Midturn Privacy Policy

App: Midturn (iOS)
Developer / data controller: Nexapps Bilişim ve Yazılım Hizmetleri Limited Şirketi, Soğanlık Yeni Mah., Soğanlık D-100 Kuzey Yanyol Cad., A Blok No: 72/2, İç Kapı No: 10, Kartal, İstanbul, Türkiye
Contact: support@nexapps.co

1. The short version

Midturn is a perimenopause wellness journal that turns your daily check-ins into a weekly pattern narrative and a report you can bring to your clinician. It is built local-first:

• Your symptom history lives on your iPhone, not on our servers. Daily check-ins (symptoms, severity, sleep, cycle/spotting, HRT/supplement adherence) are stored in the app’s local database on your device, which we cannot read. Midturn never writes them to iCloud; if you have iCloud Backup turned on, your iPhone’s own encrypted backup, which Apple runs, may include them (§3.1).
• The only health data Midturn ever sends off your device is a pseudonymous summary, sent transiently to generate your weekly narrative or monthly report — and only after you explicitly agree on the in-app consent screen. For a weekly narrative it includes each day’s check-in from the week being summarized; for a monthly report, statistics without the daily detail. We never store that summary on our servers.
• The AI analysis is performed by Anthropic, our AI provider. It is named here because you have the right to know exactly who processes your data. Anthropic may not use your data to train its models under our agreement with them.
• No ads. No trackers. No sale of data. Ever. Midturn contains no advertising SDKs and does no cross-app tracking. The App Store privacy label’s “Data Used to Track You” section is empty by design.
• You can delete your account and data from inside the app, and you can revoke AI consent at any time — daily logging keeps working, and your entries are kept on your iPhone.

The rest of this policy is the long version of those five sentences.

2. Scope and definitions

This policy covers the Midturn iOS app and the nexapps platform services behind it. It does not cover Apple’s own processing (App Store purchases, iCloud Backup, iOS notifications), which Apple describes in its own privacy documentation.

• On-device data — data stored in Midturn’s local database on your iPhone (and in your iPhone’s own backup, if you use one — §3.1).
• Transient AI summary — the pseudonymous data derived from your logs that is sent to generate a narrative or report — for a weekly narrative, including each day’s check-in from the week being summarized — processed in memory, and not stored by us.
• Account data — the minimal server-side records that make the service work (a random account identifier, device basics, subscription state).

3. What data we handle, and where it lives

3.1 Data stored on your iPhone (never on our servers)

Stored in Midturn’s local, on-device database (SwiftData). Midturn never writes your health data to iCloud: it uses no CloudKit sync and no iCloud Drive, as Apple’s App Review Guideline 5.1.3(ii) requires. Like the rest of your iPhone’s app data, the database is part of your iPhone’s own encrypted backup: if you have iCloud Backup turned on, that backup — which Apple runs, not us — may include it.

• Your daily check-ins: symptom selections (from Midturn’s curated perimenopause symptom list) with 1–5 severity, sleep quality, cycle/spotting entries, and HRT/supplement adherence entries you record.
• Your onboarding symptom-history quiz answers.
• The weekly narratives generated for you (they are delivered back to your device and stored there), and a short record of each Appointment Report made for you: when it was made, the period it covers, how many entries it drew on and how complete your log was for it, whether it includes the written summary and, if the app asked you to rate it, when it asked and any answer you gave. The report’s PDF is not kept: the app makes it when you ask for it and holds it in memory, never in its storage; it writes a copy to the iPhone only when you share or save it, and deletes that copy when the share ends, or at the next launch if the app was closed first. A copy you save or send from the share sheet is yours, outside Midturn.
• Streaks, reminders, and app preferences.

Notes on control:

• Midturn’s check-in is tap-based; there is no free-text symptom field, so no free-text diary content exists to leave your device.
• You can create an encrypted local export of your data for backup or moving to a new iPhone; you control that file. There is no cross-device cloud sync in this version.
• If you share an Appointment Report with your clinician, you do that yourself through iOS share functions; we are not part of that transmission and never receive the report.
• If you delete the app without exporting, your on-device data is deleted with it. A backup of your iPhone made earlier — in iCloud Backup or on a computer — keeps its copy until that backup is replaced or deleted; those backups are yours and Apple’s, and we cannot reach them.

3.2 The transient AI summary (leaves your device only with your explicit consent)

To write your weekly pattern narrative (about once a week) and your monthly report summary, the app computes a summary of the period being analyzed on your device and sends it to our server: for the weekly narrative, that week’s check-ins day by day together with statistics; for the monthly report, statistics without the daily detail. This happens only after you have accepted the in-app health-data and AI consent screen, and you can turn it off at any time.

