Biomatic Privacy Policy
Effective 28 September 2026
1. Introduction
Biomatic is an iPhone app made by Actogram Ltd. It reads activity data — and, if you allow it, sleep and heart-rate data — from the Apple Health app and your iPhone's motion sensors, sends it to our server and calculates your chronotype, rhythmotype, the hour-by-hour shape of your day, points and tokens.
This Privacy Policy explains what personal data we collect, why, where it goes, how long we keep it, and what rights you have. It applies to the Biomatic app and to the pages about Biomatic on our website, actogram.ai (the website keeps only standard server logs — IP address, page requested, time — for 90 days).
Biomatic processes data about your health. We treat it as special category data under the UK GDPR and the EU GDPR and as consumer health data under US state laws, and we process it only with your explicit consent. We are not a healthcare provider and we are not a "covered entity" or "business associate" under the US HIPAA.
At a glance
- We collect: step counts from Apple Health and your iPhone's motion sensors; if you switch on Additional Data — sleep stages, heart rate, resting heart rate and workouts (including workout routes where recorded); your Apple sign-in identifier; basic device information and crash reports; and, only if you switch it on, usage statistics. Crash reports and usage statistics are processed with AppMetrica and never include Health data.
- We use it to calculate and show you your metrics and to keep the app working and secure. If you separately allow it, we also keep de-identified copies to improve and validate our calculation method.
- We store it on a server in Frankfurt, Germany (EU), hosted by DigitalOcean, while your account exists.
- We do not sell your data, do not pass it to advertising networks or data brokers and do not use Health data for advertising.
- You can change your consents, ask for a copy of your data, or delete your account at any time — in Settings → Data & Privacy or by writing to services@actogram.ai.
2. Who we are and how to contact us
The controller of your personal data is Actogram Ltd, a company registered in England and Wales (company No. 14594952), registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Actogram Ltd is registered with the UK Information Commissioner's Office (ICO), registration number ZC252163.
- Privacy and data requests: services@actogram.ai
- Phone: +44 7473 968854
- EU representative (Article 27 EU GDPR): Prighter Group — see "Our representative in the EU" below
We have not appointed a Data Protection Officer — the law does not require one for an organisation of our size and activities. Write to services@actogram.ai for anything about your data.
Our representative in the EU
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
- European Union (EU)
Prighter gives you an easy way to exercise your privacy-related rights (for example, requests to access or erase personal data). If you want to contact us via our representative Prighter, or make use of your data subject rights, please visit: https://app.prighter.com/portal/11935821603
EU data protection authorities can also contact us through Prighter. You can always write to us directly at services@actogram.ai instead.
powered by Prighter
We are subject to UK data protection law (UK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025). Where the EU GDPR or other local laws apply to you, we honour the rights they give you (see section 10).
3. What data we collect
3.1 Health and activity data (special category data)
With your explicit consent, Biomatic reads the following from the Apple Health app (HealthKit) and from the iPhone motion sensors (Motion & Fitness) and sends it to our server:
| Consent | Category | What exactly | Where it comes from |
|---|---|---|---|
| App Features | Steps | Step counts with timestamps — minute by minute. At first sign-in we import the last 6 months; after that we keep receiving new data as it appears. Plus live step counts | Apple Health; iPhone motion sensors |
| Additional Data | Sleep | Sleep stages (in bed, asleep, awake, and REM / core / deep where available) with start and end times | Apple Health (recorded by Apple Watch or another sleep-tracking device you use) |
| Additional Data | Heart rate | Heart-rate samples with timestamps | Apple Health |
| Additional Data | Resting heart rate | Daily resting heart rate | Apple Health |
| Additional Data | Workouts | Workout type, start and end time, duration, distance, energy burned, and the workout route (GPS coordinates) where your device recorded one | Apple Health |
| both | Source device | For each record, which device recorded it (for example iPhone or Apple Watch) | Apple Health metadata |
The app needs step data to work. Additional Data makes your metrics more precise: sleep stages let us measure your night-rest window instead of estimating it from gaps in movement; heart rate and resting heart rate help the algorithm tell activity from rest and sleep; workouts and their routes give distance for the shape of your day. You choose in iOS which Health types Biomatic may read, and you can switch Additional Data off at any time in Settings → Manage Consent. Biomatic only reads Health data; it never writes to Apple Health.
