Privacy and Data Protection Notice

What this notice covers

This Privacy and Data Protection Notice applies to the eMRI / Emotional MRI website, early-access and contact forms, mobile application, eMRI accounts, in-app analyses, notifications, support services, and eMRI privacy or account-deletion pages.

eMRI is a digital wellbeing service that evaluates short emotional check-ins alongside body, health, and activity signals from wearable or health-platform sources when the user permits such access. eMRI is not a medical device and does not provide medical diagnosis, treatment, monitoring, emergency services, or professional psychological counselling.

Short summary

eMRI is intended only for people aged 18 or older.
On the website, early-access signup data, contact messages, technical security data, and optional usage data may be processed.
In the mobile app, account, emotional check-in, user note, health and activity, context, device, security, and optional usage data may be processed.
Health data is processed only with your explicit permission and only for the data types you select.
Connecting health data and using AI-supported analysis are optional.
We do not sell personal or health data and do not use health data for targeted advertising.
You can change permissions, request a copy of your data, and request deletion of your account.

Scope and age requirement

The Service is designed only for people aged 18 or older. We do not intend to knowingly collect data relating to children. If you believe that data relating to a person under 18 has been processed, please contact hello@emotionalmri.com.

Website, early-access, and contact data

Early-access form: your email address, page language, submitting page, and technical user-agent information.
Contact form: your name, email address, message, page language, submitting page, and limited technical records to prevent misuse.
Email delivery: information needed to send early-access confirmation emails or contact-form notifications.
Technical logs: limited technical data such as IP address, timestamp, request information, and similar records for security, debugging, service continuity, and misuse prevention.

Data we may process in the mobile app

Account and profile data: name, surname, email address, account identifier, sign-in method, verification information, session records, language, country, and user preferences.
Emotional check-ins and self-reports: emotion, intensity, stress, energy, body tension, selected context, activity or social situation, evening summary, weekly reflection, and optional notes.
Health, body-signal, and activity data: only to the extent you expressly permit, heart rate, resting heart rate, heart-rate variability, sleep, steps, movement, exercise, active energy, and other permitted health data clearly presented in the app.
Time and context data: time of a check-in or activity, time of day, day of week, context selected by the user, and limited contextual indicators where necessary for a feature.
Technical, security, and support data: app version, device model, operating system, language, session, network, error, crash, security records, and support communications.
Optional analytics data: if you separately consent, app-usage events, feature interactions, and performance information.

Precise location data

Precise location data is processed only if separately explained in the application and expressly permitted. If no such feature is enabled, eMRI does not collect precise location data.

Why we process data and our legal bases

Create an account, provide secure sign-in, and deliver the core Service: account, profile, and session data; performance of a contract under GDPR Article 6(1)(b).
Provide check-ins, history, summaries, and reports: self-reports, context, and account data; performance of a contract under GDPR Article 6(1)(b).
Receive health and activity data and create personal pattern indicators: health data and relevant context; explicit consent under GDPR Articles 6(1)(a) and 9(2)(a).
Generate optional AI-supported insights: limited and, where possible, pseudonymised summaries; consent and, where health data is involved, explicit consent.
Manage early-access signup and contact requests: form data and technical records; pre-contractual steps, consent, or legitimate interests depending on the request.
Send reminders and notifications: notification token and preferences; consent or delivery of the requested feature.
Secure the Service, correct errors, and prevent misuse: technical, error, and security records; legitimate interests under GDPR Article 6(1)(f).
Conduct optional product analytics: usage and performance data; consent.
Comply with law and manage legal claims: relevant account, transaction, and communication records; legal obligation or legitimate interests.

Health platforms

Connecting Apple Health or Android Health Connect is optional. eMRI uses only the data types selected by the user in the device permission interface and within the permitted scope.

Apple, Google, and device manufacturers may have their own rules for processing data within their services. This Notice does not cover independent processing carried out by those third parties in their own applications or accounts.

Data obtained through Apple Health or Health Connect is not sold or used for advertising, advertising profiles, data brokerage, or disclosure to third parties for those purposes.

AI-supported analysis

AI-supported analysis is used only if you separately enable it in the application. When enabled, eMRI may create a limited summary from relevant emotional check-ins, context, and permitted body signals and send that summary to a contracted AI service provider to generate a personal insight.

The summary is designed not to contain your name, email address, or direct account identifier. Pseudonymisation, however, does not necessarily make data anonymous. Information entered into free-text notes may contain personal or sensitive details.

AI outputs are probabilistic and may be inaccurate or incomplete. They are not medical assessment, diagnosis, treatment, crisis support, or professional psychological advice. eMRI does not make decisions producing legal or similarly significant effects concerning users solely on the basis of AI output.

Notifications and analytics

Reminders and notifications are optional. You can change notification permission in device settings and manage notification types in the application.

Where optional analytics or error-monitoring tools are used, the provider, data types, and purpose are listed below. Health data is not included in advertising or analytics profiles.

