Legal

Privacy Policy

AscMX OÜ — Health Journal · Symply Notes

Effective date: May 2025 — Version 1.2 · Sepapaja tn 6, 15551 Tallinn, Harju Maakond, Estonia · Registered in Estonia — EU GDPR Compliant

This Privacy Policy applies to Health Journal — Symply Notes on both iOS (Apple App Store) and Android (Google Play). Where features or requirements differ between platforms, this is clearly indicated with iOS and Android labels.

1. Who We Are

This Privacy Policy applies to the "Health Journal — Symply Notes" mobile application and related services (collectively, "the App"), operated by AscMX OÜ, a company registered in Estonia (the "Company", "we", "us", or "our").

Registered address: Sepapaja tn 6, 15551 Tallinn, Harju Maakond, Estonia. For all data protection enquiries, contact us at: privacy@symplynotes.com.

We act as the Data Controller for your personal data as defined under the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act.

2. What This App Does

The App is a personal health journaling tool designed to help you record how you are feeling, organise your experiences over time, and generate structured summaries to bring to your appointment. The App is not a medical device, does not provide medical advice, and does not diagnose, treat, or prevent any medical condition.

All content generated by the App is intended solely to help you communicate your experiences at your next appointment.

3. Device Permissions and Features

The App requests only the permissions necessary to provide its core features. Below is a full explanation of each permission, what it is used for, and what we do not do with it. Where behaviour differs between iOS and Android, this is clearly noted.

3.1 Microphone

The App requests access to your device's microphone solely to record voice notes that you initiate by tapping the Record button. You are always in control of when a recording begins and ends.

Audio recordings are transmitted securely to our servers over an encrypted connection (TLS) for transcription and health information extraction. Audio files are deleted from our servers immediately after processing is complete — within seconds. Only the extracted text summary is stored.

We do not record audio passively, in the background, or without your explicit action.

  • iOS: You will be shown a system permission prompt the first time you use the Record feature. The reason string shown is: "Health Journal - Symply Notes uses your microphone to record voice notes. Audio is processed to extract health information and is not stored." This is defined in Info.plist as NSMicrophoneUsageDescription.
  • Android: Microphone access is declared in the AndroidManifest and requested at runtime when you first use the Record feature.

3.2 Biometric Authentication

If you choose to enable biometric sign-in, the App allows you to unlock it using your device's biometric system. This is entirely optional and can be disabled at any time in Settings.

Your login credentials are stored securely on your device. AscMX OÜ never transmits, receives, or stores your biometric data on our servers. Biometric data never leaves your device.

  • iOS: Credentials are stored in Apple Keychain, protected by the device's Secure Enclave. The system Face ID or Touch ID sheet is presented when biometrics are used. You will see a prompt: "Health Journal - Symply Notes uses Face ID to let you sign in quickly and securely." This is defined in Info.plist as NSFaceIDUsageDescription.
  • Android: Credentials are stored in Android Keystore, which is hardware-backed on supported devices. The system biometric dialog (fingerprint or face unlock) is presented when biometrics are used.

3.3 Local Notifications

With your permission, the App schedules local notifications on your device to remind you to log how you are feeling, and to prepare for upcoming appointments (24 hours before and 30 minutes before).

These notifications are scheduled entirely on your device. They do not involve any external servers, no data leaves your device for this feature, and we do not use push notification infrastructure for reminders.

  • iOS: Notification permission is requested via the iOS system dialog. You can manage notification preferences at any time in your device's Settings > Notifications.
  • Android: On Android 13 and above, notification permission is requested via the system runtime dialog. On earlier versions, notifications are enabled by default and can be managed in device Settings.

3.4 Subscriptions and Payments

Paid subscriptions are managed via RevenueCat. AscMX OÜ receives only your entitlement status (whether you are subscribed or not) — we do not receive, process, or store your payment card details or billing information.

  • iOS: Subscription payments are processed entirely by Apple via the App Store. Subscription management, cancellation, and refund requests are handled through your Apple ID account settings.
  • Android: Subscription payments are processed entirely by Google via Google Play. Subscription management, cancellation, and refund requests are handled through your Google Play account settings.

