Effective Date: November 15, 2025
Last Updated: November 15, 2025
This Privacy Policy explains how River's Lab OY ("we," "us," or "our") handles information in connection with:
Data Controller:
Balázs Attila Szász
River's Lab OY
Aallonhuippu 3a 9
02320 Espoo, Finland
Email: hello@scrambledbrain.app
Your privacy is the foundation of everything we build.
Our promise to you is simple: We cannot see, access, share, or analyze your personal health data entered into the Scrambled Brain App. Period.
This isn't just a policy — it's how we built the software. Your tracking data never leaves your device. We have no servers that store your symptoms, moods, notes, or any other health information. This means we are physically unable to access, share, or sell your personal health data.
Important Legal Context:
Under the EU General Data Protection Regulation (GDPR) and Finland's Data Protection Act (1050/2018), health information is classified as "special category data" requiring extra protection (GDPR Article 9).
Here's why this matters for Scrambled Brain:
Because your health tracking data is stored exclusively on your device with 256-bit AES encryption, and because we have no technical ability to access it:
We only become a data controller for the limited technical data described in Sections 3 and 4 below.
What this includes:
Where it's stored:
Your control:
Legal basis:
To be crystal clear: We never collect, see, store, or manage any of your personal tracking data (symptoms, moods, notes, etc.). That data is yours and lives only on your device.
To help us fix bugs and improve the App's features, with your explicit consent, we may collect anonymous, aggregated usage analytics through PostHog (a privacy-focused analytics platform).
What we collect (only if you opt in):
What we DO NOT collect:
Legal basis: Your explicit consent (GDPR Article 6(1)(a))
How to opt in/out:
Data retention: Anonymous analytics data is retained for 24 months, then automatically deleted.
International data transfers: PostHog processes data in the EU and uses Standard Contractual Clauses (SCCs) for any transfers outside the European Economic Area. Read PostHog's privacy policy: https://posthog.com/privacy
One of Scrambled Brain's key features is generating professional PDF reports from your tracking data.
Important: When you generate and share a PDF report:
Note: Scrambled Brain is currently entirely free. We plan to introduce optional paid "Pro" features in the future (exact timing to be announced).
When subscription features become available:
Legal basis (when applicable): Performance of contract (GDPR Article 6(1)(b))
International data transfers: RevenueCat processes data in the United States under Standard Contractual Clauses. Read RevenueCat's privacy policy: https://www.revenuecat.com/privacy
When you visit our Site, our hosting provider automatically collects some technical data to ensure the site functions properly.
What we collect:
Why we collect it:
Legal basis: Legitimate interests (GDPR Article 6(1)(f)) — ensuring website security and functionality
Data retention: Server logs are automatically deleted after 90 days
Who has access: Our website hosting provider (details available upon request)
Our Site uses cookies — small text files stored on your device to make the website functional.
Essential Cookies (No Consent Required):
Analytics Cookies (Require Consent):
Your control:
Legal basis:
Under GDPR and Finnish law, you have the following rights regarding any data we process (i.e., website logs and analytics):
Request a copy of any data we hold about you
Request correction of inaccurate data
Request deletion of your data
Request that we limit how we use your data
Receive your data in a machine-readable format (though note: your App data is already portable via PDF export and lives on your device)
Object to processing based on legitimate interests
If you've consented to analytics, you can withdraw consent anytime without affecting past processing
File a complaint with the Finnish Transport and Communications Agency (Traficom), Data Protection Ombudsman:
How to exercise these rights:Email us at hello@scrambledbrain.app with "Data Rights Request" in the subject line. We will respond within 30 days.
Note on App data: Because your health tracking data is stored only on your device and we cannot access it, the above rights apply only to the limited data we process (website logs, analytics). You have complete control over your App data at all times.
We take security seriously, though the nature of our on-device architecture means your health data is inherently more secure than cloud-based alternatives.
For App data (on your device):
For data we process (website, analytics):
Your responsibility:
Age Requirement: Scrambled Brain is intended for users aged 16 and older (or the age of digital consent in your EU country, whichever is higher).
Parental Responsibility: If you are under 18, please use Scrambled Brain with a parent or guardian's knowledge and supervision.
No Intentional Collection: We do not knowingly collect personal data from children under the age of digital consent. If we become aware that we have inadvertently collected such data, we will delete it immediately.
For Parents: If you believe your child has provided us with data without consent, please contact us at hello@scrambledbrain.app.
