Last Updated: November 22, 2024


Introduction

Our data processing activities are based on:

  • Contract performance (Art. 6(1)(b) GDPR) for subscription services
  • Legitimate interests (Art. 6(1)(f) GDPR) for app functionality
  • Consent (Art. 6(1)(a) GDPR) for audio processing

Subscription Services

Subscription Tiers

  • Free Tier: Basic features at no cost
  • Basic Subscription
  • Pro Subscription

All payment processing and subscription management is handled through Apple’s App Store Kit. RevenueCat is used solely for anonymous subscription verification using device-specific identifiers.

Data Processing and Storage

Audio Processing

When you use the speech-to-text feature:

  • Audio recordings are transmitted to OpenAI’s Whisper service for processing
  • Transmissions are encrypted using industry-standard protocols
  • No audio data is permanently stored on our servers
  • Processing is performed in compliance with GDPR requirements

Data Minimization


Following GDPR Article 25, we implement data minimization by:

  • Using anonymous identifiers for subscription tracking
  • Processing data only when necessary for specific features
  • Storing content locally on your device

User Rights Under GDPR

You have the following rights:

  • Access your personal data
  • Request data correction
  • Request data deletion
  • Withdraw consent for audio processing
  • Data portability
  • Lodge a complaint with a supervisory authority

Technical and Organizational Measures

We implement appropriate technical and organizational measures to ensure data security:

  • End-to-end encryption for data transmission
  • Local storage of user-generated content
  • Secure API communications with third-party services
  • Regular security assessments

Third-Party Service Providers

We work with the following third-party service providers who may process your data:

OpenAI (Whisper)

  • Purpose: Speech-to-text conversion
  • Privacy Policy: openai.com/privacy
  • Data Processing Agreement: openai.com/policies/data-processing-addendum

Firebase Crashlytics

  • Purpose: App performance monitoring and crash reporting
  • Privacy Policy: firebase.google.com/support/privacy
  • Data Processing Agreement: https://firebase.google.com/terms/data-processing-terms

RevenueCat

  • Purpose: Anonymous subscription verification
  • Privacy Policy: revenuecat.com/privacy
  • Data Processing Agreement: revenuecat.com/dpa

Apple Services

  • Purpose: App distribution and payment processing
  • App Store Privacy Policy: apple.com/legal/privacy/data/en/app-store
  • App Store Review Guidelines: developer.apple.com/app-store/review/guidelines

These third-party providers maintain their own privacy policies and terms of service. We encourage you to review their respective privacy policies to understand how they process your data. We regularly review our providers‘ privacy practices to ensure they meet our standards and comply with applicable data protection laws.Note: The links provided above should be accessed through the respective service providers‘ official websites to ensure you are viewing the most current versions of their policies.