Skip to content
TAKT

Legal

Privacy Policy

Version: · Applies to the app “Takt – Zyklus & Periode” and to the website taktcycle.com

This English version is the legally authoritative one for Ireland and for every country in which Takt is offered in English and for which no version of its own exists. For Germany and Austria, the German version (Datenschutzerklärung) is authoritative — there this English text is a translation to read along, and where the two versions differ, the German text governs. For users in the United States there is a separate document, and there English is the authoritative version: Consumer Health Data Privacy Policy.

The essentials in five lines

  • There is no account and no registration.
  • The app does not know who you are.
  • All entries are held in a single encrypted data block.
  • No server, no backend, no cloud of ours.
  • No disclosure to third parties — neither sold nor traded nor “shared in anonymised form”.

You do not have to take our word for it. Put your device into airplane mode. Takt carries on — entering, calculating, analysing, the “Cycle report”, all of it. Only your subscription talks to the App Store or Google Play: Takt asks there by itself whether it is active, and if the answer stays away for 14 days, full access pauses until it comes back (section 6). Takt itself opens no connection and sends nothing.

The full text below is the authoritative one; these five lines are a selection from it and do not replace it.

1. Who is responsible for this privacy policy

TRAJA Projects
Owner: Bao Anh Tran
Sulzbacher Straße 48
90489 Nürnberg
Germany

E-mail: traja.projects@gmail.com

We have not appointed a data protection officer. The conditions of Art. 37 GDPR and § 38 BDSG (German Federal Data Protection Act) are not met: we do not employ at least 20 people on automated processing of personal data, and our core activity consists neither of large-scale monitoring nor of large-scale processing of special categories of data — because we do not process our users’ health data at all (see section 2).

2. The app: why your cycle data does not exist as far as we are concerned

This is the heart of this policy, and it calls for a justification rather than an assertion.

2.1 What Takt stores on your device

Takt stores the information that you enter yourself or import from a source you have released, plus a few process flags, such as the day of your consent and the status of your subscription according to the store. A daily entry can contain:

Data Takt stores on your device
ItemValues
Basal body temperature35.0–40.0 °C
Bleedingnone · spotting · light · medium · heavy
Cervical mucusdry · creamy · watery · stretchy
Cervixthree-step (optional, off by default)
Resting pulse40–160 bpm (optional, off by default)
Intercoursea single yes for the day (optional, off by default)
Symptomsmultiple choice from 15 predefined symptoms. You can additionally choose twelve more: joints · racing heart · dizziness · concentration · anxiety · irritability · vaginal dryness · bladder · desire · tinnitus · itching · hair loss. If you begin for the first time to have Takt accompany you through your menopause, Takt switches these twelve on; you can deselect each one again.
Daily levelmild · medium · severe — only for the two symptoms hot flushes and night sweats, and voluntary there too
Notefree text that you determine yourself

The daily level is the only item that is not available for every symptom: hot flushes and night sweats often accompany women for years, and a bare yes says nothing after a few months. Anyone who does not set the level has still recorded the symptom completely — it is an addition to the yes, not a second mandatory field. Takt forms no score from it and applies no threshold; it stays the value you entered.

Additionally: your year of birth — the year only, not a full date. Takt uses it solely for the “Cycle report”. There it appears in the header, as a year and as an age range, and it selects the clinical reference range that sits beside your cycle variation; that range depends on age. From the age of 45, the “Cycle report” also carries a section on menopause. The year changes neither a forecast nor a cycle day.

Providing it is voluntary. Takt does not ask for it at first launch but only where the “Cycle report” is put together. Without the year, your value appears without a reference range; the report then becomes briefer, not wrong. You can add or remove the year at any time in the cycle settings.

There is one exception: if you have Takt accompany you through your menopause, Takt asks for the year when you begin, because your doctor places your symptoms in relation to your age. For as long as you have Takt accompany you, you can change the year but not remove it. If you end the accompaniment, you can remove it again.

In addition there are your settings, for example which signs you want to record, your cycle defaults, your notifications, the language of the interface and whether the app lock is active. Takt calculates the results from them anew each time.

