relevant authority in your jurisdiction.