Privacy Policy "Journal Platinum"

This Privacy Policy informs you about the processing of personal data when using our app "Journal Platinum".

Controller

SayYes! Ltd., Initial Business Centre, Wilson Business Park, Office 620, Manchester, M40 8WN, United Kingdom
Registered in England and Wales, Companies House number: 16047536
Email: hello@sayyes.ltd
Phone: +44 7451 252831

A data protection officer is not required for our company and has therefore not been appointed.

As we are a company based in the United Kingdom, the processing of personal data is primarily subject to the UK GDPR and the Data Protection Act 2018. For users from the European Union, the EU General Data Protection Regulation (GDPR) additionally applies.

Our Approach: Privacy by Design

At Journal Platinum, we rely on Privacy by Design. This means:

Through this proactive approach, we ensure the best possible protection of your personal data.

Data Processing in the App

"Journal Platinum" is a journaling app that allows users to record daily reflections. After the initial load, the App works entirely offline and stores your entries exclusively locally on your device. No cloud synchronization of your journal data takes place. We never have access to your entries.

Provision of the App

The web app is provided via our own Content Delivery Network, which we operate through the provider Bunny.net. Bunny.net maintains a global server network for this purpose. The iOS version is available on the Apple App Store and the Android version on the Google Play Store. When installing and using the App, the respective platform providers may collect data. This occurs under their own responsibility and in accordance with their own privacy policies.

When retrieving the App and its associated files, technically necessary connection data is processed, in particular your device's IP address, the date and time of retrieval, the file retrieved, and information about your browser and operating system. This processing is technically necessary for the delivery and security of the service. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in the reliable and secure provision of the service).

Dictation Feature and Microphone Access

The App offers an optional dictation feature. It becomes active only when you start it yourself, and requires your authorization for microphone access in your operating system's or browser's settings. You may revoke this authorization at any time.

Speech recognition runs on your device. Your voice recordings are not transmitted to us, not stored by us and not evaluated by us. The recognized text is transferred directly into the App's input field and, like any other entry, stored exclusively locally.

For on-device speech recognition, you may choose between the speech recognition provided by your operating system or browser, or open source speech models you select yourself. If you use your operating system's or browser's speech recognition, the respective provider's (Apple, Google) terms and privacy notices also apply, to which you have already agreed as part of setting up your device or granting microphone access. We have no influence over this processing.

If you choose an open source speech model, the relevant model file is downloaded once from our own server (www.journalplatinum.com) and then stored on your device. In doing so, only the technically necessary connection data described above is processed. The content of your dictations is not affected by this; recognition itself takes place without an internet connection. The legal basis for the download is Art. 6(1)(b) GDPR (performance of the usage agreement), as it occurs at your request.

App Permissions

The App only requests the permissions required for the features you use — in particular access to the microphone for the dictation feature and access to file storage for exporting and importing your data. You may revoke these permissions at any time in your device's settings; the App's other features will remain usable.

Export and Import of Your Data

The App offers an export and import function that allows you to back up and restore your data as a file. The files created in this process remain within your control. No transmission to us takes place. You are solely responsible for the safekeeping and security of these files.

Share Function

The App enables you to share individual content via your operating system's share function. The content is passed exclusively to the application you choose (e.g. messaging app, email program or clipboard) and leaves your device only at your explicit initiative. No transmission to us or storage on our servers takes place in this process. The provider of the application you choose is responsible for any further processing. The legal basis is Art. 6(1)(b) GDPR, as the sharing occurs at your request.

Recommendations and Affiliate Links

The App contains a product area with recommendations that include affiliate links to third-party offers, including Amazon, Ringana, Solflora and Nature Heart. As long as you do not click on such a link, no data is transmitted to these providers. If you click on a link, you will be redirected to the respective provider's website; from that point on, that provider's privacy and cookie policies apply. In particular, your IP address and information about your usage behavior may be processed and cookies may be set. We have no influence over this processing. We recommend that you read the privacy policies of the respective providers. The legal basis for providing the links is Art. 6(1)(f) GDPR (legitimate interest in the economic financing of our service).

Retention Period and Deletion

Since your journal data is stored exclusively locally on your device, we have no access to it and no control over its retention period. You may delete your entries at any time directly within the App, or remove your data entirely by uninstalling the App or deleting the website data in your browser. Downloaded speech models can be removed again in the App's settings. Technically necessary connection data arising from the delivery of the App is deleted or anonymized after a short period.

Legal Bases for Data Processing

As your journal data is processed exclusively locally on your device, no processing of personal data by us as controller takes place in this respect. To the extent that data is nevertheless processed in connection with the provision of the App (e.g. via app stores, our CDN, or the download of speech models), this occurs for the performance of the usage agreement (Art. 6(1)(b) GDPR) as well as on the basis of our legitimate interest in the reliable and secure provision of the App (Art. 6(1)(f) GDPR).

Categories of Data Collected

When using our App, the following data is processed:

We do not collect special categories of personal data within the meaning of Art. 9 GDPR. Should you record sensitive information in your entries, it remains exclusively on your device and is not processed by us.