2.1a Your life path — events you set yourself

Alongside your cycles you can record what was happening in your life: pill or ring · hormonal or copper IUD · pregnancy · breastfeeding · fertility treatment · menopause · illness · medication · surgery · therapy · diet or weight · sport · shift work · relationship · job · moved · stress · good time · holiday — or something else in your own words. Each event has a day or a period, how sure you are of the date, an optional note and your own reading of it ("rather good" or "rather hard"). For a pregnancy you can record how it ended — with a birth, or earlier.

Takt does not distinguish between a miscarriage and a termination, and it stores no such distinction anywhere.

After the pill. Once you have ended a period of "pill or ring", or entered the day for it, you can record which station of your path you are at (the withdrawal bleed · waiting · the first bleed of your own · the first cycle · the first cycles · restless · getting calmer · arrived) and on which day you chose it. Your path begins with your reason: Takt asks why you stopped, and shows it to you again on your path, so that you do not forget what you are doing it for. Without a reason, the path does not begin; you can change it at any time. For the reason, Takt suggests four (side effects · my mood · living without hormones · don't need contraception anymore); you can also state it in your own words, up to 30 characters. Takt also remembers that you have started your path. Takt sets none of this itself: every station and every reason comes from your tap. If you tell Takt the day you stop, and your life path has no ongoing period of "pill or ring", Takt creates one for you. In doing so you can say since when you have been taking the pill; this is voluntary, and an approximation is enough. If you say nothing, its start is set to roughly the day before, until you change it. In the note of this entry, Takt writes a sentence on where it comes from; you can change or delete it. If you choose "my mood" as your reason, the link to mood comes first on your path; nothing is calculated from your reason. If you record a hormonal IUD after stopping, your path shows this as its end ("I use other contraception now"); nothing is stored for this. If you record "pill or ring" again or your entry is ongoing again, your path ends: Takt then deletes your stations, your reason and the start of your path, permanently. If you stop again later, a new path begins. With "End your path" you delete them yourself. Your "pill or ring" entry stays in the life path; there you delete it like any other event. These details are kept in your backup file, not in the “Cycle report”.

A period of "pill or ring" or "pregnancy" counts for the calculation as a pause. After "pill or ring", Takt calculates only with your cycles afterward; after a pregnancy, your cycles from before also keep counting. The calculation only learns the dates, never the type of event, and Takt never names a cause for what you record. All other events feed into no calculation. What the life path shows is your own cycles — before and since and year by year.

Your menopause. You can have Takt accompany you through your menopause. You begin this yourself, and you end it yourself. For this, Takt stores three things: the day you began, the day you ended, and the part that you mark for yourself on the page about the course (cycles become less regular · the unsettled years · the last period · the first year after · the years after). Only you set the part. Takt derives it from nothing and does not calculate with it.

When you begin, Takt creates a "menopause" period in your life path, with the start you give, if there is none there yet. The first time you begin, Takt switches on twelve more symptoms in your daily entry (section 2.1). You can also choose them without having Takt accompany you through your menopause, and you can deselect each one again.

From your entries, Takt counts: the days since your last bleed, the intervals between your bleeds, and the days with bleeding and with symptoms, per month and over the years. Takt forms no level, no score and no assessment of where you stand in your menopause from this. Such figures also appear in a section of their own in the “Cycle report” for as long as you have Takt accompany you through your menopause, and, independently of that, from the age of 45. The part you marked and the day you began are not in the “Cycle report”.

If you end the accompaniment, your entries and the period are kept in your life path; you delete the period there like any other event. The part you have marked for yourself is deleted in the process. The accompaniment brings no notifications of its own. All of these details are in your backup file; the table (CSV) names only the symptoms of the day.

2.1b Your doctor section — what you take to the appointment

Appointments with date, time and the name of the practice you type in, your reason in one sentence, your topics for the conversation, a note about the visit and items you pay for yourself (service and amount). Plus a note for your doctor, if you want to pass it on in the “Cycle report”.

Only two things from here go into the “Cycle report”: your note and the events you choose for it yourself — under Takt's own term, with the date only if you want it. Appointments, practice name, your visit note and the cost items stay in the app.

Free text stays free text. In your notes you write whatever you like, including diagnoses, medications or treatments. Takt shows them to you and carries them into your backup, but it does not search, interpret or calculate with them.

