Legal
Bornly Privacy Policy
Effective date: October 30, 2026
Version: 9
Controller: Bornly ApS ("Bornly", "we", "us")
Health, pregnancy, nutrition, sleep, and well-being information can be highly sensitive. This Policy explains what Bornly processes across its websites and Services, why, with whom, for how long, and what choices you have.
1. Who we are
Bornly ApS, CVR 39857340, is the controller for the processing described here.
Privacy requests: privacy@bornly.com
Support: support@bornly.com
Privacy questions and data-protection requests may be sent to privacy@bornly.com.
2. Scope
This Policy covers Bornly websites, accounts, apps, APIs, support, subscriptions, notifications, widgets, and related features, including Gutly, Crunchly, Pregnancy/Gestatly, Contraction Timer, Baby Names, Night Lab, and Perkly. A point-of-use notice may give additional details and controls for a particular feature.
Third-party services you use independently, such as Apple, an app store, a healthcare provider, or a person you invite, have their own privacy practices.
3. Key commitments
- We do not sell personal data or consumer health data, including for monetary or other valuable consideration.
- We do not use personal data for cross-context behavioural advertising.
- We process health and similarly sensitive data only with an applicable legal basis and explicit consent where required.
- This Policy identifies Bornly's AI uses. AI features are user-selected or described in the relevant experience, and an affirmative choice is used where consent is required.
- We limit AI requests to content and context reasonably needed for the selected feature. Text, images, names, health records, or combinations of information you submit may still identify you.
- You may withdraw consent and request access, correction, export, restriction, objection, or deletion as applicable.
4. Data we collect
4.1 Account and relationship data
- name, email, password hash, language, time zone, settings, account and consent status;
- authentication tokens, Sign in with Apple data, security events, and device registrations;
- app, group, partner, invitation, and permission relationships;
- subscription, entitlement, transaction, refund, and limited billing metadata. Payment providers, not Bornly, handle full card numbers.
4.2 Data by app and feature
| Service or feature | Data you may provide, import, or generate |
|---|---|
| Gutly | Food and meal logs or photos; ingredients and nutrition; symptoms, bowel movements, mood, stress, optional birth date, optional sex or gender, weight and other body data; scores, summaries and patterns; food notes; goals; AI-assisted food actions or conversations where offered; and feedback |
| Crunchly | Food and meal logs or photos; nutrition and energy data; body mass; user-selected display goals and preferences; AI-assisted food recognition, logging, or conversations where offered |
| Pregnancy/Gestatly | Pregnancy dates and status, due date, cycle or birth-related details; body, mood, temperature, heart, activity, kick and contraction logs; maternity-contact details; pregnancy content interactions; partner-sharing choices |
| Contraction Timer | Contraction timestamps, duration, frequency, pain ratings, timing sessions, maternity-contact details, user-configured reminder state, Live Activity state, and optional partner notification data |
| Baby Names | Country and naming preferences; viewed, liked, disliked, excluded, favourite, group and partner activity; gender filter; AI prompts and up to 12 messages from the same suggestion conversation; first, optional middle, and last name entered for full-name analysis |
| Night Lab | HealthKit sleep records you authorise, self-reported sleep and rested scores, check-ins, comparison-routine choice, adherence, notes, experiment metrics, and generated summaries or reports |
| Perkly | Caffeine drinks, estimated dose and a curve based on a five-hour default half-life that may be adjusted by selected factors, bedtime and display settings, reminders, history, and, after you grant Apple's permission, caffeine entries written to HealthKit where the integration is active |
| Support and feedback | Message, reply address, survey answer, app context, and optional screenshot or attachment |
Not every app collects every category. Collection depends on what you use and choose to enter.
4.3 Automatically collected technical data
We may collect IP address, request time, app and build version, operating system, device model, locale, time zone, subscription state, authentication and security events, feature-interaction events, request diagnostics, error information, and service logs. We use this data to operate, secure, troubleshoot, measure, and improve the Services, subject to available settings and consent requirements.