Location. Biomatic does not ask for access to your iPhone's location and does not collect it. The only location data we receive is the route inside a workout you allow us to read from Apple Health, where your device recorded one.
3.2 Data we calculate from it
Your chronotype, rhythmotype, the hour-by-hour shape of your day, pace, average pace, performance, points, tokens, consistency score, best week and night-rest window. These are derived from your health data and are treated with the same care.
3.3 Account data
Your Apple sign-in identifier, an internal account code, and your settings: daily goal, rest-detection mode, notification switches, consent switches. There is no password — sign-in is handled by Apple.
We do not store an e-mail address for your account: Apple may pass us a relay address when you sign in, and we do not keep it. If you write to us at services@actogram.ai, we of course see and keep that correspondence (see 3.7). Your nickname is shown in the app and is not stored on our server.
3.4 Technical data
iPhone model, iOS version, app version, time zone, language, push-notification token, IP address and request logs on our server (kept for security and debugging), and the date and time of your consents.
Crash reports (our own server). When the app fails, iOS gives it a technical crash report (MetricKit): app and iOS version, screen, device model and the technical frames of the failure. The app sends this to our own server, linked to your account code. It contains no Health data and no free text. We keep these reports for 12 months.
Crash reports and diagnostics (AppMetrica). We also use AppMetrica, an app-analytics service (see section 6), for a cleaned copy of the same technical crash information and for basic diagnostics. AppMetrica receives a crash report — what the app was doing when it failed — together with basic diagnostics: device model, iOS and app version, screen resolution, app performance data, app launches, an AppMetrica device identifier and your IP address. We do not send AppMetrica your account code, e-mail, nickname, Apple identifier or any Health data or metrics. We do not switch on AppMetrica's location collection and we do not use the advertising identifier (IDFA).
3.5 Usage statistics (only if you switch "Help improve the app" on)
Events about how you use the app, recorded with AppMetrica against the AppMetrica device identifier (not your account): which screens you open and for how long, navigation between screens, onboarding steps completed, settings changed, notifications opened, and whether you opened the feedback widget. This does not include any Health data or anything calculated from it — no step counts, heart-rate values, sleep records, locations, metrics, points or tokens. We do not use advertising SDKs.
3.6 Feedback
Star ratings and text you type in the feedback widget, together with the screen you were on, and your answers to the weekly in-app question.
3.7 Support correspondence
If you write to services@actogram.ai, we keep your message and our reply.
We do not collect: your name (unless you put it in your nickname or write to us), your contacts, photos, your device's location history, audio, payment card details (Biomatic is free in this release), or any Health data types other than those listed in 3.1.