No field is mandatory, with two exceptions: if you begin your path after the pill, you state your reason (section 2.1a); if you have Takt accompany you through your menopause, you state your year of birth (section 2.1). Every other field left empty stays empty — Takt fills nothing in and estimates nothing into place. An exception is the strength of a bleed: if you enter a whole period after the fact, or carry over bleeding days without a strength from another app, Takt enters it as "medium". You can change each day. You can hide optional signs permanently. What you do not enter does not exist.

Takt deliberately does not ask for: your name, your e-mail address, your full date of birth, your location, your contacts, your telephone number, your device ID or an advertising identifier. There is no account and no registration. The app does not know who you are.

2.2 Where this data is stored

All entries are held in a single encrypted data block. On the iPhone it sits in the operating system’s keychain (the iOS Keychain), tied to your device. On Android it sits encrypted in the app’s private storage area, and the key for it is protected by the Android Keystore. In both cases the key does not leave the device, and we have no access to it.

Outside this block there are two kinds of things: what a Takt widget has to draw, if you place one, and your scheduled notifications, if you allow them (section 5). A widget cannot look inside the encrypted block; what it displays has to sit readable next to it. How much that is, you decide twice — with the version you place (on the home screen “Ring only” or “Ring with text”, on the iPhone lock screen round or rectangular), and at any time with the level under More → App → Widget: “Show everything”, “Without words” or “Hide everything”. On “Hide everything” what sits there is a ring without a date, exactly as every fresh installation shows it. None of it is transmitted anywhere, and with “Delete all data” it disappears too. If you place no widget, this store does not come into existence.

Takt removes itself from device backups. Without this step an operating system would include the data block in the backup of your Apple or Google account — not to us, but nonetheless to a second location. Takt counteracts this in four ways at once:

So that this state cannot be lost unnoticed, an automated test checks it on every change to the program: if one of the four routes falls away, the test fails before a new version comes into being.

What this means for you, together with its downside: your entries are on this device. A device backup therefore also does not carry them to a new device — when you switch, you take your history with you via the backup file that Takt creates for you (see section 4). That file lies where you put it and is subject to your decision.

Two protective mechanisms are built in:

2.3 What Takt does not do

We list this individually, because the absence of these things is the product:

2.4 The legal classification: who is the controller — and what follows from that?

This question is the actual point, and we answer it openly, because the answer explains why this policy is so short where your health data is concerned.

Our classification: we are a controller within the meaning of the GDPR — and precisely for that reason we can show you how little that means at Takt.

We could make it easier for ourselves. There would be the argument that a maker of purely on-device software is not a controller at all, because it never sees the data. We do not run that argument, for one simple reason: it does not stand up to scrutiny.

The test asks about decision-making power, not about access. Under Art. 4(7) GDPR, the controller is whoever determines the purposes and means of the processing. That is exactly what we do: we determine which fields exist, how the calculation works, what is stored for how long and what happens on deletion. You decide whether you enter something — not for what purpose or how it is processed. The fact that the data never leaves your device changes nothing about this: the State Commissioner for Data Protection of Baden-Württemberg expressly answers the question whether a controller must have access to the data with no — what matters is "a determining influence on the purpose and the (essential) means", "even if they never actually have, or will have, access to the data".

Why we do not play this down. A controllership that is argued away is worthless in a dispute — and it would sit at odds with what we otherwise claim. We would rather accept it and show what it actually has to work with:

Controller obligations and what they amount to at Takt
Controller’s obligationWhat it looks like at Takt
Disclose recipientsThere are none. No server, no processor, no analytics tool.
Third-country transferDoes not take place — the data does not leave your device.
Provide access to dataYou already have it in full: in the app and as an export.
ErasureYou do it yourself and immediately. We could not, even if we wanted to.
Report a data breachA break-in at our end cannot reach your cycle data. None is held there.
Keep a record of processing activitiesWe do. It is unusually short — that is precisely the point.

What follows from this is not a weakness but the proof: most of a controller’s obligations run into the void with us, because there is nothing for them to act upon. Not because we have evaded them, but because the app is built this way. A provider with a server would have to explain to you at this point whom it has engaged and how long it stores things. We have to explain to you that the question has no subject matter here.