When an app retrieves articles, symptom definitions, symptom groups, or app-specific content from the Waastly/CDN content service, the service receives or can receive IP and request metadata, app and language, collection or document identifiers, and the requested article category or feature identifier. Bornly does not intentionally send the user's account profile, journal entries, HealthKit records, or health-log payload in these content requests. Requested identifiers can nevertheless reveal an interest in health-related content.
The public website and in-app cross-promotion can also load fixed marketing or app images from Waastly/CDN. The provider receives IP and request/device metadata, referrer information where sent, and the fixed asset path, which can reveal the visited Bornly page or app context. These fixed image URLs do not intentionally contain an account identifier, journal entry, HealthKit record, or health-log payload.
Crunchly can stream a fixed onboarding video from Cloudflare Stream. Cloudflare receives IP and request/device metadata plus the fixed video identifier, which reveals the Crunchly app context. The video request does not intentionally contain an account identifier, journal entry, HealthKit record, body measurement, goal, or other health-log payload.
Pregnancy/Gestatly loads a static pregnancy image from Imgix. Imgix receives IP, request and device/browser metadata and the static asset path, which identifies the Pregnancy app context. The URL does not include the user's account, pregnancy week, due date, journal entries, or other pregnancy record.
When feedback AI or automated support triage is offered and selected, its prompt may include the submitted text, attachments, app context, account or subscription context, and a diagnostic snapshot such as app/build, OS/device, locale/time zone, usage totals, accessibility settings, and error information. We seek to minimise and, where appropriate, redact this material, but free text and attachments may still contain personal or sensitive data.
Where enabled, free apps may show clearly labelled ads for other Bornly apps. Campaign selection uses the current app and placement, not health entries, pregnancy stage, symptoms, food logs, sleep records or HealthKit data. Premium access, active trials and lifetime unlocks remove automatic ads in the current app. Device-local history stores display and dismissal times to limit frequency, even when analytics is off. Usage analytics measures campaign impressions, clicks, dismissals, report-flow openings and purchase-flow entries. When the same account is identified in more than one Bornly app, we may match a recommendation click to first use and provider-confirmed purchases in the recommended app. This does not identify every download and uses no fingerprinting or third-party advertising identifier. You may turn off usage analytics in Settings; ads and their local frequency limits continue without measurement.
4.4 Data from others and integrations
- Apple HealthKit data categories you separately authorise;
- app-store and RevenueCat purchase or entitlement events;
- Sign in with Apple account information selected by you;
- content or status shared by an invited partner or group participant;
- content and nutrition reference data from providers and public datasets.
If another person provides identifiable information about you, we use it only for the stated relationship or shared feature and provide this Policy or an equivalent notice at invitation, first contact, or first disclosure where GDPR Article 14 requires it. We may delay or omit individual notice only where law permits and appropriate safeguards apply.
HealthKit permission may be changed in device settings. Bornly does not use HealthKit data for advertising or sell it.
One Bornly account and shared data model can make compatible records available across more than one Bornly app. For example, a food or caffeine record created in one app may appear in another app that uses the same food journal. The receiving app processes the record under this Policy and its point-of-use notices.
