Effective Date: 2026-04-25 · Last Updated: 2026-05-10
This Privacy Policy describes how CWDS OÜ (“we,” “us,” or “our”) handles personal data in connection with:
alexzah.com and any related subdomain (the “Websites”);We are the data controller for the personal data we handle in connection with the Service. You can contact us at the address in Section 16.
The short version. The content of your reflections — your anchor object, your daily care choices, your evening reflection answers — stays on your device. We do not collect it. The Application does include the same standard behavioural analytics tools as our Websites (Google Tag Manager, Google Analytics 4, Microsoft Clarity), which record screen views, taps, milestones, and conversion events — but never the text of your reflections. Purchases pass through a small set of named third parties. We do not sell personal data.
We process different categories of data in different contexts. This Section separates them by surface (App vs. Websites).
We receive the following categories of data from, or on behalf of, App users:
When you visit a Website, read a sales page, open a marketing email, or begin a checkout flow, we and our processors may receive:
If you contact us by email, via a support form, or by replying to a marketing email, we receive the contents of that communication and your email address. We use this to respond and keep a record of the conversation.
We want to be explicit about what we do not collect from inside the Application, because the brand promise of the App depends on it.
We do not collect, store on our servers, or transmit to any third party:
We do not:
What we do collect from the App is described in Section 2.1: behavioural analytics events (screen views, taps, milestone events, conversions) and purchase/support data. The text content of your reflections is never sent to those analytics tools.
The Inner Child Self-Care App is a Progressive Web App. Its daily prompts, reflection logging, anchor selection, day-by-day progress grid, and PDF export run locally on your device, in the browser’s storage area for the App.
The Application’s core practice functions do not require a connection to our servers; the App is designed so that, once loaded, it remains usable offline. The Application does, however, load behavioural analytics tools when you are online — Google Tag Manager, Google Analytics 4, and Microsoft Clarity — the same tools used on our Websites. While you are online, those tools record screen views, taps, milestone events, share/export clicks, and conversion events, and they may set or read cookies and similar identifiers in your browser.
We have configured these tools to record behaviour signals only (for example: a tap on the “Export” button, or completion of a day). The text content of your anchor choice, daily care entries, and reflection answers is never written into these analytics events. Microsoft Clarity, in particular, is configured to mask text inputs by default, and we apply additional input-masking conventions inside the App to keep your reflection content out of session recordings.
If you wish to use the Application without these analytics, you can use a browser or browser extension that blocks Google and Microsoft analytics domains, or decline analytics-related cookies through the consent banner where applicable law gives you that choice.
The following information is stored in the browser’s local-storage area on your device:
Some of this information may also be mirrored in a small first-party cookie on your device, used by the App to restore identity and onboarding state in environments (for example, iOS standalone PWAs) where local storage is unreliable.
You can delete locally stored Application data by:
Because we do not keep this data on our servers, we cannot recover it if it is lost from your device.
iOS, Android, and other platforms may include browser data in device backups, migration flows, or account-based sync. Those backups are controlled by the platform provider and by the account that is signed in on the device, not by us. You can manage backup behaviour through your device settings.
The Application includes an option to export your full 21-day journal to a PDF generated on your device. You may also use your device’s native share sheet to send that PDF, or to share information about the Application itself, with another person or another app of your choice. Once you choose to export or share, the data leaves the Application’s local storage and is no longer governed by this Privacy Policy; it is governed by the policies of whichever destination you send it to. You are solely responsible for that choice.
The Websites (and, for behavioural analytics, the Application as described in Section 4) use third-party tools common to commercial online services. This Section lists the tools currently in use. You can opt out of most of them through your browser or through the consent banner on the Websites.
| Tool | Where | Purpose | Data Handled | Opt-out |
|---|---|---|---|---|
| Cookie-Script | Websites | Consent management (CMP) | Country/region, consent state, cookie ID | Re-open the consent banner |
| Google Tag Manager (GTM) | Websites + App | Tag orchestration | Loads the tags below | Controlled by each tag |
| Google Analytics 4 (GA4) | Websites + App | Pageview, screen-view, and event analytics | Pageviews, screen views, events, UTM parameters, device and browser data, pseudonymised IP | opt-out |
| Microsoft Clarity | Websites + App | Session recordings and heatmaps | Anonymised interaction data; text inputs masked | opt-out or reject in banner |
| Meta Pixel + Conversions API (CAPI) | Websites (sales / thank-you / app) | Ad attribution and retargeting (browser pixel + server-side purchase events) | Pageviews and conversion events from the browser; for purchases, server-to-server events with order data, IP, _fbp/_fbc cookies, and — only with marketing consent — hashed email and customer reference | Off-Facebook activity controls; reject marketing in the consent banner |
| Stripe | Checkout | Payments | Card and transaction data during checkout | Handled by Stripe |
| GetResponse | Marketing and transactional email | Email address, open and click activity | Unsubscribe link in every email |
Server-side advertising measurement (Meta Conversions API): Alongside the browser-based Meta Pixel above, after a successful purchase we send a server-to-server event to Meta's Conversions API (CAPI). This event includes the order amount, currency, product identifiers, your IP address, and the _fbp/_fbc cookies Meta set in your browser. If you accepted marketing cookies in our consent banner (or, where you are outside the EU/EEA/UK/Canada and no banner was required, by default under applicable local law), the event also includes a SHA-256 hashed version of your email and an internal customer reference. We never send your email in plain text. Both browser and server events share an event_id so Meta deduplicates them and counts the purchase only once. If you declined marketing cookies, the server event is sent without your hashed email or customer reference.
