Privacy Policy

Effective Date: October 10, 2025

Last Updated: October 15, 2026

1. Introduction

This Privacy Policy explains how Seauton ("we," "our," or "us") collects, uses, and protects personal information when you use our mobile and web applications (the "Service"). Seauton is committed to safeguarding your privacy and ensuring that your personal data is processed in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

Data Controller: Marcin Oleszkowicz Przysieki 352, 38-207, Poland Email: seauton.team@gmail.com

2. Information We Collect

We collect only the information necessary to provide and improve the Service:

a. Account Information: When you sign in with your Google account or Sign in with Apple, we receive basic profile information (such as your name, email address, and profile picture).

b. User Content: You may create or upload content such as written journal entries, voice recordings, or reflections. This data is stored securely in our cloud infrastructure and used only to deliver the Service's features, such as personalized AI-powered feedback and psychological insights.

c. Sensitive Data: Due to the nature of the Service, your journal entries and voice recordings may contain sensitive personal data, including information about your mental health, emotions, thoughts, beliefs, or personal experiences. We process this data only with your explicit consent, which is requested when you first use the Service, and solely for the purpose of providing personalized AI-driven insights.

d. Analytics and Product Usage Data: We use PostHog (hosted on PostHog Cloud EU servers in Frankfurt, Germany) and Google Firebase Analytics to understand how users navigate and interact with the Service, for example which screens are visited, which features are used, navigation patterns, and aggregated usage trends. This helps us identify friction points, fix bugs, and improve the Service.

PostHog also records anonymised session replays: a reconstruction of how a session unfolded on screen, showing navigation, taps, and timing. All text is masked before the recording leaves your device, so replays show the layout and the interaction, not what you wrote or read. Session replays are deleted after 30 days.

Product analytics is enabled by default and is processed on the basis of our legitimate interest in maintaining and improving the Service. You can turn it off at any time in Settings, Data & Privacy, Anonymous product analytics. Once turned off, it stays off.

We also use Meta (Facebook) SDK and AppsFlyer to measure advertising effectiveness and attribute app installs to specific marketing campaigns. These are used only with your consent. On iOS, this data is collected only after you grant permission through the App Tracking Transparency (ATT) prompt.

Privacy by design, your journal content is never sent to analytics providers. All input fields, journal entries, voice transcripts, AI-generated insights, therapy session content, and any text containing user-generated thoughts are explicitly masked before any analytics SDK can capture them. We never send your email, name, or IP address to PostHog. Only a pseudonymous user identifier (UUID) is used to distinguish sessions.

e. Subscription and Payment Data: All payments are processed securely through the Apple App Store or Google Play Store. Subscriptions are available on a monthly or annual basis, including applicable free trial periods (7 days for monthly and 14 days for annual plans). Seauton does not collect, process, or store any credit card or payment details. Payment and billing information are handled exclusively by the respective store in accordance with their privacy and security policies.

f. Device Identifiers: Our third-party analytics and advertising partners (Meta, AppsFlyer) may collect device identifiers (such as IDFA) for the purposes of advertising attribution and analytics. On iOS, this data is collected only after you grant permission through the App Tracking Transparency prompt.

3. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

• Performance of a contract: To provide, operate, and maintain the Service, including managing your account and delivering core features (Article 6(1)(b) GDPR).

• Explicit consent: To process sensitive personal data contained in your journal entries and voice recordings, and to provide AI-powered psychological insights (Article 9(2)(a) GDPR). You provide this consent during the sign-in process, and you may withdraw it at any time by deleting your account.

• Consent: For advertising attribution and marketing purposes, including data collected by Meta and AppsFlyer (Article 6(1)(a) GDPR). This is collected only after you give explicit consent, and on iOS only after you grant permission through the ATT prompt. You may withdraw this consent at any time without affecting access to the Service.

• Legitimate interest: For product analytics (PostHog and Firebase Analytics), and to ensure the security, stability, and performance of the Service, prevent fraud, and improve our product (Article 6(1)(f) GDPR). We have assessed that this processing is limited to pseudonymous behavioural data, excludes all journal content and all sensitive data, and does not override your rights and freedoms. You may object at any time by turning off Anonymous product analytics in Settings.

