Privacy Policy TEMPO

 

PRIVACY POLICY OF TEMPO

Last updated: October 2026

1. Data controller

The data controller responsible for the personal data collected through the TEMPO application is:
Juan Manuel Calderón Olivencia
Address: Calle Diego de Alcántara, 2, Bloque 3, 41500 Alcalá de Guadaíra, Sevilla, Spain
Contact email: hola@kumera.es
Hereinafter, «KUMERA» or «TEMPO».

2. What TEMPO is

TEMPO is an application designed to help people record moments, emotions, reflections and personal experiences through tools such as Diary, Clima (Weather), Cápsulas del Tiempo (Time Capsules), Pausa (Pause) and other features oriented towards personal wellbeing and mindful reflection, including the optional crossing of these records with sleep and physical activity data.
TEMPO has been developed following the principles of Privacy by Design and Privacy by Default established in Article 25 of the General Data Protection Regulation (GDPR), with the aim of minimising the amount of personal data processed and maximising the user’s control over their information.

3. What data we process

TEMPO is designed so that most of the information stays exclusively on the user’s device.
Depending on the features used, we may process the following categories of data:

Account data

  • Email address.
  • Technical identifiers associated with authentication.

Content data

Only when the user voluntarily activates the encrypted backup:

  • Diary entries.
  • Clima records or emotional state.
  • Time Capsules.
  • Attached photographs.
  • Voice notes.
  • Information generated during Pausa sessions.
  • Experiments, discoveries and progress in Pausa programmes.

Time Capsules sent to another person

If you send a Time Capsule to another person, we also process that person’s email address (to notify them that they have received it) and the content of the Capsule. See section 7bis for details on how this content is protected.

Health data (optional)

Only when the user voluntarily activates the Health feature in Settings:

  • Minutes of sleep.
  • Daily step count.
  • Average daily heart rate.
  • Daily exercise minutes.

This data comes from Apple Health (HealthKit) or Health Connect, depending on the device’s operating system, and is read exclusively to cross it with your own Clima records and show you possible relationships between your rest, your activity and your mood. This crossing is calculated entirely on your device: the specific values for sleep, steps, heart rate and exercise are not transmitted to TEMPO’s servers nor included in the encrypted backup. More detail in section 9.

Location data (optional)

Only when the user voluntarily activates the corresponding feature in Settings, TEMPO uses your approximate location to check the weather and public holidays in your area for each Clima record. This location is queried from external providers (see section 10) and is never sent together with your personal content nor included in the encrypted backup. Before being stored or sent, the coordinates are rounded to two decimal places (a precision of about 1 km).

Technical data

  • Error and technical failure logs.
  • Information necessary to guarantee the security and functioning of the application.
  • Information related to authentication and session management.
  • Application usage events (product analytics), only if you expressly accept them (off by default): which features are used and how often, to help us improve TEMPO. This never includes the content you write (not the Diary text, photographs, voice notes, or the mood you select).
  • If you grant notification permission, a push notification identifier for your device, linked to your account, so we can let you know when someone sends you a Time Capsule.

TEMPO does not request or process any more personal data than is strictly necessary to provide the service.

4. Specially sensitive data

Certain content that the user chooses to voluntarily enter into TEMPO may reveal information related to their physical or mental health, emotional state, personal habits or intimate circumstances.
In particular, if the user activates the Health feature described in section 3, TEMPO will read minutes of sleep, steps, heart rate and exercise minutes, which constitute special category data (health data) under Article 9 of the GDPR. For this reason, this feature:

  • Is never enabled by default: it requires an explicit action by the user in Settings.
  • Never requests permission from the operating system until the user activates it.
  • Is based on the user’s explicit consent (Art. 9.2.a GDPR).

For this reason, certain backup, synchronisation and Health data reading features can only be activated with the user’s express consent.
This consent can be withdrawn at any time from within the application itself or from the device’s Health/Health Connect settings, without affecting the lawfulness of the processing carried out before its withdrawal.

