Privacy Policy

What Tawen Does and Doesn't Do With Your Data — In One Page

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The headline: Your health data never leaves your device. The Company does not receive, store, transmit, sell, or share it. Website visits also involve the analytics processing described in Section 3.5; cookie-free does not mean that no personal data is processed.

Washington State residents: A separate Consumer Health Data Privacy Policy applies specifically to consumer health data covered by the Washington My Health My Data Act. See https://tawen.app/health-privacy for that policy.

1. Who We Are; Scope

Icemint LLC (the "Company," "we," "us," or "our") is a limited liability company organized under the laws of the State of Wyoming, United States, with its principal place of business at 30 N Gould St, Ste R, Sheridan, WY 82801. The Company operates the Tawen Android application (the "App") and the website at tawen.app (the "Website" and, together with the App, the "Services").

For privacy questions or to exercise the rights described in this Policy, contact us at [email protected].

Geographic availability. Tawen is distributed through Google Play in selected countries and regions, including the United States and Canada. Availability depends on your Google Play country and the current app and purchase settings. The Website is in English; Google Play shows the applicable local price and purchase availability. Our current marketing focus is the United States and Canada; app distribution is not limited to those two countries.

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2. Our Privacy-by-Architecture Approach

Tawen is designed so that the wellness data used to compute your readiness score never leaves your device. This is not a marketing claim — it is enforced by the App's architecture:

• Health Connect access is read-only. The App reads Health Connect data directly into device memory and never copies it off your device.
• Scoring runs on your device. Pillar calculations and the readiness score are computed locally on your device.
• AI narratives are generated on your device. When available, Google's on-device Gemini Nano (via the ML Kit GenAI Prompt API) produces your daily insight narrative locally on your device; where it is unavailable, the App falls back to a rule-based explanation. Weekly reports are also produced on your device; their explanations may be rule-based or use on-device AI when supported and available. The prompts and the generated text never reach the Company's servers or Google's cloud.
• Local storage only. The App's local database stores only:
  • the computed readiness score (integer 0–100), normalized pillar sub-scores (decimals 0.0–1.0), and AI narrative text;
  • the hourly input snapshots of Health Connect metrics from which each score is computed (derived working data, never raw Health Connect records);
  • weekly reports (Pro);
  • optional day tags you add on the Dashboard ("Tag today"), along with their timestamps;
  • internal metadata such as algorithm version and narrative template version that lets the App reason about its own historical rows correctly. The database never stores raw Health Connect records. None of the above is transmitted off your device.
• On-device storage and deletion. Tawen stores its derived data only in a local database on your device, and nothing is uploaded. How much history you can view is limited to the last 7 days (free) or 90 days (Pro) — a display limit, not a deletion schedule. Separately, older on-device data is automatically cleaned up over time by an on-device process, and you can delete all on-device data at any time via Settings → Privacy → Delete all data. The cleanup runs entirely on your device; the Company is not involved and never sees the data.
• No write-back to Health Connect. The App never writes data to Health Connect.

Because of this architecture, the Company does not receive, collect, store, process, sell, or share your health-related data. References below to "we collect" or "we process" apply only to the limited categories of non-health telemetry described in Section 3.

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3. The Non-Health Data We Do Receive

3.1 Firebase Crashlytics (crash diagnostics)

When the App encounters an unexpected failure, we receive an automatic crash report containing:

• a Firebase Installation ID (a pseudonymous device identifier);
• a stack trace and the code path that caused the failure;
• device model, Android version, CPU architecture;
• App version and build number;
• timestamp and foreground/background state.

No health data is included. The App's architecture prevents any score, pillar value, or Health Connect record from being attached to a crash report.

Default: Crash diagnostics are enabled by default when you accept the Terms of Service at first launch. You can turn them off at any time.

Retention: Google retains crash reports for 90 days.

Purpose: To diagnose and fix bugs that affect the App's reliability.

Opt-out: Settings → Privacy → Diagnostic data.

3.2 Firebase Analytics (anonymous usage events)

If you turn on usage analytics, we use Firebase Analytics to understand how users interact with the App in aggregate. Usage analytics are OFF by default; no usage events are collected unless you explicitly turn them on. Our Analytics implementation is constrained by code to allow only string event names and a whitelist of string/boolean parameters. Examples of events: onboarding_complete, score_viewed, pillar_drill_down, paywall_view, purchase.

