Privacy Policy

Effective date: September 2, 2026

1. Introduction

Daily Talk Topics is operated by Phi IT, a sole proprietorship (eenmanszaak), at Bazillehof 46, 1628 XD Hoorn, the Netherlands, registered with the Dutch Chamber of Commerce under KVK 85537578 ("we", "our", "us"). Phi IT is the controller for the processing described here.

Contact us at [email protected]. This notice covers the Android app, website, support, and related backend services.

2. Information We Collect

Installation and usage records

The app creates a random installation identifier and authentication token. Our server stores the identifier, a one-way token hash, creation and activity dates, streak values, selected category and date, and subscription status. We use these pseudonymous records to authenticate the app, provide and order daily content, enforce limits, maintain streaks, prevent abuse, and support deletion. No account name, login email, or phone number is required.

Subscription Data

Google Play processes payments. RevenueCat receives the installation identifier as an App User ID and supplies entitlement status, product ID, purchase and expiry dates, aliases where applicable, and synchronization event identifiers. We do not receive card or bank details.

Suggestions, feedback, and support

If you submit a topic suggestion or feedback, we store its text, the installation identifier, and a timestamp for authorized review. Support email includes information you choose to send and may include your installation identifier. Do not include sensitive or unnecessary personal information. If an approved suggestion is incorporated into the general topic library, its text may remain as unattributed app content after the source submission and identifier are deleted.

Network and operational data

Requests expose IP address, user agent, and technical metadata to Cloudflare and our hosting infrastructure. The backend uses IP addresses temporarily for registration rate limiting. Operational and security logs may contain request metadata, event identifiers, or installation identifiers.

3. How We Use Your Information

  • Contract performance: provide app content, maintain requested settings and streaks, and validate Pro access.
  • Legitimate interests: secure the service, enforce rate limits, diagnose faults, review feedback, and improve content. Our interests are operating a reliable and safe service.
  • Consent: initialize advertising technologies and request ads where consent is required. You can refuse or withdraw without losing the free app's core functionality.
  • Legal obligations and claims: retain or disclose records when lawfully required and establish or defend legal claims.

4. AI-Generated Content

Conversation topics are generated with a self-hosted language model. Generation prompts contain internal category and date context, not installation records, selections, suggestions, feedback, or subscription data. Generated content does not make decisions about users that produce legal or similarly significant effects.

5. Third-Party Services

Our app uses the following third-party services:

  • RevenueCat acts as our subscription-management processor and processes pseudonymous customer, device, receipt, and entitlement data. See RevenueCat's Privacy Policy.
  • Google Play processes purchases and account-level transaction records under Google's terms.
  • Google AdMob and User Messaging Platform provide consent choices and contextual banner advertising. Google acts as a separate controller for parts of its advertising processing. See Google's Privacy Policy.
  • Cloudflare provides network security, delivery, and the authentication boundary for our restricted admin interface.
  • Hosting, logging, and email providers process technical logs, stored app records, or support correspondence for us.

6. Advertising

Google's User Messaging Platform requests your choices before Mobile Ads is initialized where required. If permission to request ads is unavailable or consent gathering fails, the app does not show a banner. Banner requests are configured as non-personalized, but contextual advertising may still process IP address, device and advertising identifiers, interactions, consent records, diagnostics, and fraud-prevention information.

You may choose Consent, Do not consent, or Manage options. Where Google requires a privacy-options entry, it is available in Settings so you can change or withdraw your choice. Pro subscribers do not see advertisements, although consent configuration may occur while subscription status is being initialized.

We do not send selected categories, topic suggestions, or feedback to AdMob for targeting.

7. Data Storage and Security

The installation identifier and authentication token are stored using Android secure storage. Ordinary local app storage contains cached topics, selections, revealed-topic history, streak and subscription cache, notification time, onboarding, theme, haptic, review-prompt, and deletion-lock preferences. Local storage is accessible to the app and is removed when you clear app storage or uninstall, subject to Android backup behavior.