What applies to you is a separate question. That you record your own data for yourself is a purely personal activity (Art. 2(2)(c) GDPR) — you do not thereby become a controller yourself. That protects you and says nothing about how we are to be classified. Two different questions that are often conflated.

And frankly: no court has yet decided a case about an app where nobody but the user ever has access. We have chosen the more cautious position, not the one more comfortable for us.

Why this policy exists at all, then. For three reasons. First, the classification above applies only to the app: for our website, for support by e-mail and for purchase through the stores things look different, and we describe those cases in full below. Second, both stores require every health app to have a publicly accessible privacy policy, regardless of architecture. And third — the actual reason — you should be able to check what we claim instead of having to believe it. A privacy policy that nobody understands protects nobody.

2.5 Your consent at first launch — what it is and what it is not

When setting Takt up we expressly ask you to consent to the recording of health data in the app. We are honest about what this consent achieves:

This consent is our legal basis. Cycle data is health data and therefore a special category of personal data (Art. 9(1) GDPR); processing it is prohibited in principle unless one of the exceptions applies. We rely on your explicit consent under Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. That is not a safety net and not a precaution, but the operative ground — consistent with our classification in section 2.4.

At the same time it achieves two things: it documents your conscious decision, and it satisfies what both stores require of apps that record health data.

Consent is voluntary and is not hidden in the small print: it is a separate step during setup, in plain language, with its own act of agreement. You can withdraw it at any time in the app, in the More section under the legal group — labelled “Manage consent”. Withdrawal takes effect for the future; the lawfulness of the recording that took place up to that point remains unaffected. Your already stored entries remain unchanged on your device after a withdrawal until you delete them yourself or remove the app — we cannot touch them.

3. Apple Health and Health Connect: Takt works separately from them

Takt stays completely separate from Apple Health and Health Connect. No system permission, no permission dialog, no ongoing access, no import. The app reads nothing there, and it never writes anything there.

A legal basis is moot here, because there is no processing. Where nothing is collected, there is nothing left to consent to.

§ 25 TDDDG does not apply here, and the reason has become simpler: the provision concerns an app’s access to your device. Takt accesses no health store. Nor does it apply to Takt’s own storage of your entries: that is the core service itself and therefore “strictly necessary” (§ 25(2) no. 2 TDDDG).

4. Export, backup, “Cycle report”: the only way out — and you are the one who takes it

Takt can release your data for you:

These files are generated entirely on your device. Nothing is sent to us — not even the “Cycle report”.

As soon as you share the file, however, it leaves your device. Takt hands it over to your operating system’s share function for that purpose. What happens after that is determined by you alone through your choice of destination: sending by e-mail goes via your e-mail provider, storing in a cloud then sits with that cloud provider, sending by messenger with that messenger. Those destinations’ privacy terms apply, not ours — we are not involved and learn nothing about it.

Our advice, and we mean it: a cycle export is a health document. Treat it like a doctor’s letter. For the way to your doctor, the PDF on your own device or a printout is the safest form; an unencrypted e-mail is not.

5. Notifications, widgets, alerts

6. Purchase and subscription through the stores

Takt has no payment system of its own and no account. The purchase of the subscription runs exclusively through the Apple App Store or Google Play.

What we are not concealing here: Apple and Google know that you have downloaded and bought Takt — that is the one data trail an app without a server also produces, and we cannot take it away from you. It says nothing about your cycle, because no store reaches that far. But it exists, it lies outside our influence, and for a user with a high need for protection it is the remaining gap. We would rather name it than pretend it does not exist.

7. The website taktcycle.com

The classification in section 2.4 does not apply to the website — here we are the controller. It nevertheless stays manageable.

7.1 What arises when you open the page

Opening the website produces a few technically necessary details — some your browser sends along, the rest arise as the page is delivered:

page accessed · date and time of access · volume of data transferred · message about successful retrieval · browser type and version · operating system · referring page (referrer) · your IP address

Without your IP address, no server would know where to send the answer. That is not a decision of ours, it is how the internet works.

No access log is created from this. On the zone our host delivers this site from, logging is switched off. So no file is kept that records your visit with IP address, time and page accessed — we receive no such file, we store none, and we evaluate none. Whether the switch is still off is read again automatically every time the site is updated.

