Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent, in connection with the provision of our application.

Our terms of use also apply to your use of the Vale! app.

The terms used are not gender-specific.

Last updated: November 8, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Relevant Legal Bases
• Security Measures
• Disclosure of Personal Data
• International Data Transfers
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Provision of the Online Offer and Hosting
• The Vale! App
• Contact and Inquiry Management
• Third-Party Providers Used (Vercel, GitHub)
• Changes and Updates
• Glossary of Terms

Controller

Mateo Arenas Salas
Elisabethenstraße 60
64283 Darmstadt, Germany

Email: mateoas@icloud.com

Overview of Processing Activities

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of data processed

• Contact data.
• Content data.
• Usage data.
• Meta, communication, and procedural data.
• Log data.

Categories of data subjects

• Communication partners.
• Users.

Purposes of processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online offer and user friendliness.
• Information technology infrastructure.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we base our processing of personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. Should more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

• Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract.
• Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests, fundamental rights, and fundamental freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transmission and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Applicability of data protection provisions in the country of registered office: In the country in which the controller has its registered office, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

Security Measures

In accordance with the legal requirements, taking into account the state of the art, the cost of implementation, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, availability, and its segregation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to any compromise of data. We also take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Disclosure of Personal Data

In the course of our processing of personal data, it may occur that such data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in connection with the use of third-party services or the disclosure or transmission of data to other persons, bodies, or companies (which becomes apparent from the postal address of the respective provider, or where the privacy policy explicitly refers to data transfers to third countries), this always takes place in accordance with the legal requirements.

For data transfers to the USA, we rely on the Data Privacy Framework (DPF) where the recipient is certified under it; the EU Commission recognized the DPF as a safe legal framework by an adequacy decision dated July 10, 2023. Where a recipient is not certified under the DPF, the transfer is based on the EU Commission's Standard Contractual Clauses, which establish contractual obligations to protect your data.

For each individual service provider, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/. Specific information on the providers we use can be found in the section "Third-Party Providers Used (Vercel, GitHub)".

For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission's website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consent is revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply where statutory obligations or particular interests require longer retention or archiving of the data.

In particular, data whose storage is necessary for the assertion, exercise, or defense of legal claims or to protect the rights of other natural or legal persons may be retained for longer accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.

Where multiple retention periods or deletion deadlines are specified for a given piece of data, the longest period shall always apply. Data that is no longer retained for its original purpose, but is retained due to statutory requirements or other reasons, is processed exclusively for the reasons justifying its retention.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, arising in particular from Articles 15 to 21 GDPR:

• Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent given to us at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be deleted without delay, or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
• Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with legal requirements, in a structured, commonly used, and machine-readable format, or to request that it be transmitted to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the GDPR. The authority responsible for us is Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (the Hessian Commissioner for Data Protection and Freedom of Information), P.O. Box 3163, 65021 Wiesbaden, Germany, https://datenschutz.hessen.de.

Provision of the Online Offer and Hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to deliver the content and functions of our online services to the user's browser or device.

• Types of data processed: Usage data (e.g., page views and length of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offer and user friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and deletion: Deletion in accordance with the information provided in the "General Information on Data Storage and Deletion" section.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

• Provision of the online offer on rented storage space: For the provision of our online offer, we use rented storage space as well as the associated computing capacity and software from specialized hosting providers (see the section "Third-Party Providers Used (Vercel, GitHub)"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files." Server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the event of malicious attacks, so-called DDoS attacks), and also to ensure the server's utilization and stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.

The Vale! App

Vale! is an app for iPhone, iPad and Mac that shows, live and in large type, what is said in the room, for anyone who is losing their hearing or finds a conversation hard to follow. It has no user accounts, no analytics, no advertising and no tracking. Apart from the feedback described below, the app sends nothing to us or to third parties.

Microphone and speech recognition: The app uses the microphone only after you allow it and only while it is listening (between Start and Stop). What the microphone hears is turned into text on your device by the speech recognition built into iOS, iPadOS and macOS. The audio is not recorded, not saved and not sent to us or to third parties.

