MOVE YS Privacy Policy
MOVE YS is planned to run as two services: one for Russia and an international one. During the beta, only the Russian service is operating — the app is offered to people in Russia, and records are stored in a database located in Russia.
- If you live in Russia, the Russian version applies: Политика конфиденциальности (in Russian). It is the one in effect today.
- Everyone else — the text below. It was written in advance for the international service, which has not launched yet. It does not apply to anyone today and is published so that it can be read before it does.
MOVE YS Privacy Policy
Version 1.1 of September 24, 2026
THIS DOCUMENT IS NOT YET IN EFFECT.
For the duration of the beta test, MOVE YS operates only in the Russian service: the app is offered to people in Russia, records are stored in a database located in the Russian Federation, the international service has not been launched, and users outside Russia are not being accepted. This document takes effect on the day the international service is launched, and not earlier. Until that day, the Russian documents apply:
https://move-ys.ru/privacy(in Russian) andhttps://move-ys.ru/terms(in Russian).This text has been published openly in advance so that it can be read and reviewed before it starts to apply. It contains no commitments that bind anyone as of today.
This policy is written for those who selected a country outside Russia during registration. It has been prepared in accordance with the requirements of the EU General Data Protection Regulation 2016/679 (the "Regulation", also known as the GDPR), Articles 13 and 14, and applies to all users of the international service, wherever they are located.
If you selected Russia, a different document applies to you: https://move-ys.ru/privacy. It involves a different database, a different operator and a different governing law.
Contact details
- Data controller (operator): Individual Entrepreneur ԳԱՐԻՊՈՎ ԻՍԼԱՄ ԻԼՇԱՏԻ (Garipov Islam Ilshati), Republic of Armenia, state registration number 286.1574480, taxpayer identification number (ՀՎՀՀ) 20245109, address: Republic of Armenia, Yerevan, Malatia-Sebastia administrative district, Hovhannisyan Street (Հովնաթանի), building 14, apartment 32
- Representative in the European Union (Article 27 of the Regulation): not appointed. The international service has not been launched, and there are no users in the European Union. A representative will be appointed and named here before the service starts operating; until that day this document is not in effect — see the notice above.
- Data Protection Officer: not appointed for the same reason. Whether MOVE YS is required to appoint one under Article 37 of the Regulation is a question for a lawyer; the author of this text is not a lawyer and has not attempted to make up an answer.
- E-mail for any data-related requests: move-ys@pomogatorapp.ru
You may contact us at the e-mail address above, in the language of your country or in English. As soon as a representative in the European Union is appointed, their contact details will appear here, and you will also be able to contact them.
1. What MOVE YS is
MOVE YS is an app for personal records: tasks, habits, calendar, notes and journal, finances, as well as health sections: menstrual cycle, sleep and well-being, nutrition, body measurements. It includes a voice assistant, Mo.
Mo is a program, not a person. We state this plainly, as required by Article 50 of the EU Artificial Intelligence Act: you are interacting with an artificial intelligence system. Mo makes mistakes, and what it says does not constitute medical, legal or financial advice.
2. What data we process
2.1. Account
Profile name, e-mail address, phone number (if you provided it), login and password hash, PIN hash and lock settings, time zone, language, currency, units of measurement, subscription details, list of your devices (name, platform, date of last sign-in).
Passwords and PINs are not stored in plain text anywhere. The PIN hash is not transmitted to the server.
2.2. Your records
Tasks and projects; habits; calendar events and reminders; notes, journal, quotes, drafts; photo of the day; contact details of other people that you enter; counters and goals; financial transactions, including photos of receipts.
2.3. Special category data (Article 9 of the Regulation) — health data
Menstrual cycle (dates, symptoms, nature of discharge, mood, notes, pregnancy markers); well-being and symptoms, including blood pressure and medications; sleep and activity; body measurements; nutrition and nutrition questionnaire; anything you yourself write about your health in the journal, notes or the assistant's memory.
Menstrual cycle data constitutes both data concerning health and data concerning sex life. We process it only on the basis of your explicit consent (see Section 3).
2.4. The Mo assistant
Your conversations with the assistant; the assistant's memory about you — brief facts that you asked it to remember or that it inferred from the conversation; technical details of requests (model, volume, cost).
2.5. Technical data
A log of your actions in the app (for points, achievements and statistics) and a log of security events (sign-ins, granting and withdrawal of consents, deletions).
2.6. What we do not collect
No geolocation. No advertising identifiers, trackers or analytics SDKs. No access to your contacts, calls or SMS. No background audio recording. There are no ads in the app at all. We do not buy data about you from third parties and do not enrich your profile with external sources.