Your pseudonymous summary is processed by Anthropic, our AI provider. It reaches our server in a request from your account; our server removes your account identifier and sends Anthropic the summary without it.

What the summary contains: aggregated statistics and structured severity series derived from your entries for the period being analyzed — e.g. symptom frequency and severity aggregates, sleep-quality aggregates, cycle-phase markers, and adherence indicators; for the weekly narrative, also each day’s entries from that week (symptom severities, sleep quality, bleeding level, and whether HRT or supplements were taken, with days you did not log marked as not logged) — plus one-line summaries of your earlier narratives and non-identifying request metadata (app identifier, feature name, app version).

What it never contains: your name, email address, phone number, contacts, precise location, advertising identifiers, device fingerprints, photos, or free text you write (none exists — see §3.1).

The path it takes: your device → our server in Germany (EU) → Anthropic’s API, encrypted in transit (TLS) on both legs. Our server sends Midturn’s AI requests straight to Anthropic: they never pass through Cloudflare’s AI Gateway or any other AI routing service. The provider is:

• Anthropic, PBC (United States) — our AI provider. It stores requests in the United States and may process them in the United States, Europe, Asia or Australia; for safety review, product support or incident response, it may also process them in other countries where it or its affiliates operate.

What is stored, and by whom:

• nexapps stores none of it. The summary and the generated narrative are processed transiently and are not written to our databases, logs, or backups. Our systems retain only content-free usage metadata about the request (feature name, model used, token counts, latency, processing status, estimated cost) for billing, abuse prevention, and reliability.
• At the AI provider: Anthropic keeps it only under its standard commercial API terms. The AI provider deletes the summary within 30 days — unless its automated safety systems flag the request, in which case it may keep it for up to two years — and never uses it to train models. We have no separate zero-data-retention agreement with it, and, like any company, it may keep a request for longer where the law requires it to.

Provider changes: we name our AI provider here deliberately. Adding or replacing a provider is a change to this policy — we will update it and, where the change is material, ask for your consent again before your data reaches a new provider.

3.3 Account and device data (on our servers)

Midturn works without registration. On first launch the app creates a pseudonymous account:

• A random account identifier (UUID) — not derived from your name, email, phone number, or any Apple identifier. The same identifier is your customer identifier at RevenueCat (§3.4) and, if you allow usage data, your analytics identifier at PostHog (§3.5).
• Device basics: a random device identifier we assign at first launch, platform (“ios”), OS version, device model and when the app was last active — used for sessions, compatibility and abuse prevention.
• Session credentials: short-lived access tokens and rotating refresh tokens (stored server-side only as cryptographic hashes).
• Your IP address, which any internet connection reveals. Our server uses it for about a minute to limit abusive request rates and removes it from its logs; it is not stored with your account. RevenueCat and Sentry receive it when the app connects to them (§3.4, §3.6). PostHog and Anthropic never receive it.

There is no sign-in of any kind: Midturn never asks for your name, email address or phone number.

3.4 Purchases and subscription state

Payments are processed by Apple through the App Store; we never see your payment card details. To know which features you’re entitled to, we use RevenueCat (subscription management, USA). The app connects to RevenueCat directly, so RevenueCat receives your pseudonymous account identifier, your device’s IP address, the identifier Apple gives our apps on your device (identifierForVendor), your device model, iOS and app version, language settings and App Store country, and — from Apple — the product, price, currency, subscription state (trial, active, cancelled, billing issue, expired), period dates and store transaction identifiers. Our servers keep a copy of RevenueCat’s subscription events for your account and the entitlement state they add up to, and, if you allowed usage data, subscription events (for example that a trial or a paid subscription started, with the plan and, for a paid subscription, its price) are also recorded in our analytics (§3.5).

3.5 Usage analytics (content-free, EU-hosted)

We measure how the product performs using PostHog (EU Cloud, hosted in the EU). Analytics never contain your health entries — this is an engineering rule, not just a policy: apps on the nexapps platform cannot send analytics directly; events flow through our server, which stamps identity server-side and forwards a fixed, content-free event taxonomy.

