Privacy policy
Last updated: October 17, 2026
This translation is provided for information. In case of discrepancy, the French version prevails.
No password. No data sold.
1. Data controller
Victor Gassmann, independent developer based in France — contact@winter-arc.fr.
2. Data processed
| Data | Source | Purpose | Where |
|---|---|---|---|
| User ID, email address (or Apple “Hide My Email” relay address) | Sign in with Apple | Create and recover your account, restore your winter arc on another device | Server (Supabase, European Union) |
| User ID, email address, name and profile picture of your Google account | Continue with Google, only if you choose this sign-in method | Create and recover your account; only the ID and the email address are used by the app | Server (Supabase, European Union); the app keeps no Google session |
| Goal chosen during onboarding, winter arc dates, status, flame freeze | Entered in the app | Running the challenge | Server and device |
| Daily check-ins of the 9 rules (rule, date, done / not done, manual or Health source) | Entered in the app or derived from steps | Tracking, flame, statistics, synchronization | Server and device |
| Daily step count | Apple Health, if you allow it | Automatically check off “10k steps” | Device only; only the “rule completed” result is synced, never the step count |
| Day 1 photo, daily photos (optional) and day 90 photo | Camera or photo library | Before / after comparison and timelapse, shown only on day 90 | Device only, never transmitted, excluded from iCloud backups; the timelapse video only leaves your phone if you save or share it |
| Photo chosen for a story (sharing screen on days 7 and 30) | Your photo library, through the iOS photo picker (the app only sees the chosen photo) | Compose the image you share | Device only, kept while the screen is open; it only leaves your phone if you share the image |
| Answers to the first two onboarding questions, reminder preferences | Entered in the app | Local personalization | Device only |
| Subscription status, Apple transaction ID | App Store | Check access, restore purchases | RevenueCat (subscription provider) and Apple |
| Visits to winter-arc.fr (other than /app and /tiktok): pages viewed, source (Google search, social network, other website) and campaign parameters (utm), time spent and scrolling, clicks on links and buttons (including the App Store badge) and their position on the page (heatmap), device type, browser, operating system, screen size, language, time zone | Sent by your browser during the visit, without cookies or anything stored on your device. To count each visit only once, PostHog computes a fingerprint on its servers from the IP address and the browser, with a key destroyed every day | Find out which pages and which sources bring visitors and downloads, and improve the website | PostHog (European Union), IP address not stored |
| Opening of the winter-arc.fr/app and winter-arc.fr/tiktok links: source (TikTok, Instagram…), in-app browser, operating system (iOS, Android), screen displayed, link copied or not, sign-up to the Android list (yes / no, never the email), country inferred from the IP address | Sent by your browser when you open these links, under a random ID discarded with the page (no cookies) | Find out which links lead to downloads, and how many people are waiting for Android | PostHog (European Union), IP address not stored |
| Email address (Android waiting list) | Entered on winter-arc.fr/app (or /tiktok) from an Android phone, only if you leave it | Write to you once, on the day Winterarc comes out on Android | Server (Supabase, European Union), readable only by the publisher; never sent to PostHog |
| Anonymous usage statistics: onboarding screens reached, start date chosen, paywall seen, purchase, notifications and Apple Health turned on (yes / no), full days, app opens, shares (and the app chosen to share) and notifications tapped, notification tone chosen (normal or No Mercy), Duo steps (username chosen, duo proposed by link or by username, invitation shared, opened, accepted or declined, duo left, shared flame milestones, report, block), group steps (group created and its number of spots, link shared, invitation opened, group or waiting list joined, group left, member removed, link changed, group exit and its reason, spot obtained, group flame milestones and the flame going out), leaderboard (sign-up, exit, opening, your place and your streak), referrals (link shared or opened, referrer named, first full day) and community group requests (form opened, request sent and how, network and follower range chosen, approval), screen displayed, crash reports (technical trace of the error, no personal content), iPhone model, iOS and app versions, language and time zone | Generated by the app, under a random ID specific to the installation | Understand where the app loses its users and improve it | PostHog (European Union), IP address not stored; never your name, your email, your account ID, your username, your photos or your steps |
| Apple sign-in token (refresh token) | Apple, at sign-in | Revoke your Apple sign-in when you delete your account, as Apple requires | Server, restricted access |
| Registration of the install with Apple (SKAdNetwork) | The app, at first launch | If you installed the app after seeing an ad, Apple reports it to TikTok in aggregated, delayed form, without any identifier | Apple, then TikTok, with nothing that identifies you |
| iPhone advertising identifier (IDFA), model, iOS and app versions, language, IP address, app install and opens, purchases (plan, price, currency) | TikTok SDK, only if you tap “Allow” when iOS asks whether Winterarc may track your activity (once, after the signature) | Find out which TikTok ads bring installs and subscriptions | TikTok; never your rules, check-ins, photos, health data, email or username |
Winterarc does not collect your location or your contacts. The advertising identifier is only read, and sent to TikTok, if you allow tracking; you can change your mind at any time in iOS settings (Settings → Winterarc → Allow Tracking). Usage statistics can be turned off in one tap: Settings → Anonymous analytics. Motivational quotes and reminders are generated locally; only Duo, group and referral notifications are sent from the server (section 3).
