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Privacy Policy

Last updated March 19, 2026

1. Data Controller

Nicotine Free Life Coaching Service
Email: hello@nicotinefree.life

2. What Data We Collect

When using the service, we collect the following personal data that the user provides through the WhatsApp conversation:

First name, phone number, nicotine product used, daily usage amount, years of use, reason for quitting, wake-up time, language, and chosen quit date.

We also store the conversation history (messages with Niko, your AI coach) to enable the service to function.

3. Why We Collect Data

Data is processed for the following purposes: personalized nicotine cessation coaching and support, tracking program progress, scheduling morning and evening messages based on the user's wake-up time, and improving the service.

4. Legal Basis for Processing

Processing of personal data is based on the user's explicit consent (GDPR Art. 6(1)(a)).

Data related to nicotine dependence constitutes health data, which belongs to special categories of personal data under the GDPR (Article 9). Processing of this data is based on the user's explicit consent to the processing of special categories of personal data (GDPR Art. 9(2)(a)).

The user gives consent by initiating a conversation with the Niko coach on WhatsApp. Consent can be withdrawn at any time by discontinuing use of the service and requesting deletion of data.

5. Data Processors and Transfers

The service uses the following third-party service providers that process personal data on behalf of the data controller:

Supabase (database, EU West Ireland) stores user data and conversation history.

Anthropic (Claude AI, USA) processes conversation history to generate AI coaching responses. Anthropic automatically deletes API inputs and outputs within 7 days and does not use API data for model training.

Meta / WhatsApp (WhatsApp Cloud API) transmits messages between the user and the service.

Vercel (server infrastructure, USA) runs the service code.

Data is transferred outside the EU (Anthropic and Vercel, USA). Transfers are based on EU-approved transfer mechanisms (Standard Contractual Clauses).

6. Data Retention and Deletion

User data and conversation history are retained for the duration of active use of the service. The most recent 15 messages are actively used for AI context.

Data deletion is performed upon request by contacting hello@nicotinefree.life. We will delete data within 30 days of the request.

If a user has been inactive for 6 months, their data will be automatically deleted.

7. Your Rights

You have the right to request access to your data, rectify inaccurate data, request deletion of your data, restrict processing, object to processing, request data portability, and withdraw your consent at any time.

You can exercise your rights by contacting hello@nicotinefree.life. We will respond to requests within 30 days.

You also have the right to lodge a complaint with a supervisory authority. For users in Finland: the Office of the Data Protection Ombudsman, tietosuoja.fi.

8. Automated Decision-Making

The service uses artificial intelligence (Claude AI) to generate conversational responses. The AI does not make legal or similarly significant decisions concerning the user. Program progression (day transitions) occurs automatically based on the calendar.

9. Data Security

Personal data is protected with appropriate technical and organizational measures. All traffic is encrypted (HTTPS/TLS). The database is protected with access controls and network restrictions. Database access is limited to the service administrator. Conversation history is not shared with third parties. Administrator accounts have multi-factor authentication (MFA) enabled.

10. Changes to This Privacy Policy