Privacy Policy
Draft. This text is not yet in effect.
This is an English translation. The Finnish version governs.
1. Controller
DATA-TAKOMO OY, business ID (fill in), (address). Contact for privacy matters: (email).
2. Personal data we process
(To be written: Google or Apple Account details (Apple may provide a hidden relay email address), profile and settings, calls and transcripts, memories, credits and purchases, device and technical data.)
3. Purposes and legal bases
(To be written.)
4. Recipients and processors
(To be written: hosting, database, AI provider, app stores, sign-in.)
(Preliminary:) The AI provider is OpenAI. During a call, your speech and Ayveena’s replies are processed by OpenAI’s service in real time. OpenAI does not keep a recording or the conversation after the call, because we do not turn its storage on. When Ayveena picks out the things you asked it to remember, the text is sent to OpenAI without storage. OpenAI does not use the data to train its models. OpenAI keeps logs for monitoring abuse of its service for up to 30 days, unless the law requires longer retention.
5. Transfers outside the EU/EEA
(To be written.)
6. Retention
(Preliminary, to be reviewed before publication.)
- Call transcripts: 30 days after the call.
- The IP address recorded with a call: 30 days after the call.
- Fetches on the Your account page: for each one only the user id, the time and the IP address, for 30 days, so you can see when your data was fetched and fetches can be limited. They also go with the account.
- OpenAI’s abuse-monitoring logs of calls and of picking out memories: up to 30 days under OpenAI’s own terms. OpenAI keeps no recordings of calls.
- Ayveena’s memories: only facts you explicitly asked Ayveena to remember during a call, at most five from one call and at most ten at a time. Each fact is deleted at most 30 days after it was saved. Facts are checked by automated moderation before they are saved. They are not shown in the app, but you can see and delete them on the Your account page (section 7).
- Call start details (the memories and display name stored in the call’s settings): deleted when the call ends, and an unused call reservation one hour after it expires.
- Unfinished credit orders: cancelled after 21 days, and orders that did not lead to a purchase are deleted after 30 days.
- Sign-in: a session ends if the app is not used for 90 days. A sign-in on the Your account page lasts only in that browser tab and ends when you close it. The page uses no cookies.
- Profile, settings, credits and owned items: for as long as the account exists.
- Purchase records: as required by the Finnish Accounting Act (vouchers 6 years and the books 10 years from the end of the financial year), also after the account is deleted.
- Call duration, credit and usage figures are kept without identifying details for statistics and bookkeeping.
7. Your rights
(To be written: access, rectification, erasure, restriction, portability, objection.)
(Preliminary:) You can use most of your rights yourself on the Your account page, signed in with the same Google account as in the Android app:
- Access: see everything we keep about you: your profile, Ayveena’s memories, your calls and their transcripts, items, credit purchases and when you signed in.
- Portability: download all your data as one machine-readable file (JSON).
- Rectification and erasure: delete one memory, all memories or one call’s transcript. The call’s time, length and credits are kept for bookkeeping. Your name and speech language can be changed in the app’s settings.
- Deleting your account: see section 8.
Other requests, such as correcting something the page cannot correct, restricting or objecting to processing, can be sent to the contact in section 1. We answer within one month. Accounts of the iPhone app come to the Your account page later; until then, requests about them go to the same contact.
8. Deleting your account
(Preliminary:) You can delete your account in the app’s settings, or without the app on the Your account page. There, deleting needs a sign-in within the last 10 minutes. The deletion is permanent and cannot be undone.
When you delete your account, we delete your profile, settings, memories, transcripts and owned items. Unused credits lapse as described in the terms of service. Purchase records are kept for bookkeeping without a link to your account, and call duration, credit and usage figures stay in our statistics without identifying details.
9. Children
(To be written.)
10. Changes to this policy
(To be written.)
11. Complaints
You have the right to lodge a complaint with the supervisory authority. In Finland this is the Data Protection Ombudsman.
