Voceris — Privacy Policy

DRAFT — not legal advice. This document was generated from the app's actual data practices as found in the codebase. Before publishing you MUST:

1. Fill every [BRACKETED] placeholder.
2. Have it reviewed by a qualified privacy lawyer for your target markets.
3. Make sure the app's real behavior matches every claim here (see the "Known gaps" notes — some statements are only true after you ship the fixes listed in the app-store review).

Last updated: [EFFECTIVE DATE — e.g. 2026-05-29] Applies to: the Voceris mobile application ("App") and related backend services.

1. Who we are

Voceris ("Voceris", "we", "us", "our") provides a voice‑training application that records your voice, analyzes vocal characteristics, and returns a "charisma" score with personalized exercises.

• Data controller: [LEGAL ENTITY NAME]
• Registered address: [COMPANY ADDRESS]
• Privacy contact: [privacy@trainmyvoice.app]
• EU/UK representative (if applicable): [NAME / ADDRESS or "Not applicable"]
• Data Protection Officer (if appointed): [NAME / EMAIL or "Not appointed"]

If you have questions about this policy or your data, contact us at the address above.

2. Summary (the short version)

• The App records your voice and sends the recording (and a text transcript of what you said) to third‑party AI providers so we can analyze it.
• We build a voice profile ("voiceprint") from acoustic features of your voice to track your progress over time and to check that it is the same person recording. Depending on where you live, this may be treated as biometric data.
• We use analytics, attribution, crash‑reporting, and a sampled session‑replay tool to understand and improve the App.
• We offer auto‑renewing subscriptions processed by Apple. We never see or store your payment card.
• You can delete your data from inside the App at any time, or by contacting us.
• We do not sell your personal data for money. Some advertising/analytics activity may be considered "sharing" or a "sale" under certain US state laws — you can opt out (see Section 11).

This summary is for convenience only; the full policy below governs.

3. The data we collect

3.1 Voice recordings and derived voice data

• Audio recordings of your voice that you create in the App.
• Transcripts and word‑level timings produced from those recordings.
• Acoustic measurements / vocal biomarkers derived from your voice — for example median pitch (F0), pitch variation, jitter, shimmer, harmonic‑to‑noise ratio, vocal fry, pace, pauses, and filler frequency.
• A voice profile / acoustic fingerprint ("voiceprint") built by aggregating these measurements over time. We use it to (a) measure your progress against your own baseline and (b) perform a coarse same‑speaker check so another person picking up your device does not corrupt your baseline.
• Perceptual estimates generated by AI about your recording, such as estimated emotion, confidence impression, and stress/tension markers, plus your score, tier, percentile, and coaching notes.

Note on biometric data: Because we create a voice profile used to help verify that recordings come from the same speaker, this data may qualify as biometric information under laws such as the EU/UK GDPR (Article 9), the Illinois Biometric Information Privacy Act (BIPA), Texas CUBI, and Washington law. We process it only with your consent and only to provide the features described above. We do not use it to identify you to third parties.

3.2 Profile and preferences

• Your selected goal (e.g. dating, public speaking, professional, content).
• Self‑reported sex (used only to calibrate acoustic norms; optional).
• Reminder time and time‑zone offset for daily practice notifications.
• Streak, scan counts, exercise‑completion, and training‑plan progress.

3.3 Account and device identifiers

• A Firebase anonymous user ID created automatically on first launch (you can use the App without giving us your name or email).
• If you ever link a sign‑in provider: your email, display name, and avatar from that provider.
• Internal user ID, RevenueCat subscriber ID, push notification token.
• Device and technical identifiers, including the Advertising Identifier (IDFA) only if you grant App Tracking Transparency permission, plus analytics/attribution identifiers (see 3.5).
• IP address and request metadata in our server logs (used for security and rate limiting).

3.4 Subscription and purchase data

• Your subscription status, product identifier, purchase/expiry dates, renewal state, store, and environment, received from Apple via RevenueCat.
• We do not receive or store your credit‑card or payment details — Apple handles all payments.

3.5 Usage, analytics, attribution, and diagnostics

• Product analytics events (e.g. screens viewed, onboarding steps, scans started) via Mixpanel and Firebase Analytics.
• A sampled session replay (currently a small percentage of sessions) via Mixpanel. Replays are recorded after onboarding and have on‑screen text and images masked by default; they are used to diagnose UX problems.
• Marketing attribution (which ad or campaign led to your install, and purchase events) via AppsFlyer and Apple's SKAdNetwork.
• Crash and error diagnostics via Firebase Crashlytics.

We do not knowingly collect more categories than those listed above. If we add new processing, we will update this policy.

4. How we use your data (purposes)

We do not use your voice recordings to train third‑party public AI models for purposes unrelated to providing you the service, and we instruct our AI providers accordingly to the extent their terms allow. [CONFIRM THIS MATCHES YOUR OPENROUTER / MODEL‑PROVIDER CONTRACTS BEFORE PUBLISHING.]

