Privacy Policy

Last updated: 13 August 2026

1. Introduction

This Privacy Policy explains what information the App collects, why it is collected, how it is used, and what choices you have. It applies to the mobile application and to the services that support it. By using the App you accept the practices described here. If you do not agree with them, please stop using the App.

2. Company information

The App is operated by SLBS financial & business services GmbH (“we”, “us”), which acts as the controller of the personal data described in this Policy. You can reach us at any time at help@slbsfinancialbusiness.services.

3. Categories of information we collect

3.1 Content you write

The core of the App is a written conversation about how you feel. The text you type — entries, replies, answers to reflection questions, and names you give to your topics — is sent over an encrypted HTTPS connection to our server, where it is stored under an anonymous installation identifier and used to generate the App’s responses, summaries and weekly reflections.

3.2 Photos, voice and speech

3.3 Device and installation data

We create an anonymous installation identifier and session tokens, stored in the device Keychain, so your history is available to you across launches. We do not ask for an email address or a password, and the App has no sign-in screen or user account.

3.4 Automatically collected data

Our server and the providers listed below receive technical data such as device model, operating system version, app version, language, IP address, coarse country derived from it, timestamps, crash reports and diagnostic events (for example, screens opened and features used). The App does not collect precise location.

3.5 Purchases

Subscriptions are sold through the Apple App Store. Payment is handled entirely by Apple: we never see or store your card details. We receive from Apple and from our providers the fact of a purchase, the product identifier, the price and currency, and the subscription status.

3.6 Notifications

If you allow notifications, the App receives a push token from Apple, used to deliver the weekly reflection reminder and, for our attribution provider, to distinguish an uninstall from an inactive device. You can withdraw permission at any time in iOS Settings.

3.7 Advertising identifier (tracking)

On first launch the App asks, through Apple’s App Tracking Transparency prompt, whether we may use the advertising identifier (IDFA) to measure the effectiveness of our marketing. If you decline, no advertising identifier is used, and the App remains fully functional.

3.8 Support requests

If you write to us, we process your message and your contact details in order to answer you.

4. Special categories of data

What you write in the App concerns your emotional state and personal circumstances, and may reveal information that data protection law treats as sensitive. We handle it accordingly:

The App is a self-reflection tool. It is not a medical device, it does not provide diagnosis or treatment, and it is not a substitute for professional care or emergency services.

5. How we use information

Our legal bases, where the GDPR applies, are the performance of our contract with you (operating the App and your subscription), your consent (notifications, tracking, optional features), and our legitimate interest in a stable and secure service.

6. Automated processing by AI models

The text you send is processed by artificial-intelligence language models operated by us or by our processing providers on our behalf, in order to generate the App’s replies and summaries. The transfer happens over HTTPS. This processing produces text shown back to you; it does not make decisions with legal or similarly significant effects. Photos and audio recordings are not sent for this processing — only the text you send.

7. Third-party providers

We use the following providers, each of which receives only the data needed for its function:

We do not sell personal data, and we do not share it for cross-context behavioural advertising.

8. Disclosure of information

We disclose information only: to the providers above, acting on our instructions; where required by law, court order or a valid request from a public authority; to protect our rights, safety, or the safety of others; and in connection with a merger, acquisition or sale of assets, in which case we will inform you of the change.

9. Security and retention

Data in transit is protected by TLS. Session credentials are kept in the device Keychain. Photos and voice recordings never leave your device. We keep conversation data for as long as you use the App, and delete it, together with the anonymous identifiers attached to it, when you ask us to. Deleting the App removes the locally stored content on your device.

10. International data transfers

Our providers may process data in countries other than yours, including outside the European Economic Area. Where that happens, the transfer is covered by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or an adequacy decision.

11. Your rights

Subject to applicable law, you may request access to your data, its correction or deletion, a restriction of processing, a copy in a portable format, or object to processing based on legitimate interest; where processing rests on consent, you may withdraw it at any time. Residents of California, Colorado, Connecticut, Virginia and other US states with comprehensive privacy laws additionally have the right to know, delete, correct, and to opt out of sale or sharing of personal information and of targeted advertising — we do not sell or share personal information, and sensitive data is not used for advertising. Write to help@slbsfinancialbusiness.services and we will respond within the period the law allows. You may also complain to your local data protection authority.

12. Children’s privacy

The App is not directed to children and is not intended for anyone under 13. We do not knowingly collect personal data from children. If you believe a child has provided us with data, contact us and we will delete it.

13. Third-party links

The App may link to external websites and resources. We are not responsible for their content or their privacy practices; read their policies before providing them with information.

14. Updates to this Policy

We may update this Policy as the App changes. The revised version takes effect when published at this address, and the date at the top of the page shows when it was last changed. Material changes will be brought to your attention in the App.

15. Contact information

SLBS financial & business services GmbH
Email: help@slbsfinancialbusiness.services