Privacy Policy

1. Data Controller

The data controller is Cristiano Saggin, an independent software developer operating under the EightyFourNow brand, based in Llançà (Girona), Spain. For any privacy-related request, please write to support@hearofy.io.

2. Scope

This policy governs the processing of personal data collected through the website hearofy.io and through the mobile application Hearofy — Life Memos ("the App").

3. Data collected on the website

The hearofy.io website does not use profiling cookies or third-party tracking tools. We only process data that users voluntarily choose to share via email, along with the minimal technical logs automatically generated by the hosting infrastructure (Firebase Hosting / Google Cloud) for security and service operation purposes.

4. Microphone access and how we process your voice

The App requests access to your device's microphone (Android permission RECORD_AUDIO) solely to let you record voice memos. Microphone access is activated only when you explicitly tap the record button inside the App: Hearofy does not record or listen to audio in the background, and it never accesses the microphone without your direct, in-the-moment action.

Once a recording is captured, it is processed according to the “AI Engine” mode chosen in Settings. By default, processing happens in the cloud; you can switch to a local mode at any time:

• • Full Cloud (default): the recording is sent to Google Cloud Vertex AI (Gemini models) for transcription and analysis. Content is transmitted securely (encryption in transit), is never used to train artificial intelligence models, and is deleted from our processing servers as soon as transcription/analysis is complete — the audio is not retained in the cloud beyond that step. If the cloud call fails and you have downloaded the local models, processing is retried on your device.
• • Local with Cloud backup: audio is processed on your device with the downloaded models; only if local processing fails is the recording sent to the cloud, with the same guarantees as above.
• • Local only: everything runs on your device; audio and transcript are never transmitted to any server, not even as a fallback.

For the full details on cloud processing (what is sent, retention, withdrawing consent) see Cloud processing of your voice.

After processing, the resulting transcript and memo (not the raw audio) are stored only on your device (including any Android system backup copy, Section 9). There is no store of memo content on our backend: the backend is used for processing and for your account, and does not keep your memos. Backup is described in Section 9.

If transcription or analysis fails, the raw recording is kept on your device only, in the App's private storage, for up to 7 days so you can retry. It is deleted automatically when that period ends or when the retry succeeds, and you can delete it at any time before then. This copy is excluded from Android backup and is uploaded to the processing service only when you tap Retry, with the same guarantees described above.

5. No voiceprints or biometric identification

Hearofy does not extract, generate, or store voiceprints or any other biometric identifier derived from your voice for the purpose of uniquely identifying you. The App's AI models are used exclusively to transcribe speech to text and to extract dates, categories, and similar contextual information from that text — never to recognize or verify a speaker's identity.

6. Third-party services

The App relies on the following providers. Where indicated, the provider acts as a data sub-processor; for ad delivery, Google AdMob acts as an independent data controller under the Google Controller-Controller Data Protection Terms.

7. Advertising, consent and non-personalised ads (Google AdMob / CMP)

The Free plan of the App displays ads served by Google AdMob: banners and a rewarded ad that you choose to watch to get extra cloud credits.

Before serving ads that require your consent, in the countries of the European Economic Area, in the United Kingdom and in Switzerland the App shows you a message managed by a certified Consent Management Platform (CMP) compliant with the IAB Europe Transparency & Consent Framework (TCF). The message appears on the first launch of the App, before any ad is requested: until you make a choice, the App does not request ads. From that message you can:

• •Consent: you will see personalised ads, selected also on the basis of your interests.
• •Do not consent: you will not see personalised ads. In regions where consent is required (EEA, UK, Switzerland) the App does not request ads until you consent; you can change your choice at any time from Settings → Privacy and data.
• •Manage options: choose purpose by purpose, and object to processing based on our legitimate interest.

What happens if you refuse. If you do not consent, in regions where consent is required the App does not request ads: we do not use your advertising identifier to select ads, we do not build a profile of your interests and we do not show you retargeting ads. Elsewhere consent is not required and ads are served without the consent message.

Legal bases for advertising data. Ad personalisation is based on your consent (Article 6(1)(a) GDPR and Article 5(3) of the ePrivacy Directive, Article 22.2 LSSI). Serving non-personalised ads, aggregate performance measurement and protection against fraud and invalid traffic are based on our legitimate interest in funding the free version and protecting the service (Article 6(1)(f) GDPR). For those purposes we do not read your advertising identifier (how Google processes it as an independent controller is described in its policies); to protect against fraud and invalid traffic we may use cookies or local storage on your device for that purpose only, without profiling. Your voice, your memos and the content of your recordings are never used to select ads.

