Chargewise Privacy Notice

Effective date: 28 October 2026 · Data controller: ANKYR+YRD LIMITED, Cayman Islands (privacy@chargewiseapp.net)

This Privacy Notice explains how ANKYR+YRD LIMITED collects, uses, and protects your sensitive health data in compliance with the Cayman Islands Data Protection Act (DPA), UK GDPR, EU GDPR, and US State Consumer Health Data Laws (including Washington MHMDA).

1. Data we collect and purpose

We process personal data solely to provide you with lifestyle pacing and reminder features:

Account data. Your name (as given when you were invited) and email address. The email address is used for passwordless sign-in, to tell you when your account is signed in on a new device, and to warn you before an inactive account is deleted.

Health data. Self-reported symptom logs, check-ins, custom reminders, day-type selections, salt and protein amounts (only if switched on), and weekly reviews. If you pair a Garmin watch with Chargewise Sync: your heart rate, Body Battery, steps, and overnight heart-rate variability.

Security data. IP address and device details of sign-ins. For each signed-in device: browser and device details, last used time, and current time zone. Passkeys: public key and device label (fingerprint/face data stays locally on your device). Browser notification details retained for delivery; notification history kept for 14 days. Device sign-in history is kept with your account until deleted. Inactive sign-ins end after 7 days and are deleted after 90 days. The sign-in log is kept for 180 days. If you pair a watch: its name and the IP address it was paired from.

Watch apps. Chargewise Pacing Face (watch face) shows your heart rate, Body Battery, stress, steps, and minutes above your limit locally. Chargewise Sync (watch app) sends heart rate (~1/min), Body Battery, steps, overnight HRV, and the watch's battery level and reading checks over encrypted connection every 15 mins. Readings and checks kept 14 days; daily summary figures kept with account. Watch data is used only for your own pacing: your day's suggested colour, questions about time above your heart-rate limit, and your summaries.

2. Lawful basis for processing

Health data (logs, check-ins, watch readings): UK/EU GDPR Art 6(1)(a) & Art 9(2)(a) — explicit consent; Cayman DPA Schedule 3 — explicit consent; US health laws — opt-in consent. Account & security data: UK/EU GDPR Art 6(1)(b) (contract performance) and Art 6(1)(f) (legitimate interest in account security).

3. Explicit consent mechanisms

Sign-up. Before first use, you tick two boxes. Checkbox 1: "I agree to the Terms of Use and Privacy Notice." Checkbox 2: "I explicitly consent to ANKYR+YRD LIMITED processing my sensitive health data (symptom logs, check-ins, pacing reminders, and paired watch readings) to provide Chargewise. I can stop new watch readings at any time by unpairing my watch, or withdraw consent for stored data by deleting my account." You also confirm that you are 18 or older. The time and version of your agreement are recorded.

Weekly summary emails (off by default). If you enable weekly summary emails in Settings, a summary of your health data, including your watch's readings if one is or was paired, is sent via standard email to your registered address. Standard email is not end-to-end encrypted. You may disable this at any time.

4. Infrastructure and international transfers

Cloudflare. App logic runs on Cloudflare Workers (nearest data center). Primary storage in Cloudflare D1 (Eastern North America). Covered under Cloudflare Standard Contractual Clauses (SCCs) and UK Addendum. Notifications deliver empty wake-up pings through browser push services (Google, Apple, Mozilla, Microsoft). Garmin transfers data via Connect app under user's Garmin terms.

Backups. An encrypted copy of the database is made each night and kept in Cloudflare R2; the 30 most recent copies are kept and older ones are deleted. Only ANKYR+YRD LIMITED holds the key that decrypts them, and uses it only to restore the service.

Resend. Transactional emails (sign-in links, new-device and inactivity notices, and opt-in weekly summaries) are dispatched via Resend under standard UK/EU SCC data transfer addenda.

Operator access. Chargewise has no screen for browsing users' health data. ANKYR+YRD LIMITED's administrators can reach the database through the company's Cloudflare account, and use that access only to run and support the service, such as confirming an account exists or restoring from a backup, never to read health records for any other purpose.

5. Data retention and deletion

User-initiated deletion. You can delete your account and all associated health records within app settings. Deleted data is removed from the database at once. It remains for up to 30 days in Cloudflare's point-in-time recovery history, and in the encrypted backups until they are replaced by newer ones (normally within about 30 days). A technical deletion log (holding an unidentifiable account ID and timestamp) is kept for 365 days solely to re-apply account deletions if a database backup is restored.

Inactivity policy. Accounts inactive for 12 consecutive months are automatically deleted from Cloudflare D1 databases, preceded by an email warning at month 11.

If Chargewise ends. If Chargewise ever ends, we will provide at least 12 months' advance notice by email and in the app. Your data remains fully exportable throughout the notice period and will be permanently deleted when the service closes.

6. User rights and contact

You have the right to access, export, rectify, or delete your personal data. Contact privacy@chargewiseapp.net. To request an update to your sign-in email address, contact privacy@chargewiseapp.net.

You can reach our UK and EU representatives directly at privacy@chargewiseapp.net.

You can also complain to the Cayman Ombudsman, the UK ICO, or your local EU data protection authority.

7. Cookies

2 essential cookies (30-day session, 400-day device recognition). Offline entries stored locally until sent.

8. Security advice

Lock your phone. To hide reminder titles on lock screen, toggle Settings → Notifications → 'Show reminder names'.

US Consumer Health Data Notice

For users in the US, including under Washington's My Health My Data Act: the consumer health data we collect, why, and its sources are in §1; we do not sell it, and share it only with the service providers in §4; you can access, export or delete it (§6).