Privacy Policy for Odyseya

Effective Date: October 2026
Last Updated: October 2026

Introduction

This Privacy Policy explains what personal data the Odyseya mobile application (the "App") processes, why, on what legal basis, who else receives it, how long it is kept, and what rights you have. It is written to meet the information duties of the EU General Data Protection Regulation (GDPR) and the UK GDPR.

Odyseya is a tool for self-reflection, habits and personal growth. It is not medical advice, diagnosis or therapy.

1. Who Is Responsible for Your Data

The controller of your personal data is:

• Controller: Joanna Cholas
• Contact for privacy matters: odyseya.journal@gmail.com
• Data protection officer: none appointed; for data protection matters please write to odyseya.journal@gmail.com

You can contact us at the address above about anything in this policy, including exercising your rights.

2. What We Collect

2.1 Your Account

• Email address and password, or the account identifier from Sign in with Apple or Google, used to sign you in. Passwords are handled by Firebase Authentication and are never stored by us in plain text.
• Display name, if you give one.
• A profile photo, if you choose one. It stays on your phone and is not uploaded.
• Your consent choices, with the date, the document versions you accepted and the IP address the request came from, kept as proof of consent.

2.2 What You Write and Say

• Voice entries. Your voice is turned into text on your phone by the phone's built-in speech recognition, which the App sets to run on the device only. The audio is not saved as a recording and is never uploaded - not to us, not to Apple or Google, and not to any AI provider. Only the resulting text becomes your entry.
• Typed and imported entries. Text you type, or text read from a .txt, .docx or .pdf file you pick. The file itself is read on your phone and is not uploaded.
• Other things you write in the App, such as your North Star and values, goals you set for areas of your life, intentions, letters to yourself, and your Oasis board (feelings, meanings, goals and morning words).

2.3 What the Companions Produce

If you allow companion reflections, the App stores what Jerboa, Little Owl and the Camel write for you: reflections, suggested directions, readings of My Desert, and the patterns, themes and categories they detected. Jerboa also keeps a small ledger of durable facts drawn from your entries (for example people, projects, places, ongoing situations, health and preferences) so later reflections have context.

2.4 Photos of Handwritten Pages

If you scan a handwritten page, the text is read on your phone. Cloud handwriting reading is currently switched off, so the photo never leaves your phone. Only the text you then save becomes your entry.

2.5 Technical and Usage Data

• Crash reports: when the App crashes or hits an error, Firebase Crashlytics receives the technical details (device model, operating system and App version, the error itself) together with your account identifier, so we can reproduce and fix the problem.
• Usage statistics: only if you switch on "Anonymous usage" before your first entry, Google Analytics for Firebase receives counts of taps and screens with a pseudonymous identifier. It never receives what you write.
• Security records: our server functions record calls to them (time, account identifier, email, IP address, device user agent) to detect abuse and keep the service secure, and count AI requests per account to apply fair-use limits.

2.6 What We Do Not Collect

• No audio recordings.
• No location data is collected. The only exception is the Help, right now screen: if you choose to allow it, the App uses your approximate location on your phone to work out which country you are in, so that it can show local helplines. Only the country is used. Your location is never stored, never sent to us and never shared with the AI providers. The phone's own location service (Apple or Google) turns the position into a country.
• No advertising identifiers, no advertising or cross-app tracking, and we never sell your data.

3. Where Your Data Is Kept and How It Is Protected

3.1 On Your Phone

The text of your entries, the answers you write to companion questions, your letters to yourself, intentions and Oasis board are encrypted on your phone with AES-256-GCM before they are saved to our database. The encryption key is created on your phone and kept in its secure storage (iOS Keychain or Android Keystore); it is not sent to us. This means we cannot read that content in our database.

3.2 In Our Cloud Database

Your data is stored in Google Firebase (Cloud Firestore) in Google Cloud, London (europe-west2). Our server functions run in Google Cloud's europe-west2 region (London, United Kingdom).

Some data is stored in readable form because the companions and the App need it on the server: your account details, consent records, your North Star, values and goals, companion reflections and suggestions, detected patterns, themes and categories, the facts ledger and the state of My Desert. Google encrypts all stored data at rest.

To create a reflection, the text of an entry is sent from your phone to our server over an encrypted connection (TLS), passed to the AI provider, and not kept by the server in readable form afterwards.