We rely on a small number of trusted partners to provide our services. Each has their own privacy policy:
| Service | Purpose | Location | Privacy Policy |
|---|---|---|---|
| PostHog | Anonymous analytics (opt-in only) | EU-based | https://posthog.com/privacy |
| RevenueCat | Subscription management (future) | USA (SCCs) | https://www.revenuecat.com/privacy |
| Apple/Google | Payment processing (future) | Various | https://www.apple.com/legal/privacy/<br>https://policies.google.com/privacy |
Important: We do not share your personal health tracking data with any third party. These services only receive the specific technical data necessary for their function (as described above).
Primary operations: All primary data processing occurs within Finland and the EU.
Third-party transfers:
We ensure all international transfers comply with GDPR Chapter V requirements.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
How we'll notify you:
Your continued use of Scrambled Brain after changes take effect constitutes acceptance of the updated policy.
Version history: Available upon request at hello@scrambledbrain.app
Looking ahead: We're developing Scrambled Brain Insights, a companion app for healthcare professionals to create custom tracking templates for their patients.
When this launches:
We'll update this policy and notify you before Insights affects how Scrambled Brain works.
Questions about this Privacy Policy?
Email: hello@scrambledbrain.app
Data rights requests or complaints:
Email: hello@scrambledbrain.app
Subject: "Data Rights Request"
Data Protection Officer: Not applicable (River's Lab is a small operation not required to appoint a DPO under GDPR Article 37)
Supervisory Authority:
Finnish Transport and Communications Agency (Traficom)
Data Protection Ombudsman
Website: https://tietosuoja.fi/en/home
Email: tietosuoja@traficom.fi
✅ Your health data never leaves your device — we physically cannot access it
✅ You control everything — delete anytime, no accounts, no cloud storage
✅ Optional analytics are truly optional — and completely anonymized
✅ We're transparent — this policy explains exactly what we do (and don't do)
✅ You have rights — access, deletion, portability, and more under GDPR
✅ Currently 100% free — paid features coming later, but core tracking stays free
Questions? We're a small, human team in Finland. Email us anytime: hello@scrambledbrain.app
This policy complies with:
Last reviewed by legal: November 2025
The following gives a simple overview of what kind of personal information we collect, why we collect them and how we handle your data when you are visiting or using our website. Personal information is any data with which you could be personally identified. Detailed information on the subject of data protection can be found in our privacy policy found below.
Who is responsible for the data collection on this website?
The data collected on this website are processed by the website operator. The operator's contact details can be found in the website's required legal notice.
How do we collect your data?
Some data are collected when you provide them to us. This could, for example, be data you enter in a contact form.
Other data are collected automatically by our IT systems when you visit and use our website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the website. These data are collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.
What rights do you have regarding your data?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that your data be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
When visiting our website, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is usually anonymous, encrypted, and pseudonimized, meaning that we will not be able to identify you through this data. You can object to this analysis or prevent it by not using certain tools. Detailed information can be found in the following privacy policy.
The operators of this website take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy.
If you use this website, various kinds of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens.
Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
The party responsible for processing data on this website is:
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).
Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. Please note that data processed before we receive your request may still be legally processed.
If there has been a breach of data protection legislation, the affected person may file a complaint with the competent regulatory authorities.
You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
If you enter into a contract which requires you to send us your payment information (e.g. account number for direct debits), we will require this data to process your payment.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are only made via encrypted SSL or TLS connections. You can recognize an encrypted connection in your browser's address line when it changes from "http://" to "https://" and the lock icon in your browser line is visible.
In the case of encrypted communication, any payment details you submit to us cannot be read by third parties.
As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have your data be corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.
We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.
Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.
Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain in your device's memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.
Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored pursuant to Art. 6 paragraph 1, letter f of the EU DSGVO/GDPR. The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy.
The website provider automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) of the EU DSGVOGDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) of the EU DSGVOGDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.
Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract, for example, to companies entrusted to deliver goods to your location or banks entrusted to process your payments. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.
The basis for data processing is Art. 6 (1) (b) of the EU DSGVOGDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us, for example, to banks entrusted to process your payments.
Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.
The basis for data processing is Art. 6 (1) (b) of the EU DSGVOGDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
This website uses the open source web analytics service Matomo. Matomo uses so-called "cookies". These are text files that are stored on your computer and that allow an analysis of the use of the website by you. For this purpose, the information generated by the cookie about the use of this website is stored on our server. The IP address is anonymized before it is stored.
Matomo cookies remain on your device until you delete them.
The storage of Matomo cookies is based on Art. 6 (1) (f) of the EU DSGVOGDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising.
The information generated by the cookies about your use of this website will not be disclosed to third parties. You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website.
If you do not agree with the storage and use of your data, you can disable this feature here. In this case, an opt-out cookie will be stored in your browser to prevent Matomo from storing your usage data. If you delete your cookies, this will mean that the opt-out cookie will also be deleted. You will then need to reactivate it when you return to our site if you wish your activity not to be tracked.