• The Android Advertising ID (AAID) is disabled (google_analytics_adid_collection_enabled=false in the App's manifest).
• We track no numeric health values, no scores, no advertising identifiers, and no precise location.
• Country is derived from IP address at the request level by Google and is not stored against your installation.
• Analytics data retention is configured to 2 months.

Purpose: To understand which features users find and use, to improve product decisions.

Opt-in / management: Settings → Privacy → Usage analytics. This is independent of Crashlytics.

3.3 Firebase App Check / Play Integrity (anti-abuse)

We use Firebase App Check with the Play Integrity backend to confirm that requests come from a genuine, unmodified Tawen installation on a Play-certified Android device. This involves an attestation token derived from device-integrity signals; the underlying signals are not shared with the Company. App Check tokens are retained by Google for replay protection in accordance with Google's published Firebase retention policy.

Purpose: To prevent abuse of our backend (such as token forgery or automated abuse).

3.4 Google Play Billing

When you purchase Tawen Pro, payment is processed entirely by Google LLC through Google Play. The Company receives only:

• an anonymized order identifier; and
• a purchase token to verify your entitlement.

The Company does not receive or store your name, card number, billing address, or any payment information.

Purpose: To grant and verify your Tawen Pro license.

3.5 Website (tawen.app)

The Website uses Cloudflare for delivery and security and Fathom Analytics, provided by Conva Ventures Inc., to understand website traffic and improve its content. The homepage and legal pages load Fathom's script from cdn.usefathom.com. Website analytics are separate from the App's Firebase settings; those settings do not control website measurement.

What is processed. Pageview requests include the site identifier, page, referring site and campaign information when present. Fathom receives the request's IP address and browser User-Agent and derives browser/device and approximate-location information. It uses site-specific visitor signatures that change daily, without analytics cookies. Its ordinary analytics records do not store raw IP/User-Agent fields; separate security/bot processing can retain IP information. Page duration may also be measured. See Fathom's data journey.

Controls and retention. Fathom loads automatically on these pages. Our current embed does not enable Fathom's Do-Not-Track option or implement a Global Privacy Control handler. Browser content blockers can prevent the analytics script from loading. Daily signature rotation does not delete stored analytics records. Provider handling is described in Fathom's privacy policy and data processing agreement. Contact [email protected] about website data or a rights request.

Cloudflare may set the short-lived __cf_bm bot-management cookie. See our Cookie Policy for website cookies and analytics. Do not place personal or health information in website URLs or campaign parameters.

The Website’s email contact links open your email client with our address pre-populated. If you send us an email, we receive your email address and message content; we use this solely to respond to your enquiry. You can request deletion at any time at [email protected].

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4. Automated Processing and AI Disclosure

Tawen computes a daily readiness score from data on your device. This is automated processing, but the score does not produce legal effects or similarly significant effects on you. It is a wellness estimate that you can view, contextualize, and ignore at any time. You can always view the pillar breakdown to understand how the score was derived.

AI-generated content disclosure. The daily insight narrative — the explanation behind your score — may use AI or a rule-based explanation. It can update on your device as your readiness score changes. When supported and available, AI explanations are produced by Google's on-device Gemini Nano via the ML Kit GenAI Prompt API, running locally on your device; where on-device AI is unavailable, the App produces a rule-based explanation instead. Your prompts and the resulting text never reach the Company's servers or Google's cloud. AI-generated content is clearly labelled as such in the App. AI outputs may contain errors and do not constitute medical advice. See Section 2 of the Terms of Service.

Weekly reports (Pro) are a weekly synthesis of your week, drawn from the same on-device data. Their explanations may be rule-based or use on-device AI when supported and available. The App identifies the explanation source; AI availability is not guaranteed by a Pro purchase.

For California users: The Company does not use Tawen's readiness score, narratives, weekly reports, or any other Tawen output to make any decision about you (including any decision relating to employment, housing, credit, insurance, healthcare, education, or essential goods or services). All scores and outputs are informational only; you alone decide whether and how to act on them.

