This is a draft, not a policy in force. The bracketed details are for the operator to fill in, and the document should be reviewed by a data protection professional before publication. The substance describes what the application actually does, as implemented in the code.
1. Who controls your data
The controller is the operator of the Sippa application:
Name: Györkös Balázs e.v. (sole trader)
Registered seat: 7634 Pécs, Bajmi dűlő 28., Hungary
Sole trader registration number: 6143550
Tax number: 63368101-1-22
Email: hello@sippa.io
Data protection officer: [TO COMPLETE if one has been appointed — otherwise: "none appointed"].
2. Why this policy matters more than most
Sippa tracks your alcohol consumption. What you record about it — together with your height, weight and sex — is health data under Article 9 GDPR, a special category of personal data. The law sets a stricter condition for processing it than for ordinary data.
We therefore process this data solely on your explicit consent (Article 9(2)(a) GDPR). You may withdraw that consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
3. What we process
3.1 Account data
- first and last name
- email address
- password — stored only as a one-way hash; we neither know nor can recover your password
- chosen language
- date of birth — to enforce the minimum age of 18
- country — after you register we pre-fill it from where you connect (Cloudflare derives the country from your IP address; we do not store the IP address for this), and you confirm or change it during setup or in your profile. We also store whether the value was pre-filled by us or set by you.
- profile picture, if you upload one
- the nickname you give the Sippa character, if you set one
3.2 Health data (special category)
- sex
- height and weight
- drink entries: type, name, quantity, unit, alcohol content, time of consumption, and any note you attach
- day closes: whether the day was alcohol-free or you drank, the "alcohol-free tomorrow?" intention, and the day's note if you write one
- if you add them: who you drank with (alone or with others) and the mood behind it (for example stress, celebration)
- if you turn it on: the fact that you are pregnant or planning a pregnancy, and since when (pregnancy mode)
- values derived from the above: alcohol units, daily and weekly totals, streaks, total alcohol-free days
3.3 Usage data
- experience points, level, unlocked badges, personal records
- the ledger of points awarded
3.4 Technical data
- session cookie and sign-in token, so you are not asked to sign in on every page
- IP address and user agent in server logs, for operation and security
- days of use: on which days you used the app, on which platform (web, iOS, Android) and which version — one entry a day, saying nothing about your drinking
4. Purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Creating and running your account, signing in | account data, technical data | Performance of a contract — Art. 6(1)(b) |
| The core service: recording consumption, totalling it, reflecting it back | health data | Explicit consent — Art. 9(2)(a) |
| Motivational features: points, levels, badges | usage data | Performance of a contract — Art. 6(1)(b) |
| The written part of the weekly recap (Sippa+; can be switched off in Profile → Weekly recap → "Include the written summary") | the week's aggregate figures (see Anthropic's row in section 5) | Explicit consent — Art. 9(2)(a) |
| Enforcing the minimum age | date of birth, country | Performance of a contract — Art. 6(1)(b) |
| Country-specific content: support lines, the national drink unit and minimum age | country | Performance of a contract — Art. 6(1)(b) |
| Aggregate statistics to improve the service (for example users per country), never traceable to individuals | country, account and usage data | Legitimate interest — Art. 6(1)(f) |
| Pregnancy mode: adjusting goals and messages (any alcohol counts as over the limit) | the fact of pregnancy and its start date | Separate explicit consent — Art. 9(2)(a); asked when you turn it on, and you can turn it off at any time |
| Blocking abuse and automated sign-ups | IP address, challenge token | Legitimate interest — Art. 6(1)(f) |
| Security, debugging, operations | technical data | Legitimate interest — Art. 6(1)(f) |
| Running the service and support: in the operator's admin interface, viewing account data (name, email, country, language, subscription, last day of use) when you ask for help; nobody sees your health data there, only aggregates that cannot be traced to individuals | account data, days of use | Legitimate interest — Art. 6(1)(f) |
5. Who we share it with
We do not sell your data and we do not use it for advertising. The service relies on these providers:
| Provider | What it receives | Why |
|---|---|---|
| Vultr — The Constant Company, LLC (319 Clematis Street, Suite 900, West Palm Beach, FL 33401, USA); the server runs in Warsaw, Poland | all stored data | running the server and the database |
| Ploi (Amperestraat 16J, 3861 NC Nijkerk, the Netherlands; KvK: 94117233) | access to the server, and so technically to the data on it | managing the server and deploying new versions |
| Neon, LLC (part of the Databricks group, USA); the data is held in Frankfurt, Germany | a backup copy of the stored data | an off-site backup with a second provider |
| Cloudflare, Inc. | all traffic to sippa.io (IP address, technical request data); on registration, the challenge token your browser generates (Turnstile) | serving and protecting the traffic, deriving the country from the IP address, filtering out automated sign-ups |
| Anthropic, PBC (USA) | for Sippa+ subscribers with the written summary switched on: the week's aggregate figures — units this week and last week, your own weekly limit, the number of drinking and alcohol-free days, your goals, your streaks, and the week's heaviest day (its weekday and units). No name, email address, date or individual entry is sent. | writing the text of the weekly recap with artificial intelligence |
| Google Ireland Ltd. (Google Fonts) | IP address when fonts are fetched | rendering the site's typefaces |
For the operator: Vultr, Neon, Cloudflare and Google belong to US companies, so — even though Vultr and Neon store the data in the EU — a transfer outside the EU may occur. Name the safeguard here explicitly: Neon, LLC is certified under the EU–US Data Privacy Framework; Vultr relies on standard contractual clauses. Google Fonts can also be self-hosted, which removes that transfer entirely.
Anthropic: the weekly aggregate figures belong to an identified user, so they are health data. Anthropic's data processing agreement is needed (part of its commercial terms, with EU SCCs); check its retention and model-training terms, and consider making the written summary off by default (today it is on by default).
A data processing agreement under Article 28 GDPR is required with all three hosting and operations providers: Vultr signs one on request, Neon's is part of its terms, and Ploi has to be asked.
6. How long we keep it
- Account and health data: for as long as your account exists. If you delete your account, we erase them permanently within [TO COMPLETE: e.g. 30] days.
- Server logs: [TO COMPLETE: e.g. 30] days.
- The log of administrator actions (who changed what on which account and when — for example granting a subscription or blocking an account): 2 years.
- Billing records: if a paid tier ever launches, 8 years under Hungarian accounting law.
7. Your rights
- Access: request a copy of the data we hold about you.
- Rectification: have inaccurate data corrected.
- Erasure: have your data deleted.
- Restriction: have processing restricted.
- Portability: receive your data in a machine-readable format.
- Objection: object to processing based on legitimate interest.
- Withdraw consent: at any time, as easily as you gave it.
Write to hello@sippa.io. We respond within one month at the latest.
8. Where to complain
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Falk Miksa utca 9–11, 1055 Budapest, Hungary
Postal address: 1363 Budapest, Pf. 9
Phone: +36 1 391 1400
Email: ugyfelszolgalat@naih.hu
Web: naih.hu
You may also go to court, including the court with jurisdiction over your place of residence.
9. Security
Passwords are stored as one-way hashes. Connections are encrypted with HTTPS. Only the application can reach the database. No system is ever completely secure, and we do not claim otherwise.
10. Cookies
The application uses a session cookie to keep you signed in. It is strictly necessary for the service to work, so it does not require separate consent. We use no analytics or advertising cookies.
11. Children
The service is intended solely for people aged 18 and over. We do not knowingly process data about anyone under 18. If we discover such data, we will delete it.
12. Changes to this policy
If we make a material change, we will tell you in the application or by email. Earlier versions remain available with their dates.