4. Why we use your data and on what legal basis
| Purpose | Data | Legal basis (UK GDPR / EU GDPR) |
|---|---|---|
| Calculating and showing your metrics — chronotype, rhythmotype, shape of your day, points, tokens, consistency, best week, night-rest window | Step data (App Features), derived data, settings | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) — the App Features consent. You can withdraw it at any time; the app then stops working because there is nothing to calculate |
| Making the same metrics more precise | Sleep, heart rate, resting heart rate, workouts (Additional Data) | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) — the separate Additional Data consent, optional |
| Improving and validating our calculation method — checking that chronotypes, rhythmotypes and scores are calculated correctly across users, using de-identified copies of the data (no Apple identifier, account code or device identifiers) | De-identified health and activity data, derived data | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) — a separate, optional consent ("Help improve our method"), off by default. The app works in exactly the same way whether it is on or off, and refusing it has no consequence. Internal use only in this release; we will not publish results or share data with outside researchers without asking you separately first |
| Creating and running your account, syncing your data to your device, sending service messages in the app (for example about changes to these documents) | Account data, technical data | Contract (Art. 6(1)(b)) |
| Keeping the service working and secure — logs, backups, crash reports (via AppMetrica), error diagnosis, abuse prevention | Technical data | Legitimate interests (Art. 6(1)(f)): running a reliable and secure service. We have balanced this against your interests; logs are minimal and short-lived |
| Understanding how the app is used and improving it | Usage statistics | Consent (Art. 6(1)(a)) — the "Help improve the app" switch, off by default |
| Reading and answering your feedback and support requests | Feedback, support correspondence | Legitimate interests (Art. 6(1)(f)): improving the product and helping you. Please do not include health details in feedback; if you do, we treat them under the same explicit consent as your other health data |
| Complying with the law — responding to lawful requests, keeping records of consent and of your requests | Records | Legal obligation (Art. 6(1)(c)) |
We do not use your data for advertising, profiling for marketing, or automated decisions that have legal or similarly significant effects on you. Your rhythmotype and scores are calculated automatically, but they only describe your own activity pattern and have no effect beyond what you see in the app.
Apple Health data specifically. In line with Apple's HealthKit rules, we do not use Health data for advertising or marketing, do not sell it, do not disclose it to data brokers or advertising platforms, do not share it with third parties without your permission, and do not use it for any purpose other than providing the Biomatic service and the de-identified method improvement you have consented to.
5. Device permissions
Biomatic asks iOS for the following permissions. Each can be changed later in iOS Settings; refusing a permission limits the related feature but does not stop you using the app as long as at least one step source is available.
- Health — read access to steps and, if you choose, sleep, heart rate, resting heart rate and workouts.
- Motion & Fitness — live step counts from the iPhone's motion sensors.
- Notifications — goal-moment nudges, the token at biological midnight, weekly summary. Separate switches in Settings.
6. Where your data is stored and who can access it
Storage. Your data is stored on servers in Frankfurt, Germany (EU), hosted by DigitalOcean, LLC under DigitalOcean's data processing agreement. Wherever you use the app from, your data goes directly to this server. Data is encrypted in transit (TLS) and at rest.
Backups. We keep encrypted backup copies so that we can restore the service after a failure. They are encrypted before they leave our server, one weekly copy is kept with an external storage provider that never receives the keys and cannot read the contents, and all copies are deleted after 30 days. We will name the provider if you ask.
Access inside Actogram. A named, limited set of Actogram staff who need access to run the service. Access is role-based, logged and reviewed.
Processors and other recipients.
| Recipient | Role | What they get | Location |
|---|---|---|---|
| DigitalOcean, LLC | Hosting (processor) | Everything stored on the server, encrypted | Frankfurt, Germany (EU) |
| Apple Inc. | Sign in with Apple, App Store, push notifications | Your Apple ID relationship, push token and notification payloads, under Apple's own privacy policy | Apple acts under its own terms |
| Outside researchers | — | None in this release. If we later want to share de-identified data with research partners, we will ask for your separate consent first | — |
| AppMetrica — Air Smart Advertising Solutions FZ-LLC, the provider of AppMetrica under its data processing agreement | Crash reporting and usage analytics (processor, under the AppMetrica data processing agreement) | Crash reports and diagnostics as described in 3.4; usage statistics only if "Help improve the app" is on. No Health data, metrics, account code, e-mail or nickname | Dubai, UAE; may use affiliated sub-processors outside the UK and EEA (see section 7) |
| Prighter Group and its local partners | Our EU representative (Article 27 EU GDPR) | Only what you or an EU data protection authority send through Prighter, which forwards it to us | European Union |
| Authorities, courts, professional advisers | Legal compliance | Only what the law requires or a claim needs | As required |
We do not use any e-mail-sending service in this release: service messages are shown in the app, and any e-mail we send comes from our own support mailbox. If we add a processor (for example an e-mail service), we will name it here before it receives any data.
