Privacy policy

Updated 23 October 2026

This policy explains what personal data we process, what it is used for and what rights you have. It applies to the website adhd-momentum.com and the ADHD Momentum app.

1. Data controller

Satu Valero
Business ID 2792062-4
Espoo, Finland
Email: info@adhd-momentum.com

For data protection matters, the contact person is Joakim Kaipainen. We don’t have a separate data protection officer, because the scale of our operations doesn’t require one.

2. What data we process

Email list and enquiries

  • email address
  • name, organization and phone number, if you give them with a quote request
  • the message or additional information you write on a form
  • the consent text of the form as it was visible, the time of submission and the page the form was sent from
  • IP address and browser identifier

The IP address and browser identifier are stored to prevent misuse and to show when and where consent was given. They are not used for marketing.

Test group sign-up

  • first name and email address
  • phone type, age group and everyday situation
  • areas where you need support, and a free-form reason
  • optionally, whether you have an ADHD diagnosis, are waiting for an assessment or recognize traits in yourself
  • the consents you give, the time of submission, IP address and browser identifier

We use this data to select the test group and for related communication, and as anonymous summaries for developing the service. When you sign up, you also join the email list.

Subscriptions and use of the app

  • subscriber’s name and email address
  • order and payment history, billing details
  • authentication data for logging into the app
  • information on which membership is valid and when it ends
  • in-app purchase details: the product, the dates of purchase and renewal and the status of the subscription, stored against your account identifier
  • the progress you save in the app: completed exercises, assessment answers, your own routine, wins of the day, weekly star ratings and free-form feedback
  • app usage events, for example which exercise or lecture was opened and when
  • the time when you accepted the app’s terms of use and disclaimer

We don’t process payment card data. Payment is handled by a payment provider, which receives and processes card details in its own system. We only receive information on whether the payment succeeded.

What we don’t collect

The app doesn’t ask for or store health data. We don’t ask about diagnosis or medication. The only exception is the test group sign-up, where you can choose to say whether you have an ADHD diagnosis. The answers to the app’s assessment are stored in the user’s profile until the user deletes their profile or asks for it to be deleted.

The answers to the feedback survey filled in after the four-week program are stored in two places: with your progress in your account, like the other data you save in the app (we can see them in connection with your account), and as a separate anonymous copy for developing the service, without an email address or any other information that could identify the respondent.

The app doesn’t collect location data or your phone’s contacts, and it has no advertising or ad tracking.

3. Basis and purpose of processing

  • Consent. Joining the email list and the related marketing. You can withdraw your consent at any time.
  • Explicit consent. Information about a diagnosis or assessment given in the test group sign-up. You can withdraw your consent at any time, in which case we delete the information.
  • Performance of a contract. Delivering the subscription, managing access, billing and customer service, and saving your progress in the app so that it is kept and follows you from one device to another.
  • Legal obligation. Keeping receipts as required by the Finnish Accounting Act.
  • Legitimate interest. Preventing misuse and spam, technical maintenance of the service and developing the service. For development, funding applications and reports to organizations we use only summaries from which an individual user can’t be identified.

4. Retention period

  • Email list: until you withdraw consent or until the data is no longer needed.
  • Test group application: three months from the end of the test period or, if you were not accepted into the group, from the selection notice. After that, name, email address and other identifying data are removed from the application, and the remaining anonymous data is used only for summaries. Email list data is kept according to the email list’s retention period.
  • Quote requests: two years from handling the request.
  • Order data and accounting records: six years, as required by the Accounting Act, from the end of the calendar year in which the financial year ends.
  • IP addresses and log data: twelve months.
  • Data you save in the app: for as long as your account exists. When you delete the account, the data is deleted.
  • Anonymous copy of survey answers kept for development: it can’t be linked to you, so it isn’t removed with the account.

5. Who the data is disclosed to

We don’t sell or rent personal data. We use the following service providers, who process data on our behalf:

  • Hostinger: server platform for the website and email.
  • Google Firebase: app authentication, access management and storing the data you save in the app. The servers are located in Finland (europe-north1).
  • Stripe: payment traffic and verification of payment transactions.
  • RevenueCat: management of in-app purchases and subscriptions. The service verifies a purchase made through the App Store or Google Play and tells the app whether your membership is valid. It processes your account identifier and the purchase and subscription details. It does not receive your payment card details. The service may process data outside the EU, see section 6.
  • Bunny.net: delivery of the app’s recordings and images. The service processes the technical data needed to deliver a file, such as the IP address.
  • Google Play and App Store: distribution of the app. The app stores process data related to downloading and installing according to their own privacy practices.

If your employer or another organization has obtained a membership for you, only anonymous summaries about the whole group’s use and experiences are reported to it, for example how many have started, which exercises have been used and how the feedback survey was answered. Summaries are given only when the group has at least five users, and an individual user can’t be identified from them. The organization is not given names, email addresses or any individual user’s answers, exercises or progress. Free-form feedback may be quoted in a report only if it does not reveal who wrote it.

Data may be disclosed to an authority if the law requires it.

6. Transfers outside the EU

We aim to keep data within the EU and the EEA. If a service we use processes data outside the EU, the transfer is based on the standard contractual clauses approved by the European Commission or on the Commission’s adequacy decision on data protection.

7. Cookies

The website uses cookies that are necessary for the site to function. We use Google analytics.

The app doesn’t use cookies, ad tracking or analytics services. It stores your progress on your device and in your account.

You can block cookies in your browser settings. Blocking necessary cookies may break features of the site.

8. Protecting the data

Connections to the site are encrypted (HTTPS). Access to personal data is limited to those who need it to do their jobs, and access requires a personal login. The forms have protections against spam and automated submissions.

9. Your rights

You have the right to:

  • know whether we process data about you, and get a copy of it
  • have incorrect data corrected
  • request deletion of your data
  • restrict or object to processing
  • receive the data you’ve given in a portable format
  • withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing done before it

Send requests by email to info@adhd-momentum.com. We reply within one month. We may ask you to prove your identity before releasing data.

If you believe we process your data unlawfully, you can lodge a complaint with the Office of the Data Protection Ombudsman in Finland (tietosuoja.fi/en).

Deleting your ADHD Momentum account and data

You can delete your account and all the data you’ve saved in the app yourself:

  1. Open the ADHD Momentum app and log in.
  2. From the bottom menu, go to Journey and open Progress.
  3. In the Account section at the bottom of the page, choose Delete account and confirm.

Deletion is immediate and final. It removes your login, your progress, your routine, your ratings and your feedback.

If you can’t access the app, send a deletion request to info@adhd-momentum.com from the email address you’ve logged in with. We delete the account and the related data within 30 days and confirm the deletion by email.

Order and payment data required by the Accounting Act is kept for the statutory period, and the anonymous copy of survey answers kept for development remains because it can’t be linked to you.

10. Changes

We keep developing the service, so this policy may be updated. We’ll announce significant changes on the site. The valid version is always on this page, and the update date is shown at the top of the page.