Ciomia Privacy Policy

Last updated: September 5, 2026 · Version 3.0

This Privacy Policy explains how Ciomia handles information when you use the Ciomia app. Ciomia is designed to minimize data collection and to use Apple-provided platform services for supported app functionality, including availability of app data across compatible Apple devices.

This Privacy Policy should be read together with the Terms of Service. The current version is available at https://ciomia.app/privacy.

1. Who we are

Ciomia is provided by:

PE BUDNYI VOLODYMYR (individual entrepreneur / ФОП)
Registered address: 01001, Ukraine, c. Kyiv, st. Mrii, build 20, fl. 90
Email: ciomia.support@gmail.com
Website: https://ciomia.app

For privacy questions or requests, contact us at ciomia.support@gmail.com.

Where applicable data-protection law treats the provider as a controller of processing performed through the app, the provider is the controller for that processing.

2. The short version

Apple ecosystem. Ciomia uses Apple-provided platform services to support app functionality and, where available and enabled, data availability across your compatible Apple devices. These services depend on your Apple Account, device settings, and Apple services.
HealthKit access is permission-based. Ciomia reads only the Apple Health data types for which you grant access and uses them to provide the app's health and wellness features.
No separate Ciomia synchronization service. Ciomia does not operate a separate health-data synchronization service. Supported synchronization and device-to-device availability are provided through Apple platform services.
No advertising or cross-app tracking. Ciomia does not use health data for advertising, marketing, data brokerage, or cross-context behavioral advertising.
Payments are handled by Apple. We do not receive your payment-card number or full billing details.
You control permissions and your data. You can change Health permissions in Apple system settings and manage Ciomia data using the app's available controls and applicable Apple system settings.

3. Information Ciomia handles

3.1 Apple Health / HealthKit data

With your permission, Ciomia may read health and fitness data from Apple Health that is necessary for features you choose to use, such as heart rate, heart-rate variability (HRV), steps, active energy, sleep, workouts, and relevant profile characteristics such as biological sex and date of birth.

The exact HealthKit data types requested by a particular app version are disclosed in the app's permission flow and must match the app's App Store privacy disclosures.

Ciomia uses HealthKit data only to provide health and wellness functionality to you. Ciomia does not use HealthKit data for advertising, marketing, or data-broker purposes and does not disclose HealthKit data to third parties except where you expressly initiate or authorize a sharing feature that is permitted by applicable law and Apple's rules.

Ciomia does not write health data to HealthKit unless a future app version clearly introduces such a feature and this Policy, the app's permission text, and App Store disclosures are updated before that feature is released.

3.2 Information you enter

Depending on the features you use, you may enter information such as laboratory results, blood-pressure readings, procedures, clinician or doctor contact details, menstrual-cycle information, notes, and attachments.

This information is handled by the app using storage and security capabilities provided by Apple. Where supported and enabled, Apple platform services may make app data available across compatible devices associated with your Apple Account. Sensitive fields are protected using platform security controls and, where implemented by the app, application-level authenticated encryption.

3.3 Derived scores and insights

Ciomia may calculate wellness scores, trends, summaries, or other derived information from data available on your device. These calculations are performed for the purpose of providing the app's functionality to you. Derived health or wellness information is treated as sensitive information and is not used for advertising or marketing.

3.4 Subscription information

Purchases and auto-renewing subscriptions are processed by Apple through the App Store and StoreKit. The app may receive entitlement information needed to determine whether premium features are available. We do not receive your payment-card number.

Apple may process transaction and account information under Apple's own terms and privacy policy.

3.5 App settings

Preferences such as units, appearance, feature settings, and onboarding state may be stored by the app and, where supported, made available across your compatible Apple devices through Apple platform services.

4. Apple Intelligence / Foundation Models

If Ciomia offers an Apple Intelligence feature, the app will identify the feature and allow you to choose whether to use it where a choice is required.

When Ciomia uses Apple's on-device SystemLanguageModel, prompts and generation are processed on the device. Ciomia will not intentionally send your health information to a cloud language model unless a future version clearly introduces that functionality, obtains any required permission, and updates this Policy and the app's disclosures before release.

Because Apple can change the capabilities and processing modes available through its operating systems and Foundation Models framework, Ciomia's implementation will be configured so that any health-data feature described as "on-device" uses an on-device model rather than a cloud model.

AI-generated text is informational only. It is not a diagnosis, treatment recommendation, or medical decision.

5. Third-party services

Ciomia relies on Apple platform services necessary to distribute and operate the app, including:

Apple Health / HealthKit for permission-based access to health and fitness information;
Apple ecosystem services for supported app storage, synchronization, backup, restoration, security, and data availability across compatible devices, depending on your Apple Account and device settings;
App Store / StoreKit for purchases, subscriptions, entitlement verification, and related App Store functionality;
Apple Intelligence / Foundation Models, if you choose or use an applicable feature and the feature is available on your device.