5. Why we process data and legal bases
| Purpose | Typical data | GDPR legal basis |
|---|---|---|
| Create accounts, sync, deliver requested features, exports, and support | Account, content, device, support | Contract, Art. 6(1)(b) |
| Process health, pregnancy, biometric-related, or similarly sensitive content | Health and well-being data | Explicit consent, Arts. 6(1)(a) and 9(2)(a), where Bornly has obtained it; otherwise a feature-specific notice must identify another valid Art. 6 basis and Art. 9 condition before that processing begins |
| Deliver requested articles, symptom definitions, and localized app content | IP/request metadata, app/language, collection/document and article category or feature identifiers | Contract, Art. 6(1)(b); explicit consent under Art. 9(2)(a) where a requested identifier reveals health-related activity |
| Provide user-requested meal AI where the input can reveal health data | Meal descriptions/photos and AI-created meal-log edit instructions | User's requested AI action and consent where relied upon; explicit consent where special-category data is included, Arts. 6(1)(a) and 9(2)(a) |
| Extract or check a user-requested public food-catalogue contribution | Product labels/photos, food submissions or corrections, and relevant catalogue context | User's requested AI action and consent where relied upon; explicit consent where submitted content includes special-category data, Arts. 6(1)(a) and 9(2)(a) |
| Process optional feedback with AI | Feedback and diagnostic snapshot | Consent, Art. 6(1)(a); explicit consent if special-category data is included |
| Provide paid access and records | Subscription and transaction data | Contract, Art. 6(1)(b); legal obligation, Art. 6(1)(c) |
| Security, abuse prevention, service integrity, and defence of claims | Technical, audit, and account data | Legitimate interests, Art. 6(1)(f); legal obligation where applicable |
| Measure and improve the apps with first-party usage analytics | App-usage events, app version, device model and OS version, and Bornly user ID | Legitimate interests in understanding and improving our apps, Art. 6(1)(f); on by default, and you can object at any time with Settings > General > Usage analytics |
| Reliability and security | Request and diagnostic data | Legitimate interests with balancing, Art. 6(1)(f); consent where a non-essential future analytics feature requires it |
| Draft or translate surveys, analyse research, and create internal product or marketing drafts | Staff briefs, product materials, survey text and responses, aggregated results, and app business context | Legitimate interests in product research, localisation, and responsible marketing, Art. 6(1)(f); consent, including explicit consent, where required for submitted responses or sensitive data |
| Send service messages | Contact and account status | Contract or legitimate interests |
| Send marketing | Contact and preferences | Consent where required; otherwise a locally permitted basis with opt-out |
| Comply with law and respond to authorities | Relevant records | Legal obligation, Art. 6(1)(c), or legitimate interests |
Bornly displays or links the applicable Terms, Privacy Policy, and medical or AI notices in its apps. Account creation records acceptance of the Terms and acknowledgement of the Privacy Policy. Some features, including certain health-AI, feedback-AI, HealthKit, partner-sharing, marketing, or research flows, present an additional choice. Where Bornly relies on consent, the feature must obtain a valid choice for the relevant purpose and categories before that processing begins. Bornly may record the document or notice version, app, account or device, choice, and time.
You may withdraw consent through an available in-app control or privacy@bornly.com. Withdrawal applies to future processing and does not make earlier lawful processing unlawful. It does not automatically delete existing records or output; deletion can be requested separately. Refusing or withdrawing a consent can make the feature that needs it unavailable, but we do not make optional processing a condition of unrelated access unless the processing is genuinely necessary for the requested service.
Questionnaires, feedback, partner sharing, and other optional flows may have their own notices and choices. Free text and attachments can contain sensitive data, so provide only information you are authorised and comfortable to submit. Required account data generally includes the sign-in and legal-acceptance information needed to create and secure an account; other profile, health, photo, HealthKit, sharing, survey, marketing, feedback, and AI fields depend on the feature you choose.
6. AI processing
Our AI Policy describes each AI use in more detail.
OpenAI currently provides Bornly's external generative-AI processing. Depending on the feature, a request may include meal descriptions or photos; product, barcode, ingredient-list, or nutrition-label images; food submissions or corrections; health, nutrition, sleep, pregnancy, or lifestyle records selected for a requested analysis or conversation; baby-name preferences, conversation history, or a name entered for analysis; feedback and diagnostics; survey or research material; catalogue content; and the generated output needed for a follow-up request.
Bornly may also use AI for internal or operational work such as food-catalogue enrichment, translation, survey drafting or analysis, feedback triage, support drafts, product research, quality review, and marketing drafts. The input can include user content or sensitive data when the stated purpose and legal basis allow it. We seek to minimise inputs, restrict access, and use aggregated or de-identified information where it is sufficient. Human review is required before consequential external action, but machine translations, suggestions, or other low-risk output may be displayed without individual review.