If Actogram Ltd is acquired or merges, your data may be transferred to the new owner under obligations consistent with this Policy; we will tell you before that happens and you will be able to delete your account first.
7. International transfers
Actogram Ltd is in the United Kingdom; our server is in Germany. Transfers of personal data between the UK and the EEA are covered by adequacy decisions on both sides. If you use Biomatic from outside the UK and the EEA, your data is transferred to our EU server when you use the app; this is necessary to provide the service you have asked for. The weekly backup copy described in section 6 is held by a storage provider outside the UK and the EEA under a data processing agreement with the EU Standard Contractual Clauses and the UK Addendum; it is encrypted and the provider never receives the keys. AppMetrica stores the technical data it collects on its own servers, including outside the UK and the EEA, in countries that the UK and the EU have not found to provide adequate protection. For these transfers we rely on the Standard Contractual Clauses in AppMetrica's data processing agreement and on our transfer risk assessment, and we limit what AppMetrica receives to crash reports, technical diagnostics and — if you switch it on — usage statistics, with no Health data and nothing that identifies your account. Contact us for details.
8. How long we keep your data
| Data | Kept for |
|---|---|
| Health and activity data, derived metrics, account data, settings | While your account exists |
| Crash reports on our own server | 12 months |
| Backup copies (encrypted) | Daily copies and a weekly archive, both deleted after 30 days |
| Additional Data (sleep, heart rate, workouts) | While the Additional Data consent is on; deleted within 30 days after you switch it off |
| Usage statistics (AppMetrica) | Collected only while the switch is on; turning it off stops collection at once. Statistics already sent are not linked to your account and are kept for as long as we use AppMetrica |
| Feedback and weekly-question answers | While your account exists; text may be kept in de-identified form afterwards |
| Server request logs | 90 days |
| Crash reports and diagnostics (AppMetrica) | For as long as we use AppMetrica; not linked to your account. Deleted when we close our AppMetrica account |
| Security and audit logs (administrator actions, exports) | 12 months |
| Support correspondence | 3 years after the last message |
| Records of your consents; records of requests and complaints you make under this Policy | 6 years after your account is deleted / after the request is closed (to demonstrate compliance) |
Deleting your account. In Settings → Data & Privacy → Delete my account, or by writing to us. Everything listed above (except the last two rows and the AppMetrica data, which is not linked to your account) is deleted from our live systems within 30 days, and from backups within the same 30 days. The link between your de-identified code and you is destroyed. De-identified copies already used to improve our method (without your Apple identifier, account code or any device identifier) are kept — after the link is destroyed they are no longer connected to you and cannot be recalled.
Withdrawing consent without deleting the account. Turning off App Features stops sending and deletes your health and activity data and derived metrics from the server within 30 days; your account stays. Turning off Additional Data does the same for sleep, heart rate and workouts only.
Inactive accounts. If you have not opened the app for 24 months, we will notify you in the app and by push notification and, if you do not return within 30 days, delete your account and data.
9. Security
Encryption in transit; health data encrypted in the application before it is stored, with the keys held separately from the database; role-based access with multi-factor authentication for administrators; access logging; separation of the de-identification key from method-development copies, held by a named key holder; regular backups with restore tests; vulnerability patching; a written personal-data-breach procedure. If a breach is likely to result in a high risk to you, we will tell you without undue delay and, where required, report it to the ICO within 72 hours.
