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Privacy Policy

Last updated August 12, 2026

1. Data Controller

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

2. What Data We Collect

When you use the service, we collect the following personal data, either from your WhatsApp account or from what you tell Niko during the conversation:

Identifiers: your phone number and your first name. If your WhatsApp profile name contains a surname, we discard it and store the first name only. You can of course tell Niko whatever name you prefer to be called.

Health-related information: the nicotine product you use, your daily usage amount, how many years you have used nicotine, your reason for quitting, your quit date, your progress through the program, and the number of times you have restarted after a relapse.

Service settings: your wake-up time, your time zone, your language, whether you chose to skip the Discovery phase, and whether the program is paused.

Consent record: whether you have given consent, and the timestamp at which you gave it.

Conversation history: the messages you send to Niko and the replies Niko sends to you, stored so the service can remember your situation between messages.

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 your wake-up time and time zone, and improving the service.

We do not sell your data, we do not use it for advertising, and we do not use it to train AI models.

4. Legal Basis for Processing

Processing of personal data is based on your 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 your explicit consent to the processing of special categories of personal data (GDPR Art. 9(2)(a)).

How consent is obtained: before any personal information is collected, Niko asks you directly in the WhatsApp conversation whether you agree to your health data being processed, and links to this policy. The program only continues if you say yes. Your consent and the time you gave it are recorded in our database. Simply starting a conversation is not treated as consent.

Withdrawing consent: you can withdraw your consent at any time by telling Niko you want to stop, or by emailing hello@nicotinefree.life. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. If you would also like your data deleted, see section 6.

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, USA and Ireland) carries the conversation. Because the service runs on the WhatsApp Cloud API, the content of every message in both directions passes through and is processed on Meta's servers. This includes your first name and your program day, which are sent to Meta as parameters of the scheduled morning and evening messages. Messages sent through the Cloud API are not end-to-end encrypted in the same way as ordinary personal WhatsApp chats between two individuals.

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

Data is transferred outside the EU (Anthropic, Vercel and Meta, 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 as long as you actively use the service.

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

If you have been inactive for 6 months, your data and conversation history are deleted automatically.

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 you. Program progression (day transitions) occurs automatically based on the calendar and your time zone.

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. Administrator accounts have multi-factor authentication (MFA) enabled.

Your conversation history is never sold and is not disclosed to anyone other than the processors listed in section 5, who act on our instructions, unless we are required to disclose it by law.

10. Changes to This Privacy Policy

We may update this privacy policy as the service develops. The date of the most recent update is shown at the top of this page, and the current version is always available at nicotinefree.life/privacy.

If we make a change that materially affects how your personal data is processed, we will inform you through the WhatsApp conversation before the change takes effect. If a change requires new consent under the GDPR, we will ask for it separately.

11. Contact

For any question about this policy, your data, or to request deletion, contact hello@nicotinefree.life.