Only if you allow it. Right after its welcome screen, Midturn asks whether it may share usage data, and you can change your answer at any time in Settings → Privacy → “Share usage data”. Until you answer, the app keeps these events on your iPhone and sends none of them; if you say no, it deletes them and sends none, and our servers record no usage analytics for your account — including the subscription and AI-use events they would otherwise record. If you allow it and later turn it off, nothing more is sent or recorded from then on, and we ask PostHog to delete your analytics profile and its events. We keep your answer, and when you gave it, with your account record (§3.3). Your answer to the AI consent screen (§11) is recorded either way, because it is the record of that consent, not analytics.

• Examples of events: app opened, onboarding step completed, check-in completed (the fact, never the contents), narrative generated (metadata only), paywall viewed, trial started, subscription renewed, notification opened.
• Properties attached: pseudonymous account identifier, app identifier, subscription status, days since install, app version, platform, screen names, and counts or categories about how you use a feature (for example how many items a check-in had, how many days a weekly pattern covered, the plan of a subscription event and, for a paid one, its price, and the reason you chose when deleting your account).
• Feature flags: PostHog is also used to decide which version of a feature the app shows. Our server asks it with your pseudonymous account identifier only if you allowed usage data; otherwise it asks with one identifier shared by everyone who has not, so PostHog does not learn that the question is about you.
• Reports on a weekly pattern: if you report a pattern with “Something feel off? Tell us” (Terms §5), we keep only the reason you chose, the version of the prompt that wrote the pattern and the week the report was sent in — never your pseudonymous account identifier or the pattern’s text. A report is sent whether or not you allow usage data, because it is a message you choose to send rather than a measurement of how you use Midturn, and it reaches PostHog attached to no account. For the same reason, deleting your account cannot find or remove a report you sent.
• Never attached: symptom names, severities, cycle data, narrative text, or any health content.
• If you allow usage data, onboarding then asks two optional, non-clinical product questions (where you found Midturn, and where else you track your symptoms); your answers are recorded as content-free analytics choices, not health entries. If you do not, it does not ask them.

3.6 Diagnostics

Crash and error reports via Sentry (EU region), configured to scrub personal data. No health content, emails, tokens, or request/response bodies are included in error reports or server logs. Error reports carry no account identifier. If you allow usage data, Sentry’s own software also records your app sessions — when Midturn was opened, for how long, and whether it closed normally or crashed — with a random installation identifier, so that sessions from one installation can be grouped; it is not connected to your account. If you do not, no session is recorded. A change of answer applies from the next time Midturn starts.

3.7 Transactional email

Midturn never asks for your email address, so we send you no email — no marketing email, and no account email either: account deletion is confirmed in the app (§7). If you write to us, we use your address and your message only to answer you; our mailbox is hosted by Google (Google Workspace).

3.8 What we never collect

No precise location. No contacts. No photos. No microphone. No browsing or search history. No advertising identifiers (no ATT prompt — there is nothing to track). No third-party advertising or tracking SDKs. We do not sell or rent any data, and we do not share any data for advertising. Midturn shows no ads and embeds no third-party trackers or advertising identifiers — there is nothing to track.

4. Purposes and legal bases

Where the law of the country you live in requires your consent for a purpose in this table, consent is the basis we rely on for it: for health data and the AI summary, the explicit consent you give on the in-app consent screen (§11), which you can withdraw in the app at any time; for usage analytics (§3.5), the answer you give when the app asks, which you can change at any time in Settings; for the other purposes, the consent you give by using Midturn after this policy has been made available to you, which you can withdraw by deleting your account (§7).

Health-related data is never used for advertising, marketing, data mining, or any purpose other than the health-management features you asked for (this is also an App Store rule for health apps, Guideline 5.1.3(i), and we adopt it as a binding commitment).

5. Who receives data (named processors)

We use a small number of service providers (“processors”). Each processes data for us under its own data-processing terms. We confirm, per Apple Guideline 5.1.1(i), that each provides the same or equal protection of your data as stated here.

We have no advertising partners, no data brokers, and no affiliates. We do not disclose health-related data to any third party except the processors above, for the purposes above, with your consent where required.

6. International transfers

Midturn is operated from Türkiye, our servers are in Germany, and some of the processors in §5 are in the United States. Using Midturn therefore moves data across borders: to our servers in Germany (Hetzner); to the analytics and crash-reporting services PostHog and Sentry, which store this data in the EU but are based in the United States and may also process it there and in other countries where they or their subprocessors operate; and to processors based in the United States — Anthropic for the transient AI summary, RevenueCat for subscription management, Cloudflare for encrypted backups, and Google for any email you send us. Anthropic may also process the summary in Europe, Asia or Australia (§3.2). Each receives only the data §5 lists, for the purpose §5 states, and processes it under its own data-processing terms. Data held in another country is subject to that country’s laws and may be accessible to its courts, law-enforcement and national-security authorities.

