The App is published by Cristiana Calota, an individual developer based in Romania ("we", "us"). For the purposes of the EU General Data Protection Regulation (GDPR) and similar laws, we are the controller of the little personal data described in this policy. Contact: bakabakaa2018@gmail.com.
We do not operate a server that receives anything from the App. The App contains no analytics, advertising, crash-reporting or tracking code, and it does not ask for your name, email address, phone number, location, contacts or camera. We do not know who you are, what you ask, or what the models answer.
The App asks for the microphone in two places, and uses it only while you are using them: during a call, so what you say can be turned into text on the device, and when you record a short passage to make your own voice (section 3.1). Nothing picked up by the microphone is sent anywhere.
Specifically, none of the following ever leaves your device or reaches us: your prompts and conversations, photos you attach, images you generate and the prompts for them, music you make, what you say during a call, the voice sample you record to make your own voice, your settings, and the list of models you have installed.
Everything the App works with is stored inside the App's own container on your device, protected by iOS. That includes conversations, attached photos, generated images and music, your voice sample, downloaded models and your settings. You can delete conversations and models inside the App, and deleting the App deletes all of it.
Like any app, Nodal's data is included in your iPhone backups if you have them turned on (iCloud Backup or a computer backup). Those backups are made by Apple's software under your Apple settings, not by us, and are covered by Apple's privacy policy.
Images you choose to save go to your Photos library, which the App can only write to, with your permission, and never reads.
If you choose to make your own voice, the App either records you reading a short passage, or reads an audio clip you pick from Files together with the words you confirm are said in it. It processes that recording on your iPhone into a voice sample: a compact description of how you sound and a coded form of the recording, which the voice model uses to speak in your voice. The recording itself is not kept once the sample is made.
The voice sample is stored only in the App's container on your iPhone. It is never uploaded, never sent to us or to anyone else, is excluded from iCloud and computer backups, and is used for one thing only: reading text aloud in your voice when you ask the App to. It is not used to identify or verify you, and we never have access to it. Because the voice sample is made from a recording of you, some laws treat it as sensitive or biometric information; we never collect, receive, store, sell or share it, and the App creates it only when you tap Record and read the passage yourself, or import a clip and confirm you have the right to use that voice. The words you type for an imported clip are stored with the voice sample, on your iPhone only, and deleted with it.
You can delete your voice sample at any time in Speak or Settings, under Voices, My voice, Delete. Deleting the App also deletes it. Record or import only your own voice, or the voice of someone who has given you their clear permission (see the Terms of Use).
The App contains no AI model. When you choose to download one, the App fetches the file directly from its public repository, currently Hugging Face. When you use the in-app search for community models, the words you type are sent to Hugging Face's public search API to return results.
As with any web request, Hugging Face receives your device's IP address, the name of the file requested, your search terms, and standard technical details such as the App's identifier. We do not receive any of this and cannot see what you download or search for. Hugging Face processes it under its own privacy policy. Downloading needs a connection; using a model afterwards does not.
Purchases are made through Apple's App Store. Apple handles payment, receipts and refunds under Apple's privacy policy. We never see your payment details, your name or your Apple Account.
To confirm that a purchase is genuine and to unlock the features you paid for, including on a new phone or after reinstalling, the App uses RevenueCat, a purchase-management service. RevenueCat receives:
This is used for app functionality (verifying receipts and turning features on) and for aggregate analytics about purchases, such as how many purchases were made. It is not used to track you across other companies' apps or websites, and it is not linked to your identity. RevenueCat processes this data as our processor under its privacy policy, and it is disclosed on the App Store's privacy label for the App as Purchase History, not linked to you.
If you email us, we receive your email address, whatever you write and any attachments you include. We use it only to answer you and to fix what you reported, we keep it for as long as we need to do that and to keep a record of the resolution, and we do not add it to any list or share it, except where the law requires. Support email is handled through Google's Gmail service.
| Data | Who receives it | Why | Linked to you |
|---|---|---|---|
| Prompts, chats, photos, images, music, audio, your voice sample | Nobody. Stays on the device. | The App's function | Not applicable |
| Model file requests and search terms, IP address | Hugging Face | Delivering the models you asked for | No |
| Purchase information, anonymous installation ID, device and app version, IP address | Apple, RevenueCat | Payment, receipt verification, unlocking features, purchase analytics | No |
| Your email address and message | Us, via Gmail | Support | Yes, when you write to us |
Where the GDPR applies, we rely on: performance of our contract with you (the purchase verification in 4.2 and delivering the models you request in 4.1), our legitimate interest in running and improving the App and in preventing fraud (aggregate purchase analytics), and, for support email, your request to be contacted and our legitimate interest in answering you.
Apple, Hugging Face and RevenueCat may process the data described above outside the European Economic Area, including in the United States. Each of them states in its own privacy policy the safeguards it uses for such transfers, such as the EU Standard Contractual Clauses or the EU-US Data Privacy Framework. We keep support email in our Gmail account.
Data on your device stays until you delete it or the App. Purchase records at RevenueCat are kept for as long as needed to honour your purchase and for our accounting obligations. Support email is kept for as long as needed to resolve your request and keep a record of it, then deleted.
Because almost everything is on your own device, most rights are exercised by you directly: you can read, export, correct or delete your data inside the App or by deleting it. For the personal data we do hold, in practice support emails, you can ask us to access, correct, delete or export it, to restrict or object to its processing, and you can withdraw consent where processing is based on it. Write to the address above and we will respond within one month. If you are in the EU or UK you also have the right to complain to your data protection authority; in Romania that is the ANSPDCP.
Under Apple's App Tracking Transparency rules, the App does not track you and will never ask for tracking permission.
We do not sell or share personal information, as those terms are used in the California Consumer Privacy Act and similar US state laws, and we have not done so in the past 12 months. We do not use personal information for targeted advertising or profiling. Residents of those states have the same rights described above, and we will not treat you differently for using them.
The App is rated for adults and is not directed at children under 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has sent us personal data, contact us and we will delete it.
Your data is protected by the security of your device: the App's container is encrypted by iOS when the device is locked, and nothing is transmitted to us. Purchase data is sent to Apple and RevenueCat over encrypted connections. No method of storage or transmission is completely secure, so please keep your device updated and protected with a passcode.
We may update this policy when the App changes or the law does. The current version is always at this address with its date at the top. If a change means data starts leaving your device that did not before, we will say so clearly in the App before it happens.
Cristiana Calota, Romania
Email: bakabakaa2018@gmail.com
Support: nicky-byte.github.io/nodal-support