Privacy Policy - Bugsy

Last Updated: January 18, 2026

  1. Introduction

This Privacy Policy describes how Rayane Benhizia (hereinafter "we", "our" or "the Publisher"), a sole proprietor established in France, collects, uses and protects your personal data when using the Bugsy mobile application (hereinafter "the Application").

We place great importance on protecting your privacy and are committed to complying with the General Data Protection Regulation (GDPR) and all applicable data protection laws.

Contact: For any questions regarding this policy, you can contact us at rayanebenhizia@icloud.com.

  1. Data Collected

2.1 Directly Collected Data

Username: You create a username when you use the Application. This username is visible to your friends in the insect exchange feature.

Apple ID (iCloud) and Firebase: The Application uses Apple's CloudKit and Firebase for account management. Your Apple ID is used to synchronize your data across your Apple devices.

Friend Code: A unique code automatically generated by the Application to enable exchanges with other users (maximum 10 friends).

2.2 Location Data

Approximate Location: We collect your approximate location only to retrieve local weather information. This weather data is used to:

Display weather on insect cards

Enhance AI conversations by indicating whether the insect would be active in these weather conditions

Important: Only weather data (and not your precise GPS location) is transmitted to the Gemini AI chat service.

2.3 Health Data (HealthKit)

Daily Step Count: With your explicit permission, the Application accesses your step count data via HealthKit to allow you to earn stars (in-app credits) by reaching 5,000 steps per day.

This data is never shared with third parties and remains exclusively on your device.

2.4 Usage Data

Application Progress: Your insect collection, stars (credits), daily quiz results and status (free or GOLD account) are stored on CloudKit and Firebase.

AI Conversation History: Conversations with insects via Gemini AI are saved locally on your device only. They are not stored on our servers. If you delete the Application, these conversations will be permanently lost.

2.5 Analytics Data

Firebase Analytics: We use Google's Firebase Analytics to collect anonymized usage statistics of the Application, such as:

Pages visited

Time spent on certain features

General interactions with the Application

This data is aggregated and does not personally identify you.

2.6 Advertising Data

There is no advertising display in the app.

  1. Data Usage

We use your personal data only for the following purposes:

Application Operation: Manage your account, collection, insect exchanges and progress

Experience Personalization: Adapt AI interactions based on local weather and season

Daily Rewards: Calculate your stars earned via step count, quiz and bonuses

Application Improvement: Analyze usage via Firebase to optimize features

We never sell your personal data to third parties.

  1. Data Sharing with Third Parties

4.1 Essential Services for Operation

Apple CloudKit: Your account data, collection and progress are stored on Apple's servers via CloudKit. Apple acts as a data processor and is subject to its own privacy policy.

Google Gemini AI: When you use the AI chat (feature reserved for GOLD accounts), the following information is sent to Google:

Your message and limited conversation history for context

Current weather data (not your GPS location)

Information about the insect you are conversing with

Conversations are not stored online by us, but Google may process this data according to its own privacy policy.

4.2 Analytics

Firebase Analytics (Google): Collects anonymized usage data for global statistics.

4.3 No Other Sharing

We do not share your data with any other third parties, except as required by law (court order, administrative requisition, etc.).

  1. Data Retention Period

Account Data (CloudKit): Retained as long as you use the Application. If you delete your account or the Application, your CloudKit data may be deleted according to your device's iCloud settings.

AI Conversations: Stored locally on your device only, deleted if you uninstall the Application.

HealthKit Data: Never stored by us, remains in Apple's Health app.

Analytics Data (Firebase): Anonymized and retained according to Firebase settings (generally 14 months).

  1. Your Rights (GDPR)

In accordance with GDPR, you have the following rights regarding your personal data:

Right of Access: You can request a copy of your personal data

Right of Rectification: You can correct your data (for example, modify your username)

Right to Erasure: You can request deletion of your data

Right to Restriction of Processing: You can request limitation of the use of your data

Right to Data Portability: You can receive your data in a structured format

Right to Object: You can object to processing of your data for advertising purposes

Right to Withdraw Consent: You can withdraw your HealthKit access authorization at any time in iOS settings

To exercise these rights, contact us at rayanebenhizia@icloud.com.

You also have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés) in France.

  1. Data Security

We implement appropriate technical and organizational measures to protect your data:

Apple CloudKit: Uses encryption in transit and at rest

Local Storage: AI conversations are stored locally on your secure device

Limited Access: Only necessary services (CloudKit, Gemini, Firebase) have access to data strictly required for their operation

However, no data transmission over the Internet is completely secure. We cannot guarantee absolute security.

  1. Cookies and Tracking Technologies

The Application uses the following tracking technologies:

Firebase Analytics: Uses device identifiers to track Application usage

  1. Minors

The Application is intended for users aged 12 and over. We do not knowingly collect personal data from children under 12 without parental consent. If you believe we have collected data from a minor without authorization, contact us immediately.

  1. Changes to this Policy

We may modify this Privacy Policy at any time. In case of substantial modification, we will inform you via a notification in the Application or by any other appropriate means.

The last update date is indicated at the top of this document. We encourage you to regularly consult this page.

  1. International Data Transfers

Some of our service providers (Google for Firebase and Gemini) may be located outside the European Union. These transfers are governed by appropriate safeguards in accordance with GDPR (standard contractual clauses, Privacy Shield, etc.).

  1. Contact

For any questions regarding this Privacy Policy or to exercise your rights:

Rayane Benhizia Sole Proprietor Email: rayanebenhizia@icloud.com

By using the Bugsy Application, you accept this Privacy Policy.