Privacy notice

dlytful privacy notice

Last updated: {{LAST_UPDATED_DATE}}

This notice explains what personal data dlytful collects, why, how long we keep it, and the rights you have. It covers the dlytful website, the Android beta application, the iOS waitlist, and the dlytful app itself.

dlytful is an early-stage product in development. We follow data minimisation and user control, and we only claim what the product can currently demonstrate. This notice will be updated as the product develops.

1. Who is responsible for your data

The data controller is {{CONTROLLER_LEGAL_NAME}}, registered at {{CONTROLLER_REGISTERED_ADDRESS}}, registry code {{CONTROLLER_REGISTRY_CODE}}.

For any privacy question or to exercise your rights, contact {{PRIVACY_CONTACT_EMAIL}}.

Data protection officer: {{DPO_CONTACT_OR_NONE}}.

2. A note about information about other people

dlytful helps you remember details about people already in your life. This means you may record personal information about other people, such as family, friends, or colleagues, who are not dlytful users and have not signed up themselves.

You decide what to record. Please record only what is appropriate, and treat information about others with the same care you would want for information about yourself. dlytful is designed to store as little as the product needs to function, to keep sensitive details off lock screens by default, and to let you edit or delete anything you have recorded.

If you believe someone has recorded information about you in dlytful and you want to know what is held or ask for it to be removed, contact {{PRIVACY_CONTACT_EMAIL}}. We will handle the request in line with data protection law. In some cases we may be unable to identify records about you without further detail, or we may need to involve the user who created them.

3. Sensitive information

Some notes may include sensitive information, such as health, religious or political views, sexual matters, or similar. Under data protection law this is special category data and receives extra protection.

dlytful asks you to confirm before saving information it detects as highly sensitive, keeps it out of automatic location prompts and lock-screen text by default, and relies on your explicit consent as the legal basis for holding it. You can delete it at any time. If you do not want dlytful to hold sensitive information about someone, do not record it.

4. What we collect

Account information, such as your email address and sign-in credentials.
Beta application information, such as your first name if provided, email address, Android phone model or version, and your free-text answers.
iOS waitlist information, which is your email address and your consent record.
Notes you record, by voice or text, and the transcripts of voice notes.
Structured details extracted from your notes, such as a person, a date, an event, a suggested question, and a sensitivity level.
Information you choose to record about other people.
Saved places you create.
Optional movement history, only if you turn it on.
Limited technical and diagnostic data needed to run the service securely. This does not include the content of your notes.

5. Why we use your data and our legal basis

To create and run your account and provide the core features. Legal basis: performance of a contract with you.
To transcribe your notes, extract structured details, and prepare reminders. Legal basis: performance of a contract with you, and your explicit consent where a note contains special category data.
To hold and surface sensitive information you choose to record. Legal basis: your explicit consent.
To provide optional movement history and improved reminder timing. Legal basis: your consent, which you can withdraw at any time by turning the feature off and wiping the history.
To assess your Android beta application and contact you about the beta. Legal basis: your consent.
To add you to the iOS waitlist and notify you when iOS testing opens. Legal basis: your consent.
To keep the service secure, prevent misuse, and understand and improve how the product performs, using data that does not include note content. Legal basis: our legitimate interests in running a safe and functional product.

6. Automated processing and profiling

If you turn on movement history, dlytful uses your patterns to improve the timing of reminders. This is a form of profiling. It only affects when a private reminder is offered to you. It does not make any decision that has a legal or similarly significant effect on you, and dlytful does not use it to rank people or judge your relationships. You can turn movement history off and wipe it at any time.

Cookies and website analytics

The website currently uses no non-essential cookies, browser storage or analytics trackers. Its interaction helper emits temporary events within the page and does not send them to a provider. No cookie banner is shown because no non-essential cookie or tracker loads.

8. International transfers

Where a provider processes data outside the European Economic Area, we rely on {{NON_EEA_TRANSFER_MECHANISM}}, such as the relevant European Commission adequacy decision or standard contractual clauses, together with appropriate safeguards. You can contact us for more detail on a specific provider.

9. How long we keep it

Raw audio from voice notes: deleted after successful transcription by default. You can choose to retain raw audio, and that setting is off by default.
Your notes, extracted details, and people you add: kept until you delete them or close your account. On deletion they are removed from active systems, and residual copies in backups are removed within 30 days.
Account information: kept for the life of your account and up to 30 days after closure.
Beta application information: kept for the beta selection process and the duration of the beta, then deleted within 90 days of the beta ending, unless you become an ongoing user or ask us to delete it sooner.
iOS waitlist email: kept until iOS testing opens or you withdraw, whichever comes first.
Movement history: kept only as long as needed to improve timing, wipeable by you at any time, and purged automatically after a period of inactivity.

Where a period is described as planned, it reflects the intended beta design and will be confirmed as the product is built.

10. Your rights

Under data protection law you have the right to access your data, correct it, delete it, restrict or object to certain processing, receive a copy in a portable format, and withdraw consent at any time where we rely on consent. Withdrawing consent does not affect processing that already took place.

To exercise any right, contact {{PRIVACY_CONTACT_EMAIL}}. We aim to respond within one month.

You also have the right to complain to a data protection authority. In Estonia this is the Estonian Data Protection Inspectorate, Andmekaitse Inspektsioon. If you live elsewhere in the European Economic Area, you may contact your local authority.

11. Security

We use measures designed to protect your data, including encryption of data in transit and at rest, restricted internal access, and secure storage of sensitive records. Because dlytful is in development, some security measures are still being built and hardened, and this notice will be updated as they are completed. We will not overstate what is in place.

12. Age

dlytful is not intended for children. You must be at least 16 years old to use dlytful or to apply for the beta.

13. Changes to this notice

We may update this notice as the product develops. We will change the date at the top, and for significant changes we will take reasonable steps to let you know.

14. Contact

For any question about this notice or your data, contact {{PRIVACY_CONTACT_EMAIL}}.