4. AI-Powered Processing and Profiling

Seauton uses artificial intelligence to process journal entries and voice transcripts, identify recurring themes and emotional patterns, and provide personalized reflections.

AI processing is part of saving an entry, including generating titles, categorization and emotional analysis. Additional reflection features may process multiple previous entries. Text is processed through Anthropic, while voice recordings are sent to AssemblyAI for transcription before the resulting text is used in journaling features.

Processing of sensitive personal data contained in your entries is based on your explicit consent. AI processing is currently essential to Seauton’s journaling functionality: the app does not offer a journaling mode that disables it.

AI-generated insights are intended for self-reflection and personal growth. They may be incomplete or inaccurate and do not constitute medical advice, diagnosis or treatment.

You may withdraw your consent to AI processing by contacting us at seauton.team@gmail.com, or delete your account through the app settings. Because saving entries currently involves AI processing, you cannot continue using this functionality after withdrawing that consent. Withdrawal does not affect the lawfulness of processing carried out before it.

5. How We Use Your Information

We use your personal data to:

• Provide, operate, and maintain the Service;

• Personalize your experience and provide AI-powered feedback and insights;

• Improve app performance and develop new features;

• Communicate with you about updates or policy changes;

• Measure the effectiveness of our advertising campaigns and optimize marketing efforts;

• Process subscription status information received from the app stores to manage access to paid features;

• Ensure compliance with applicable laws.

We do not sell or rent your personal data to third parties. We never use your wellness data or journal entries for the purposes of credit scoring, insurance eligibility, or in recruitment and employment processes.

6. Data Sharing

We share data with the following categories of third-party service providers, solely for the purposes described in this policy:

• Supabase: Cloud infrastructure for secure data storage and authentication. Your account data, journal entries, and voice recordings are stored on Supabase servers.

• PostHog: Product analytics and session replay, hosted on PostHog Cloud EU (Frankfurt, Germany). PostHog receives only behavioural data such as screen views, button taps, navigation flow, and masked session replays showing how a session unfolded on screen. Session replays are retained for 30 days and are then deleted. All sensitive content, including journal entries, voice transcripts, AI-generated insights, therapy sessions, and any text containing user-generated thoughts, is masked at the source and is never transmitted to PostHog. We do not share your email, name, IP address, or any other identifying information with PostHog. Events are labelled with a randomly generated analytics identifier that is created on your device and is never linked to your account, so analytics data cannot be traced back to you or to your journal. This data is processed on the basis of our legitimate interest in maintaining and improving the Service, and you may object at any time by turning off Anonymous product analytics in Settings, Data & Privacy.

• Meta (Facebook): Advertising attribution and campaign optimization. Used only with your consent.

• AppsFlyer: Advertising attribution, install tracking, and marketing analytics. Used only with your consent.

• OneSignal: Push notification delivery. OneSignal receives only an anonymous device token required to deliver notifications you have opted into. No journal content, AI insights, or other sensitive personal data is sent to OneSignal.

• Anthropic (AI Provider): Processing of journal entries and voice transcripts to generate personalized psychological insights. Data sent to Anthropic is used solely to deliver the Service and is strictly not used by them for their own AI training purposes. We confirm that Anthropic provides the same or equal protection of user data as outlined in this Privacy Policy.

• AssemblyAI: AssemblyAI processes audio recordings to generate text transcripts. After retrieving a completed transcript, Seauton's backend attempts to send a deletion request for the transcription. A failed deletion request does not prevent the transcript from being returned to the user. Audio and transcription artifacts may remain subject to AssemblyAI's applicable retention policies and deletion processing times, and may be used by AssemblyAI to improve its speech recognition models in accordance with its own terms.

• Google (Firebase Analytics): Product analytics covering app opens, screen views, authentication steps, and subscription funnel events, used to measure onboarding and conversion. Firebase receives no journal entries, no voice recordings, no AI-generated insights, and no sensitive personal data.