7. Retention and deletion

Deleting your account (in-app)

Settings → Delete Account. This is available to every user, requires no phone call or email, and does the following:

1. Immediately on our servers: your account is closed and its personal data deleted; devices and session tokens are destroyed; AI usage metadata is unlinked from you. What remains is the account’s random identifier with a few content-free status fields, purged 30 days later — later only if a processor has not yet confirmed its deletion (step 3) — and your AI consent records (table above), which we keep for five years.
2. On your device: the app wipes its local database — your symptom history, narratives and report records are erased (export first if you want to keep your check-ins and narratives). A backup of your iPhone made before the deletion keeps its copy until that backup is replaced or deleted (§3.1).
3. At our processors (completed within 30 days): deletion of your analytics person profile at PostHog and your subscriber record at RevenueCat.
4. Confirmation: shown in the app.
5. Backups: deleted records persist only inside encrypted backups until those expire per the schedule above; backups are used solely for disaster recovery and are not used to “restore” deleted accounts.

Important: deleting your account does not cancel an active App Store subscription — Apple controls billing. Cancel in iOS Settings → Apple Account → Subscriptions, ideally before deleting your account. The app reminds you of this in the deletion flow.

You can also revoke AI consent without deleting anything — see §11.

8. Your rights

Depending on where you live, you have the rights below. Exercise any of them in-app (deletion, consent revocation, export) or by contacting support@nexapps.co. We do not discriminate against you for exercising rights. Because your account has no name or email, include the Support ID shown in Midturn’s Settings when you write to us, so we can find your records.

• Everyone: access/copy of your server-side data; deletion; consent withdrawal; correction; complaint.
• Canada: access to and correction of your personal information, withdrawal of consent, and a complaint to the Office of the Privacy Commissioner of Canada or, in Québec, the Commission d’accès à l’information du Québec.
• Australia: access and correction under the Australian Privacy Principles, and a complaint to the Office of the Australian Information Commissioner.
• New Zealand: access and correction under the Privacy Act 2020, and a complaint to the Privacy Commissioner.
• EEA/UK (GDPR Arts. 15–22): access, rectification, erasure, restriction, portability, objection (including to legitimate-interest processing), withdrawal of consent without affecting prior processing, and complaint to your supervisory authority.
• Türkiye (KVKK Art. 11): learning whether your data is processed, requesting information, learning the purpose, knowing third-party recipients, correction, erasure/destruction (Art. 7), notification of correction/erasure to recipients, objection to solely-automated adverse results, and compensation for unlawful processing. Send your application to support@nexapps.co; applications are answered within 30 days per KVKK Art. 13 and the Veri Sorumlusuna Başvuru Tebliği.
• US state health-data laws: see §9.

Outside the United States (for which see §9), we answer every request or complaint within 30 days, and within 20 working days in New Zealand; if you are not satisfied, you can take it to the regulator for your country. The person in charge of protecting personal information is our Managing Director, at support@nexapps.co.

Most of your data is on your device, where “access” and “portability” are direct: the encrypted local export gives you a copy of your check-ins, narratives and AI consent choices. Restoring it into Midturn brings back your check-ins and narratives; consent is never restored from a backup, and Midturn asks for it on the phone you use. The Appointment Report PDF gives you a readable copy you can share.

9. US consumer health data (Washington MHMDA and similar laws)

The section below is our Consumer Health Data notice. It is also published as a standalone Consumer Health Data Notice, which is the authoritative version and the target of every Consumer Health Data link on the site.

This is Midturn’s Consumer Health Data Privacy Policy for the Washington My Health My Data Act (RCW 19.373), the Nevada consumer health data law (SB 370), the Connecticut Data Privacy Act’s consumer-health provisions, and similar U.S. state laws.

Categories of consumer health data we collect, and why:

Sources: you (your in-app entries) and your device. Sharing: consumer health data is disclosed only to the processors named in Midturn’s Privacy Policy (the AI provider, under the transient-summary disclosure and only with your consent; the hosting, subscription and crash-reporting providers; and, only if you allow usage data, the analytics provider — which receive the account and usage records in the third row above), each acting under its own data-processing terms. We have no affiliates. We do not sell consumer health data and do not share it for advertising. We do not use geofencing, and specifically do not geofence around any facility providing in-person health care.

