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Privacy Policy

Last Updated: April 25, 2026

1. Overview

Protokel is owned and operated by Clear Persist Ecom, operating under the trade name (handelend onder de naam) Protokel ("Protokel," "we," "us," or "our"), based in the Netherlands.

This Privacy Policy explains what information we collect when you use the Protokel mobile application (the "App"), how we use it, who we share it with, and your rights.

Protokel is a personal peptide protocol tracking and organizational tool for informational and record-keeping purposes only. We do not provide medical advice, diagnosis, or treatment.

Our core principle: We collect only what is necessary to operate the App. We do not sell your data. We do not share your health-related data for advertising purposes.

By creating an account or using the App, you agree to this Privacy Policy. If you do not agree, do not use the App.


2. Definitions

  • Health-related data: Information you enter into the App about your peptide protocols, including vial details, dose logs, schedules, and preparation records.
  • Third-party service providers: Companies we work with to operate the App, each bound by their own privacy policies and, where applicable, data processing agreements.
  • Personal data: Any information that identifies or could identify you as an individual.
  • Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

3. Information We Collect

3.1 Account Information

When you create an account, we collect:

  • Email address (from Apple Sign-In or Google Sign-In)
  • Full name (if provided by your authentication provider)
  • Authentication provider used (Apple or Google)

We do not collect or store your password. Authentication is handled entirely by Apple or Google.

3.2 Onboarding Information

During onboarding, you may provide:

  • Your primary goals for peptide tracking
  • Your experience level with peptides
  • Your current protocol status
  • Peptides you are currently using
  • Vial configuration details including preparation dates

This information is used to personalize your App experience and is stored in your account.

3.3 User-Entered Tracking Data

Information you choose to enter in the App, including:

  • Vial inventory (peptide names, amounts, diluent volumes, preparation dates, expiry dates, status, notes)
  • Dose logs (peptide name, dose amount, unit, timestamp, notes)
  • Dose schedules (frequency, timing, scheduled days)
  • Custom peptide entries
  • Notes attached to vials or doses

3.4 AI Assistant Data

The App includes an AI assistant powered by Anthropic's Claude API. When you use this feature:

  • The messages you type and relevant peptide context from your current session are sent to Anthropic's servers (located in the United States) to generate a response.
  • Protokel does not store your AI conversation history. Conversations exist only during your active session.
  • Anthropic processes this data under their own privacy policy and data processing terms. Anthropic does not use your inputs to train their models when accessed via their API.

Use of the AI assistant is optional. By sending a message to the AI assistant, you consent to the transfer of that message data to Anthropic's servers in the United States. You can withdraw this consent at any time by choosing not to use the AI assistant feature.

3.5 Subscription Information

We collect:

  • Subscription status and entitlement state
  • Subscription plan type and expiration date

Payment information (credit card details, billing address) is never collected or stored by Protokel. All billing is handled by the applicable app store or payment processor (such as the Apple App Store or Google Play Store) and managed through RevenueCat.

3.6 Device and Technical Information

We and our service providers may collect limited technical information including:

  • Device type and model
  • Operating system version
  • App version
  • Crash reports and diagnostic data

This data is collected through Sentry and/or Google Firebase Crashlytics to maintain App reliability and fix bugs.


4. How We Use Your Information

We use your information to:

  • Provide and operate the App
  • Store and synchronize your tracking data
  • Authenticate your account
  • Deliver App features including protocol tracking, dose logging, vial management, AI assistant, and the peptide library
  • Send optional notifications (dose reminders, vial expiry alerts)
  • Manage your subscription access
  • Personalize your experience based on onboarding preferences
  • Diagnose crashes and improve App stability
  • Respond to support requests

5. What We Do Not Do

  • We do not sell your personal data
  • We do not share your health-related data for advertising or marketing purposes
  • We do not provide medical advice, diagnosis, or treatment
  • We do not use your tracking data to make dosing or health recommendations
  • We do not use third-party analytics or advertising SDKs
  • We do not track you across other apps or websites
  • We do not use App Tracking Transparency because we do not track users

6. Medical Disclaimer

All health-related data in the App is self-reported by the user. Protokel does not verify, validate, or assess the accuracy of any data entered by users.

The AI assistant provides educational information only and does not constitute medical advice. Protokel bears no liability for decisions made based on data displayed in the App or responses generated by the AI assistant.

Users should always consult a qualified healthcare provider before making medical decisions. For the full medical disclaimer, visit protokel.com/disclaimer.


7. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following legal bases:

  • Contract performance (Article 6(1)(b) GDPR): Processing your account data, tracking data, and subscription information is necessary to provide the App's services to you.
  • Legitimate interest (Article 6(1)(f) GDPR): Crash reporting and technical diagnostics to maintain App reliability and security. Our legitimate interest is ensuring the App functions correctly for all users.
  • Consent (Article 6(1)(a) GDPR): Use of the AI assistant (which involves data transfer to the United States) and optional push notifications. You can withdraw consent at any time as described in Section 13.

8. Automated Decision-Making

Protokel does not use your personal data for automated decision-making or profiling as defined under Article 22 of the GDPR.

The AI assistant generates responses based on your input, but it does not make decisions about you, your access to the App, or your account. No features of the App produce legal or similarly significant effects based on automated processing of your personal data.