7.2 Hosting

The website is hosted by BunnyWay, informacijske storitve d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia. The host processes the data named above on our behalf; a data processing agreement under Art. 28 GDPR is in place. The servers are located in the EU/EEA. No transfer to third countries outside the EU/EEA takes place.

7.3 What the website does not do

7.4 The feedback form on /en/contact

There is a form on /en/contact for telling us what you notice about the app. It has no field for your name, none for your e-mail address and none for anything out of your cycle — not because we delete those details later, but because we never ask for them in the first place.

What you send. You pick three answers from fixed lists: what you noticed, where in the app it happened, and what it was about. You may add a message — optional, at most 2,000 characters. The form also contains a field that is invisible to people and catches automated submissions; its contents are only checked and are never stored.

What is stored out of that. The three answers you picked, your message if you wrote one, and the day you sent it. We write nothing more into the entry: no time of day, no running number. Instead of a number, each entry is given a random name.

The storage underneath does record a time, though, and we can read it. Here we separate two things that are easily conflated: the entry, and the storage it sits in. The entry carries no time of day — the storage does. Of its own accord it notes, for every file, when that file was created, accurate to the millisecond. Alongside the time, that also leaves the order in which a day’s feedback came in; the random name on its own does not prevent it. And this record is available to us: we read it with the same access key we use to fetch the feedback itself. Presenting it as a purely technical matter of our provider’s would therefore not be honest.

Why we do not simply switch it off. The storage has no setting for that. Overwriting a file afterwards would not remove the record but replace it with a different point in time; bundling entries into one file per day would merely move the same thing up a level. What does limit it effectively is deletion: the record goes when the entry goes, and we delete an entry once it has been evaluated (see Storage period below). Until then it holds that we can see when you sent this form — and with it, roughly, when you were occupied with the app. That is precisely the link we wanted to avoid; at the storage layer we did not manage it, and we would rather write that down than leave it unsaid.

What is never read. Your IP address, your browser identification and the referring page are not even read out when you submit — they are simply not available to the receiving end. The distinction matters to us: “we do not store it” is a promise about how we handle a detail, whereas “we do not collect it” means the detail does not exist on our side at all. The only thing checked on submission is whether it came from our own site, and that value is our own domain name; it says nothing about you.

Where the feedback is kept. In separate storage of its own in Germany, apart from the rest of the website. That storage cannot be retrieved over the network — there is no address at which anyone could call the entries up; we retrieve them with the access key. It is operated by the same processor as the hosting in 7.2 and under the same Art. 28 GDPR data processing agreement.

The upper limit counts entries, not people. We accept at most 500 pieces of feedback per day. What is counted is how many entries already lie there that day — not how often somebody has pressed send. There is expressly no counter per sender and none per IP address.

Taken on its own, a stored entry cannot be attributed to anybody — three picked values and a date say nothing about you. The optional message can undo that, because you can write whatever you like into it, and we store it exactly as you wrote it. Please do not: give us no name, no address and nothing out of your cycle. Describe what you noticed, not yourself.

We cannot answer you. There is no account and no address an answer could go to — that is not carelessness but the consequence of our not knowing who you are. If you need an answer, write us an e-mail instead (section 8).

The transmission itself is not anonymous. As with opening any page, submitting the form carries your IP address to our host — without it the request would arrive nowhere. What arises in the process, and why no access log comes of it, is described in 7.1.

7a. Takt on social networks

Takt has profiles on Instagram, TikTok, YouTube, X, Reddit, and Pinterest, all under taktcycle. The app and this website do not embed any of these networks. You reach a profile only if you open the platform yourself.

What we process there. We read and reply to what you write to us publicly: comments under our posts and mentions of our profile, together with your public profile name. The basis is our legitimate interest in talking to the people who reach out to us publicly (Art. 6(1)(f) GDPR). If you write something about your health in a public comment, you have made it public yourself (Art. 9(2)(e) GDPR). We may hide or delete comments that reveal more about you or others than belongs in that place. For anything that concerns you personally, the best way to reach us is by e-mail (section 8).

Direct messages on Instagram. Our inbox there is open, and we reply. Two things go with that: messages on Instagram have no longer been end-to-end encrypted since May 2026 — what you write to us there sits with Meta and is readable by Meta. And we keep our replies there short: anything about your cycle, your health, or your subscription, we answer by e-mail (section 8), where it stays between you and us. Whatever is in a message, we read it and answer it, and then delete it; we don't add it to any list and we don't evaluate it.