3. Purposes and legal bases
The Regulation requires the legal basis to be stated separately for each purpose. Here they are.
| Purpose | Data | Legal basis |
|---|---|---|
| Creating and maintaining an account, providing access to the app | 2.1 | Article 6(1)(b) — performance of a contract with you (the user agreement) |
| Storing and displaying your records, synchronising them across devices, sending reminders you have set up | 2.2 | Article 6(1)(b) — performance of a contract |
| Operating the health, cycle, nutrition and measurements sections | 2.3 | Article 9(2)(a) — your explicit consent; for ordinary data, Article 6(1)(a) |
| Operating the voice assistant: speech recognition, carrying out requests | 2.4 and whatever data from 2.2–2.3 the request concerns | Article 6(1)(b) for the assistant function and Article 9(2)(a) — your explicit consent as regards health data |
| Handling support requests | 2.1 and the text of the request | Article 6(1)(b) and 6(1)(f) — our legitimate interest in responding to users |
| Security of the service, prevention of abuse and fraud | 2.5 | Article 6(1)(f) — our legitimate interest in protecting the service and your data from unauthorised access. We have balanced this interest against your rights: only technical logs are processed, not the content of your records |
| Subscription accounting and compliance with tax obligations | purchase details | Article 6(1)(c) — compliance with a legal obligation |
Whether providing data is mandatory. Your account and the content of your records are necessary to provide the service: without them the app cannot work, and the contract cannot be performed. Health data and use of the assistant are optional: without them the app works, just without the corresponding sections and without the assistant.
4. Consent: how we obtain it and how you withdraw it
We obtain consent to process health data through a clear affirmative action: a separate screen with clear wording and an unticked box by default, separate from acceptance of the user agreement. We do not use pre-ticked boxes, "bundled" consents or "by continuing, you agree".
You may withdraw your consent at any time — via "Settings → Consents → Withdraw" or by writing to move-ys@pomogatorapp.ru. Withdrawing consent is as easy as giving it. Withdrawal does not affect the lawfulness of processing carried out before it (Article 7(3) of the Regulation).
What happens after withdrawal is described in Section 8.
5. Voice, photos and the Mo assistant
Your voice leaves your device. When you tap the microphone, the app records audio and transmits the recording to an external language model. The same applies to photos you send to the assistant.
What is sent: the entire phrase (it may contain anything, including information about your health); the assistant's memory about you; the titles of your records in the sections the request concerns; photos you send; technical details of the request.
What is not sent: records made without involving the assistant; sections you have closed off from the assistant; your password and PIN; your name, e-mail and internal identifier — requests to the model are de-identified.
Who the recipient is: the Unifically service (unifically.com), an intermediary providing access to language models, and the model providers to which it routes the request (OpenAI, Google, Anthropic, xAI; speech recognition — Deepgram — the specific model depends on the task). We choose the provider and settings so that request texts are not stored longer than necessary to produce a response and are not used for training.
How to opt out: turn the assistant off entirely, or close off individual sections from it, or do not use voice. The app remains a fully functional journal and planner.
6. Who we share data with
| Recipient | What | Role | Where |
|---|---|---|---|
| Supabase, Inc. | everything you synchronise | processor under a data processing agreement (Article 28 of the Regulation) | data is hosted in a European region; the company itself is located in the United States |
| The Unifically service (unifically.com), an intermediary providing access to language models, and language model providers | data described in Section 5 | processors under a data processing agreement | United States and other countries outside the EEA |
| App store (App Store, Google Play) | the fact and amount of a purchase | independent controller of its own data | according to the store's rules |
| Individual Entrepreneur ԳԱՐԻՊՈՎ ԻՍԼԱՄ ԻԼՇԱՏԻ (Garipov Islam Ilshati), Republic of Armenia | staff access to data for support and administration | controller | outside the EEA |
| Public authorities | what is specified in a lawful request | — | as required by law |
We do not sell your data, do not share it with advertisers, insurers, banks or employers, and do not use it for advertising.
The current list of processors is published on this page and updated when changes occur.
7. Transfers of data outside the European Economic Area
Some processing takes place outside the EEA: our staff are located in the Republic of Armenia, the model providers are in the United States, and the hosting company is registered in the United States, although it hosts data in a European region.
We carry out such transfers on the basis of standard contractual clauses adopted by the European Commission (Article 46(2)(c) of the Regulation), concluded with each recipient, and — where the recipient participates in the EU-U.S. Data Privacy Framework — on the basis of the corresponding adequacy decision (Article 45). Before each transfer to a country without an adequacy decision, we carry out a transfer impact assessment and apply supplementary measures: de-identification of requests, encryption in transit, and a prohibition on the recipient storing the content of requests or using it to train models.
You can obtain a copy of the standard contractual clauses by writing to move-ys@pomogatorapp.ru. We will send it with the commercial terms redacted.
