Halflight — Privacy Policy

Deutsche Fassung · This is a translation. If the two versions differ, the German version applies.

Last updated: 21 October 2026

1. Controller and scope

This policy applies to the Halflight app for iPhone and Android. The controller under the General Data Protection Regulation (GDPR) is:

We have not appointed a data protection officer because the legal requirements for this are not met.

2. In short

Halflight is a voice journal: you talk about your day, the app turns it into text, keeps your entries by date and lets you reflect on them in a chat.

• The app stores your entries, recordings, summaries, chats and your profile on your device. It keeps recordings there until you delete the entry; recordings that belong to no entry are deleted after two days.
• You do not need an account. The app knows neither your email address nor your phone number.
• For some features, content is sent encrypted to our server and from there to AI models of Microsoft Azure. This only happens after you have explicitly agreed in the app. Our server does not store this content, and it is not used to train AI models.
• Usage statistics and crash reports are only sent with your consent.
• We do not sell data, show no advertising and do not track you across other apps or websites.

3. What we process, why, and on what legal basis

Downloading the app

When you download the app from the App Store or Google Play, Apple or Google process data such as your account identifier, payment data and the time of the download. They do this under their own responsibility; we do not receive this data. More: Apple, Google.

Content on your device

The app stores your entries, recordings, summaries, chats and your profile on your device. It keeps recordings there until you delete the entry; recordings that belong to no entry are deleted after two days. This data stays on your device until you delete it. It is protected by your phone's encryption and, if you have switched on device backups (iCloud or Google), your operating system may include it in them.

Processing by AI models — only with your consent

For the following features the app sends content encrypted (HTTPS/TLS) to our server at Supabase, which passes it on to AI models that Microsoft runs for us in Azure. The answer goes back to your device. The app sends:

• voice recordings, to turn them into text;
• the text of your entries, so the app can tag them, write day and month summaries and suggest questions. This also happens in the background when you open the app;
• your chat messages together with the conversation so far and an extract from your journal (summaries and the entries the conversation is about), so the answer fits your journal;
• photos you attach in the chat or import from pages of a paper diary;
• the mood you pick in the mood check and the time of day, so the app can write a fitting word for the day;
• texts the app wrote for you, when you switch the language, so they can be translated;
• the name in your profile and your language, so the answers address you correctly.

Journal entries often contain specially protected data, for example about your health, your beliefs, your relationships or your sex life (Art. 9 GDPR). That is why we only process your content through the AI service with your explicit consent. Before the first transfer, the app shows you a separate screen explaining what is sent, to whom and why. Legal basis: your consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). You can withdraw it at any time in Settings → Privacy. Without consent your recordings stay on the device and wait to be turned into text; the chat and summaries are not available.

Our server only passes the content on and does not store it. Under its contract terms Microsoft does not use it to train models. Microsoft may, however, keep requests and answers for up to 30 days to detect misuse of its services; only for that purpose and only accessible to authorised staff. The AI models do not receive any identifier of your device.

Text generated by AI models can be wrong. The app does not make decisions about you on this basis.

Installation identifier and cost counters

When you first open the app, it creates a random identifier for this installation and sends it with every request to our server. Per identifier and day, the server counts the number of requests, the kind of feature and the cost incurred. It does not store any content. We need these counters to enforce usage limits, to fend off misuse and to keep exact track of our costs. Legal basis: Art. 6(1)(b) and (f) GDPR; our legitimate interest is an affordable and secure service. After 13 months the server removes the identifier from the counters: only totals per app, feature and day remain, which cannot be linked to anyone. We keep those totals as part of our cost records for up to ten years. When you choose Delete all my data in the app, it creates a new identifier; the old counters can then no longer be linked to anyone. Storing the identifier on your device is strictly necessary for the features you use (§ 25(2) no. 2 TDDDG).

Like every server, ours receives the IP address of your device for technical reasons. Supabase processes it to deliver responses and to fend off attacks in logs that are kept for a short time; we do not combine it with other data (Art. 6(1)(f) GDPR).

Conversation suggestions from our database

When it starts and when you switch the language, the app loads the day's conversation suggestions from our database at Supabase. The request contains the app, the language, the date and, for technical reasons, your IP address, but none of your content and no identifier of you as a person. Legal basis: Art. 6(1)(b) GDPR.

Subscriptions

You buy subscriptions through the App Store or Google Play; Apple or Google are your contractual partner for the payment. We never see your payment details. To know whether your subscription is active, the app exchanges a random customer identifier and the store receipt with our service provider RevenueCat. Legal basis: Art. 6(1)(b) GDPR. Purchase records are kept while your subscription exists and then for at most three years, so that questions and claims can be settled (§ 195 BGB). On request we have them deleted at RevenueCat earlier.