Primary backend records are hosted on infrastructure we administer in the European Union. API communications use HTTPS and bearer-token authentication. No security measure eliminates all risk.

We do not sell personal data. We disclose data only as described here, on your instruction, or when legally required.

8. International Data Transfers

RevenueCat, Google, Cloudflare, and support providers may process data outside the European Economic Area, including in the United States. Depending on the recipient and transfer, safeguards include an adequacy decision such as the EU-US Data Privacy Framework where the recipient is certified, or European Commission Standard Contractual Clauses with supplementary measures. Contact us for information about safeguards relevant to your data.

9. Data Retention

  • Installation, selection, streak, and linked subscription records remain in the primary database until you delete them, request deletion, or they are no longer needed for the service or legal obligations.
  • Suggestions and feedback remain until reviewed, deleted, or no longer needed. Approved suggestion text may remain as unattributed app content.
  • Registration rate-limit keys expire after approximately one hour without access.
  • Subscription and transaction records may be retained by Google and RevenueCat under their policies and for legal, accounting, fraud, or claims requirements.
  • Application logs in our central logging system are retained for 30 days. Cloudflare and other infrastructure providers apply their documented service retention periods.
  • Backups are retained only for disaster recovery under a restricted rotation. Deleted records are not intentionally restored into active use and are removed as backup copies expire.

10. Data Deletion

Settings > Delete My Data removes the current installation record and directly linked selections, streak, suggestions, feedback, and subscription status from our primary database when the request succeeds. It also clears credentials, content, streak, and subscription state used by the app. Some non-identifying local preferences remain until you clear Android app storage or uninstall.

This action also requests deletion of the matching RevenueCat customer record. It does not cancel a recurring Google Play subscription, so cancel that separately in Google Play. It does not delete Google transaction records, logs awaiting expiry, backups awaiting rotation, or suggestion text already incorporated as unattributed content.

Alternatively, follow our data deletion instructions or email us. We normally respond to privacy-rights requests within one month, subject to lawful extensions or retention exceptions.

11. Children's Privacy

The service is not directed to children under 16. Users under 16 should not submit personal information without authorization from a parent or legal representative. A parent or guardian should approve purchases where required. Contact us if you believe a child has submitted personal data so we can assess and delete it where appropriate.

12. Your Rights (GDPR)

Subject to applicable conditions and exceptions, you may have the right to:

  • Request access to data associated with your device identifier
  • Request correction of inaccurate data
  • Request deletion of your data
  • Object to processing of your data
  • Request restriction of processing
  • Data portability
  • Withdraw consent at any time, where processing is based on consent
  • Lodge a complaint with a supervisory authority — for the Netherlands, this is the Autoriteit Persoonsgegevens

To exercise a right, contact us and include the installation identifier shown by the app if available. We use proportionate verification and will explain if a right does not apply. You may complain to the Autoriteit Persoonsgegevens.

Providing an installation identifier is necessary for authenticated app delivery and deletion. Suggestions, feedback, notifications, and advertising consent are optional; refusing them does not remove core access. Subscription information is necessary only for Pro access.

13. Website and browser data

Our public pages use no first-party analytics, advertising pixels, or browser-storage code. Page presentation assets are served from our own origin. Cloudflare and hosting infrastructure still receive ordinary request metadata and may use strictly necessary security or delivery mechanisms. Links to external sites load those sites only when you follow them.

14. Changes to This Policy

We may update this notice when our service or legal obligations change. We will update the effective date and provide an in-app or other prominent notice before a material change where required. A privacy notice describes processing; it does not rely on continued use as consent.

15. Contact and controller details

Phi IT (sole proprietorship / eenmanszaak)
Bazillehof 46
1628 XD Hoorn
The Netherlands
KVK 85537578
[email protected]
Daily Talk Topics