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5. Data Retention

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6. Your Privacy Rights — By Region

You may exercise the rights below by contacting [email protected]. We will acknowledge your request within 10 business days and respond substantively within 45 days (extendable once by an additional 45 days for complex requests, with notice to you). We will not discriminate against you for exercising your rights. You may also designate an authorized agent to submit a request on your behalf — we will verify the agent's authority and may require verification of your identity.

Because most of the data described in this Policy is on your device, not on our servers, the most powerful rights you have are device-side: revoke Health Connect permissions in Android Settings, and tap Settings → Privacy → Delete all data in the Tawen App.

6.1 All users

Regardless of where you live, you may:

• ask what data we hold about you and how we use it;
• ask us to correct data we hold about you;
• ask us to delete data we hold about you;
• manage diagnostic and usage data in Settings → Privacy: turn off crash diagnostics (on by default), and turn on usage analytics (off by default);
• stop using the Services and uninstall the App at any time.

6.2 California residents (CCPA, as amended by the CPRA)

If you are a California resident, you have the following rights:

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Categories of personal information we collect (CCPA Notice at Collection):

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We do not collect on our servers: precise geolocation, biometric identifiers, government IDs, social security numbers, financial account numbers, account credentials, contents of mail/email/SMS, race, ethnicity, religious beliefs, union membership, genetic data, sexual orientation, or any data that would constitute "Sensitive Personal Information" as defined in Cal. Civ. Code § 1798.140(ae). The readiness score and pillar values derived from Health Connect data — which would qualify as Sensitive Personal Information if collected by us — are processed and stored entirely on your device and are never transmitted to or received by the Company. See Section 2.

Retention: See Section 5.

Authorized agent. A California resident may use an authorized agent. The agent must provide written authorization signed by you and may be required to verify their own identity.

6.3 Washington residents (My Health My Data Act)

Washington's My Health My Data Act, RCW 19.373 et seq., regulates "consumer health data."

In summary, applicable to all Washington residents: the Company does not receive, transmit to its servers, or store on its infrastructure any consumer health data as defined under RCW 19.373.010. All health-derived values — your readiness score, pillar sub-scores, and AI narratives — are computed and stored entirely on your device, under your sole control, and can be deleted by you at any time via Settings → Privacy → Delete all data. None is transmitted to or stored by the Company. You may withdraw consent at any time by revoking Health Connect permissions in Android Settings.

For the full Washington-specific disclosure, including the affirmative non-sale and non-geofencing statements required by RCW 19.373.040 and .060, see the Consumer Health Data Privacy Policy at https://tawen.app/health-privacy (also linked directly from the tawen.app homepage).

6.4 Nevada residents (Nev. Rev. Stat. Chapter 603A; SB 370)

Nevada law regulates the collection, sharing, and sale of "consumer health data." For the same architectural reason described in Section 6.3 — your on-device readiness score and pillar values are never received by the Company's servers — the Company does not receive, transmit to its servers, or store on its infrastructure any consumer health data within the meaning of Nevada law. You may exercise the rights listed in Section 6.1 with respect to any non-health data the Company may hold.

Nevada law also gives Nevada residents the right to opt out of the sale of certain "covered information" as defined in NRS 603A.340. We do not sell your covered information. To submit a verified request to that effect, contact [email protected].

6.5 Connecticut residents (CTDPA, as amended)

Connecticut residents have the rights to access, correct, delete, port, and opt out of the sale/targeted advertising of personal data, plus heightened protections for "consumer health data." For the same architectural reason described in Section 6.3, the Company does not receive, transmit to its servers, or store on its infrastructure any consumer health data as defined under Conn. Gen. Stat. § 42-515(8). You may exercise the rights in Section 6.1 against any non-health personal data the Company may hold about you.

Appeal. If we deny your privacy request, you may appeal by replying to our response within 60 days. If your appeal is denied, you may submit a complaint to the Connecticut Attorney General via portal.ct.gov/AG.

