Privacy Policy

[[CONTROLLER_LEGAL_NAME]] (company number [[CONTROLLER_REG_NO]]), [[CONTROLLER_ADDRESS]], [[CONTROLLER_MEMBER_STATE]], is the data controller for the personal data described in this policy. "Zavox", "we" and "us" mean that company.

Privacy questions and requests about your rights: support@zavoxapp.app. Everything else: support@zavoxapp.app.

We have not appointed a Data Protection Officer. Privacy enquiries are handled directly by the company at the address above.

This policy covers the Zavox iOS app and the zavoxapp.app website.

It does not cover Apple. When you sign in with Apple, buy a subscription, or download the app, Apple processes your data for its own purposes as an independent controller, under Apple's privacy policy. We do not control that processing and cannot describe it for them.

Two of these are worth calling out because they are easy to miss: we keep your individual onboarding answers, not just the score they produce; and the coach notes are an AI-written characterisation of you, which you can read and delete at any time.

What we do not collect:

• Advertising identifiers (IDFA) or any identifier used for tracking.
• Location data.
• Your contacts, photo library, or files.
• Browsing or search history.
• Crash reports, performance diagnostics, or behavioural analytics.
• Push notification tokens — reminders are scheduled entirely on your device.
• Your name. We do not receive it from Apple.
• Your date of birth. See section 17.
• Payment card details. Apple handles payment; we never see them.

• You give it to us — your answers, your journals, your messages, your username.
• It is produced by your use of the app — progress, streaks, results, league standing.
• We infer it — your Nice Guy Index, your attachment style, your coach notes, and whether a message matched our crisis-phrase check. These are guesses made by software, not findings, and section 7 explains them.

Under the GDPR we need a lawful basis for each purpose. Here is every purpose and its basis.

Where we rely on consent you can withdraw it at any time, and withdrawing is as easy as giving it. Withdrawal does not undo processing we already carried out lawfully. Where we rely on legitimate interests you can object — see section 16.

Some of what you tell Zavox is sensitive: how you are feeling, what you are struggling with, what you write in your journal. European law treats data about mental health as a special category needing your explicit permission, and we treat your assessment results, coach notes, journals and coach conversations that way.

We ask for that permission separately — on its own screen, with its own control, never bundled into accepting the Terms and never pre-ticked. You can withdraw it at any time in Settings.

Zavox scores your answers, labels an attachment style, and writes a short summary of your situation that shapes what the coach says and which lessons you see. Under the GDPR this is profiling, and we want to be straightforward about it.

None of it decides anything with legal or similarly significant effect for you. It changes which lesson comes next and how the coach phrases things. It does not set your price, gate features, or determine eligibility for anything.

Even so, you can:

• See your score, your attachment label and your coach notes in the app.
• Change your answers, or reset the assessment.
• Delete the coach notes, at which point they are regenerated only if you keep using the coach.
• Contact a human at support@zavoxapp.app if you disagree with how the app has characterised you.

The AI coach is powered by OpenAI. We send your content to OpenAI's API to generate each reply. This is the most significant thing Zavox does with your data, so here is exactly what is sent.

When you send a message to the coach, we send OpenAI: your Nice Guy Index, your attachment style, your focus summary, the patterns you selected, your full coach notes, up to 8 of your journal entries that you have allowed the coach to read (the first 300 characters of each), a 30-day summary of your exercise activity, your open missions, up to 20 of your previous coach messages in full, and the message you just sent.

Periodically, to keep your coach notes current, we send up to 15 journal entries and up to 30 coach messages together with your assessment scores.

In roleplay practice we send the recent messages of that conversation, including what you typed. No profile data is included.

When generating a practice scenario we send only your selected pattern, attachment style and Index score.

The model is gpt-4o-mini and OpenAI processes it in the United States. See section 14 for how that transfer is protected.

Journal entries are stored on our servers, not only on your device. They sync when you are signed in so you do not lose them if you change phone.