10. Your rights
You can exercise most rights yourself in Settings → Data & Privacy; for anything else write to services@actogram.ai. We will reply within one month (extendable by two months for complex requests; we will tell you if so), or within the period that the law of your state or country sets, if different (for example 45 days under US state consumer-health-data laws). Requests are free unless manifestly unfounded or excessive. The surest way to reach us is from inside the app, where you are already signed in with Apple. If you write to us by e-mail instead, we need to work out which account is yours: we do not store an e-mail address or a name, so we will ask you for details that only you can see in the app. If we cannot identify your account from what you can tell us, we will say so — the law does not require us to collect extra data about you just to make that possible.
Everyone
- Withdraw consent at any time (Settings → Manage Consent). This does not affect processing that happened before.
- Access — a copy of your data and the information in this Policy. Write to services@actogram.ai with "Data request" in the subject line; we send your data within one month in a machine-readable format (JSON).
- Rectification — correct your settings in the app; ask us for anything else.
- Erasure — delete your account in Settings, or ask us.
- Restriction — ask us to limit processing (for example while you contest accuracy or object).
- Objection — object to processing based on legitimate interests; we will stop unless we have compelling grounds.
- Portability — receive your data in a structured, machine-readable format.
- No automated decisions with legal or similarly significant effects are made about you.
- Complain to us — write to services@actogram.ai with "Complaint" in the subject line. We will acknowledge within 30 days and respond without undue delay.
- Complain to a regulator — in the UK, the Information Commissioner's Office (ico.org.uk, +44 303 123 1113). In the EU/EEA, your national data protection authority. You can do this without complaining to us first.
European Union / EEA. You have the rights under the EU GDPR described above. You can exercise them through our EU representative, Prighter (https://app.prighter.com/portal/11935821603), or directly with us.
Switzerland. You have the rights under the Swiss Federal Act on Data Protection (FADP) described above. Write to us at services@actogram.ai; you can also complain to the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch).
California (CCPA/CPRA). You have the right to know, delete, correct, and to limit the use of sensitive personal information. We do not sell or share personal information for cross-context behavioural advertising and have not done so in the preceding 12 months; we do not use or disclose sensitive personal information for purposes other than providing the service. We will not discriminate against you for exercising your rights. You may use an authorised agent; we will verify the agent's authority. Categories of personal information collected in the preceding 12 months: identifiers (Apple sign-in identifier, account code, device identifiers), sensitive personal information (health data as listed in 3.1), internet/electronic activity (usage statistics, if enabled), geolocation (workout routes only), inferences (your metrics). Sources, purposes and recipients are as described in sections 3, 4 and 6.
Washington, Nevada, Connecticut and other US states with consumer-health-data laws. See our separate Consumer Health Data Privacy Policy. In short: we do not sell consumer health data, do not share it with any third party, do not use it for targeted advertising, and do not use geofencing around health facilities. You may confirm and access it, receive the list of any third parties and affiliates it has been shared with, withdraw consent, delete it, correct it, obtain a portable copy, and appeal our decision.
Other US states (Virginia, Colorado, Utah, Texas, Oregon, Montana and others). You have the rights of access, correction, deletion, portability, and to opt out of targeted advertising, sale and profiling (none of which we do). If we decline a request, you may appeal by replying to our decision; we will answer within the period your state law sets (45 days in Colorado; 60 days in Connecticut and Virginia; otherwise 45 days) and, if we still decline, tell you how to contact your state Attorney General.
Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act), and other countries. You have the rights of access, correction, deletion and portability described above, and you may complain to your local authority. Contact us at services@actogram.ai.
11. Children
Biomatic is intended for people aged 18 or over. We do not knowingly collect data from anyone under 18. If we learn that we have, we will delete the account and its data. If you think a person under 18 is using Biomatic, tell us at services@actogram.ai.
12. Changes to this Policy
We may update this Policy. A new version takes effect with the app release in which it appears; the app shows a notice on first launch after the update, and where a change requires it we will ask for your consent again. Versions are numbered and dated; previous versions are available on request.
13. Contact
Actogram Ltd · 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom · services@actogram.ai · +44 7473 968854