3.3 Security Measures

• Encrypted connections (TLS) for all network traffic.
• On-device encryption of entry text and other personal writing, as described above.
• Database rules that let each signed-in person reach only their own data.
• Firebase App Check, to accept requests only from genuine copies of the App.
• Optional app lock with Face ID, Touch ID or your device passcode, and a fresh Face ID check every time you export.

No system is perfectly secure, but we work to keep the risk as low as we reasonably can.

4. Why We Use Your Data and on What Legal Basis

4.1 Providing the Journal Service

Creating your account, signing you in, storing and syncing your entries and other content, My Desert, the Oasis board, letters to yourself, export and account deletion.

• Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).
• Because what you write can reveal information about your health or other sensitive matters, we store it on the basis of the explicit consent you give before your first entry (Art. 9(2)(a) GDPR). You can withdraw it by deleting the entries concerned or your account.
• When you set your North Star or a goal for an area of your life, its text is sent to OpenAI to check that it is phrased as something within your own reach. This is part of the feature you are using (Art. 6(1)(b) GDPR).

4.2 Companion Reflections (AI)

Jerboa's reflections, Little Owl's directions, the Camel's readings in My Desert and on the Oasis board.

• Legal basis: your consent (Art. 6(1)(a) GDPR) and, because entries can reveal sensitive information, your explicit consent (Art. 9(2)(a) GDPR), given before your first entry. Reading handwriting with AI also needs its own separate consent.
• Withdrawing consent: at any time, in Settings > How the companions think > Companion reflections. From then on nothing is sent for AI processing. Withdrawal does not affect processing that took place before it.

4.3 Usage Statistics

• Legal basis: your consent (Art. 6(1)(a) GDPR), through the optional "Anonymous usage" switch before your first entry. To withdraw it later, contact us at odyseya.journal@gmail.com.

4.4 Security, Crash Diagnostics and Fair Use

Crash reports, security records, App Check and limits on AI requests.

• Legal basis: our legitimate interest in keeping the App working, secure and free from abuse (Art. 6(1)(f) GDPR). You can object at any time (see Section 9).

4.5 Service Messages and Support

Emails about your account or your data (for example a notice before entries are deleted under Section 8) and answers to messages you send us.

• Legal basis: performance of our contract (Art. 6(1)(b) GDPR) and our legitimate interest in answering you (Art. 6(1)(f) GDPR).

4.6 Legal Obligations

Keeping proof of your consent, answering requests from authorities where the law requires it, and, once paid plans exist, keeping records required by tax and accounting law.

• Legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR).

4.7 Payments

During the beta the App is free and no payments are taken. If paid plans are introduced, purchases will be handled by the Apple App Store or Google Play and subscription status by RevenueCat, on the basis of our contract with you (Art. 6(1)(b) GDPR).

5. AI Processing and Automated Decisions

The companions are language-model prompts, not people. No human reads your entries. A full description of what each companion receives is in the AI Notice, available in the App.

Reflections are one possible reading of your words, offered for your own reflection. They are not decisions that produce legal effects for you or affect you in a similarly significant way within the meaning of Art. 22 GDPR, and nothing in the App - your account, access or price - is decided automatically on the basis of what you write.

Your content is never used by us, or by OpenAI under its API terms, to train AI models.

6. Who Receives Your Data

We use the following service providers, who process data on our behalf under data processing terms:

• Google (Firebase): authentication (including Sign in with Google), database, server functions, App Check, crash reports (Crashlytics) and, only with your consent, usage statistics (Google Analytics for Firebase). Google also delivers service emails we send from our Gmail account. Privacy: https://firebase.google.com/support/privacy
• OpenAI: generates companion reflections, suggestions and readings, and checks the wording of your North Star and goals. It receives the text described in the AI Notice, never your name, email or location. Under OpenAI's API terms, the data is not used for training and may be kept for up to 30 days for abuse monitoring before deletion. Privacy: https://openai.com/policies/privacy-policy
• Google (Gemini API): Cloud handwriting reading is currently switched off: handwritten pages are read on your phone only, and no photo leaves it.
• Apple (Sign in with Apple): if you choose it, to sign you in. Speech recognition and on-device text reading run on your phone and send nothing to Apple or Google.
• RevenueCat and Apple App Store / Google Play: only once paid plans exist, to process purchases and manage subscription status (your account identifier and purchase details). Privacy: https://www.revenuecat.com/privacy

We may also disclose data where the law requires it, for example to comply with a court order, or where necessary to protect someone's life or safety.

We never sell your personal data and never share it for advertising.

