Changes from 1.0
Your weight never leaves your phone. Neither does anything else you type in.
Lowmark has no login, no account, and no server of ours behind it. The only time the app talks to a network at all is when you buy something — that conversation is with Google Play Billing, and it's between your phone and Google. We are not part of it, and nothing you've entered into Lowmark is either. Everything below is the long version of that, and an honest account of what would have to change before any of it stops being true.
We don't sell data. We have never sold data. There is no version of this app that is funded by selling data — it's funded by people paying for it.
Lowmark is operated by Manduc S-V. Emanuel-Sorin Persoană Fizică Autorizată (PFA), trading as Actinfinity, a sole trader registered in Romania under fiscal registration number CUI 43177210, with its registered address at Str. Ludoș nr. 5, bl. 52, et. P, 550151 Sibiu, jud. Sibiu, Romania.
For the purposes of the EU General Data Protection Regulation (GDPR), Manduc S-V. Emanuel-Sorin PFA is the data controller.
You can reach us about anything in this policy at privacy@actinfinity.app.
The following is stored in a database on your device and is not transmitted to us, to any cloud service of ours, or to any third party:
We do not have a copy of any of it. If you uninstall the app without exporting or backing up your data, it is gone, and we cannot restore it for you. This is a deliberate trade-off: we chose the design where losing your phone loses your data over the design where we hold your body's history on our servers.
Backup and restore. The app can export your data to a file, and import it back. That file is created on your device and goes wherever you send it — your own storage, your own cloud drive, your own computer. It does not pass through us. Once you place that file somewhere, it is governed by that service's privacy policy, not ours.
To be exact, because vagueness here would be dishonest: this version of the app contains no analytics, no crash reporting, no advertising, no tracking of any kind, and no way for you to give us your email address. There is no account to create and no server of ours for the app to talk to. The one exception is purchases, which Google Play handles for us — see §4 for exactly what that means and what little we see because of it.
We have no record that you installed Lowmark, no record that you opened it, and no identifier of any kind for your device or your installation.
We intend to add three things in a future version, because we cannot improve a product we know nothing about:
When we do that, the planned retention is 24 months for analytics events, 90 days for crash reports, and, for an email address, until you unsubscribe or ask us to delete it.
None of it starts silently. Before any version of Lowmark sends anything off your device beyond what §4 already describes, we will publish an updated version of this policy, update the Data safety section on our Google Play listing, and tell you inside the app — not by quietly changing a date at the top of a page nobody reads.
Lowmark has a free tier that stays free, and one paid unlock — Lowmark Full — sold two ways: an auto-renewing yearly subscription with a 14-day free trial, and a one-time lifetime purchase. Both are products you buy through Google Play, not through us.
Every part of that transaction — taking your payment, renewing the subscription, letting you cancel it, and handling refunds — is done by Google Play, under Google Play Billing, and governed by Google's own privacy policy and terms. We never see your card number, your billing address, or your bank details. Google does not give them to us, and we do not want them.
You manage, cancel, or check on your subscription directly with Google, at play.google.com/store/account/subscriptions — not inside Lowmark, and not by writing to us.
What we can see: Google Play Console, the dashboard Google gives every developer, shows us aggregate figures about orders — such as that a purchase happened, which product, and a country — the same kind of summary any app's developer sees for their own sales. Google shares with us only what Google Play Console shows developers; we never see your name, your email, or any payment detail, whoever you are.
Whether you own Lowmark Full, and how (yearly, trial, or lifetime), is written to your phone so the app can unlock accordingly — that's the entry in §2. It is not sent to us. If you reinstall the app or move to a new phone, Google Play itself restores your entitlement when you sign in with the Google account that bought it; we play no part in that either.
Android asks you, or asks the system on your behalf, for each of these. Here is what each one is for, in one sentence:
To be explicit about what we do not ask for: no location, no advertising ID, no contacts, and no access to any health-platform integration (Health Connect, Google Fit, or similar). The app does not request any of those permissions, and has no code path that would use them.
Nobody, beyond what §4 describes for a purchase. No data about your weight, your measurements, your targets, or anything else you enter leaves your device.
If that changes as described in §3.1, this section will name every service provider we use, what they receive, and why — and each will be bound by contract to process data only on our instructions. We will never sell your data, and we will never transfer it as part of a marketing arrangement. If Lowmark is ever acquired, this policy travels with the data, and you will be told before anything changes.
We may disclose data if we are legally required to — a court order, a lawful request from an authority with jurisdiction over us. Today that would produce nothing beyond the aggregate order data described in §4, because we hold nothing else. We will tell you if we are ever permitted to.
On your phone, wherever your phone is. Purchases pass through Google Play, which processes them under its own policy; there is no other transfer to describe.
Under the GDPR, you have the right to access the data we hold about you, rectify anything inaccurate, erase it, restrict or object to our processing, receive it in a machine-readable format (portability), withdraw consent where consent is the basis, and complain to your national data protection authority.
In practice, today, the honest answer to "what do you hold about me" is nothing beyond the aggregate order summaries described in §4, and those hold nothing that identifies you personally. We will still answer you, in writing, and confirm it.
To exercise any of these rights: privacy@actinfinity.app, or see https://actinfinity.app/lowmark/delete. We answer within 30 days. We do not charge for this, and we do not make you argue for it.
For the data on your phone, you don't need us at all: uninstalling the app removes its database with it. We have no copy to delete on our side.
Lowmark is not intended for anyone under 18. We do not knowingly collect data from anyone under that age. If you believe a child is using the app, write to privacy@actinfinity.app.
Your data is held in the app's own storage on your device, protected by your device's operating system and whatever lock you use on your phone. Anything the app ever transmits — a purchase, handled by Google Play Billing — is encrypted in transit using TLS.
We cannot promise that no system will ever be breached — nobody honest can. We can promise that a breach of our systems would not expose anybody's weight, because it isn't there. We keep as little as possible, which is the only security measure that never fails.
Lowmark is not a medical device. It does not diagnose, treat, cure, or prevent any medical condition, and nothing it shows you is medical advice. The data you enter is not a medical record and is not covered by medical confidentiality frameworks, because we are not a healthcare provider. Consult a healthcare professional for medical advice.
If we change this policy in a way that affects what we collect or what we do with it, we will tell you in the app before the change takes effect. The version number and date at the top of this page tell you which text is current.
Manduc S-V. Emanuel-Sorin Persoană Fizică Autorizată (PFA), trading as Actinfinity
Str. Ludoș nr. 5, bl. 52, et. P, 550151 Sibiu, jud. Sibiu, Romania
CUI 43177210
privacy@actinfinity.app
Supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, Romania — www.dataprotection.ro.