8. How long we keep data
| What | Retention period |
|---|---|
| Your account and your records | for as long as the account exists |
| A record you have deleted | until the trash is emptied; once emptied, it is destroyed, including on the server |
| All content upon deletion of the account | destroyed immediately and completely — no later than 30 days, including backups |
| Health data upon withdrawal of consent | records in the "Cycle", "Sleep", "Activity", "Body measurements" and "Nutrition" sections are destroyed immediately — both on the device and on the server, including items in the trash; backups — no later than 30 days. Records in other sections are not affected by this withdrawal |
| Conversations with the assistant and its memory upon withdrawal of consent to the transmission of speech | not destroyed: this withdrawal stops the transmission of your speech to the external model, but does not erase what you have already written. You can delete conversations yourself — in the conversation list |
| Security event log | 12 months |
| Records of granting and withdrawal of consents | 3 years after withdrawal or account deletion — as evidence of the lawfulness of processing |
| Payment documents | the period established by the tax legislation of the operator's country |
Before destroying health data, we will offer you the option to export it as a file.
9. Your rights
Under the Regulation, you have the right to:
| Right | Article | How to exercise it |
|---|---|---|
| Access your data and information about the processing | 15 | Settings → My data; or write to us |
| Rectify inaccurate data | 16 | directly in the app |
| Erase data ("right to be forgotten") | 17 | Trash; Settings → Delete account |
| Restrict processing | 18 | write to move-ys@pomogatorapp.ru |
| Receive data in a machine-readable format and transmit it to another service | 20 | Settings → Export data (JSON and CSV) |
| Object to processing based on legitimate interests | 21 | write to move-ys@pomogatorapp.ru |
| Withdraw consent at any time | 7(3) | Settings → Consents |
| Not be subject to a decision based solely on automated processing | 22 | we make no such decisions, see Section 10 |
| Lodge a complaint with a supervisory authority | 77 | with the data protection authority of your country of residence or of the place of the infringement |
We respond within one month of receiving a request. If a request is complex or there are several requests, this period may be extended by a further two months, and we will inform you of this and explain the reason (Article 12(3)). Responses are free of charge; a fee may be charged only for manifestly unfounded or repetitive requests.
How we verify your identity. We treat a request made from the app as coming from you if you are signed in to your account. We act on a request sent by e-mail if it comes from the address specified in your account, or after confirmation with a one-time code. This protects against a third party exporting or deleting your data.
10. Automated decision-making and profiling
We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Article 22 of the Regulation).
Cycle predictions, calorie counts, points and achievements are calculations based on your own records and are shown only to you. They do not evaluate your personality, do not affect access to services and are not shared with anyone.
11. Children
The app is not intended for persons under 16 years of age. We chose 16 — the upper limit of the range set by Article 8 of the Regulation — so that the threshold works for all countries. If you are a parent and discover that a child under 16 has created an account, write to move-ys@pomogatorapp.ru: we will delete it and all associated data.
12. How we protect data
- access to data is restricted at the level of the database itself: each user sees only their own rows;
- the connection between the app and the server is encrypted;
- passwords and PINs are stored only as an irreversible hash;
- access to the app can be locked with a PIN or biometrics, and individual sections can be locked;
- a security event log is maintained;
- a data processing agreement under Article 28 of the Regulation has been concluded with each processor;
- a data protection impact assessment has been carried out (Article 35), since we process special category data; it is reviewed whenever the processing changes.
What we do NOT do, and you should know this. Records in the health sections are not encrypted with a separate key either on the device or on the server: they are stored in the same way as your other records. This is a deliberate choice, not an oversight — records encrypted with a separate key cannot be searched and cannot be synchronised across your devices, and losing the key would mean losing the section forever. The PIN and section lock restrict access to the records, not the records themselves. We preferred to say this plainly rather than promise protection that does not exist.
13. Personal data breaches
If a personal data breach occurs that poses a risk to your rights and freedoms, we will notify the supervisory authority within 72 hours of becoming aware of it (Article 33), and where the risk is high, we will also inform you without undue delay (Article 34), explaining what happened and what to do.
14. Changes to this policy
A new version is published on this page with its date and version number; previous versions remain available. We notify you of material changes in the app in advance. If the purpose of processing health data changes, we will ask for your explicit consent again.
15. Contacts
- Us: move-ys@pomogatorapp.ru
- EU representative: not appointed (see the "Contact details" section at the beginning of the document).
- Data Protection Officer: not appointed (ibid.).
- Supervisory authority: the data protection authority of your country of residence. A list is available on the website of the European Data Protection Board.
Version 1.1 of September 24, 2026. The previous version is 1.0 of September 2, 2026; it is available at move-ys.ru/privacy-1.0 (in Russian).