Privacy Policy

Last updated: February 2026

1. Data Controller

The controller of personal data is:

Sole trader (JDG) European Union
Email: [email protected]

For all data protection inquiries, please contact us at the email above.

2. Scope and Application

This Privacy Policy applies to the mobile application (“App”), related backend infrastructure, AI-powered features, and associated services (collectively, the “Service”).

This Policy is provided in accordance with:

Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR)
Applicable national data protection laws
Apple App Store privacy requirements
Google Play Data Safety requirements

By using the Service, you acknowledge that your personal data may be processed as described in this Policy.

3. Categories of Personal Data Processed

We may process the following categories of data:

3.1 Information You Provide

Email address
Account identifiers
Authentication credentials (via secure providers)
Content submitted within the App

3.2 Automatically Collected Data

IP address
Device type and operating system
Application version
Log data
Usage interactions
Crash reports and diagnostics

3.3 Analytics Data

Session data
Aggregated usage statistics
Feature interaction data

We do not intentionally collect special categories of personal data (Art. 9 GDPR). If such data is voluntarily submitted, it is processed solely for providing the Service.

4. Purposes and Legal Bases for Processing

We process personal data strictly for the following purposes:

Purpose	Legal Basis
Account registration and authentication	Art. 6(1)(b) – Contract
Providing core application functionality	Art. 6(1)(b) – Contract
AI-powered features	Art. 6(1)(b) and/or Art. 6(1)(f)
Security, fraud prevention, and logging	Art. 6(1)(f) – Legitimate interest
Analytics and performance monitoring	Art. 6(1)(f) – Legitimate interest
Compliance with legal obligations	Art. 6(1)(c) – Legal obligation

Where required by law, processing is based on user consent (Art. 6(1)(a)).

5. AI Processing Disclosure

Certain features of the Service may use artificial intelligence models.

User-submitted content may be processed by external AI providers solely to generate requested outputs.

AI providers may include:

OpenAI
Anthropic
Google

The AI provider may change over time due to infrastructure decisions, testing, or service optimization.

We:

Do not sell personal data to AI providers
Require contractual safeguards
Require processing solely for service delivery
Do not permit training on user data unless explicitly stated

Users should not submit confidential, regulated, or sensitive data unless necessary for intended functionality.

6. Service Providers (Data Processors)

We use third-party processors to operate and secure the Service.

Infrastructure & Hosting

Own servers hosted within the European Union
Amazon Web Services (AWS)
Microsoft Azure
Google Cloud Platform
iDrive
Backblaze

Backend & Analytics

Google Firebase
Google Analytics

Error Monitoring

Sentry

All providers process data under applicable data processing agreements (DPAs).

7. International Data Transfers

Some providers may process data outside the European Economic Area (EEA).

Where such transfers occur, we rely on:

European Commission adequacy decisions
Standard Contractual Clauses (SCCs)
Additional safeguards where required

Data transfers are performed in accordance with Chapter V of the GDPR.

8. Data Retention

We retain personal data only as long as necessary for:

Providing the Service
Fulfilling contractual obligations
Complying with legal requirements
Resolving disputes
Ensuring security

Data may be deleted or anonymized when no longer required.

Users may request deletion of their account and associated personal data, subject to legal retention obligations.

9. Data Sharing and No Sale of Data

We:

Do not sell personal data
Do not share personal data for advertising purposes
Do not engage in data brokerage

Personal data is shared only with service providers necessary for operating the Service.

10. User Rights (GDPR)

If you are located in the European Economic Area, you have the right to:

Access your personal data
Rectify inaccurate data
Request erasure
Restrict processing
Object to processing
Request data portability
Withdraw consent (where applicable)

Requests may be submitted to: [email protected]

You have the right to lodge a complaint with a supervisory authority in your EU Member State.

11. Security Measures

We implement appropriate technical and organizational measures, including:

Encryption in transit (TLS)
Access controls
Authentication safeguards
Monitoring and logging
Data minimization practices

However, no system can guarantee absolute security.

12. Children’s Privacy

The Service is not directed to children under 16 (or lower age permitted by national law). We do not knowingly collect personal data from children without required consent.

If we become aware of such processing, we will delete the data.

13. App Store & Platform Compliance

In accordance with Apple and Google requirements:

Data collection practices are transparently disclosed
Tracking for advertising purposes is not performed
Sensitive permissions are requested only when necessary
Users may request account deletion
Data is processed only for specified purposes

14. Limitation of Liability

To the maximum extent permitted by applicable law:

We are not responsible for independent processing performed by third-party providers.
We are not liable for service interruptions or security incidents beyond our reasonable control.
Users are responsible for ensuring that submitted content complies with applicable laws.

15. Changes to This Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated via the App or website. Continued use of the Service after updates constitutes acceptance of the revised Policy.