Privacy Policy

Last updated: August 6, 2026 | Effective: August 6, 2026

1. Data Controller

The data controller for personal data processed by Pepitt is:

Paul Haardt
SIREN 105832190 - see our Mentions légales
Email: [email protected]
Data protection contact: [email protected]

We do not currently have a designated Data Protection Officer (DPO) as our core activities do not meet the GDPR Art. 37 thresholds, but you can reach us about any privacy concern at the address above.

When you record other people, you act as the data controller for their personal data and we act as your processor for that content (we process it only to deliver the Service, on your instructions). We are an independent controller for your account, billing, and service-operation data.

2. What Data We Collect

2.1 Data you provide

• Account data: email address (verified), Firebase Auth UID, optional phone number (if you opt into phone verification).
• Audio recordings: the audio files you choose to record or import.
• Recording metadata: friendly name, language, optional context notes you attach.
• Transcripts and notes: AI-generated text derived from your audio.
• Recipes and contexts: templates you create to guide note generation.
• Promo codes: if you redeem one.

2.2 Data we collect automatically

• Usage data: transcription minutes used, note generations used, subscription tier - required for billing and limits.
• Technical data: request logs (IP address, user agent, endpoint, timestamp, app version, platform) retained for up to 90 days for security and abuse-detection.
• Crash reports (first-party): if the app crashes or hits an error, it sends us a report: the error message, a technical stack trace, the screen template it happened on (e.g. notes/[id] - never the content shown on it), your app version and platform, and a random identifier that exists only for that app session and is never stored on your device or linked to your account. We use these reports solely to find and fix bugs (legitimate interest, Art. 6(1)(f)). They go to our own servers in the EU and to no one else.
• Anonymous screen counts (first-party): which screens of the app are opened, counted as templates like notes/[id] without any real identifiers, and with no identifier of you or your device attached at all. This tells us which features get used; it cannot be tied to any person. Sent to our own servers in the EU only.
• Subscription state: tier, period, expiry, sourced from RevenueCat and the relevant app store.
• Product analytics events (opt-in only): pseudonymous app events (e.g. upgrade_viewed, conversation_recorded) sent to Vexo Analytics only if you opt in - via the one-time prompt, or the Settings → Privacy toggle. Until you opt in, no analytics are sent at all, and you can turn it off again at any time. When enabled, Vexo receives an opaque, pseudonymous device identifier and the event names above. Vexo never receives your email, your name, or any recording, transcript or note content. These events are not used for advertising and use no cross-app identifier. This opt-in analytics is separate from the service & debugging logs described below.
• Service & debugging logs: by default we keep detailed logs of note generation, which can include your transcript text and the AI's output, so we can operate, debug, and improve Pepitt. You can opt out for your account at any time by emailing us (see §6); we do not use this content to train AI models.

2.3 Anonymous / guest usage

You can use Pepitt without creating an account ("Get started" as a guest, no email required). Guest usage is not un-identified: it is tied to a server-issued anonymous authentication identifier and your device identifier, which we use to apply your one-time free quota per device. Your audio, transcripts, and notes as a guest are processed and stored on our servers the same way as for a registered account (§2.1-2.2 above; the same sub-processors in §4 apply). If you do not create an account, this guest data (and the guest identity itself) is automatically and permanently deleted after 30 days of inactivity. We keep only an aggregate record of quota already used against your device (no audio, transcript, or note content) indefinitely, solely to prevent re-granting the same free quota via reinstall. If you create an account, your guest content is transferred to it and the guest identity is later deleted the same way.

2.4 Optional data

• Location: only when you enable it. Used to tag recordings with a place name for search and display on your device. Coordinates and place names are stored only on your device and are never transmitted to or stored on our servers.
• Marketing email address: if you opt in on our website to receive product-news emails (see §12).

3. Legal Basis (GDPR Art. 6)

4. Third-party Processors (Sub-processors)

We share specific data with the processors below strictly to deliver the Service. We put a data processing agreement in place with each as required by GDPR Art. 28, and each operates under its own privacy policy:

Each row below shows exactly what data leaves us, who receives it, why, and the legal basis. Read each row on its own: a processor only ever receives the data listed in its own row.

The "no email, no name, no content" assurance applies to Vexo Analytics only. Every other processor necessarily receives the data listed in its own row so that the Service can work - for example, Mistral receives your transcripts and Soniox receives your audio. The opt-in Vexo analytics is also entirely separate from the server-side generation & debugging logs described in §2.2 and §6, which may contain your transcript text and are kept under legitimate interest with an email opt-out.

