Privacy Policy

Effective date: February 17, 2026

1. Introduction

Daily Talk Topics ("the App") is operated by Phi IT, a sole proprietor (eenmanszaak) based in Hoorn, the Netherlands ("we", "our", "us"). We are the data controller responsible for the processing of your personal data as described in this Privacy Policy.

This Privacy Policy explains how we collect, use, and protect your information when you use our App.

2. Information We Collect

Device Information

When you first open the app, we generate a random device identifier. This identifier is used solely to provide you with daily content and manage your subscription status. We do not collect your name, email address, phone number, or any other personally identifiable information.

Subscription Data

If you purchase a subscription, payment processing is handled entirely by Apple (App Store) or Google (Google Play). We receive only your subscription status (active or inactive) through RevenueCat. We do not have access to your payment details. If a free trial is offered, we receive the trial status (active or expired) but no additional personal data is collected during the trial period. If you use the "Restore Purchases" feature, we verify your original purchase and transfer subscription data from your previous device identifier to your current one. The previous device identifier's association with the subscription is replaced.

Topic Suggestions

If you submit a topic suggestion, we store the suggestion text along with your device identifier. Suggestions are reviewed and may be included in future content.

Usage Data

We collect basic usage data such as which categories you select. This data is associated with your device identifier, not your personal identity.

3. How We Use Your Information

  • Deliver daily conversation topic content
  • Manage your subscription status
  • Process and review topic suggestions
  • Improve app content and user experience
  • Enforce rate limits to prevent abuse

4. AI-Generated Content

Conversation topics in the App are generated with the assistance of artificial intelligence using a self-hosted language model. No user data is sent to any external AI service. The AI system processes only internal content prompts and does not have access to your device identifier, usage data, or any other user information.

5. Third-Party Services

Our app uses the following third-party services:

  • RevenueCat — Manages in-app subscriptions. We share your device identifier with RevenueCat to track subscription status. See RevenueCat's Privacy Policy.
  • Google AdMob — Displays advertisements to free-tier users. We request non-personalized ads only. AdMob may collect certain device information for ad serving and fraud prevention as described in Google's Privacy Policy.
  • Apple App Store / Google Play — Handles payment processing for subscriptions.

6. Advertising

Free-tier users see banner advertisements served by Google AdMob. We request non-personalized ads only, meaning ads are not based on your interests or browsing behavior. AdMob may still collect certain device information for ad serving, frequency capping, and fraud detection as described in Google's privacy policy. Pro subscribers do not see advertisements.

Apple App Tracking Transparency (iOS)

On iOS, the App does not request permission to track you across apps and websites owned by other companies (App Tracking Transparency). We do not use the Identifier for Advertisers (IDFA) for ad personalization or cross-app tracking.

7. Data Storage and Security

Your device identifier and authentication token are stored securely on your device using platform-native secure storage (iOS Keychain / Android Keystore). Server-side data is stored on secured servers within the European Union. We use HMAC-based authentication and HTTPS encryption for all API communications.

We do not sell, trade, or transfer your data to third parties beyond what is described in this policy.

8. International Data Transfers

Our servers are located within the European Union. However, some third-party services we use (RevenueCat, Google AdMob) are operated by companies based in the United States. When data is transferred outside the EU, these transfers are protected by appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, or the EU-U.S. Data Privacy Framework.

9. Data Retention

Device identifiers and associated data are retained for as long as you use the App. If you uninstall the App, your device identifier is no longer sent to our servers. Inactive device records may be deleted after 12 months of inactivity. You may contact us at any time to request immediate deletion of your data.

10. Data Deletion

You can delete all data associated with your device directly from the App by going to Settings and selecting "Delete My Data". This immediately removes your device record, category selection history, topic suggestions, and subscription data from our servers. Alternatively, you can request deletion by contacting us at [email protected], and we will process your request within 30 days.

Note that data held by third-party services (RevenueCat, Google, Apple) is subject to their respective data deletion policies.

11. Children's Privacy

Our App is not directed at children under 13. We do not knowingly collect information from children under 13. If you believe we have collected information from a child under 13, please contact us so we can delete it.

12. Your Rights (GDPR)

If you are located in the European Economic Area, under the General Data Protection Regulation (GDPR) you 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 any of these rights, contact us at [email protected].

Legal Basis for Processing

We process your data on the following legal bases:

  • Contract performance — Delivering daily content, managing your subscription, and processing payments (necessary to provide the service you use)
  • Legitimate interest — Enforcing rate limits, preventing abuse, and improving app content (our legitimate interest in maintaining and improving the service, balanced against your rights)
  • Consent — Processing topic suggestions you voluntarily submit

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects concerning you.

13. Your Rights (CCPA)

If you are a California resident, under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) you have the right to:

  • Know what personal information we collect and how it is used
  • Request deletion of your personal information
  • Request correction of inaccurate personal information
  • Opt out of the sale or sharing of your personal information
  • Not be discriminated against for exercising your rights

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. To exercise your CCPA rights, contact us at [email protected]. You may also designate an authorized agent to make a request on your behalf.

14. Cookies, Web Tracking, and Do Not Track

The App does not use cookies. Our website pages (such as this Privacy Policy and our Terms of Service) are static pages that do not use cookies, tracking pixels, or any web analytics tools.

We do not currently respond to "Do Not Track" (DNT) browser signals, as there is no industry-standard technology for recognizing or honoring them. We do, however, honor Global Privacy Control (GPC) signals where required by applicable law.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be reflected by an updated effective date at the top of this page. We will notify you of material changes through the App or other reasonable means. Continued use of the App after changes constitutes acceptance of the updated policy.

16. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at:

[email protected]

Daily Talk Topics