Feature availability changes over time. Free text, images, names, health records, account or display names, or a rare combination of facts may identify a person. A feature that analyses a full name necessarily sends the entered name. This Policy describes the material categories and purposes even where a shorter in-app notice does not repeat every detail.
We do not authorise AI providers to train general-purpose models on Bornly API inputs or outputs. Under OpenAI's current API data controls, API content is not used for training by default and default abuse-monitoring content may be retained for up to 30 days unless an approved shorter-retention control applies or law requires longer. See the Subprocessors page for the current provider and location information.
Bornly may store source records, prompts, generated output, conversation messages, usage totals, model or feature identifiers, diagnostics, and timestamps so a requested feature works, history can be shown, limits can be enforced, quality and safety can be reviewed, and incidents can be investigated. Withdrawal stops future optional processing; it does not automatically delete existing source records or outputs. Use an available deletion control or contact us for deletion.
Bornly does not use generative AI to make solely automated decisions that produce legal or similarly significant effects about users. We may use permitted AI to classify feedback and draft responses or engineering issues; humans remain responsible for consequential action.
7. Partner, group, and public sharing
Partner and group features share only after an invitation, join, or other user action. Depending on the feature, recipients may see profile names, pregnancy/labour status, contraction metrics, hospital details, baby-name preferences and votes, or group activity. The relevant screen shows what is shared. Invitees receive this Policy or an equivalent privacy notice when Bornly first contacts them or exposes shared data where required.
Invited people act independently when they receive and use data for their own purposes. They can copy or screenshot it. Revoke access when appropriate, but revocation cannot retrieve copies already made.
Bornly does not make health logs public by default. If a future feature permits public posting, it will use a separate, clear sharing action and notice.
8. Recipients
We disclose data only as needed:
- to infrastructure, storage, content-delivery, email, subscription, payment, customer-operations, and AI providers acting under contract;
- to USDA FoodData Central when a requested barcode lookup needs an external public food reference; the service receives the product barcode and Bornly server request metadata, not the user's account identifier or health-log payload;
- to Apple and app stores for distribution, purchases, push delivery, Sign in with Apple, HealthKit, widgets, or platform functions you use;
- to people you invite or direct us to share with;
- to advisers, auditors, insurers, or transaction parties subject to appropriate duties;
- to authorities or others where legally required or necessary to establish, exercise, or defend legal claims, protect rights and safety, or address fraud and security; or
- in a merger, financing, reorganisation, insolvency, or sale, with notice and protections required by law.
The Subprocessors page lists current processors and operational recipients. We do not sell or rent personal data and do not share it for cross-context behavioural advertising.
9. International transfers
Bornly is in Denmark. Providers may process data in the EEA, United States, or other countries listed on the Subprocessors page. For restricted EEA or UK transfers, Bornly uses an applicable adequacy decision, the European Commission's Standard Contractual Clauses with the UK addendum where needed, or another lawful safeguard, together with required assessments and supplementary measures. You may request a copy or description of the safeguard used for your data.
10. Retention and deletion
We keep personal data only while needed for the stated purpose, account operation, consent evidence, security, legal compliance, or claims. Criteria include whether your account is active, whether a record remains user-visible, statutory accounting periods, dispute limitation periods, security risk, and backup cycles.
Typical rules and deletion-path limitations are:
- account and primary synced user content: while the account or record exists, then deletion or de-identification after a valid request subject to legal exceptions;
- AI conversations, source inputs, outputs, feedback, support material, analytics, survey responses, consent evidence, and audit records: for the applicable feature, research, security, support, compliance, or claims period; these records may require a verified privacy request and may not all be removed automatically by the in-app account-deletion workflow;
- current, revoked, and superseded consent records: only while needed to administer the choice and demonstrate compliance, subject to applicable limitation periods and legal holds;
- transaction and tax records: for the statutory accounting period, generally five years after the relevant financial year in Denmark;
- support, security, and incident records: for the period needed to resolve the matter, prevent abuse, and establish or defend claims;
- raw survey responses: for the disclosed research or product-improvement window, until a valid deletion request is completed, or until a legal hold ends; aggregate or de-identified research may be retained separately where it can no longer be linked to a person;
- backups: removed through the normal protected-backup rotation and not restored except for continuity or security recovery.
