Privacy Policy
Privacy Policy
Version: 1.3 Effective date: 14/05/2026 Last updated: 14/06/2026 Data controller: independent developer (natural person) based in Geneva, Switzerland. Full legal identity of the controller: Roberto Galati. Full postal address: P.O. Box 1073, 1227 Carouge, Switzerland. Privacy contact: privacy@pumpdiary.com Legal contact: legal@pumpdiary.com Support contact: support@pumpdiary.com
1. Purpose
This policy explains how PumpDiary collects, uses, stores and protects users' personal data. It is interpreted in light of the Swiss Federal Act on Data Protection and the GDPR where applicable.
2. Local-first approach
Local mode without an account:
- The application can be used without creating an account.
- Entered data stays on the user's device, in an encrypted local database when the platform allows it.
- No personal data is transmitted to PumpDiary servers in this mode.
Premium account mode with online backup:
- Advanced features may require an account, a premium subscription and explicit consent for online processing of health-related data.
- Data is synchronized with Supabase, our hosting provider, encrypted in transit and at rest.
- Withdrawal of consent for online backup blocks synchronization and may result in deletion of synchronized online backup data.
3. Categories of data processed
3.1 Account and identification data, online backup mode only
- Email address.
- Internal user identifier.
- Authentication information managed by the authentication provider.
- Profile display name.
3.2 Functional data
- Application preferences.
- Reminders and reminder series defined by the user.
- Stock storage preferences chosen by the user.
- Personal equipment, for example breast pumps and flange sizes.
3.3 Health-related data of the user
PumpDiary may process health-related data when the user enters it, including:
- data relating to lactation: volumes, durations, frequency and expressing techniques;
- self-reported physical scores or tags, for example pain or sensitivity;
- self-reported emotional tags;
- personal reminders configured by the user, including when they concern personal supplements or medicines.
This data is based on explicit consent in online backup mode. The application does not prescribe any treatment, make any medical recommendation or calculate any dosage.
3.4 Data relating to the infant
The user may enter identification data for their child: first name, date of birth and sex. This data is processed under the responsibility of the parent or legal representative who enters it. PumpDiary does not carry out nutritional, medical or growth monitoring of the infant.
3.5 Milk stock data
PumpDiary may process stored volumes, dates, storage methods, stock statuses and withdrawal events. This data is used to manage a personal inventory of expressed milk and not for nutritional recommendation.
3.6 Technical, support and operations data
- Messages exchanged with support when the user contacts PumpDiary.
- Minimal technical logs necessary for operation, security or debugging.
- Functional events strictly necessary for certain operations, for example synchronization, consents, online backup data deletion or reminders, when generated by the application.
This data is not used for advertising, tracking or artificial intelligence.
3.7 Subscription and payment data
- Premium status and technical subscription identifiers.
- Payment is processed by Apple App Store or Google Play through RevenueCat. PumpDiary does not have access to full bank card data.
3.8 Data not collected
PumpDiary does not collect:
- biometric identification data;
- location data;
- advertising or marketing tracking data;
- data sent to artificial intelligence services;
- nutritional or medical monitoring data of the infant beyond information entered by the parent.
4. Purposes and legal bases
| Purpose | GDPR legal basis | Swiss FADP legal basis |
|---|---|---|
| Provide the service in local mode | Performance of contract | Contractual necessity |
| Create and manage the online backup account | Performance of contract | Contractual necessity |
| Process health data in online backup mode | Explicit consent | Explicit consent |
| Process infant identification data | Consent of the legal representative and performance of contract | Consent of the legal representative and contractual necessity |
| Manage premium subscriptions | Performance of contract | Contractual necessity |
| Respond to support | Performance of contract or legitimate interest | Contractual necessity or overriding interest |
| Security, fraud prevention and continuity | Legitimate interest or legal obligation | Overriding interest or legal obligation |
Where the legal basis is consent, the user may withdraw it at any time, without retroactive effect on processing already carried out.