9. Third-Party Services

Protokel works with the following service providers:

ServicePurposeData InvolvedLocation
SupabaseAuthentication, database, data storageAccount data, tracking dataEU (Ireland, eu-west-1)
Anthropic (Claude API)AI assistant responsesMessage text, peptide context from current sessionUnited States
Apple Sign-InAuthenticationEmail, nameApple infrastructure
Google Sign-InAuthenticationEmail, nameGoogle infrastructure
Apple App StoreiOS subscriptions and billingSubscription status (no payment card data)Apple infrastructure
Google Play StoreAndroid subscriptions and billingSubscription status (no payment card data)Google infrastructure
RevenueCatSubscription managementSubscription status, purchase metadataUnited States
SentryCrash reportingCrash logs, device info, app versionUnited States
Google Firebase CrashlyticsCrash reportingCrash logs, device info, app versionUnited States

One or both crash reporting services (Sentry and Firebase Crashlytics) may be active at any given time. Additional payment processors may be used for specific platforms and will be listed in this section when active.

Disclaimer: Protokel is not responsible for the privacy practices of third-party service providers beyond the contractual agreements we maintain with them. We encourage you to review the privacy policies of each service provider independently.

Sub-processor changes: If we add new third-party service providers that process your personal data, we will update this Privacy Policy accordingly. Material changes to our sub-processors will be communicated through the App or via the updated policy at protokel.com/privacy.


10. International Data Transfers

Your account and tracking data is stored in the European Union (Supabase, hosted in AWS eu-west-1, Ireland).

Certain data is transferred outside the EU:

  • AI assistant messages are sent to Anthropic's servers in the United States when you use the AI feature.
  • Subscription data is processed by RevenueCat in the United States.
  • Crash reports may be processed by Sentry and/or Firebase Crashlytics in the United States.

These transfers are safeguarded by Standard Contractual Clauses (SCCs) and/or the EU-U.S. Data Privacy Framework where applicable, as implemented by each service provider.

If you access the App from outside the EU, your primary data remains stored in the EU. Data flows to the United States occur only as described above.


11. Data Storage and Security

  • All account and tracking data is stored in Supabase (PostgreSQL) within the EU, protected by Row Level Security (RLS) ensuring each user can only access their own data.
  • Data is encrypted in transit (TLS) and at rest where supported by our providers.
  • We use industry-standard security measures to protect your information.
  • Despite these measures, no system can guarantee absolute security.

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

  • Notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours of becoming aware of the breach, as required by Article 33 of the GDPR.
  • Notify affected users without undue delay if the breach is likely to result in a high risk to their rights and freedoms, as required by Article 34 of the GDPR.

Notification will include the nature of the breach, the likely consequences, and the measures taken or proposed to address it.


13. Your Privacy Rights and How to Exercise Them

All Users

You have the right to:

  • Access the personal data we hold about you
  • Correct inaccurate data
  • Request deletion of your data
  • Export a copy of your data (available via CSV export in the App)
  • Withdraw consent for optional features at any time

How to Withdraw Consent

You can withdraw consent for specific features as follows:

  • AI assistant: Stop using the AI assistant feature. No data is sent to Anthropic unless you actively send a message.
  • Push notifications: Disable notifications in your device settings or within the App under Profile.
  • All data processing: Delete your account within the App under Profile. This will permanently remove all your personal data within 30 days as described in Section 14.

You may also contact us at support@protokel.com to exercise any privacy right.

EEA/UK Residents (GDPR)

You additionally have the right to:

  • Restrict processing of your data
  • Object to processing based on legitimate interest
  • Data portability (receive your data in a structured, machine-readable format)
  • Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl or your local Data Protection Authority

California Residents (CCPA)

You have the right to:

  • Know what personal information we collect and how it is used
  • Request deletion of your personal information
  • Opt out of the sale of personal information — we do not sell personal information
  • Non-discrimination for exercising your privacy rights

We will respond to all privacy requests within 30 days.


14. Data Retention and Deletion

Your account and tracking data is stored for as long as your account remains active.

If you request account deletion (available in the App under Profile):

  • Your request will be processed within 30 days.
  • All personal data, tracking data, vials, dose logs, schedules, and profile information will be permanently deleted from our database.
  • Some limited information may be retained if required by law or for fraud-prevention purposes.

AI assistant conversations are not stored and require no deletion action.

Crash report data is retained according to the retention policies of Sentry and/or Firebase Crashlytics.


15. Age Requirement

Protokel is intended for users 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that a minor has created an account, we will delete the account and associated information promptly.

If you believe someone under 18 may have provided us with personal information, contact us at support@protokel.com.


16. Cookies and Tracking

The App does not use cookies, web beacons, or pixel trackers. We do not use any third-party analytics, advertising, or tracking SDKs. We do not participate in cross-app or cross-site tracking.


17. Business Transfers

If Clear Persist Ecom is involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity as part of that transaction. We will notify you of any material changes to how your data is used. Continued use of the App after notification constitutes acceptance. You may delete your account before the transfer takes effect if you do not agree.


18. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be available within the App and at protokel.com/privacy with a revised "Last Updated" date. Material changes will be communicated through the App. For material changes that significantly affect your rights or how your data is processed, we will seek your affirmative consent through the App before the changes take effect. Continued use of the App after non-material changes are posted constitutes acceptance of the updated policy.


19. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the Netherlands. Any disputes arising from or relating to this Privacy Policy or your use of the App shall be subject to the exclusive jurisdiction of the competent courts in Amsterdam, the Netherlands.

If you are a consumer residing in the European Union, you retain the right to bring proceedings in the courts of your country of residence in accordance with applicable EU law, including Regulation (EU) No 1215/2012 (Brussels I Recast). Nothing in this Privacy Policy limits your statutory consumer rights under applicable EU or national law, or your right to lodge a complaint with a Data Protection Authority.


20. Privacy Contact

For all privacy-related questions, requests, or complaints, you may contact our designated privacy contact person (contactpersoon voor gegevensbescherming):

Clear Persist Ecom, operating under the trade name (handelend onder de naam) Protokel

Email: support@protokel.com

Privacy Policy: protokel.com/privacy

Terms of Service: protokel.com/terms

Medical Disclaimer: protokel.com/disclaimer

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