Privacy Policy
Last updated: July 12, 2026
This Privacy Policy explains how Nicola Eberhard ("we", "us", "our") processes personal data when you use Satro. We are established in Austria as a sole proprietorship (Einzelunternehmen) and offer the service to users in the European Economic Area (EEA), United Kingdom, and United States. Your thoughts belong to you — we treat your journal content as private and do not sell it.
For users in the EEA, we process personal data in accordance with the EU General Data Protection Regulation (GDPR). For users in the United Kingdom, we apply the UK GDPR and the Data Protection Act 2018. For users in the United States, additional rights may apply as described in Section 11 below.
1. Data controller
Nicola Eberhard
Sole proprietorship (Einzelunternehmen)
St.Andrä 87
9433 St.Andrä
Austria
Trade:
Dienstleistungen in der automatischen Datenverarbeitung und Informationstechnik
Email: nicolaeberhard28@icloud.com
GISA Number: 39856838
Member of: Wirtschaftskammer Kärnten
2. Categories of personal data
- Account data: email address, display name, language, timezone, workspace preferences
- Content you create: journal entries, goals, weekly reflections, space assignments, voice transcripts
- Usage and billing data: subscription status, AI and voice usage counters, payment metadata from Stripe or Apple (we do not store full card numbers)
- Technical data: session cookies required for authentication; push notification tokens if you enable reminders
3. Purposes and legal bases
- Provide the service (contract): account, sync, AI features you request, subscriptions
- Security and abuse prevention (legitimate interests): protecting accounts and infrastructure
- Tax and accounting (legal obligation): records for paid subscriptions
- Reliability (legitimate interests): bug fixing and service improvement — we do not use your journal content to train third-party AI models. We do not sell personal data and do not use journal content, goals, reflections, or voice recordings for advertising purposes.
4. Service providers and international transfers
We use trusted processors to operate Satro:
- Google Firebase (EU/US) — authentication and database hosting
- OpenAI (United States) — journal entries, goals, reflections, and voice recordings are only transmitted to OpenAI when required to provide AI features explicitly requested by the user
- Stripe (EU/US) — web subscription payments
- Apple — in-app purchases on iOS, when available
- Vercel — application hosting
Voice recordings are processed solely for transcription and AI functionality requested by the user. Voice recordings are not used for advertising, profiling, or third-party model training.
Where personal data is transferred outside the EEA/UK (for example to the United States), we rely on appropriate safeguards such as the EU/UK Standard Contractual Clauses and provider data processing agreements. Contact us for more information about safeguards relevant to your data.
5. Retention
We keep your data while your account is active. When you delete your account, we remove your journal content and profile from our systems. Account deletion permanently removes access to your data and cannot be undone.
Deleted data may remain in encrypted backups for a limited period before being permanently removed according to infrastructure provider retention schedules. Statutory retention for tax records (typically up to seven years for invoices) may still apply.
6. Security
We implement industry-standard technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction. However, no internet-based service can be guaranteed to be completely secure.
7. Your rights
Depending on applicable law, you may have the right to:
- Access your personal data
- Rectify inaccurate data
- Delete your data (Settings → Delete account)
- Export your data (Settings → Download my data)
- Restrict or object to certain processing
- Withdraw consent where processing is consent-based
- Lodge a complaint with a supervisory authority
Supervisory authorities: In Austria, the Austrian Data Protection Authority (dsb.gv.at). In the UK, the Information Commissioner's Office (ico.org.uk). You may also contact your local EU/EEA authority if you live in another member state.
Privacy requests: nicolaeberhard28@icloud.com
8. Children
Satro is not directed at children under 13. We do not knowingly collect personal data from children under 13. Users in the EEA and UK must be at least 16 years old (or the applicable minimum age in their country). If you believe a child has provided us with personal data, contact us and we will delete it promptly.
9. Cookies
We use strictly necessary session cookies to keep you signed in. We do not use advertising or third-party tracking cookies. Disabling session cookies may prevent login.
10. Changes
We may update this policy when our practices or legal requirements change. We will post the new version on this page and update the "Last updated" date. Material changes may be notified by email or in-app notice where required.
11. Additional rights for US residents (CCPA / CPRA)
If you are a resident of California or another US state with applicable privacy laws, you may have the following rights regarding your personal information:
- Right to know: you may request disclosure of the categories and specific pieces of personal information we have collected about you.
- Right to delete: you may request deletion of your personal information, subject to certain exceptions (Settings → Delete account).
- Right to correct: you may request correction of inaccurate personal information we hold about you.
- Right to opt out of sale or sharing: we do not sell or share personal information for cross-context behavioral advertising.
- Right to non-discrimination: we will not discriminate against you for exercising any of these rights.
To exercise these rights, contact us at nicolaeberhard28@icloud.com. We will respond within 45 days as required by applicable law.