The text: The text exists only in your device's memory while the app is open. It is never written to storage, and it is gone when you clear it, quit the app or restart the device. It leaves your device only if you share it yourself through the system's share sheet; the app or person you share it with then decides what happens to it.

Settings on the device: The app keeps your settings (text size, caption theme, appearance, the language it listens for, whether the welcome was shown) and your agreement to the terms of use (its version, the time and the app build) on your device. They are not sent to us, and they are deleted when you delete the app.

Apple's speech model: The first time you use a language, the operating system may download that language's speech model from Apple. The system makes this download, not the app; Apple receives your device's IP address and the request, as described in Apple's privacy policy. Neither the audio nor the text is sent in the process. After that, the speech recognition works without an internet connection.

Feedback: Settings ▸ Send Feedback is the only request the app itself makes; see "Contact and Inquiry Management" below.

• Types of data processed: Content data (the text you share or send as feedback). Meta, communication, and procedural data (the IP address in Apple's download).
• Data subjects: Users.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; provision of our online offer and user friendliness.
• Retention and deletion: The text only while the app is open; settings until you delete the app.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Please respect the people around you: let them know that what they say is shown as text, and do not share their words without their agreement.

Contact and Inquiry Management

When contacting us (e.g., by email, telephone, or through the feedback form on our website), as well as in the context of existing user and business relationships, the information provided by the inquiring parties is processed to the extent necessary to respond to the inquiries and any requested measures.

• Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as related information such as authorship or time of creation). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., through the feedback form on our website). Provision of our online offer and user friendliness.
• Retention and deletion: Deletion in accordance with the information provided in the "General Information on Data Storage and Deletion" section.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further information on processing activities, procedures, and services:

• Contact by email: When you contact us by email or other means, we process the personal data transmitted to us in order to respond to and process the respective inquiry. This generally includes information such as name, contact information, and, where applicable, further information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
• Feedback in the app and on the website: You can report a bug or suggest a feature on our website's support page and in the app (Settings ▸ Send Feedback). The report contains only the type, title and text you enter, with the app version and platform; it reaches us as described under "Third-Party Providers Used (Vercel, GitHub)". Do not put personal data in the report that you do not want us to read; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Third-Party Providers Used (Vercel, GitHub)

For the operation and provision of our application, we use the following third-party providers as processors:

• Vercel: With Vercel Inc., based in the USA, we operate a serverless function that receives feedback from the app and from our website and forwards it to GitHub Issues for internal follow-up. Vercel receives the content of the report (type, title, text, app version and platform) and your IP address; the app sends no email address, device identifier or other data about you. The function uses the IP address to limit too many reports in a short time and holds it only in memory for that purpose. Vercel is certified under the Data Privacy Framework (see the "International Data Transfers" section). Further information on data protection at Vercel can be found at: https://vercel.com/legal/privacy-policy; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
• GitHub: GitHub, Inc., based in the USA, stores feedback as an issue in a private repository that only we can access. It receives the type, title and text of the report, together with the app version and platform. GitHub also hosts our website and these legal documents (GitHub Pages); when you visit them, GitHub processes your IP address and the access data described under "Provision of the Online Offer and Hosting". GitHub is certified under the Data Privacy Framework (see the "International Data Transfers" section). Further information on data protection at GitHub can be found at: https://docs.github.com/site-policy/privacy-policies/github-general-privacy-statement; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Changes and Updates

We ask that you regularly inform yourself of the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your participation (e.g., consent) or other individual notification.

Where we provide addresses and contact information for companies and organizations in this privacy policy, please note that such addresses may change over time, and we ask that you verify the information before making contact.

Glossary of Terms

This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their statutory definitions apply. The following explanations are intended primarily to aid understanding.

• Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content published across various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.
• Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include information on file size, creation date, document author, and revision history. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, social network messages, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify processes.
• Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which features they prefer, how long they spend on certain pages, and which paths they take through an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Log data: Log data is information about events or activities logged within a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system issues, monitor security, or generate performance reports.
• Controller: The "controller" refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether collecting, evaluating, storing, transmitting, or deleting it.

Created with the free privacy policy generator from Dr. Thomas Schwenke, Datenschutz-Generator.de