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Privacy Policy

Last updated: May 3, 2026

1. Data Controller

The data controller responsible for the processing of personal data under Article 4(7) GDPR is:

Sadik Deniz Cakmak
Babenhäuserstraße 113
63322 Rödermark
Germany

Email: support@max-ly.app
Web: max-ly.app

For all privacy-related inquiries, please contact the email address above.

2. General Information on Data Processing

This Privacy Policy applies to the Maxly mobile application (the "App"), available for download from the Apple App Store and Google Play Store.

We process personal data only when necessary to provide the App and its features. Processing is based on your consent or when permitted by law.

3. What Data We Process

3.1 Local Data on Your Device

The following data is stored exclusively on your device and not transmitted to our servers:

This data does not leave your device, except in cases described in Section 3.2.

3.2 Data Sent to Our Services

When you use the AI coaching feature, the following data is transmitted to our servers:

Content data:

Technical data:

The following data is NOT sent to our servers:

3.3 Optional Data

Crash reports and error logs: If the app crashes, technical diagnostic data (stack trace, device model, operating system version) is anonymously transmitted via Sentry. This helps us fix bugs. You can disable this in app settings.

Anonymous usage analytics: We collect anonymized events via PostHog (e.g. "onboarding started", "task completed") to improve the app. No content of your inputs is tracked. You can disable this in app settings.

4. Purpose and Legal Basis

PurposeLegal Basis
Providing AI coaching functionalityArt. 6(1)(b) GDPR (contract performance)
Improving the app via anonymous analyticsArt. 6(1)(f) GDPR (legitimate interest)
Bug fixing via crash reportsArt. 6(1)(f) GDPR (legitimate interest)
Responding to your support requestsArt. 6(1)(b) GDPR

5. Sharing with Third Parties

We share your data with third parties only in the following cases:

5.1 Anthropic (AI Processing)

To generate personalized coaching content, we use the Claude API from Anthropic, PBC (548 Market St, PMB 90375, San Francisco, CA 94104, USA). Your inputs (goal, tasks, reflections) are transmitted to Anthropic for processing.

Anthropic processes this data in accordance with their own privacy policy: https://www.anthropic.com/legal/privacy

Anthropic is certified under Article 46 GDPR via Standard Contractual Clauses (SCCs). Anthropic does not use your data for AI training purposes (see Anthropic Commercial Terms).

5.2 Cloudflare (Hosting & Worker)

We use Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) as our backend infrastructure. Requests to our AI services are routed through Cloudflare Workers.

Privacy policy: https://www.cloudflare.com/privacypolicy/

Cloudflare is GDPR-compliant and uses EU data centers where possible.

5.3 Apple / Google

When you download the app and during crash reporting, data is processed by Apple (App Store) and Google (Play Store) according to their respective privacy policies.

5.4 Sentry (Crash Reporting, Optional)

If enabled, we use Functional Software, Inc. (Sentry) for error logging. Privacy policy: https://sentry.io/privacy/

5.5 PostHog (Analytics, Optional)

If enabled, we use PostHog Inc. for anonymous usage analytics. Privacy policy: https://posthog.com/privacy

6. Data Retention

7. Your Rights

You have the right to:

Competent supervisory authority:

The Hessian Commissioner for Data Protection and Freedom of Information
Postfach 3163
65021 Wiesbaden, Germany
Web: datenschutz.hessen.de

Send requests to exercise your rights to: support@max-ly.app

8. Children

Maxly is intended for users aged 17 and over. We do not knowingly process data from children under 17. If we become aware that a minor has provided us with data, we will delete it immediately.

9. Data Security

We use HTTPS/TLS encryption for all data transmissions between the app and our servers. Local data is stored in your device's protected app sandbox.

10. Important Notice on Coaching Content

Maxly is not a substitute for medical, psychotherapeutic, or other professional advice. AI-generated coaching content is based on general methodologies and is not intended as medical, therapeutic, or legal advice.

For mental health crises, please contact:

📞 Telefonseelsorge Germany: 0800 111 0 111 (free, 24/7)
🚨 In emergencies in Germany: 112 (Emergency Services)
🌍 For users in other countries: Please contact your local crisis helpline. International directory: findahelpline.com

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy when legal requirements change or the app introduces new features. The current version is always available at https://max-ly.app/privacy

Material changes will be announced within the app.