Consent: we collect consumer health data only with your consent, with one exception: what is necessary to provide the app you asked for — your pseudonymous account and subscription records, which by their nature show that you use a perimenopause app. Midturn’s usage analytics, which would show it too, are collected only if you allow them when the app asks (Privacy Policy §3.5). Your consent is asked on a separate, plain-language in-app consent screen (not bundled into general terms acceptance), and Midturn never sends the summary of your check-ins without it. Collection limited to your device happens as part of the service you signed up for.

Your rights (WA/NV/CT residents): the right to confirm whether we collect or share consumer health data; to access it, including a list of the third parties (and any affiliates) it was shared with; to withdraw consent; and to have it deleted — including propagation of the deletion to our processors and, on the timeline in Midturn’s Privacy Policy, to backups. Submit requests in-app or to support@nexapps.co. We respond within 45 days (extendable once by 45 days where reasonably necessary). If we refuse a request, you may appeal by replying to our decision or writing to us with the subject “Health data appeal”; we decide appeals within 45 days and, if the appeal is denied, we provide a way to contact the Washington Attorney General (or your state’s equivalent) to raise a concern.

Legal process (our subpoena policy): we do not disclose consumer health data to government entities or litigants except upon valid, binding legal process, which we review and construe narrowly; where lawful, we notify you before disclosure. Structurally, the most protective answer is architectural: we cannot produce symptom histories we do not possess — your logs are on your device, not on our servers, and we do not store the transient AI summaries. What could be produced from our systems is limited to the pseudonymous account, subscription, and content-free usage records described in Midturn’s Privacy Policy.

10. Notifications and marketing choices

• Midturn 1.0 sends no notifications from our servers and holds no push token. Its notifications are scheduled by your iPhone: the daily check-in reminder you can turn on in Settings (Reminders), and, if you have allowed notifications, a note that your weekly pattern is ready when the app has prepared it in the background.
• Notifications are optional and controlled by iOS permission; the app never requires them.
• No marketing email. No third-party marketing of any kind. Health data is never used for marketing (see §4).

11. Consent, and how to revoke it

Before Midturn’s first AI call, you see a consent screen describing exactly what §3.2 describes: what is sent, to whom (Anthropic), and that nothing is stored on our servers. We record the fact, time, and version of your consent (a content-free record) as required by Apple Guideline 5.1.2(i) and applicable law.

• Declining or revoking is a first-class path: daily logging, trends, streaks, and your existing narratives keep working, and your entries are kept on your iPhone. Only new narratives, and the written summary in new reports, pause, because they are the features that need the AI call.
• Revoke anytime: Settings → Privacy → “Weekly narratives & AI processing” toggle. Revocation stops all future transmissions immediately.
• Re-consent is asked if the named provider or the nature of the data sent materially changes.

Midturn also asks, right after its welcome screen, whether it may share usage data (§3.5); “Allow” and “Don’t allow” are one tap each. You can change your answer anytime in Settings → Privacy → “Share usage data”; turning it off stops all sending of usage data immediately.

12. Security

TLS encryption for everything in transit; local data protected by iOS data protection; session tokens stored in the device Keychain; server-side refresh tokens stored only as hashes; backups encrypted with keys that are never stored on our servers; EU hosting; strict server hardening; no health content in logs; provider API keys never present in the app. No system is perfectly secure; if a breach affects you, we will notify you and the regulators the law requires — for example the Office of the Privacy Commissioner of Canada, the Commission d’accès à l’information du Québec, the Office of the Australian Information Commissioner or New Zealand’s Privacy Commissioner, and, where it applies, the US Federal Trade Commission under its Health Breach Notification Rule.

13. Children

Midturn is a perimenopause app for adults. It is not directed to children: you must be at least 18 to use it (Terms of Use §3), and we do not knowingly collect data from anyone under 18. If you believe someone under 18 has used Midturn, contact us and we will delete the associated data.

14. Changes to this policy

We will post changes here with a new effective date, and for material changes (for example, a new AI provider or any new category of data leaving your device) we will notify you in-app and, where required, ask for fresh consent. Prior versions available on request.

This policy is written in English and is also published in French, Spanish and German. If a translation and this English text differ, the version that is more favourable to you applies.

15. Contact

Nexapps Bilişim ve Yazılım Hizmetleri Limited Şirketi — data controller
Soğanlık Yeni Mah., Soğanlık D-100 Kuzey Yanyol Cad., A Blok No: 72/2, İç Kapı No: 10, Kartal, İstanbul, Türkiye
Email: support@nexapps.co

Applications under Türkiye’s KVKK go to the same address and are answered within 30 days — see §8.