The Websites and the Application use:
You can clear cookies at any time through your browser settings, and you can change your consent choices through the consent banner on the Websites.
We currently do not respond to “Do Not Track” browser signals because there is no consensus on how to interpret them. We do honour the Global Privacy Control (GPC) signal where applicable law requires it.
Separate from purely local operations, the Application may make network requests when one of the following happens:
Information that you intentionally submit through these channels, and the minimum metadata required to complete the operation, is transmitted for that specific purpose. The text content of your anchor choice, daily care entries, and reflection answers is not transmitted to any of these channels for analysis.
We use a small set of named third parties to run the Service. Each has its own privacy policy, and each processes personal data only on our instructions, under a data-processing agreement or a controller-to-controller arrangement as appropriate.
| Provider | Role | Data Shared | Location |
|---|---|---|---|
| Stripe, Inc. | Payment processor | Payment, buyer email, order metadata | US + local |
| GetResponse S.A. | Email marketing and transactional email | Email address, opt-in source, open/click activity, buyer tags | Poland (EU) |
| Google LLC | Tag Manager, Analytics 4, Fonts (Websites + App) | Pageviews, screen views, events, pseudonymised IP, browser/device signals | US + local |
| Microsoft Corporation | Session analytics (Clarity, on Websites + App) | Anonymised interaction data; text inputs masked | US |
| Meta Platforms, Inc. | Ad attribution and retargeting — browser pixel + server-side Conversions API (Websites) | Pageviews and conversion events (browser); for purchases, server-side events including order amount, IP address, _fbp/_fbc cookies, and — with marketing consent — SHA-256-hashed email and customer reference | US + Ireland (EU) |
| Cookie-Script Ltd. | Consent management platform (CMP) | Country/region, consent state, cookie ID | EU (Lithuania) |
| Apple, Inc. | Platform store & payments (App Store, if/when used) | Order reference, product, App Store receipt | US + Ireland (EU) |
| DigitalOcean LLC (via Cloudways Ltd.) | Web hosting for the Websites | Server logs, IP address | EU + US regions |
| Cloudflare, Inc. | Content delivery and security | IP address, request metadata | US + edge locations |
We do not share personal data with third parties for any purpose other than those described in this Policy, or as required by law.
Several of the providers above are located in the United States or operate globally. When we transfer personal data of EU/EEA, UK, or Swiss residents outside those regions, we rely on the following safeguards, as appropriate:
You may request a copy of the safeguards in place for a specific provider by contacting us at the address in Section 16.
When the EU General Data Protection Regulation (GDPR) or the UK GDPR applies, we rely on the following lawful bases:
If you are in the EU, EEA, UK, or Switzerland, you have the right, subject to the conditions and limits in the applicable law, to:
To exercise any of these rights, contact us at the address in Section 16. We will respond within one month, or within two months for complex or numerous requests, as permitted by law.
A note on the App. Because the text of your reflections is stored only on your device, we do not hold it and cannot, in practice, return, correct, or delete it on your behalf. You can do that yourself using the in-app reset feature, by clearing site data for the Application in your browser, or by uninstalling the App from your device. We can act on data we do hold, such as your purchase record and any support correspondence.
If you are a California resident, you have the right to:
Residents of other regions may have additional rights under applicable local law. We honour any non-waivable statutory right you have where you live.
We retain personal data only for as long as we need it for the purpose for which it was collected, and for periods required by applicable law. Indicative retention windows:
| Category | Retention |
|---|---|
| Order and license records | For the operational life of the Service, plus the period required by tax, accounting, and consumer-protection law (typically 7 years under Estonian accounting law). |
| Support and bug-report conversations | Up to 3 years after the conversation, for troubleshooting and dispute resolution. |
| Marketing email activity | For as long as you remain subscribed, plus a limited period after unsubscribe to honour your opt-out request. |
| Analytics signals (GA4, Clarity, Meta Pixel) on Websites + App | Subject to the retention settings of each tool; GA4 is configured to the shortest retention option compatible with the product. |
| In-App reflection content | Stored only on your device. We do not hold a copy and cannot retain or delete it for you. |
| Payment records via Stripe | Governed by Stripe’s retention policy and applicable financial-services law. |
When retention periods expire, we delete or anonymise the data.
We apply technical and organisational measures appropriate to the sensitivity of the data we handle, including:
No security measure is perfect. If we become aware of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority as required by law, and we will notify affected users where applicable law so requires.
The Service is intended for adults. As stated in our Terms of Use, you must be at least 18 years old to use the Service. We do not knowingly collect personal data from anyone under 18. If we learn that we have received personal data of a minor, we will delete it promptly.
If you believe a minor has submitted personal data to us, please contact us at the address in Section 16 so that we can take appropriate action.
We may update this Policy to reflect changes in the Service, applicable law, or our practices. When we make material changes, we will update the “Last Updated” date at the top of this page and, where appropriate, give additional notice inside the Application, on our Websites, or by email.
If we ever decide to begin collecting categories of data from inside the Application that this Policy says we do not collect (for example, the text of your reflections), we will update this Policy, update the in-app disclosures, and where required by applicable law, we will obtain your consent before the change takes effect for you.
For privacy questions, data-subject requests, or complaints:
CWDS OÜ
Attention: Privacy
Kotkapoja tn 2a-10, Kristiine, 10615 Tallinn, Harju maakond, Estonia
Email: alex@alexzah.com
Support: alex@alexzah.com
If you are in the EU/EEA or the UK, you also have the right to lodge a complaint with your local data-protection supervisory authority. If you are in Estonia, that is the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, AKI) — aki.ee.
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