Every entry has a setting controlling whether the AI coach can read it. It is off unless you turn it on. When it is on, that entry may be sent to OpenAI as described in section 8. You can change the setting on any entry, at any time, and you can delete any entry.

Zavox checks the messages you send to the coach for phrases associated with thoughts of suicide or self-harm. If one matches, the app immediately shows crisis resources instead of a coach reply. This check runs for everyone, including people who have not subscribed.

We do not keep a record of which of your messages matched the check. The message itself is stored with the rest of your coach conversation, and is deleted when you delete your account or your conversation.

You can turn off leaderboard participation and friend requests in your profile settings. Blocking someone stops them contacting you or seeing your activity. Friend requests and nudges are visible to the person receiving them.

Apple processes your payment. We never see or receive your card details. We receive from our subscription provider whether you have an active subscription and that it came from the App Store, and we share your Zavox user ID with them so the subscription attaches to the right account.

We may also share data with professional advisers, or with authorities where we are legally required to.

Our database, sign-in and server functions run in the European Union. The AI coach is the exception.

When you use the AI coach, what you have written is sent to OpenAI in the United States. To protect it we rely on [[TRANSFER_MECHANISM]]. You can ask us for a copy of those safeguards at support@zavoxapp.app.

Our database provider is US-incorporated, so although your data is stored in the EU, their staff may access it from outside the EEA for support. That access is covered by the same kind of safeguards.

You can delete your account in the app, under Profile. Here is exactly what happens:

Two honest limits. Deleted data can persist in encrypted backups for up to [[BACKUP_RETENTION_WINDOW]] before those backups expire. And deleting your account does not retrieve content already sent to our AI provider; their retention is governed by their own terms.

Under the GDPR you have the right to:

• Access — ask what personal data we hold about you and get a copy.
• Rectification — have inaccurate data corrected.
• Erasure — have your data deleted.
• Restriction — ask us to pause processing while a dispute is resolved.
• Portability — receive your data in a machine-readable format.
• Object — object to processing based on our legitimate interests, and object at any time to direct marketing.
• Withdraw consent — at any time, without affecting processing already carried out.
• Not be subject to decisions made solely by automated means with legal or similarly significant effects. See section 7.

Several of these are self-service in the app: delete your account, edit or reset your profile, delete individual journal entries, change coach visibility, and turn off leaderboards and friend requests.

For anything else, email support@zavoxapp.app. We respond within one month. For complex requests we may extend by two further months, and we will tell you if we do.

Zavox is for people aged 16 and over. Where your device supports it we ask Apple to confirm your age range; otherwise we ask you to enter your date of birth.

We do not knowingly collect data from anyone under 16. If you believe a child has given us data, contact support@zavoxapp.app and we will delete it.

• Data is encrypted in transit and at rest.
• Database access controls mean your records are reachable only by you.
• Sign-in is handled by Apple; we never see or store a password.
• Our infrastructure runs in the EU.
• There is no analytics or tracking code in the app that could leak data to a third party.

No system is completely secure, and we cannot guarantee absolute security.

Zavox stores your profile, progress, journals, streaks and game state on your device. The core training works without an account.

Once you sign in, that data syncs to our servers. There is currently no way to have an account without sync — if you would rather nothing left your device, use Zavox without signing in.

Reminders are scheduled entirely on your device by iOS. We do not use push notification tokens, we do not operate a notification server, and no notification data reaches us. You can turn reminders off in the app or in iOS Settings.

zavoxapp.app sets no analytics or advertising cookies and does not track visitors. [[VERIFY_WEBSITE_ANALYTICS]]

We may update this policy. Material changes will be announced in the app and reflected in the date and version below. Where a change alters the basis or scope of what we do with your data, we will tell you before it takes effect — and where we rely on your consent, we will ask again rather than treating continued use as agreement.

Privacy: support@zavoxapp.app. Everything else: support@zavoxapp.app.

[[CONTROLLER_LEGAL_NAME]], [[CONTROLLER_ADDRESS]], [[CONTROLLER_MEMBER_STATE]].