When you visit our website (emotionalmri.com), with your explicit consent, we use a cookie that keeps an anonymous visitor identifier in your browser. With this cookie we collect information such as which pages you viewed, where you arrived from (e.g. a search engine or social media), your approximate country (your IP address itself is never stored), and your browser/device type. This data is never matched to your identity (name, email) and is used solely to understand how the site is used. If you decline consent, no tracking takes place.

Service providers and recipients

Supabase: authentication, database, website forms, account data, and application data storage. Current Supabase project region: eu-west-1 / West EU (Ireland).
Vercel: hosting, deployment, security, and technical logs for the website and admin panel.
Resend: transactional email delivery, such as early-access confirmation emails and contact-form notifications.
Cloudflare: domain DNS management and email-routing infrastructure services.
OpenAI Ireland Limited (Dublin, Ireland) or another AI provider: only if AI-supported analysis is enabled, generation of personal insights from limited and, where possible, pseudonymised analysis summaries. Data sent through the API is not used for model training; it is retained for up to 30 days for abuse-monitoring purposes and then deleted. Where a transfer outside the EEA is required, the European Commission's Standard Contractual Clauses or a valid adequacy decision are used.
Apple, Google, and device manufacturers: Apple Health, Android Health Connect, app stores, device permissions, and operating-system-level independent services.
Public authorities, legal advisers, or transaction parties: where required by law, a valid official request, protection of rights, or a merger, financing, restructuring, or asset transfer.

International data transfers

eMRI is operated from Germany. Some service providers may be located outside the European Economic Area or may access data from those locations. Where this occurs, we rely, as applicable, on an adequacy decision of the European Commission, the EU-US Data Privacy Framework, the European Commission's Standard Contractual Clauses, or another valid transfer mechanism and assess necessary supplementary protections.

You may request information about the applicable transfer safeguards, or a copy where available, by contacting hello@emotionalmri.com.

Retention and deletion

Account and profile data: while the account remains active; deleted or irreversibly anonymised when account deletion is completed, except for records legally required to be retained.
Check-ins, notes, and permitted health data: until the user deletes the relevant data or account, or for the maximum period separately defined in the production system.
Early-access records: while early-access, product-update, and beta-invitation purposes remain active or until you request deletion.
Contact messages: for resolution of the request and the required legal period.
AI requests and outputs: for the period verified against the production provider settings and application configuration.
Security, error, and server logs: for a short period necessary for security and troubleshooting; the exact period must match the production system.
Backups: overwritten or deleted within the ordinary backup cycle after deletion from production.

Account deletion

You can initiate account deletion inside the application or request deletion by contacting hello@emotionalmri.com. After deletion, the account and associated data are removed except for limited records legally required to be retained and copies pending deletion in the ordinary backup cycle.

Uninstalling the application does not automatically delete your account or data held on our servers.

Security

We use technical and organisational safeguards appropriate to the risks, such as data minimisation, encryption in transit, access controls, restricted privileges, logging, secure authentication, and service-provider assessments. No system can guarantee absolute security.

If you believe there is a security issue involving your personal data, contact hello@emotionalmri.com.

Your rights

Access your personal data and receive a copy.
Correct incomplete or inaccurate data.
Request deletion.
Request restriction of processing.
Receive certain data in a portable format.
Object to processing based on legitimate interests.
Withdraw consent with future effect.
Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.
Lodge a complaint with a competent data-protection authority.

Requests and complaints

You can send a request to hello@emotionalmri.com. We may need to verify your identity and connection to the account before responding. Requests are normally answered within one month. If a lawful extension is necessary due to complexity or number of requests, we will inform you. These rights are subject to legal conditions and exceptions.

In Germany, you may also complain to the authority for the place where you live, work, or where the alleged infringement occurred. If the controller is established in Baden-Württemberg, the relevant authority may be Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW).

Permissions and privacy choices

Changing Apple Health or Health Connect permissions in device settings.
Disabling notifications in device or application settings.
Withdrawing AI-supported-analysis permission in the application.
Disabling optional analytics in the application.
Deleting specific data or your account in the application.
Contacting hello@emotionalmri.com for privacy requests.

Third-party links

The Service may link to third-party websites or services. Independent processing by those third parties is governed by their own privacy notices. eMRI does not control the privacy practices of independent third parties.

Changes to this Notice

We may update this Notice when the Service, technology, or legal requirements change. We will communicate material changes in the application or by another appropriate method and update the “Last updated” date above. Where consent is required for a new purpose, we will request it before beginning that processing.

Controller and contact details

eMRI is operated from Germany and is offered internationally.

Data controller: Emotional MRI.

Registered postal address: Stäudach 31, 72074 Tübingen, Germany.

Commercial register: no commercial-register entry is currently available.

The privacy and data-rights contact address is: hello@emotionalmri.com

If a separate data protection officer is appointed, their contact details will be published here. A separate data protection officer may not be appointed unless this is legally required.