Usage statistics and crash reports — only with your consent

The app asks whether it may send usage statistics and crash reports. The switch starts off. Without your agreement the app does not start these services.

• Usage statistics (Amplitude): which screens and features you use, the app version, device model, operating system, language and a random identifier. They do not contain your entries, messages or name; Amplitude does not store IP addresses for us.
• Crash reports (Sentry): when the app crashes or an error occurs, technical details such as the error message, the device model and the app version.

Legal basis: your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). You can withdraw it at any time in Settings → Privacy. The data is deleted once we no longer need it to improve the app, at the latest after twelve months.

App updates

When it starts, the app asks our service provider Expo (650 Industries, Inc., USA) whether a new version of its content is available. This transmits the app version, the platform, a random identifier of the installation and, for technical reasons, your IP address. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is being able to fix errors quickly.

Permissions on your device

The app only asks for permissions you need for a feature, and only when you use that feature. You can withdraw any permission in your phone's settings.

• Microphone — to record your entries.
• Speech recognition — to show your words while you are still recording. The app uses Apple's speech recognition for this: on the device when your phone recognises the language there, otherwise (currently for Polish) on Apple's servers under Apple's privacy terms.
• Camera — to take a photo for the chat.
• Photos — to choose pictures for the chat or pages of a paper diary, and to save cards you share to your photos.
• Notifications — for the daily reminder. It is scheduled on the device; no data is sent to us for it.

Contacting us

When you write to us, we process your message and email address to answer you (Art. 6(1)(b) or (f) GDPR). Details on how we handle email are in the website privacy policy.

4. Recipients

These service providers process data on our behalf and according to our instructions under a data processing agreement (Art. 28 GDPR):

• Supabase, Inc. (USA) — server, database and forwarding to the AI models; Standard Contractual Clauses;
• Microsoft Ireland Operations Limited (Ireland) — AI models in Microsoft Azure; Data Privacy Framework and Standard Contractual Clauses;
• RevenueCat, Inc. (USA) — subscription status; Standard Contractual Clauses;
• Amplitude, Inc. (USA) — usage statistics, only with consent; Data Privacy Framework;
• Functional Software, Inc. (Sentry) (USA) — crash reports, only with consent; Data Privacy Framework;
• 650 Industries, Inc. (Expo) (USA) — app updates; Data Privacy Framework.

Apple and Google process data under their own responsibility when you download the app, buy a subscription or use features of the operating system.

5. Transfers to third countries

Some providers are based in the USA or process data there. The safeguard for each provider is named above under recipients: "Data Privacy Framework" means the provider is certified under the EU-US Data Privacy Framework and the transfer relies on the European Commission's adequacy decision (Art. 45 GDPR); "Standard Contractual Clauses" means we have agreed the European Commission's Standard Contractual Clauses with the provider (Art. 46(2)(c) GDPR).

Microsoft stores data in the EU. Depending on the model used, however, Microsoft may process a request in a data centre outside the EU. Microsoft is certified under the EU-US Data Privacy Framework, and our contract with Microsoft includes the Standard Contractual Clauses.

6. How long data is kept

• Data on your device: until you delete it or remove the app.
• Content sent to the AI models: not stored by us at all; at Microsoft for at most 30 days to detect misuse.
• Cost counters per installation identifier: 13 months, without content; after that only totals without the identifier.
• Purchase records: while the subscription exists and at most three years after.
• Usage statistics and crash reports: at most twelve months.

7. Your rights

You have the right to

• access your data (Art. 15 GDPR),
• have incorrect data corrected (Art. 16 GDPR),
• have your data erased (Art. 17 GDPR),
• restrict processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• withdraw consent you have given, with effect for the future (Art. 7(3) GDPR). Processing before the withdrawal remains lawful.

An informal message to hi@maverk.app is enough for any of these requests.

Because the app works without an account, we usually cannot link data on our servers to a person. If you want to exercise a right, write to us and we will tell you what we need to find your data. You can delete the data on your device yourself at any time in Settings → Delete all my data.

You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

8. Children and young people

Only people aged 16 or older can give the consents in the app (Art. 8 GDPR). Younger people use the app without the features that need consent.

9. No automated decisions

We make no automated decisions within the meaning of Art. 22 GDPR and do not create profiles.

10. Security

All connections between the app and our servers are encrypted. Only the people who need it to run the service have access to our systems.

11. Changes

We update this policy when the app or the law changes. The version published on this page applies. If what we use consented data for changes, the app will ask you again.

See also the Terms of Use and the Impressum.