5. Legal bases (EEA / UK users)

Where the GDPR or UK GDPR applies, we rely on:

• Performance of a contract — to provide the App and its features you request.
• Consent — for (a) microphone access, (b) processing of biometric/voice data, (c) tracking for advertising (App Tracking Transparency), and (d) optional notifications. You may withdraw consent at any time (Section 10).
• Legitimate interests — to secure, debug, and improve the App, and to perform aggregate analytics, balanced against your rights.
• Legal obligation — to comply with applicable law.

For special‑category (biometric) data, our legal basis is your explicit consent (GDPR Art. 9(2)(a)).

6. Who we share data with (sub‑processors and recipients)

We share data only with service providers that help us run Voceris, and only as needed. Key recipients:

We may also disclose data: (a) to comply with law or valid legal process; (b) to protect our rights, users, or the public; and (c) in connection with a merger, acquisition, or sale of assets (you will be notified).

Important — AI processing of your voice: to analyze a recording, the audio file and a transcript of your speech are transmitted to OpenRouter and processed by the third‑party AI models named above. These providers may process the data outside your country. Do not record sensitive personal information you do not want processed in this way.

We do not sell your personal data for monetary consideration.

7. International data transfers

We and our providers may process your data in the United States and other countries that may not provide the same level of data protection as your home country. Where required, we rely on appropriate safeguards such as the EU Standard Contractual Clauses and the UK International Data Transfer Addendum. Contact us for more information. [CONFIRM TRANSFER MECHANISMS WITH COUNSEL — note that audio may be routed to AI models operated in multiple jurisdictions.]

8. How long we keep data

• Voice recordings, transcripts, sessions, voice baseline: kept while your account/data exists so we can show history and measure progress, until you delete them or your account. [SPECIFY A MAXIMUM RETENTION PERIOD, e.g. "and no longer than [N] months after your last activity."]
• Account/profile data: kept until you delete your account.
• Analytics/attribution data: retained per the providers' standard retention windows.
• Server logs: [SPECIFY, e.g. 30–90 days].
• Backups: residual copies may persist in backups for a limited period after deletion before being overwritten.

When you delete your account, we delete or de‑identify your personal data as described in Section 9.

9. Deleting your data and your choices

• In‑app deletion: Open Settings → Delete My Data in the App. This deletes your account and associated personal data, including your recordings, transcripts, voice baseline/voiceprint, sessions, and training plan.

  Known gap (fix before publishing): the current build's "Delete My Data" control and the server deletion routine do not yet remove all of the above (stored audio files and the voice baseline are not deleted, and the in‑app button does not call the deletion endpoint). This section must not be published until the App actually performs a complete deletion.

• By request: email [privacy@trainmyvoice.app] and we will delete your data within [30] days, subject to legal exceptions.
• Microphone: you can revoke microphone access in iOS Settings; the App cannot record without it.
• Tracking (ATT): you can allow or deny tracking when prompted, and change it in iOS Settings → Privacy → Tracking.
• Notifications: manage reminders in the App and in iOS Settings.

10. Your privacy rights

Depending on where you live, you may have the right to:

• access the personal data we hold about you;
• correct inaccurate data;
• delete your data;
• port your data to another service;
• object to or restrict certain processing;
• withdraw consent at any time (including for biometric/voice processing and tracking), without affecting prior processing;
• lodge a complaint with your data protection authority (EEA/UK) or attorney general (US).

To exercise any right, contact [privacy@trainmyvoice.app]. We will verify your request and respond within the time required by law. We will not discriminate against you for exercising your rights.

11. US state privacy rights (California and others)

If you are a resident of California or another US state with a comprehensive privacy law, you have the rights to know, access, delete, and correct your personal information, and to opt out of "sales" and "sharing" of personal information for cross‑context behavioral advertising.

• We do not sell personal information for money.
• Our use of advertising‑attribution and analytics partners (e.g. AppsFlyer, Mixpanel) and the device Advertising Identifier may constitute "sharing"/"selling" under some state laws. Denying App Tracking Transparency, and emailing [privacy@trainmyvoice.app] with "Do Not Sell or Share My Personal Information", serve as your opt‑out.
• We process biometric/voice data as described above; we do not sell it.

[ADD any state‑specific "categories collected / disclosed" table your counsel requires, e.g. for the CCPA/CPRA "categories" disclosure.]

12. Children's privacy

The App is not directed to children and is intended for users aged [17]+. We do not knowingly collect personal data from children under [13 / 16, per your markets]. If you believe a child has provided us data, contact us and we will delete it. [If you ever target minors, you must add COPPA / age‑appropriate‑design content.]

13. Security

We use reasonable technical and organizational measures to protect your data, including encryption in transit and access controls on our systems.

Known gap (fix before relying on this section): stored audio recordings are currently served from a publicly reachable URL rather than via authenticated, short‑lived links. Restrict access (private storage + signed URLs) before publishing this policy. No method of transmission or storage is 100% secure.

14. Changes to this policy

We may update this policy from time to time. We will revise the "Last updated" date and, for material changes, provide a more prominent notice in the App. Continued use after an update means you accept the revised policy.

15. Contact

[LEGAL ENTITY NAME] [COMPANY ADDRESS] Email: [privacy@trainmyvoice.app]

This policy is a working draft generated from the Voceris codebase and is provided for development purposes only. It is not legal advice.