3.5 What the App Does NOT Access

The following permissions are not requested and the App does not access:

  • Your precise or approximate location
  • Your camera or photo library
  • Your contacts or address book
  • Your calendar (appointment dates are entered manually by you)
  • Advertising identifiers (IDFA on iOS, GAID on Android)
  • Any cross-app tracking or behavioural advertising data

4. What Data We Collect

4.1 Data you provide directly

  • Voice recordings made within the App (deleted immediately after transcription)
  • Transcriptions of those voice recordings
  • Structured health journal entries derived from your voice notes
  • Your name and email address (for account creation)
  • Optional: your doctor's name and appointment dates

4.2 Data we collect automatically

  • App usage data (screens visited, features used, session duration)
  • Device type and operating system version
  • Crash logs and error reports
  • Subscription entitlement status (subscribed / not subscribed) via RevenueCat

4.3 Data we do not collect

  • Payment card or financial details of any kind
  • Biometric data — this never leaves your device
  • Location data
  • Contacts, camera, or photo library content
  • Advertising identifiers or cross-app tracking data

5. Health Data and Special Category Data

Information about your physical or mental health is classified as "special category personal data" under GDPR Article 9 and is afforded the highest level of legal protection.

We process your health data solely on the basis of your explicit consent, given during onboarding. You may withdraw this consent at any time by deleting your account. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

We apply the following safeguards to all health data:

  • All health data is encrypted at rest in our database (Supabase, AES-256)
  • All data in transit is protected using TLS 1.2 or higher
  • Voice audio is deleted from our servers immediately after transcription
  • Health data is never used to train artificial intelligence models
  • Health data is never shared with advertisers, data brokers, or third-party analytics platforms
  • Biometric credentials never leave your device and are never transmitted to our servers

6. How We Use Your Data

6.1 Providing the service

  • Transcribing your voice notes into text
  • Structuring your journal entries using AI processing
  • Generating appointment briefs from your logged entries
  • Storing your journal history securely
  • Sending local on-device reminders if you have opted in

6.2 Improving the App

  • Diagnosing technical issues and crashes
  • Understanding how features are used in aggregate and anonymised form

6.3 Legal obligations

  • Complying with applicable Estonian and EU law
  • Responding to lawful requests from regulatory authorities

7. Third-Party Data Processors

To provide the App's features, we share data with the following carefully selected processors. All processors are bound by Data Processing Agreements (DPAs) and are prohibited from using your data for any purpose other than providing services to us.

OpenAI (Whisper — Transcription)

Your voice recordings are sent to OpenAI's servers for transcription into text. Audio files are deleted from our servers immediately after transcription is complete. OpenAI does not use API data to train its models. OpenAI is located in the United States; transfers are covered by Standard Contractual Clauses (SCCs).

Anthropic (Claude — AI Structuring)

Transcribed text is sent to Anthropic's API to extract structured information and generate appointment briefs. Anthropic does not use API data to train its models. Anthropic is located in the United States; transfers are covered by Standard Contractual Clauses (SCCs).

Supabase (Database and Authentication)

Your account information and journal entries are stored securely using Supabase. Data is encrypted at rest. Supabase infrastructure is hosted on AWS in the EU (Frankfurt region) where possible.

RevenueCat (Subscription Management)

RevenueCat is used to manage subscription entitlements across both platforms. RevenueCat receives only your app user ID and entitlement status. Payment processing itself is handled by Apple (iOS) or Google (Android) — RevenueCat does not process payment card data.

Apple App Store (iOS — Payments and Distribution)

For iOS users, subscription payments are handled entirely by Apple via the App Store. We do not receive or store your payment card details. Apple's privacy policy applies to payment processing.

Google Play (Android — Payments and Distribution)

For Android users, subscription payments are handled entirely by Google via Google Play. We do not receive or store your payment card details. Google's privacy policy applies to payment processing.

8. Data Retention

  • Voice recordings: deleted immediately after transcription (within seconds of processing)
  • Journal entries: retained until you delete them or close your account
  • Account data: retained until account deletion, then deleted within 30 days
  • Anonymised usage analytics: retained for up to 24 months
  • Legal and billing records: retained for 7 years as required by Estonian law

When you delete your account, all personal data associated with your account is permanently and irreversibly deleted from our systems within 30 days, except where retention is required by law.

9. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights. To exercise any of these rights, contact us at privacy@symplynotes.com. We will respond within 30 days.

Right of Access (Article 15)

You have the right to request a copy of all personal data we hold about you.

Right to Rectification (Article 16)

You have the right to correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure (Article 17)

You have the right to request permanent deletion of your personal data. You can delete your account directly in the App under Settings > Delete Account, or by contacting us.

Right to Restriction of Processing (Article 18)

You have the right to request that we limit how we use your data in certain circumstances.

Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, machine-readable format (JSON or CSV) and to transfer it to another controller.