We process your transcripts and notes only on EU-based providers. We may introduce a new note-generation provider in future; if a change would send your content to a different provider or region, we will update this list and notify you in advance.

5. International Transfers

Some of our processors are located outside the European Economic Area (EEA), primarily in the United States. Transfers rely on the EU-US Data Privacy Framework (DPF) where the processor is certified, and on Standard Contractual Clauses (SCCs) otherwise.

6. Retention

• Audio recordings: if sync is off, or on the free plan, kept on our servers for up to 30 days after transcription completes (to allow re-transcription and failure recovery), then automatically deleted. On paid plans with sync enabled, your audio is retained on our servers for as long as your subscription is active (subject to your plan's storage quota); it is deleted after cancellation once your grace period ends, or sooner if you turn off sync or delete the recording yourself. The copy on your device persists until you delete it.
• Transcripts & notes: retained until you delete them, or up to 30 days after account deletion to allow recovery.
• Account data: retained while your account is active. Deleted within 30 days of account deletion, except where legal retention obligations apply (e.g. tax records, up to 10 years for invoicing data).
• Request logs: up to 90 days.
• Crash reports & anonymous screen counts: 90 days.
• Generation & debugging logs: by default these (which can include transcript text and AI output) are kept for the life of your account to operate and improve Pepitt, and are deleted when you delete your account. To stop detailed logging for your account, email [email protected] and we will switch your account to minimal logging.
• Analytics events: the pseudonymous, device-linked events described in §2.2 are retained for 12 months, after which we keep only aggregated statistics with no device identifier.
• Anonymous / guest usage: guest audio, transcripts, and notes are deleted automatically after 30 days of inactivity if you never create an account (§2.3). Only an aggregate, content-free record of quota already used against your device is kept indefinitely to prevent quota being re-granted on reinstall.

7. Your Rights (GDPR Art. 12-22)

You have the following rights regarding your personal data:

• Access (Art. 15): request a copy of the personal data we hold about you.
• Rectification (Art. 16): ask us to correct inaccurate data.
• Erasure / "Right to be forgotten" (Art. 17): delete your account from the in-app settings or our account deletion page, or email us. We will erase all data within 30 days, subject to legal retention.
• Restriction (Art. 18): ask us to limit processing in defined circumstances.
• Portability (Art. 20): request your data in a structured, machine-readable format. Use the in-app export feature, or email us.
• Objection (Art. 21): object to processing based on legitimate interest.
• Withdraw consent: revoke consent for optional features or marketing emails at any time.
• Lodge a complaint: with your national supervisory authority (in France: CNIL) or the supervisory authority in your country of residence.

To exercise any right, email [email protected]. We respond within 30 days (extendable to 90 days for complex requests under Art. 12(3)).

8. Security

We protect your data with industry-standard safeguards:

• All traffic is encrypted in transit via HTTPS / TLS 1.2+.
• Audio uploads use signed URLs scoped to your account.
• Server access is restricted to authorised personnel.
• Authentication is delegated to Firebase Authentication.
• Passwords are never stored by Pepitt - they are managed exclusively by Firebase.

No system is perfectly secure. If you suspect a vulnerability or breach, email [email protected].

9. Cookies & Tracking

The Pepitt mobile app and our web-served legal pages do not set cookies. Our website loads web fonts from Google Fonts on every page (see §4); this sends your IP address to Google but sets no cookie and stores no persistent identifier, so it is not gated behind a consent banner. If our marketing website introduces any other non-essential cookies or trackers, we will ask for your consent first via a cookie banner. Analytics events are sent via Vexo only if you opt in (see §2); they do not use cross-app identifiers and are not used for advertising.

10. Children's Privacy

Pepitt is not intended for users under 16. We do not knowingly collect data from children under 16. If you believe a minor has created an account, contact us and we will delete the account.

11. Automated Decision-Making

We do not perform any automated decision-making with legal or similarly significant effects on you (GDPR Art. 22). AI-generated transcripts and notes are informational outputs subject to your review.

12. Marketing Communications

If you give consent (for example by ticking the box on our website), we may send you occasional product-news emails via Brevo. We rely on your consent (GDPR Art. 6(1)(a)). You can withdraw consent at any time using the unsubscribe link in every email or by emailing [email protected]; withdrawal does not affect sending that happened before you withdrew.

13. Changes to this Policy

We may update this Privacy Policy. Material changes will be notified via the app at least 30 days before they take effect, with the option to object.

14. Contact

General contact: [email protected]
Privacy / data protection requests: [email protected]
Security reports: [email protected]