6.6 Other U.S. state privacy laws

Residents of any U.S. state with a comprehensive consumer privacy or consumer health data law — including without limitation Colorado, Virginia, Utah, Texas, Oregon, Montana, Tennessee, Indiana, Iowa, Delaware, New Hampshire, New Jersey, Minnesota, Maryland, Rhode Island, and Kentucky — have rights of access, correction, deletion, portability, and opt-out of sale and targeted advertising. To the extent your state's law confers additional or different rights (including without limitation Maryland's Online Data Privacy Act effective October 1, 2025, which prohibits the sale of sensitive personal data and imposes heightened minimization duties), the Company will honor those rights as required by applicable law. We extend the substantive rights described in this Section 6 to you regardless of which U.S. state's law applies. To exercise them, contact [email protected].

We do not engage in targeted advertising. We do not sell personal data. We do not engage in profiling that produces legal or similarly significant effects.

6.7 Canadian residents (PIPEDA and provincial law)

Canadian residents are protected by the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and, in Quebec, the Act Respecting the Protection of Personal Information in the Private Sector (Quebec Privacy Act, as amended by Law 25), and in Alberta and British Columbia by their respective Personal Information Protection Acts.

Canadian residents may:

• request access to and a copy of any personal information the Company holds about them;
• request correction of inaccurate personal information;
• request deletion of personal information (subject to legal-hold exceptions);
• withdraw consent for processing of personal information (note that this may limit your use of the Services);
• ask questions about the Company's privacy practices;
• file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca, or with the relevant provincial regulator (Commission d'accès à l'information du Québec, Office of the Information and Privacy Commissioner of Alberta, or Office of the Information and Privacy Commissioner for British Columbia).

To exercise these rights, contact [email protected]. For Canadian residents, the Company will respond to access, correction, and withdrawal-of-consent requests within 30 days of receipt, consistent with PIPEDA's general timeline (this is shorter than the 45-day response window described in the introduction to this Section 6, which applies to U.S. residents).

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7. International Data Transfers

The Company is established in the United States. The non-health telemetry described in Section 3 is processed by Google LLC and Cloudflare, Inc., also in the United States.

For Canadian users, the transfer of this telemetry to the United States is permitted under PIPEDA and Quebec Law 25 provided that the recipient provides a comparable level of protection. Google LLC and Cloudflare, Inc. each maintain technical and organizational safeguards consistent with PIPEDA and Quebec Law 25 standards through their respective data processing agreements.

The Services are not offered to users in the European Economic Area, United Kingdom, or Switzerland; the Company therefore does not engage in transfers from those jurisdictions.

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8. Security

• All on-device data is protected by Android's application sandbox and, where available, device-level encryption.
• All telemetry transmitted to Firebase is encrypted in transit using HTTPS/TLS 1.3.
• Firebase App Check verifies that telemetry is sent only from genuine Tawen App installations.
• We never store raw Health Connect records anywhere — only on-device derivatives.
• Our Analytics wrapper enforces at compile time that no numeric health value can be passed to Firebase Analytics.

Breach notification.

In the event of a personal data breach affecting the limited non-health telemetry described in Section 3:

• We will notify affected U.S. users in accordance with the breach-notification laws of their state of residence.
• We will notify affected Canadian users in accordance with PIPEDA's mandatory breach reporting requirements (without unreasonable delay; report to the Office of the Privacy Commissioner of Canada if the breach poses a real risk of significant harm).
• We will provide any breach notification required by applicable federal law.

Breach scope on your device. Because your wellness data lives on your device, a breach of the Company's servers cannot expose your wellness data. A loss of physical access to your device, however, would expose any data stored locally. Protect your device with a screen lock and keep your OS up to date.

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9. Children and Federal Children's-Privacy Overlay

Minimum age. The Services are not directed to children under the age of 13 in the United States or Canada. You must be at least 16 years old to use the Services. The App presents a neutral age statement during onboarding; we do not encourage users to misstate their age.

COPPA (Children's Online Privacy Protection Act, 15 U.S.C. §§ 6501–6506, and the FTC Rule at 16 C.F.R. Part 312, including the amendments finalized April 22, 2025 and enforceable April 22, 2026). COPPA applies to operators of online services directed to children under 13 or with actual knowledge that they are collecting personal information from a child under 13. The Services are not directed to children under 13 — they are positioned, marketed, designed, and rated for adults — and we do not knowingly collect personal information from anyone under 16. We do not collect biometric identifiers, government-issued IDs, precise geolocation, or any of the data categories added to "personal information" by the 2026 COPPA amendments. We do not engage in targeted advertising or third-party data sharing that would require separate opt-in consent under the 2026 amendments.