Right to Object (Article 21)

You have the right to object to processing of your personal data for purposes other than providing the service.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at www.aki.ee, or with the supervisory authority in your country of residence.

10. International Data Transfers

Some of our third-party processors are located outside the European Economic Area (EEA), specifically in the United States. These transfers are carried out in compliance with GDPR Chapter V using Standard Contractual Clauses (SCCs) approved by the European Commission.

You may request a copy of the relevant transfer safeguards by contacting us at privacy@symplynotes.com.

11. Security

We implement the following technical and organisational security measures:

  • AES-256 encryption of all data at rest in our database
  • TLS 1.2+ encryption for all data in transit
  • Biometric credentials stored on-device only — Apple Keychain (iOS) or Android Keystore (Android) — never transmitted to our servers
  • Voice audio deleted from servers immediately after transcription
  • Strict access controls limiting who within our organisation can access personal data
  • Regular security reviews of our infrastructure and processors

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33.

12. Children's Privacy and Child Safety

This section explains our position on children's access to the App, our advertising practices, our SDK compliance, and how we satisfy applicable children's privacy laws including COPPA (US) and GDPR (EU).

12.1 Age restriction and target audience

The App is not directed at, designed for, or intended to be used by anyone under the age of 16. The App does not target children as a primary or secondary audience. Our content, features, and purpose — personal health journaling to prepare for medical appointments — are intended for adults.

In our Google Play and Apple App Store listings, the App is declared as targeting users aged 16 and above. We do not knowingly collect personal data from anyone under 16.

12.2 Content appropriateness

The App's content consists solely of the user's own journal entries and AI-generated summaries of those entries. The App does not contain or display third-party content, user-generated public content, social features, chat, or community features. All content within the App is private to the individual user.

If we become aware that a child under 16 is using the App, we will: (a) immediately delete any personal data associated with that account; (b) terminate the account; and (c) take reasonable steps to prevent further access. To report a child using the App, contact privacy@symplynotes.com.

12.3 No advertising

The App contains no third-party advertising of any kind. We do not display ads, serve ads through third-party ad networks, use advertising identifiers (IDFA on iOS, GAID on Android), or engage in any behavioural or targeted advertising.

This applies universally — whether the App is being used by an adult or a minor, no advertising is present. We have no partnerships with ad networks, including Google AdMob or any other network.

We do not intend to introduce advertising into the App. If this changes in the future, we will update this policy, provide advance notice, and ensure full compliance with all applicable children's advertising regulations before any ads are introduced.

12.4 SDK and API compliance

All third-party SDKs and APIs integrated into the App have been reviewed for compliance with applicable children's laws. We confirm the following:

  • OpenAI (Whisper) — used for voice transcription only. Audio is deleted immediately after processing. OpenAI's API is not used for advertising or profiling.
  • Anthropic (Claude) — used for AI structuring of journal entries only. Not used for advertising, profiling, or data sharing.
  • Supabase — used for secure data storage and authentication. No advertising functionality.
  • RevenueCat — used for subscription entitlement management only. No advertising or tracking functionality.
  • Expo / React Native — the App's development framework. No advertising SDKs are included.

None of the above SDKs or APIs collect, share, or process data for advertising purposes. We do not include any analytics SDKs that use advertising identifiers.

12.5 COPPA compliance (US)

The App is not directed at children under 13 as defined by the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13. We do not require parental consent because the App is not intended for use by children under 13.

If we discover that we have inadvertently collected personal information from a child under 13, we will delete it immediately. Parents or guardians who believe their child under 13 has used the App should contact privacy@symplynotes.com immediately.

12.6 GDPR compliance for minors (EU)

Under GDPR Article 8, processing of personal data of children under 16 requires parental or guardian consent in the EU (member states may lower this to 13). As the App is not directed at children under 16, we do not seek or process data from this age group and do not have parental consent mechanisms in place. If a child under 16 uses the App in breach of these Terms, their data will be deleted upon discovery.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via a prominent in-app notice at least 14 days before the changes take effect. Continued use of the App after that date constitutes acceptance of the updated policy.

The current version of this policy is always available within the App under Settings > Privacy Policy and at symplynotes.com/privacy.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

AscMX OÜ

Sepapaja tn 6, 15551 Tallinn, Harju Maakond, Estonia

Email: privacy@symplynotes.com

General enquiries: contact@symplynotes.com

We aim to respond to all requests within 30 days.

Privacy Policy v1.2 — Health Journal · Symply Notes — AscMX OÜ — May 2025. Applies to iOS (App Store) and Android (Google Play).