5. Recipients and processors
Data may be shared, strictly on a need-to-know basis, with the following categories:
- hosting, authentication and database services for online backup;
- technical subscription management;
- store payment platforms;
- support and technical monitoring;
- legally authorized authorities, where legally required.
| Processor or service | Role | Main location |
|---|---|---|
| Supabase, Inc. | Authentication, database hosting, online synchronization | Singapore, with processors notably in the United States and the EU |
| RevenueCat | Technical management of premium subscriptions | United States |
| Apple App Store | In-app billing on iOS | United States / Ireland for some EU users |
| Google Play | In-app billing on Android | United States / Ireland for some EU users |
| Device notification system via Expo Notifications | Local scheduling of reminders on the device | User device / operating system |
As of this version, PumpDiary does not collect a server push token to send remote notifications containing your pumping data. Reminders are scheduled locally on the device.
No artificial intelligence processor processes personal data of PumpDiary users.
6. Transfers outside the EU, EEA and Switzerland
Some processors may be established outside the European Union, the European Economic Area or Switzerland. Where required, these transfers are governed by appropriate safeguards, including standard contractual clauses, Swiss addendum, encryption in transit and access controls.
7. Retention period
| Type of data | Duration or effect |
|---|---|
| Active account data | For the duration of online backup service use |
| Online backup data controlled by PumpDiary after account deletion | Deletion of operational data associated with the online backup account upon confirmation, subject to temporary technical copies, security logs or legal obligations outside the application database |
| Online backup data deletion only | Deletion of synchronized online backup data and retention of local data if the user chooses this option |
| Local data | Stored on the device until the user deletes it, resets the application or chooses complete deletion including local data |
| Internal subscription data | Deleted or dissociated from systems controlled by PumpDiary upon account deletion; stores and RevenueCat may retain their own supporting records according to their obligations |
| Support data | Retained for the time necessary to process the request, for security and applicable obligations, then deleted or anonymized according to retention procedures or upon account deletion where possible |
| Technical and security logs | Retained for a limited duration necessary for security, debugging, fraud prevention or legal obligations; some traces may depend on technical providers |
| Technical backups | May temporarily remain until automatic overwrite according to provider cycles; they are not actively used after deletion |
| Inactive account | No automatic deletion is guaranteed at this stage; the user may delete their account at any time from the application or by email request |
Once deleted from active systems controlled by PumpDiary, the data is no longer used to provide the service, except for legal obligations, security or exceptional technical restoration.
8. Security
Measures implemented include in particular:
- encryption in transit via TLS;
- server-side encryption at rest by the online backup provider;
- encrypted local database when the platform allows it;
- access control and least privilege principle;
- technical logging and monitoring limited to security and operational needs;
- provider technical backups when enabled.
9. Data subject rights
The user has, depending on applicable law, rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent.
To exercise these rights:
- Contact: privacy@pumpdiary.com
- Postal address: P.O. Box 1073, 1227 Carouge, Switzerland
- Supporting information may be requested to verify identity and account ownership.
9.1 Account deletion directly in the application
A deletion mechanism is available in the application: Profile > Online backup card > Delete my account.
Depending on the choice displayed in the application, the user may delete only synchronized online backup data while keeping their local data, or delete the online backup account and reset the local data on the device.
9.2 Complaint
The user may lodge a complaint with the competent authority, including the FDPIC in Switzerland or the CNIL in France where applicable.
10. Data concerning minors
The application is intended for adults or people aged at least 16 according to applicable rules. Infant-related data is entered by the parent or legal representative. It is not used for profiling, marketing, medical recommendation or nutritional monitoring.
11. Cookies, trackers, advertising and AI
As of this version, the mobile application does not use advertising cookies, marketing tracking SDKs, identifying third-party analytics, advertising or artificial intelligence services.
12. Notifications
Reminders are configured by the user and scheduled locally on their device. They can be disabled in the device or application settings. PumpDiary does not generate any reminder based on medical analysis or recommendation.
13. Non-medical nature
PumpDiary is a personal journaling and planning tool. The application is not a medical device, does not perform any diagnosis or therapeutic recommendation and does not replace medical advice.
14. Changes to the policy
This policy may be updated. The version in force is the version published in the application on the date of consultation. In the event of a substantial change, the user is informed by any appropriate means.
15. Contact
- Privacy contact: privacy@pumpdiary.com
- Legal contact: legal@pumpdiary.com
- Support contact: support@pumpdiary.com
- Address: P.O. Box 1073, 1227 Carouge, Switzerland.