7. International Transfers

Our server functions run in the United Kingdom, which the European Commission recognises as providing adequate protection. Some providers process data outside the EEA and the UK, in particular in the United States (OpenAI, Google, RevenueCat).

Where data is transferred outside the EEA or the UK, the transfer is protected by the European Commission's Standard Contractual Clauses (and the UK addendum), or by the EU-US Data Privacy Framework (and its UK extension) where the recipient is certified under it. You can ask us for a copy of the relevant safeguards at odyseya.journal@gmail.com.

8. How Long We Keep Your Data

• Entries and their reflections: until you delete them or your account. Entries are never deleted automatically.
• Other content (North Star, values, goals, letters, intentions, Oasis board, facts ledger, My Desert): until you delete it or your account.
• Account data: until you delete your account.
• Photos of handwritten pages: not kept; discarded as soon as they have been read.
• Crash reports: up to 90 days in Firebase Crashlytics.
• Usage statistics: 14 months in Google Analytics for Firebase.
• Server security logs: a limited period, by default 30 days in Google Cloud Logging.
• Proof of consent: up to 3 years after the account is deleted, only as proof of the consent given, so that we can show that consent was given.
• Data held by AI providers: OpenAI up to 30 days, as described in Section 6.

When you delete your account (Settings > Privacy centre > Delete my account), your entries, reflections, letters, Oasis board, North Star, values, goals, facts ledger, My Desert and your sign-in account are erased from our database straight away. We keep only a record of the deletion that contains a timestamp and nothing that identifies you, and your consent record as described above. Data on your phone is removed when you delete the App.

9. Your Rights

Under the GDPR you have the right to:

• Access your personal data and receive a copy of it.
• Rectification of inaccurate data. You can edit your entries and profile in the App.
• Erasure. You can delete individual entries, or your whole account in Settings > Privacy centre > Delete my account.
• Data portability. You can export your entries, reflections, letters and My Desert as PDF, plain text or JSON in Settings > Privacy centre > Export my entries. The file is created on your phone.
• Restriction of processing in the cases set out in Art. 18 GDPR.
• Object to processing based on our legitimate interest (Section 4.4), at any time, on grounds relating to your particular situation.
• Withdraw consent at any time, without affecting the lawfulness of processing before the withdrawal. For companion reflections use Settings > How the companions think > Companion reflections; for anything else, contact us.
• Lodge a complaint with a supervisory authority, in particular in the EU country where you live or work or where an alleged infringement took place. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl). In the UK it is the Information Commissioner's Office (ico.org.uk).

To exercise any right, use the App where shown or write to odyseya.journal@gmail.com. We answer within one month, as the GDPR requires; this can be extended by two further months for complex requests, in which case we will tell you why.

10. Children

Odyseya is intended for people aged 16 and over. We do not knowingly collect personal data from anyone under 16. If you believe someone under 16 has given us personal data, contact us at odyseya.journal@gmail.com and we will delete it.

11. Changes to This Policy

If we change this policy, we will update the "Last Updated" date and show the new version in the App. For material changes we will tell you in the App or by email before they take effect, and where a change relies on your consent we will ask for it again.

12. Contact Us

• Controller: Joanna Cholas
• Privacy questions and requests: odyseya.journal@gmail.com
• Data protection officer: none appointed; for data protection matters please write to odyseya.journal@gmail.com

13. Additional Information for Specific Regions

13.1 United Kingdom

UK users have the rights described above under the UK GDPR and the Data Protection Act 2018, and can complain to the Information Commissioner's Office (ICO).

13.2 California

California residents have the right to know what personal information we collect and how it is used and disclosed, to request its deletion and correction, and not to be treated differently for exercising these rights. We do not sell or share personal information for cross-context behavioural advertising.

13.3 Other Countries

If you live elsewhere, for example in Australia or Canada, you may have similar rights under local law, including the right to complain to your local privacy regulator. Contact us at odyseya.journal@gmail.com.

14. Summary

• Your voice: turned into text on your phone; the audio is never saved or uploaded.
• Your entries: the text is encrypted on your phone before it is stored; we cannot read it in our database.
• Companions: with your consent, entry text goes to OpenAI to create reflections; it is not used for training. You can switch this off at any time.
• Who else: Google (Firebase), OpenAI, Apple for Sign in with Apple, and RevenueCat only once payments exist.
• Your rights: access, correction, deletion, export, objection, withdrawal of consent, and a complaint to a supervisory authority.
• Contact: odyseya.journal@gmail.com