Your Rights

You have the right to access, rectification, erasure and restriction of processing of your data, as well as the right to object and the right to data portability. Since your journal data is stored exclusively locally on your device, you can exercise these rights directly within the App, for example by deleting or exporting individual entries or all of your data. For all other matters, you can reach us at hello@sayyes.ltd.

Where processing is based on your consent, you may withdraw it at any time with effect for the future, without affecting the lawfulness of processing carried out prior to the withdrawal.

Data Processing by Partners

CDN Provider (Bunny.net)

We use the CDN service of Bunny.net to provide our web app as well as images, videos, speech models and other files. Bunny.net operates a global network of servers for this purpose, meaning requests may also be served via servers located outside the European Union or the EEA. Bunny.net may process users' IP addresses and technical information to optimize the service. Bunny.net acts as a processor on our behalf. Further information can be found in Bunny.net's privacy policy: Bunny.net Privacy Policy

App Stores (Apple App Store and Google Play Store)

Our App is distributed via the Apple App Store and the Google Play Store. When installing and using the App, these platforms may collect and process data in accordance with their own privacy policies. We recommend consulting the respective privacy policies:

Operating System Speech Recognition

If you use the speech recognition provided by your operating system or browser, its processing takes place under the responsibility of the respective provider (Apple, Google) on the basis of the terms you accepted there. We do not receive any data in this respect.

International Data Transfers

Our CDN provider Bunny.net operates a global server network. Requests may therefore technically also be delivered via server locations outside the European Union or the EEA. Under the data processing agreement with Bunny.net, personal data (e.g. IP addresses) is nevertheless only temporarily cached at these locations (approx. 20–30 seconds) and then forwarded to a central processing service located within the EU. As a general rule, no permanent storage of personal data outside the EU takes place as a result. In connection with the provision of the App via the Apple App Store and the Google Play Store, data processing outside the EU/EEA by these providers may additionally occur; for this, we refer to their respective privacy policies. Where transfers to third countries take place, we base these on an adequacy decision or on EU standard contractual clauses.

Automated Decision-Making and Profiling

Our App does not carry out any automated decision-making, including profiling. We do not create user profiles and do not evaluate your entries.

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(f) GDPR.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data concerning you infringes applicable data protection law. The supervisory authority responsible for us in the United Kingdom is the Information Commissioner's Office (ICO, ico.org.uk). Users from the EU may also contact the data protection supervisory authority of their place of residence.

Necessity of Providing Data

Providing your data for the use of the App is neither legally nor contractually required. You are not obliged to record entries, grant microphone access, or download speech models. Without this information, only the respective affected features will be unavailable to you.

Data Security

We employ technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security measures are continuously improved in line with technological developments. You are solely responsible for the security of the device you use — for example through a device lock, device encryption and up-to-date system updates.

Right to Data Portability

Since we have no access to your data, which is stored exclusively locally, the right to data portability does not apply to us. All your data is stored locally on your device and can be exported in a common format or deleted by you at any time via the export function.

Cookies and Storage on Your Device

Our App does not use any cookies for analytics, tracking or advertising purposes. To operate the App, we store your entries and settings using your device's or browser's storage technologies (including local database and local storage). This storage is strictly necessary for you to use the feature of the App you have expressly requested and is therefore exempt from consent requirements under Section 25(2) no. 2 TDDDG (German law). The data stored in this way remains on your device and is not transmitted to us.

Age Restriction for Use

According to the Apple App Store, our App is suitable for users aged 4 and above (4+). However, we recommend that children use the App only under the supervision of a parent or legal guardian. We do not knowingly collect personal data from children.

Encryption

Data transport for the provision of the App and for downloading speech models takes place exclusively via an encrypted HTTPS connection. Your journal data and your voice recordings do not leave your device during operation of the App and are therefore not transmitted over the internet.

Notice for Users in the USA

Users residing in certain US states (including California, Virginia, Colorado, Connecticut, Utah and other states with comparable data protection laws) have rights under the laws applicable there (e.g. the California Consumer Privacy Act / CPRA), including the right to access the personal data we process about them, to deletion, to correction, and to object to the sale or "sharing" of personal data.

We do not sell or "share" (within the meaning of the CPRA) any personal data to third parties and do not carry out profiling for advertising purposes. The data arising from use of the App is limited to the technical processes described in this Privacy Policy (e.g. IP addresses during CDN delivery). To exercise your rights, you may contact us at the email address given above; we will not discriminate against you for exercising these rights.

Our App is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13 within the meaning of the Children's Online Privacy Protection Act (COPPA).

Notice for Users in Türkiye

Users residing in Türkiye are additionally informed under the Turkish Law on the Protection of Personal Data (KVKK). Since your journal data is stored exclusively locally on your device, no processing of personal data by us as controller takes place here either, with the exception of the technical processes described in this Privacy Policy (e.g. IP addresses when the App is provided via our CDN and the app stores).

You have the right to learn whether we process data about you, to request information about it, to request correction of inaccurate data, to request deletion of your data, and to object to decisions made exclusively by automated means. To exercise these rights, you may contact us at the email address given above.

In the event of complaints, you may contact the Turkish data protection authority (Kişisel Verilerin Korunması Kurumu).

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy as needed. The current version can always be found within the App.

Last updated: 29 August 2026