Ciomia does not use third-party advertising SDKs or third-party analytics SDKs in the version covered by this Policy.

If a future version adds a third-party service that receives personal data, this Policy and the relevant App Store privacy disclosures will be updated before that service is enabled for users.

Apple's own privacy practices are governed by Apple's policies: https://www.apple.com/legal/privacy/.

6. Purposes and legal bases

Where the GDPR, UK GDPR, or similar law applies, personal data is processed only as necessary for the purposes described in this Policy.

Depending on the feature and jurisdiction, the legal basis may include:

your consent, including where explicit consent is required for processing health data;
performance of a contract, where processing is necessary to provide a feature or subscription you requested;
compliance with legal obligations, where applicable; and
legitimate interests, only where permitted and where those interests are not overridden by your rights and interests.

HealthKit system authorization is an Apple platform permission. Where applicable law separately requires consent or explicit consent, Ciomia will obtain it in a legally appropriate manner rather than treating the operating-system permission alone as a substitute for every legal requirement.

Ciomia does not use your health information for solely automated decisions that produce legal or similarly significant effects.

7. Data sharing

We do not sell or rent your personal health information.

We do not share personal information for cross-context behavioral advertising and do not use health information for targeted advertising.

Information may be disclosed only where you intentionally use a feature to export or share information, where disclosure is required by applicable law, or where a service provider is introduced in a future version and the disclosure is permitted by law, appropriately protected, and disclosed in this Policy before use.

8. Retention and deletion

Ciomia does not operate a separate server-side health-data repository for the purpose of providing its synchronization functionality.

Information handled by the app remains subject to your actions, the app's available deletion controls, and applicable Apple platform and account settings. Where Apple platform services provide synchronization, backup, restoration, or cross-device availability, their operation and retention are also subject to your Apple Account settings and Apple's applicable terms and policies. Ciomia does not control Apple's retention of Apple Account or App Store transaction records.

Where we receive a privacy request or support communication by email, we may retain the correspondence as reasonably necessary to respond, maintain records of the request, prevent abuse, or comply with law.

9. Security

Ciomia uses Apple platform security features and reasonable technical measures appropriate to the sensitivity of the information handled by the app. Where application-level encryption is implemented, cryptographic keys are protected using Apple Keychain or equivalent platform security.

No storage or transmission method is perfectly secure. You can help protect your information by using a device passcode or biometrics, keeping your operating system up to date, and protecting your Apple ID.

10. Your privacy rights

Depending on your location, you may have rights concerning personal data, including rights of access, correction, deletion, portability, restriction, objection, and withdrawal of consent.

For data managed through the app and Apple platform services, you can use the app's controls and applicable Apple system settings to manage your information and Health permissions. Our ability to act directly on data managed within your Apple ecosystem may be limited by the way those Apple services are designed and controlled.

For personal data that we actually possess, such as a support email you sent to us, you may contact ciomia.support@gmail.com to exercise applicable rights. We may need information reasonably necessary to verify and process the request.

If the GDPR or UK GDPR applies, you may also have the right to lodge a complaint with the competent data-protection supervisory authority.

California

Ciomia does not sell or rent personal information and does not share personal information for cross-context behavioral advertising. If applicable law gives you privacy rights regarding personal information that we possess, you may contact ciomia.support@gmail.com to exercise those rights.

11. International use

Ciomia is offered through Apple's App Store and may be used in multiple countries. The provider is established in Ukraine.

Ciomia uses Apple-provided platform services for supported app functionality, including data availability across compatible devices. The operation of Apple Account, device, synchronization, backup, restoration, and other Apple platform services is governed by Apple's applicable terms and privacy policies. Ciomia does not operate a separate health-data synchronization service for these ecosystem functions.

Where applicable law requires safeguards, notices, representatives, or other measures for cross-border processing that we actually perform, we will implement those requirements before the relevant processing occurs.

12. Children's privacy

Ciomia is intended for users aged 13 and older. If the laws applicable to you require a higher minimum age or parental or guardian authorization, those requirements also apply.

13. Changes to this Policy

We may update this Policy when the app, law, or our data practices change. We will update the "Last updated" date and publish the current version at https://ciomia.app/privacy.

If a change materially affects how personal data is processed, we will provide any notice or obtain any consent required by applicable law before the new processing begins.

14. Contact

Provider: PE BUDNYI VOLODYMYR (individual entrepreneur / ФОП)
Registered address: 01001, Ukraine, c. Kyiv, st. Mrii, build 20, fl. 90
Email: ciomia.support@gmail.com
Website: https://ciomia.app