Deleting an app does not delete a Bornly account. Account deletion can be requested in-app where available. To request deletion across relevant operational systems and recipients, or if an in-app deletion does not cover a record, email privacy@bornly.com. Bornly will verify and complete the request as required by applicable law. Data kept solely on a device must be removed through the app, device, or platform controls. Platform subscriptions must be cancelled separately.
11. Security
We use measures proportionate to the sensitivity and risk, including transport encryption, password hashing, access restrictions, authentication, logging, backups, environment separation, and data minimisation. No system is completely secure. Contact support@bornly.com promptly if you suspect a security issue.
12. Your rights
Depending on law and circumstances, you may request:
- access and a copy;
- correction;
- deletion;
- restriction;
- portability;
- objection to legitimate-interest processing or direct marketing;
- withdrawal of consent;
- information about international safeguards; and
- review of an automated decision, although Bornly does not currently make covered solely automated significant decisions.
Email privacy@bornly.com. We may verify identity and clarify scope. We normally respond within one month under GDPR, subject to lawful extensions. Rights can have exceptions, and we will explain a refusal.
You may complain to the Danish Data Protection Agency, Datatilsynet, or your local supervisory authority. Contacting us first is welcome but not required.
Washington residents have additional rights described in our Washington Consumer Health Data Privacy Policy. Nevada residents may also request confirmation, access, a list of relevant third parties, correction, withdrawal of consent, deletion, and appeal under Nevada consumer-health-data law by using the same contact methods. We will not discriminate for exercising a privacy right.
You may review or change records through available journal, profile, account, and settings controls or request correction at privacy@bornly.com. Third-party providers can collect consumer health data over time and across different Bornly websites, apps, or provider services when their hosting, content-delivery, platform, support, analytics, or selected feature is used. This can include IP/device/request metadata, requested health-content identifiers, and the feature data described in Sections 4 and 8. Bornly authorises that collection only for the disclosed service purposes, not cross-context profiling or advertising.
13. Cookies, analytics, and communications
Website app invitations and tools send first-party event counts with the app, placement, public page path, broad device category and acquisition category (such as search or referral). The first page in a document's navigation chain is held in memory only; a full navigation resets it. Raw referrer URLs, URL queries, calculator inputs and health records are excluded. These events do not identify unique visitors or prove app installation. QR opens identify the invitation page, with acquisition source unknown. Event detail is capped near 100,000 records; daily counts expire after 400 days. Where configured, App Store campaign links carry only the app, link method and broad source category. Apple reports installation metrics separately, subject to its privacy thresholds.
Our website may use storage for security, sessions, preferences, requested functions, analytics, or marketing. Non-essential analytics or marketing cookies require consent where applicable. Apps record first-party usage events, linked to your Bornly user ID, to operate, measure and improve them. Usage analytics are on by default; you can turn them off at any time in Settings > General > Usage analytics, which stops recording and deletes events still queued on the device. Bornly apps use no advertising identifier (IDFA), no App Tracking Transparency tracking and no third-party analytics or advertising SDK.
Operational messages about security, purchases, service changes, or requested features are not marketing. Marketing messages include an unsubscribe method. Withdrawing marketing consent does not stop essential service communications.
14. Children
The Services are for adults and are not directed to children under 18. We do not knowingly create accounts for children. Contact us if you believe a child has provided personal data; we will investigate and delete it where required.
15. Breach notification
We investigate suspected personal-data incidents and notify authorities and affected people when law requires. Depending on scope, this can include GDPR notification to a supervisory authority, U.S. state notices, and the U.S. FTC Health Breach Notification Rule for covered health apps.
16. Changes
We may update this Policy when products, vendors, or laws change. The page shows the version and effective date. We will give appropriate notice of material changes and seek renewed consent where a change requires it. Prior versions may be requested from privacy@bornly.com.