Privacy Policy
Last updated: March 11, 2026
This Privacy Policy explains how Kenherli Digital Sociedad Limitada ("we", "us", "our"), a company registered in Valencia, Spain, collects, uses, and protects your personal data when you use the Watchi Telegram Mini App ("the App").
We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and applicable Spanish data protection legislation.
1. Data Controller
Kenherli Digital Sociedad Limitada
Valencia, Spain
Email: ekenherli@gmail.com
2. Data We Collect
2.1 Data provided by Telegram
When you open the App, Telegram provides us with:
- Your Telegram user ID (numeric identifier)
- Your display name (first name)
- Your username (if set)
- Your language code
- Your Telegram platform (iOS, Android, desktop)
We do not have access to your phone number, contacts, messages, or any other Telegram data.
2.2 Data you create through usage
| Data | Purpose |
|---|---|
| Focus session records (start time, duration, tag) | Display your stats, calculate streaks |
| Custom tags (e.g., "coding", "writing") | Categorize your focus sessions |
| Streak data (current streak, history) | Track and display your streak |
| Focus challenge selection | Personalize AI reports |
| Daily goal and default session duration | Your preferences |
| Notification preferences | Send only the notifications you want |
| Theme preference (light/dark) | Remember your display preference |
| Haptic feedback preference | Respect your vibration setting |
2.3 Data collected automatically
- Analytics data (only with your consent): screen views, feature usage events, error reports. Collected via Firebase Analytics using cookies. No personally identifiable data is included in analytics events.
3. Legal Basis for Processing
| Processing Activity | Legal Basis (GDPR) |
|---|---|
| Core app functionality (sessions, streaks, stats) | Art. 6(1)(b) — Contract performance |
| AI weekly reports (Pro feature) | Art. 6(1)(b) — Contract performance |
| Notifications (morning reminder, streak alerts) | Art. 6(1)(b) — Contract performance |
| Analytics and error tracking | Art. 6(1)(a) — Your consent |
4. Third-Party Services
We use the following third-party services to operate the App:
| Service | Provider | Purpose | Data Shared |
|---|---|---|---|
| Firebase Authentication | Google LLC | User authentication | Telegram user ID |
| Cloud Firestore | Google LLC | Data storage | All user data listed in Section 2 |
| Cloud Functions | Google LLC | Server-side logic | Processed as needed per function |
| Firebase Analytics | Google LLC | Usage analytics (with consent) | Anonymized usage events |
| OpenAI API | OpenAI, Inc. | AI weekly report generation | Aggregated session data (total minutes, session count, tags, streak). No personally identifiable information is sent. |
| Telegram Bot API | Telegram FZ-LLC | Notifications and payments | Telegram user ID, message content |
Google LLC processes data under the EU-US Data Privacy Framework. OpenAI API data is not used to train models (per OpenAI's API data usage policy). Telegram's privacy practices are governed by Telegram's Privacy Policy.
5. Payments
All payments are processed through Telegram Stars, Telegram's built-in payment system. We do not collect, store, or have access to any payment card information, bank details, or billing addresses. Payment processing is handled entirely by Telegram and the respective app store (Apple App Store or Google Play).
6. Cookies
The App uses cookies only for Firebase Analytics, and only after you provide explicit consent via our in-app consent banner. If you decline, no cookies are set and no analytics data is collected.
We use localStorage to remember your consent choice. This is a functional
storage mechanism, not a tracking cookie.
7. Data Retention
Your data is retained for as long as you use the App. If you request data deletion (via Settings > Delete All Data), we immediately and permanently delete:
- Your user profile
- All focus session records
- All custom tags
- Streak data and history
- AI insight reports
- Your Firebase Authentication account
This deletion is irreversible and takes effect immediately.
8. Your Rights (GDPR)
Under the GDPR, you have the following rights regarding your personal data:
- Right of access — You can request a copy of the data we hold about you.
- Right to rectification — You can request correction of inaccurate data.
- Right to erasure — You can delete all your data via the in-app "Delete All Data" function, or by contacting us.
- Right to data portability — You can request your data in a machine-readable format.
- Right to object — You can object to processing based on legitimate interest.
- Right to withdraw consent — You can withdraw analytics consent at any time by declining the consent banner or contacting us.
To exercise any of these rights, contact us at ekenherli@gmail.com. We will respond within 30 days.
You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Espanola de Proteccion de Datos, www.aepd.es).
9. Data Security
We protect your data through the following measures:
- All data is transmitted over HTTPS (TLS encryption)
- Telegram initData is validated server-side using HMAC-SHA256
- Firebase Security Rules prevent unauthorized data access
- Users cannot modify sensitive fields (subscription status, Pro access) from the client
- Cloud Functions enforce server-side validation for all critical operations
10. Children's Privacy
The App is not directed at children under the age of 16. We do not knowingly collect data from children under 16. Telegram's own Terms of Service require users to be at least 16 years old (or the minimum age in their country).
11. International Data Transfers
Your data may be processed in the United States (Firebase/Google Cloud, OpenAI) and in data centers operated by Telegram. Google LLC participates in the EU-US Data Privacy Framework. OpenAI processes data under Standard Contractual Clauses.
12. Changes to This Policy
We may update this Privacy Policy from time to time. If we make significant changes, we will notify you via the App or through a Telegram message. The "Last updated" date at the top indicates the most recent revision.
13. Contact
If you have any questions about this Privacy Policy or your data, contact us at:
ekenherli@gmail.com
Kenherli Digital Sociedad Limitada
Valencia, Spain