1. Who We Are
Daily Companion is a personal life-tracking application developed and published by Gareth Tierney trading as GTLabs ("we", "us", "our"), a sole trader registered in England.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, GTLabs is the data controller. In practice, because all personal content is stored locally on your device and never transmitted to us, we do not process your personal data in the traditional sense — you are the sole custodian of your own data.
2. Data We Collect
We do not collect any personal data. All information you enter into Daily Companion is stored exclusively on your device using local storage. This includes:
- Mood and wellbeing data — mood check-ins, energy levels, sleep records, sickness logs, gratitude entries
- Health and medication data — sickness type and symptoms, medications taken, recovery notes, daily severity ratings. This data is entered manually by you and is never transmitted or shared.
- Productivity data — tasks, habits, focus sessions, daily reviews, weekly intentions
- Financial data — expenses, budgets, monthly bills, receivables, shopping lists
- Journal entries — text entries and attached photos
- Health data — step counts, heart rate, and sleep data read from Android Health Connect (if enabled by you). This data originates from Samsung Health, Google Fit, Fitbit, or other apps connected to Health Connect on your device.
- People and events — contacts (including optional allergy and medical notes fields), calendar events, and reminders
- App preferences — theme, notification settings, PIN/biometric lock configuration
3. Legal Basis for Processing
Where any processing of personal data occurs (limited to the third-party services described in Section 6), the legal basis under UK GDPR Article 6(1) is:
- Contract performance (Article 6(1)(b)) — processing subscription purchase data through RevenueCat is necessary to fulfil our contract to provide premium features you have purchased.
- Legitimate interests (Article 6(1)(f)) — Google Play's collection of device identifiers and crash data for platform stability and security. We have assessed that this processing does not override your fundamental rights given the pseudonymous nature of the data and the necessity for app distribution.
For all content you create within the App (mood logs, journals, financial data, etc.), no legal basis is required from us because this data never leaves your device and is never processed by GTLabs.
4. How Your Data Is Stored
All content you create in the App is stored locally on your device using your browser's localStorage and the device's native storage. We do not operate any servers or cloud databases that store your personal content. Your moods, journals, habits, finances, and other entries are never transmitted over the internet by the App.
If you use the App's backup/export feature, a JSON file is generated and saved to your device's local storage. You are solely responsible for where you store or share that backup file.
5. Health, Biometric, and Wellness Data
Wellness and health logging: Daily Companion allows you to log moods, sleep, energy levels, sickness episodes (including illness type, symptoms, severity, and medications taken), and other wellness indicators. The People feature allows you to optionally record allergies and medical notes for your contacts. All of this data is entered manually by you and stored only on your device. It is used solely to display personal trends, correlations, and insights within the App. None of this data is ever transmitted externally, and GTLabs has no access to it.
Health Connect data: When you enable Health Sync in the App's settings, Daily Companion reads steps, sleep, and heart rate data from Android's Health Connect platform. Health Connect is a system-level service that aggregates data from Samsung Health, Google Fit, Fitbit, and other health apps installed on your device. This data is:
- Stored only on your device
- Used solely to display correlations and insights within the App
- Never transmitted to any external server, third party, or advertising network
- Never used for advertising, marketing, data brokering, or any commercial purpose
- Never shared with or sold to any third party
Google Play Health Apps Declaration: Daily Companion accesses the Android Health Connect API with read-only permissions to retrieve the following data types from your device:
- Steps — daily step count
- Sleep — sleep sessions, duration, and stage breakdown (deep, REM, light)
- Heart Rate — resting heart rate readings
This data is pulled from Health Connect (which aggregates data from Samsung Health, Google Fit, Fitbit, and other connected apps) and stored only on your device. It is used solely to display personal trends and insights within the App. Daily Companion does not write any data to Health Connect. No health data of any kind is transmitted to GTLabs, to our servers, or to any third party. The App does not access clinical records, medical diagnoses, or sensitive health information beyond the three data types listed above.
Biometric authentication: If you enable Face ID or fingerprint authentication for the app lock feature, biometric data is handled entirely by your device's operating system. Daily Companion never accesses, stores, or processes your actual biometric data — it only receives a pass/fail authentication result from the system.