3. Duo, groups, leaderboard and referrals
Duo and groups are optional. In a duo, you do your winter arc alongside another player, each of you keeping your own, and every day you both have a full day, your shared flame grows. A group brings together 3 to 30 players: its flame grows every day on which half of the members have a full day, with a weekly leaderboard. The streak leaderboard and referrals are optional too. For the Duo, groups, the leaderboard and referrals:
- Your username (@username), which you choose in the app, is stored on the server (Supabase, European Union). It is visible to your Duo partner, to the people you invite by username and to the people you send your invite link to.
- During a duo, your partner sees your username, your full days and how many of the day's rules you have checked off (for example 5 out of 7), since the start of the duo. They see neither the names of your rules, nor your photos, nor your goal.
- In a group, its members and those on its waiting list see your username, your place in the group (member or waiting list), your full days since you joined and how many of the day's rules you have checked off. They see neither the names of your rules, nor your photos, nor your goal. The group's name, chosen by its creator, is stored on the server and visible to anyone who has its link, along with its owner's username and the number of members. After you leave, your past days remain counted in the history of the group's flame, without your username.
- Duo, group and referral notifications (for example an invitation, your partner finishing their day, a spot opening up in a group or a month of Pro earned through a referral): the server keeps your device's notification token, provided by Apple, to send them to you through Apple's notification service. This token is deleted with your account. When you finish your day, your Duo partner receives a notification with your username; when you join a group, so does its owner. When half of a group has finished their day, those who have not finished are notified, without anyone being named.
- Reports and blocks: you can report a username or a behavior, and block a player. A report records your account, the reported account, the reason and the content in question; it is kept for moderation. A block records the blocked player, so that neither of you can invite the other; in a group, you no longer see each other's usernames, and neither of you can join a group the other is in.
- Streak leaderboard (optional): if you sign up for it, your username and your current streak of full days in a row are visible to all players; the server keeps your streak and your best streak, calculated from your daily results. You can leave it at any time, and your streak is then erased from it.
- Referrals: if you name a referrer (their winter-arc.fr/@username link, their username, or the duo or group invitation that brought you in during your first 14 days), the server keeps the connection between your two accounts, the date of your first full day and the month of Pro given to your referrer. Your referrer receives a notification with your username. Their account ID is sent to RevenueCat to give them this month.
- Public groups: the winter-arc.fr/@username link of a creator, whose account the publisher has activated, opens their public group; this link shows anyone who opens it the group's name, the creator's username and the number of members.
- Community group request (optional): if you request a public group from the app, the request goes by email from your own mailbox to contact@winter-arc.fr, and you read it over before sending it. It contains your answers (network, account, follower range, and the group name and a message if you write them), your username, your Winterarc ID, where you are in your winter arc (day and length), your full days, whether you are Pro, and the app's version and language. To approve it, the publisher also sees in the app when your account was created, your number of winter arcs, the start date of your current one, your full days and your best streak. The publisher uses this only to answer you and activate your creator account.
- Deletion: your username, your participation in duos and groups, your referral, your streak on the leaderboard, your daily results, your notification tokens and your blocks are deleted with your account (in the app, Settings → Delete my account). Reports are kept for moderation, with no link to your account.
