EquiPulse GDPR Statement

Effective Date: April 15, 2026

EquiPulse — Horse Health & Care Manager
Data Controller: 6tSevn BV
Address: Gangboord 11, 3356 DG Papendrecht, Netherlands
Contact: privacy@6tsevn.com

1. Purpose of This Statement

This GDPR Statement explains how 6tSevn BV (“6tSevn”, “we”, “us”) approaches the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) in connection with the EquiPulse mobile application. It complements our Privacy Policy and is intended for users in the European Economic Area (EEA), the United Kingdom, and other jurisdictions whose laws are based on the GDPR.

2. Privacy by Design and by Default

EquiPulse is engineered to comply with Article 25 GDPR (“Data Protection by Design and by Default”). The app is built so that no personal data is transmitted to or stored on servers operated by 6tSevn. All horse records, health data, journal entries, training logs, expenses, vaccinations, and contacts are stored locally on the user's device using Apple's SwiftData framework inside the app's sandboxed container.

Where users opt in to iCloud Sync (a Premium feature), data is synchronised exclusively through the user's own Apple iCloud account using Apple's CloudKit framework. 6tSevn does not have access to that data.

3. Personal Data We Process as a Controller

In the operation of EquiPulse itself, 6tSevn does not process any personal data of app users. Specifically, we do not collect names, email addresses, IP addresses, device identifiers, advertising identifiers, analytics, telemetry, or crash reports.

6tSevn only processes personal data in the following limited situations, which fall outside of in-app activity:

  • Direct correspondence: If you contact us by email (e.g. privacy@6tsevn.com or info@6tsevn.com), we process the email address and contents you provide for the sole purpose of responding to your message.
  • App Store transactions: Subscriptions and in-app purchases are processed by Apple. 6tSevn receives only aggregated, non-identifying sales reports from Apple.
  • Website usage: Our website may use strictly necessary technical cookies; please refer to the website's privacy notice for details.

4. Lawful Bases for Processing (Article 6 GDPR)

Where we do process limited personal data as described above, we rely on the following lawful bases:

  • Article 6(1)(b) — Performance of a contract, in connection with delivering the EquiPulse app and any subscription you purchase.
  • Article 6(1)(f) — Legitimate interests, where we respond to support questions or correspondence and ensure the security and integrity of our services.
  • Article 6(1)(c) — Legal obligation, where applicable law requires us to retain certain records (e.g. fiscal documentation related to subscription revenue received via Apple).
  • Article 6(1)(a) — Consent, where you explicitly opt in to a feature or communication.

5. Special Categories of Data

Health information about animals is not, in itself, “special category” data within the meaning of Article 9 GDPR, which concerns natural persons. Nonetheless, EquiPulse treats your data with care: it remains on your device and, where iCloud Sync is enabled, in your personal Apple account.

6. The Role of Apple

EquiPulse is distributed through the Apple App Store and uses Apple frameworks (SwiftData, CloudKit, StoreKit, UserNotifications, LocalAuthentication, WatchConnectivity). When you use these features, Apple may process personal data as an independent controller under its own privacy terms, available at apple.com/legal/privacy. 6tSevn does not control and is not responsible for Apple's processing.

7. Data Retention

Because no in-app data reaches 6tSevn, no retention period is required for that data on our side. Data you store locally remains on your device until you delete it, uninstall the app, or remove the corresponding records. iCloud-synced data follows your iCloud retention settings.

Email correspondence with 6tSevn is retained only for as long as necessary to handle your enquiry and to comply with applicable record-keeping obligations.

8. International Data Transfers

6tSevn does not transfer in-app personal data outside the EEA, because no such data reaches us. Where Apple, as an independent controller, transfers data internationally (for example, to its data centres outside the EEA), it does so under its own safeguards described in Apple's privacy documentation.

9. Your Rights as a Data Subject

Under Articles 15–22 GDPR, you have the following rights with respect to personal data we process about you:

  • Right of access — obtain confirmation of whether we process personal data about you and a copy of that data.
  • Right to rectification — have inaccurate or incomplete personal data corrected.
  • Right to erasure (“right to be forgotten”) — have your personal data deleted where the legal grounds apply.
  • Right to restriction of processing — have processing limited in certain circumstances.
  • Right to data portability — receive your personal data in a structured, commonly used and machine-readable format.
  • Right to object — object to processing carried out on the basis of legitimate interests.
  • Right not to be subject to automated decision-making, including profiling, that produces legal or similarly significant effects.
  • Right to withdraw consent at any time, where processing is based on consent.

Because EquiPulse stores all in-app data on your device, you can exercise full control directly within the app: edit, export (PDF), or delete records, and uninstall the app to remove all local data. For data processed by 6tSevn outside the app (such as email correspondence), please contact us at privacy@6tsevn.com. We will respond within one month, in line with Article 12(3) GDPR.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. The supervisory authority for 6tSevn is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), available at autoriteitpersoonsgegevens.nl.

11. Data Protection Officer

6tSevn BV is not required to appoint a Data Protection Officer under Article 37 GDPR, as our core activities do not involve large-scale processing of personal data or special categories of data. Privacy enquiries can be sent to privacy@6tsevn.com.

12. Security

In line with Article 32 GDPR, 6tSevn implements appropriate technical and organisational measures suited to the limited nature of the personal data we handle. The most important measure is structural: by not collecting or storing user data in the first place, the risk to data subjects is minimised.

13. Changes to This Statement

We may update this GDPR Statement from time to time. The effective date at the top of this page indicates when it was last revised. We encourage you to review this statement periodically.

14. Contact

For any question relating to this GDPR Statement or to your data protection rights, please contact:

6tSevn BV
Email: privacy@6tsevn.com
Address: Gangboord 11, 3356 DG Papendrecht, Netherlands