6. Third-Party Services and Pseudonymous Identifiers
While Daily Companion itself does not collect personal data, the following third-party services may process limited pseudonymous data that is necessary for the App to function:
- RevenueCat — manages subscription purchases and receipt validation. RevenueCat may process: an anonymous app-specific user identifier, your platform and OS version, purchase transaction data, subscription status, and your country/currency for pricing. This data is pseudonymous (not linked to your name or email) and is necessary for subscription management. See RevenueCat's Privacy Policy.
- Google Play Services — as the distribution platform, Google may process: your device's IP address, a pseudonymous Android Advertising ID or device identifier, crash and performance data, and app install/update metadata. This processing is governed by Google's Privacy Policy and occurs at the platform level outside our direct control. We do not receive personally identifiable information from Google.
- Google Fonts (self-hosted) — the App uses typefaces (Playfair Display and DM Sans) which are bundled locally within the App. Font files are loaded from the device — no requests are made to Google's font servers. Your IP address is never shared with Google for font delivery.
About pseudonymous identifiers: The third-party services listed above may process Device IDs, IP addresses, and transaction records under their own privacy policies. GTLabs does not have direct access to these raw identifiers, does not combine them with any other data, does not use them for profiling or advertising, and has no technical means to identify you personally from this data.
We do not use any analytics, advertising, crash reporting, or user tracking services of our own. We do not operate any first-party servers that receive data from the App.
7. Data Sharing
We do not share, sell, rent, or trade any of your personal data with any third party. Since your personal content is stored only on your device, we have no access to it and no ability to share it.
8. Data Retention and Deletion
Your data remains on your device for as long as you choose to keep it. You can delete all your data at any time using the "Clear all data" option in the App's Settings. Uninstalling the App will also remove all locally stored data.
For data processed by third-party services (RevenueCat, Google Play), retention is governed by those services' respective privacy policies. You may contact them directly to exercise your rights over that data.
9. Age Appropriateness and the UK Children's Code
Daily Companion is intended for users aged 13 and over. By using the App, you confirm that you are at least 13 years of age. If you are between 13 and 18, you confirm that your parent or guardian has consented to your use of the App.
We have designed the App in accordance with the principles of the UK Age Appropriate Design Code (the "Children's Code", issued by the ICO under the Data Protection Act 2018):
- We do not collect personal data from any user, including children
- We do not use profiling, behavioural tracking, or personalised recommendations
- We do not use nudge techniques, rewards loops, or attention-extending design patterns targeted at children
- Privacy protections are set to the highest level by default — no data leaves the device
- The App does not include social features, public sharing, user-to-user communication, or location tracking
- Geolocation services are not used or requested by the App
If you believe a child under 13 is using the App, please contact us at the address below. Since we hold no user data, we cannot identify or remove individual users, but we take children's safety seriously.
10. Your Rights Under UK GDPR
Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights:
- Right of access (Article 15) — you can view all your data directly within the App at any time
- Right to rectification (Article 16) — you can edit any data within the App
- Right to erasure (Article 17) — you can delete all data via Settings → Clear all data
- Right to data portability (Article 20) — you can export your data using the App's backup feature
- Right to restrict processing (Article 18) — since we do not process your personal content, no restriction is necessary
- Right to object (Article 21) — since we do not process your personal content, no objection is necessary
For data processed by RevenueCat or Google Play Services, you may exercise your rights by contacting those services directly. If you require our assistance, please email us at the address below.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113 if you believe your data protection rights have been infringed.
11. International Data Transfers
Your personal content never leaves your device, so no international transfer occurs for that data. However, RevenueCat Inc. is based in the United States, and Google LLC operates globally. Where these third parties transfer pseudonymous data outside the United Kingdom, they do so under appropriate safeguards including Standard Contractual Clauses (SCCs) or equivalent mechanisms recognised by the UK Government under the UK GDPR. Please refer to their respective privacy policies for details.
12. Notification Data
If you grant notification permission, the App schedules local notifications on your device for reminders you configure. These notifications are generated and delivered entirely on-device and are not routed through any external push notification service.
13. Changes to This Policy
We may update this privacy policy from time to time. Any changes will be reflected on this page with an updated "Last updated" date. For material changes, we will display a notice within the App. We encourage you to review this policy periodically.
14. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have non-exclusive jurisdiction over any disputes arising from this policy.
15. Contact
If you have any questions about this privacy policy or wish to exercise your data protection rights, please contact us at:
Gareth Tierney, trading as GTLabs, United Kingdom.