4. Legal bases
Performance of the contract (provision of the service subscribed to) for the account, the arc, the check-ins, Duo, groups, community group requests, referrals and the subscription; consent for Apple Health, the camera and notifications, which can be withdrawn at any time in iOS settings, and for the streak leaderboard, which you can leave whenever you want in the app; legal obligation and legitimate interest for revoking the Apple token and for the security of the service; legitimate interest for Duo and group moderation (word filter, reports, blocks, removals by a group's owner), for the anonymous usage statistics, which you can object to at any time in the app, and for anonymous audience measurement of the winter-arc.fr website, including the /app and /tiktok links; consent for the Android waiting list, which you can withdraw whenever you want by writing to contact@winter-arc.fr. TikTok ad measurement: consent (the iOS tracking prompt), which you can withdraw at any time in iOS settings; registration of the install with Apple (SKAdNetwork), which sends no identifier: legitimate interest.
5. Recipients and processors
- Supabase (database and authentication), hosted in the European Union (Frankfurt). Each user can only read and write their own rows (row-level security); in a duo or a group, other players only see what section 3 describes. It also hosts the Android waiting list, which only the publisher can read.
- RevenueCat (subscription management): receives your account ID and Apple purchase receipts, and the instruction to give a month of Pro when you earn a referral; never your check-ins or your photos.
- PostHog (usage statistics), hosted in the European Union: receives only the anonymous events listed above (app and winter-arc.fr website), without the IP address.
- Apple: sign-in, payment and notifications (reminders are local, Duo, group and referral notifications go through Apple's notification service; no third-party notification server).
- Google: sign-in, only if you choose “Continue with Google”. Google knows that you sign in to Winterarc; it receives neither your rules, nor your check-ins, nor your photos.
- TikTok (ad measurement), only if you allow tracking: receives the data listed above, under TikTok's terms for advertisers (TikTok Technology Limited, Ireland, for Europe). It may be processed outside the European Union, in particular in the United States, with the safeguards provided by TikTok. Without your consent, the app sends nothing to TikTok: only Apple tells it, without any identifier, that an install came from one of its ads.
No data is sold or rented. Only TikTok ad measurement, if you allow it, sends TikTok the data described above.
6. Retention period
Account data is kept for as long as the account exists. Deleting the account immediately and permanently erases the server data (account, arcs, check-ins, Duo, group, leaderboard and referral data, Apple token) and the local data (photos, preferences). Reports are kept for moderation, with no link to the deleted account. Anonymous usage statistics, from the app and the website, are kept for 13 months at most. Purchase data is kept by Apple and RevenueCat under their own policies, for the duration of the subscription and of accounting obligations. The email address left for the Android version is kept until the message announcing the release is sent, then deleted; it is erased sooner on simple request to contact@winter-arc.fr. The email of a community group request is kept while it is being handled, then for as long as you are a creator if it is accepted; it is erased sooner on simple request to contact@winter-arc.fr. Data received by TikTok is kept according to its own privacy policy.
7. Your rights
Access, rectification, erasure, restriction, portability and objection, in accordance with the GDPR. The most direct way: in the app, Settings → Delete my account (real deletion, with no delay). For any other request: contact@winter-arc.fr. You can also lodge a complaint with the CNIL, the French data protection authority (cnil.fr). To withdraw your consent to ad measurement: iOS Settings → Winterarc → Allow Tracking.
8. Security
Encrypted connection (TLS) between the app and the servers, authentication through Apple or Google with no password, data kept separate for each user, photos protected by the device's encryption and excluded from backups.
9. Minors
The Application is intended for people aged 16 and over. We do not knowingly collect data about children.
10. This website
winter-arc.fr does not set any cookies and stores nothing on your device. Its pages measure their audience with PostHog (see above): to count each visit only once, PostHog computes a fingerprint on its servers from your IP address and your browser, with a random key destroyed every day, then deletes the IP address. This fingerprint cannot be traced back to you or used to follow you from one day to the next or across websites, and no profile is created. The winter-arc.fr/app and /tiktok pages count their openings under a random ID discarded with the page.
11. Changes
The version in force is published at winter-arc.fr/confidentialite. Any substantial change is announced in the Application.