How to withdraw consent or object. You can reopen the message at any time from Settings → Privacy and data → Ad privacy options: withdrawing takes the same steps as consenting. You can object at any time to processing based on legitimate interest from the same screen or by writing to support@hearofy.io: objecting does not prevent you from using the App. Upgrading to Hearofy Pro removes all advertising and the associated data processing.

7-bis. Crash diagnostics and usage statistics

The App collects two kinds of technical data, on different legal bases.

Crash diagnostics (Firebase Crashlytics) — legitimate interest (Article 6(1)(f) GDPR). When the App closes unexpectedly it sends Google a technical report containing the error stack trace, the state of the application at the moment of the error, metadata about the device and the build, and a pseudonymous installation identifier. The contents of your memos, the audio, your calendar and your identity are never sent. Reports are kept for 90 days. You can object at any time to this data being sent, from Settings → Privacy and data (the "Crash data" switch) or from the first notice you see when you open the App. Objecting does not affect how the App works.

Usage statistics (Firebase Analytics) — consent (Article 6(1)(a) GDPR and Article 5(3) ePrivacy). If you give your consent, the App sends Google aggregate statistics about how it is used (screens viewed, sessions, events), together with an app instance identifier (collection of the advertising identifier is switched off in the App), from which Google may derive an approximate location. They are used to understand which features to improve; they are not used to profile you individually. Collection starts only after your consent and stops immediately when you withdraw it from Settings → Privacy and data. Data is kept for 2 months and deleted when that period ends.

8. Legal basis for processing

Data processing is based, depending on the case, on performance of the service agreement (Terms of Service), on your consent (usage statistics; ad personalisation, see Section 7) and on the controller's legitimate interest in funding the free version with non-personalised ads, measuring performance in aggregate form, preventing fraud and abuse, and ensuring the security and proper operation of the website and the App. Where processing relies on legitimate interest, you have the right to object at any time, without this affecting your use of the App.

9. Data retention

As described in Section 4, audio processed in the cloud is deleted from servers immediately after processing is complete, while memos and transcripts stay on your device under your exclusive control. If processing fails, the raw recording stays on your device only for up to 7 days (Section 4); it is excluded from Android backup and deleted automatically at the end of that period, at the latest on the next app start. Android system backup: if Android backup (Google One / Google Backup) is enabled on your phone, or you do a device-to-device transfer, Android also copies the App's preferences file, where memos, settings and custom categories are saved. Backup to Google's cloud is performed by Google, not by us. On Android 12 and later it runs only if it can be end-to-end encrypted (a screen lock is required); on Android 11 and earlier it runs with Google's standard protections, without that guarantee. Device-to-device transfer happens directly between the two phones. Restored memos reappear when you sign in again with the same account. You can turn off Android backup in your phone's system settings. The manual export (“Back Up Now”) creates a local file that you share wherever you choose.

Crash reports are kept for 90 days. Aggregate statistical data is kept for 2 months. Deleting your account from the App removes the installation identifier and the Analytics data stored on the device (Section 11).

10. Your rights (GDPR)

As a data subject, you have the right to:

• • Access your personal data
• • Rectify inaccurate data
• • Erasure ("right to be forgotten")
• • Data portability
• • Object to processing
• • Withdraw consent at any time

To exercise these rights, write to support@hearofy.io. For account and data deletion, see the next section.

12. International data transfers

Some providers (Google Cloud / Firebase) may process data on servers located outside the European Economic Area. In such cases, the transfer is governed by Standard Contractual Clauses approved by the European Commission or other appropriate safeguards provided for under the GDPR.

13. Children

Hearofy is not directed at children under 16. You must be at least 16 years old to create an account and use the App.

We do not knowingly collect personal data from children under 16. If you believe that a child under 16 has provided us with personal data, write to support@hearofy.io: we will delete that data and, where one exists, the related account.

If you are under 18, you may use the App only if a parent or guardian accepts the Terms of Service and authorises that use: see Section 1 of the Terms of Service.

14. Complaints

You have the right to lodge a complaint with the competent supervisory authority, in particular the Agencia Española de Protección de Datos (AEPD), if you believe the processing of your data violates applicable regulations.

15. Changes to this policy

This policy may be updated periodically. Material changes will be communicated via notice on the website or within the App.