If we become aware that we have collected personal information from a child under 16 (or under 13 in the United States) without the legally required parental or guardian consent, we will delete it promptly. Parents and guardians with concerns may contact [email protected].

Other federal sectoral regimes. The Services do not collect or process: financial-account information or "nonpublic personal information" about consumers of a financial institution (GLBA / Reg P); education records held by a school or service provider for a school (FERPA); video-viewing records (VPPA); carrier customer proprietary network information (CPNI); DMV records (DPPA); or SMS/calls covered by the TCPA. Where any of these regimes would otherwise overlay our processing, they do not apply because the Services do not engage in the regulated activity.

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10. Third-Party Processors

The following third parties process the information described in Section 3 as our processors or service providers:

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We do not sell personal information to any third party. We do not share consumer health data with third parties for marketing, advertising, insurance, or any other purpose — there is nothing to share, because consumer health data stays on your device.

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11. Changes to This Policy

We will notify you of material changes to this Policy via the App or (if available) email at least 30 days before the changes take effect. The date of the most recent update appears at the top of this page. To request an earlier version, contact [email protected].

Version history:

• Version 1.4 — corrects the description of existing regional distribution, local pricing and conditional on-device explanations, and replaces obsolete launch-link wording. These corrections do not change the App’s collection, processing, entitlements or distribution settings.

• Version 1.3 — corrects website analytics disclosures to describe the existing Fathom integration, including request processing, provider and browser controls. Analytics configuration and App behavior are unchanged. This update corrects the description of existing website processing; it does not introduce new analytics collection.

• Version 1.2 — alignment with the v1.0 shipped build: (a) removed "mindfulness" from the read-data inventory (no longer read); (b) corrected telemetry consent defaults to match the shipped build — crash diagnostics are on by default after Terms acceptance with a Settings opt-out, and usage analytics are off by default and opt-in; (c) restated on-device retention as storage + a history view cap + user-initiated deletion, with no fixed auto-delete figure; (d) added the hourly input snapshots to the on-device storage inventory; (e) corrected the daily-narrative cadence to intra-day and limited AI/Gemini-Nano attribution to the daily insight (the weekly report is currently rule-based); (f) removed the CSV-export, daily-check-in-entry, and correlation-explorer disclosures for features not in the v1.0 build; (g) removed the HIPAA reference from the federal-sectoral-regime list.

• Version 1.1 — additive disclosures for new on-device features. (a) New Section 3.6 explaining the user-initiated CSV export feature. (b) Section 2 expanded to list every category of data stored on your device and to describe the weekly on-device retention purge worker. (c) Section 4 expanded to disclose that the on-device Gemini Nano model produces weekly reports and check-in synthesis in addition to daily narratives. (d) Section 5 retention table expanded to include check-in entries, the tag log, and weekly AI reports. (e) Section 10 expanded to disclose the on-device ML Kit GenAI library with an explicit assertion that no prompt or output is transmitted to Google. None of these changes reduces your rights or expands the data the Company receives.

• Version 1.0 — initial policy.

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12. Contact

Privacy enquiries and rights requests: [email protected]

Icemint LLC 30 N Gould St, Ste R, Sheridan, WY 82801 United States

Supervisory authorities (selected):

• Federal U.S.: Federal Trade Commission, ftc.gov
• California: California Privacy Protection Agency, cppa.ca.gov; California Attorney General, oag.ca.gov
• Washington: Washington State Attorney General, atg.wa.gov
• Other U.S. states: the attorney general of your state
• Federal Canada: Office of the Privacy Commissioner of Canada, priv.gc.ca
• Quebec: Commission d'accès à l'information du Québec, cai.gouv.qc.ca
• Alberta: Office of the Information and Privacy Commissioner of Alberta, oipc.ab.ca
• British Columbia: Office of the Information and Privacy Commissioner for British Columbia, oipc.bc.ca

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This Privacy Policy is effective September 26, 2026 (v1.4).