5. Purposes and legal bases of processing

We process personal data for the following purposes:

Purpose Legal basis
Creating and managing the user’s account Performance of a contract
Allowing access to and use of TEMPO Performance of a contract
Keeping encrypted backups when the user activates them Explicit consent
Crossing your Clima records with your sleep, steps, heart rate and exercise data (Health/Health Connect), only if you activate this feature Explicit consent (Art. 9.2.a GDPR, health data)
Checking the weather and public holidays in your area from your approximate location, if you activate this feature Explicit consent
Sending and receiving Time Capsules with other people Performance of a contract
Notifying the recipient of a Time Capsule (by email or, if they already have an account, by push notification) Legitimate interest of the sender and of KUMERA in the Capsule reaching the person it is meant for
Product analytics and application improvement Consent (off by default, revocable at any time in Settings)
Managing support and assistance requests Legitimate interest and performance of a contract
Guaranteeing platform security and preventing misuse Legitimate interest
Managing technical incidents and errors Legitimate interest (you can object by turning off error reports in Settings)
Complying with applicable legal obligations Legal obligation
Sending technical communications necessary for the service to function Performance of a contract and legitimate interest

TEMPO does not use personal data for advertising purposes or to build commercial profiles.

6. Our commitment to your privacy

TEMPO’s philosophy is simple: your thoughts, memories and emotions belong only to you.
For this reason, we have designed the application so that, whenever possible, your information stays exclusively under your control.
When you decide to activate cloud backup, the content is encrypted on your own device before being sent to our servers.
Our goal is to provide a personal and private tool, not to collect information about our users.

7. End-to-end encrypted backup

When the user voluntarily activates the backup:

  • The content is encrypted locally on their device before being transmitted.
  • The encrypted content is stored on TEMPO’s infrastructure.
  • The keys needed to decrypt the content remain under the user’s control.
  • The stored content cannot be read in plain text by KUMERA.

Activating this feature is entirely optional.
The sleep, steps, heart rate and exercise data described in section 9 are not part of this backup. They are never encrypted or transmitted, because they never leave the device.

7bis. Time Capsules sent to another person

When you send a Time Capsule to another person, we process their email address to notify them that they have received it, through our email delivery provider (Resend, see section 10).

  • If that person already has a TEMPO account, the Capsule’s content is end-to-end encrypted: not even KUMERA can read it, only that person can.
  • If that person does not yet have a TEMPO account, the content is protected through our database’s access controls, but is not end-to-end encrypted until they register on the application.

In addition, TEMPO includes technical mechanisms to limit the number of Capsules that can be sent per day and to the same recipient, and allows whoever receives a Capsule to block whoever sent it or report inappropriate content.

8. Information we cannot see

When encrypted backup is active:

  • Diary entries.
  • Clima records.
  • Time Capsules.
  • Attached photographs.
  • Voice notes.
  • Content generated during Pausa sessions.
  • Experiments, discoveries and progress in Pausa programmes.

remain encrypted before leaving the user’s device.
As a result, KUMERA cannot access the actual content of this information while it remains encrypted.
Important: if the user loses the code or recovery mechanism needed to access their encrypted data and does not keep any authorised device, it is possible that this content cannot be recovered.

9. Health data: sleep, steps, heart rate and exercise (Apple Health / Health Connect)

This feature is optional and is activated through a specific switch in Settings. Until you activate it, TEMPO does not request Health permission nor access any data of this kind.

What we read

Four metrics: minutes of sleep, step count, average daily heart rate and daily exercise minutes. TEMPO does not read any other health data (for example, it does not read weight, menstrual cycle data, glucose or any other type of Apple Health/Health Connect record).

What it is used for

To cross, day by day, your minutes of sleep, your steps, your heart rate and your exercise minutes with your Clima records and show you, if there is enough history, possible relationships between your rest, your activity and your mood. This analysis never replaces medical or professional advice.

Where it is processed

Entirely on your device. TEMPO does not transmit, does not store on its servers and does not include in the encrypted backup your sleep, step, heart rate or exercise values, nor the results of crossing them with your Clima.

How it is activated and revoked

Read permission is requested from the operating system (Apple Health on iOS, Health Connect on Android) only at the moment you activate the feature from Settings. You can deactivate it at any time from TEMPO or revoke the permission directly from your device’s Health/Health Connect settings.
Technical note on iOS: by Apple’s privacy design, TEMPO can never know which Health permissions you actually granted, only whether you completed the system’s authorisation dialogue.