What we see there. Since October 2026 we have run a professional account on Instagram. There, like the other platforms, Instagram shows us only aggregated numbers, for example how often a post was viewed and roughly which countries and age groups the people who see it come from. We cannot identify individual people from that. If you vote in one of our story polls, Instagram shows us your profile name and your answer; we only count how the poll turns out overall.

What the platform does on its own is its own decision. When a profile is opened, the platform collects its own data, for example about your device, your usage behaviour, and for advertising. We have no influence over that. The platforms also process data in the United States and other countries outside the EU. How, is set out in their privacy policies: Instagram · TikTok · YouTube · X · Reddit · Pinterest

You can assert your rights (section 9) against us. For what the platform itself processes, you are best off turning to it directly.

7b. Advertising for Takt

We advertise Takt with paid ads: on Instagram, in the App Store and with Google. All we set is the countries and languages, the devices and the placements where they appear, in the App Store also the search terms, and on Instagram a minimum age of 18. We do not choose interests or any characteristics relating to health, cycle or family planning. Whom a platform reaches within that frame is its own decision.

We report nothing back to the platforms: neither the app nor this website contains a pixel or any other platform tool, and we do not upload lists of people. The platforms show us aggregated numbers, for example how often an ad was shown and tapped and how many installs and purchases go back to a campaign; we cannot identify individual people from that. If you open our website from an Instagram ad, Meta measures in its own browser that the page loaded; Meta does that on its own. The legal basis for our ads is our legitimate interest in making Takt known (Art. 6(1)(f) GDPR).

8. Contact and support

If you write us an e-mail, we process your e-mail address and everything you tell us. Here we are the controller.

Important, and please take it seriously: do not send us health data unless it is unavoidable. We do not need it for a support enquiry. Describe the problem, not your cycle. If you should want to send us an export for troubleshooting after all, we will ask expressly beforehand and delete the file immediately after the matter is settled.

When we write to you first. We occasionally write to creators who speak publicly about cycle and health. For this we use your name and the postal address or business e-mail address that you published yourself, for example in the legal notice of your website. The message says where we got them.

9. Your rights

Under the GDPR you have the following rights:

Your rights under the GDPR and the corresponding articles
RightArticle
Access to the data stored about youArt. 15
Rectification of inaccurate dataArt. 16
ErasureArt. 17
Restriction of processingArt. 18
Data portabilityArt. 20
Objection to processing based on legitimate interestsArt. 21
Withdrawal of consent given, with effect for the futureArt. 7(3)

For these, contact the address in section 1.

The honest note that goes with this: as regards your cycle data, these rights run against us into the void — not because we refuse them, but because we do not have the data. Information from us about your entries would be empty information. You exercise these rights in Takt itself, directly and without an application to anyone:

And the warning that belongs with it: because there is no cloud, the data block on your device is the only copy of your history. If you delete the app, it is gone — irretrievably for us too, because we never had a copy. Make a backup first if your data means something to you.

You can also bring any privacy complaint directly to us. We confirm that we have received it and reply to you in writing as quickly as we can.

Right to lodge a complaint: you can lodge a complaint with a data protection supervisory authority at any time, Art. 77 GDPR — in particular in the member state of your residence, your place of work or the alleged infringement. The authority competent for us is the Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Postfach 1349, 91504 Ansbach, Germany.

10. Disclosure, third countries, automated decisions

11. Age

Takt is aimed at people aged 13 and over. You provide your year of birth voluntarily (section 2.1 names the one exception); the “Cycle report” uses it to place the reference range for your age beside your value. Like everything else, this information stays on your device — we do not receive it and cannot check it. Age verification therefore does not take place and is technically impossible as well. We recommend that younger users discuss using the app with a parent or guardian — not out of legal caution, but because the subject deserves it.

12. Changes to this policy

We adapt this policy when the app or the legal position changes. The version published on this page is the authoritative one; the date at the top shows its status. If something material changes about the way your data is handled, we will point it out in the app — not quietly on a subpage.


For completeness: Takt is not a medical device and does not replace medical advice. What Takt is and what it is not is set out in the Terms of Use, section 2.