7. Data Retention

Your data is stored only as long as necessary to provide the Service. You may request data deletion at any time. Once deleted, your information and User Content will be permanently removed from our systems within 30 days, except where retention is required by law.

Personal data and journal entries are retained as long as your account is active. Upon account deletion, all personal data is permanently removed from our production servers within 30 days.

Therapy session recordings: the audio file is deleted from our servers as soon as the transcript is saved, and in any case no later than 7 days after the recording. The transcript and AI summary remain in your account until you delete them or delete your account.

Data sent to Anthropic is used solely for real-time processing and is not used for model training. AssemblyAI processes voice recordings as described in Section 6.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse, including encryption in transit and at rest. However, no system is completely secure, and we cannot guarantee absolute security of your data.

9. Your Rights

Depending on your location, applicable data protection laws may grant you the following rights regarding your personal data:

• Access the personal data we hold about you;

• Rectification — request correction of inaccurate data;

• Erasure — request deletion of your data;

• Restrict processing of your data;

• Data portability — request a copy of your data in a structured, machine-readable format;

• Withdraw consent for advertising attribution and marketing at any time, without affecting the lawfulness of processing prior to withdrawal. To withdraw consent for AI processing of your journal entries, please delete your account, as this consent is essential to the Service's core functionality;

• Object to processing based on legitimate interest, including product analytics. You can turn product analytics off at any time via Settings, Data & Privacy;

• Opt out of sale or sharing of your personal data (where applicable under laws such as the CCPA). Seauton does not sell or share personal data for cross-context behavioral advertising;

• Lodge a complaint with the relevant data protection authority in your country or region. For example, in the EU/EEA you may contact your local supervisory authority (in Poland: Urząd Ochrony Danych Osobowych, https://uodo.gov.pl), and in the US you may contact your state attorney general.
  
  Please note that product analytics data cannot be linked to your account. Because we hold no mapping between the analytics identifier and any user, we are unable to identify which analytics records relate to you, and these records therefore fall outside the scope of access and erasure requests (Article 11 GDPR). All data held in your account, including journal entries and voice recordings, remains fully subject to the rights above.

  To exercise any of these rights, please contact us at seauton.team@gmail.com. We will respond to your request within 30 days as required by GDPR Article 12.

10. Account Deletion

You may delete your account and all associated data at any time through the app settings or by contacting us at seauton.team@gmail.com. Upon account deletion, all your personal data, journal entries, voice recordings, and AI-generated insights will be permanently removed from our systems within 30 days.

11. International Data Transfers

Our service providers are located in different countries. PostHog (product analytics) hosts your data exclusively within the European Union (Frankfurt, Germany), so no transfer outside the EEA occurs through this provider.

Other service providers, including Anthropic, AssemblyAI, Google (Firebase Analytics), Meta, AppsFlyer, OneSignal, and Supabase, may process data in the United States or other countries outside the European Economic Area. For these transfers, Seauton ensures that adequate data protection measures are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or other appropriate safeguards as required by GDPR Articles 44 to 49.

12. Children's Privacy

Seauton is not directed to children under the age of 16. We do not knowingly collect or process personal data from minors under 16. If we become aware that we have collected data from a minor under 16 without verifiable parental consent, we will promptly delete it.

If you are between 16 and 18 years old (or below the age of legal majority in your country of residence), we recommend reviewing this Privacy Policy together with a parent or legal guardian before using the Service.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The latest version will always be available in the app and on our website, with an updated "Last Updated" date. If we make material changes that affect how we process your sensitive data, we will notify you through the app or by email.

14. Contact

For any questions about this Privacy Policy, your personal data, or to exercise any of your data protection rights, please contact:

Data Controller: Marcin Oleszkowicz Email: seauton.team@gmail.com Address: Przysieki 352, 38-207, Poland

We will respond to privacy-related inquiries within 30 days as required by GDPR Article 12. For complaints, you may also contact the Polish Data Protection Authority (Urząd Ochrony Danych Osobowych) at https://uodo.gov.pl, or your local supervisory authority within the EU/EEA.