10. Who we share data with

We do not sell, rent or transfer personal data to third parties for advertising purposes.
To provide the service we use technology providers that act as data processors under Article 28 of the GDPR.
We may currently use providers such as:

  • Supabase (infrastructure, database, authentication and storage).
  • Apple (application distribution, in-app purchases and, if you activate the Health feature, reading sleep, steps, heart rate and exercise data through HealthKit, where applicable).
  • Google (application distribution, in-app purchases and, if you activate the Health feature, reading sleep, steps, heart rate and exercise data through Health Connect, where applicable).
  • Resend (sending emails related to authentication, the functioning of the service, and notifying you of received Time Capsules).
  • Expo (650 Industries, Inc., United States): sending push notifications through its service, which delivers them via Apple’s notification service (APNs) or Google’s (Firebase Cloud Messaging) depending on your device, and distributing app updates.
  • Open-Meteo (checking the weather based on your approximate location, only if you activate this feature).
  • Nager.Date (checking national public holidays based on your country, only if you activate this feature).
  • PostHog (product analytics, only if you accept it: which features are used, hosted within the European Union).
  • Sentry (technical error monitoring, hosted in Germany, European Union).

Open-Meteo and Nager.Date receive only approximate coordinates or the corresponding country code at the time of the query, never personal content (Diary, Clima, Capsules, voice notes, etc.) nor identifiers from your account.
We may also use other technology providers strictly necessary for TEMPO to function, always subject to data processing agreements and the guarantees required by applicable regulations.

11. International transfers

As a general rule, data is stored on infrastructure located within the European Economic Area (EEA).
TEMPO’s main infrastructure is currently hosted within the European Union.
Should any provider involve an international transfer of data outside the EEA, that transfer will only take place when adequate safeguards exist under Articles 44 et seq. of the GDPR, including, where applicable, Standard Contractual Clauses approved by the European Commission or other legally recognised mechanisms.

Some of the providers listed in section 10 are based in the United States (for example, Expo, Resend, Apple or Google). Where a provider may access personal data from outside the EEA, the transfer relies on the EU-U.S. Data Privacy Framework if the provider participates in it, or on the European Commission’s Standard Contractual Clauses.

12. Data retention

We will keep personal data for as long as the account remains active.
If an account has not been logged into for more than 24 months, we will send an email notice informing you that, if the application is not used again within the following 30 days, the account and all its data will be permanently deleted. If the user logs in at any point within that period, the account is automatically excluded from deletion.
The sleep, steps, heart rate and exercise data described in section 9 are never stored on our servers, so they are not subject to a retention period on our part. Their retention on your own device depends on Apple Health or Health Connect and your operating system settings.
When the user deletes their account or requests the deletion of their data:

  • The associated information will be deleted or anonymised.
  • This process will take place within a maximum of 30 days, unless a legal obligation requires a longer retention period.

Certain technical information or information related to legal obligations may be retained for the periods required by applicable regulations.

13. Your rights

You can exercise the following rights free of charge:

  • Right of access: to know what personal data we process about you.
  • Right of rectification: to modify or correct inaccurate information.
  • Right of erasure: to request the deletion of your personal data.
  • Right to object: to object to certain processing based on legitimate interest.
  • Right to restriction of processing: to request that certain data be retained but not used temporarily.
  • Right to data portability: to receive a structured copy of the data you have provided to us.
  • Right to withdraw consent: to withdraw, at any time, any consent given (including consent for the Health feature), without affecting the lawfulness of the processing carried out prior to its withdrawal.
  • Right not to be subject to automated decisions: TEMPO does not make decisions based solely on automated processing, nor does it build profiles with legal effects on users.

14. How to exercise your rights

You can exercise your rights:

  • Through the features available within the application itself.
  • By writing to: hola@kumera.es
  • Even without an account, from Settings you can export to a file or delete everything stored on your device.

You also have the right to lodge a complaint with the competent supervisory authority. This authority is, generally, the data protection authority of your country of habitual residence, your place of work, or the place where the alleged infringement occurred.

15. Minors

TEMPO is intended for people aged 16 or over, in every country.

The application is not intended for anyone under that age, and it checks this at the start by asking for your date of birth.

If we detect that we have collected personal data from someone under 16, we will delete it as soon as possible.

16. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or destruction.
Among other measures, TEMPO uses:

  • Data encryption.
  • Secure credential storage.
  • Protection through security mechanisms provided by the device’s operating system.
  • Access controls.
  • Measures aimed at guaranteeing the confidentiality, integrity and availability of information.

However, no system is completely immune to security incidents, and we cannot guarantee absolute security.

17. Changes to this policy

We may update this Privacy Policy to adapt it to legal, technical or functional changes in TEMPO.
When changes are significant, we will inform users through the application itself or through other appropriate means.

18. Contact

For any query related to this Privacy Policy or to the processing of your personal data, you can contact:
Kumera
hola@kumera.es
Last updated: October 2026.