Privacy Policy

The controller responsible for processing within the meaning of the General Data Protection Regulation (GDPR) is FDM Software GmbH, Adelheid-Popp-Gasse 8/2/57, 1220 Vienna, Austria, FN 678054 p, Commercial Court of Vienna (Handelsgericht Wien).

For all questions about data protection and to exercise your rights, you can reach us at office@fdm-software.at.

We have not appointed a data protection officer because we are not legally required to do so.

Account. You sign in with your Google or Apple account. From Google, we receive your Google identifier, your email address, your name, and the address (URL) of your profile picture. From Apple, we receive your Apple identifier, the email address you share with Relate, your name on your first sign-in, and a token we use to revoke the link when you delete your account. In addition, we store the status of your account, your plan, when your account was created and activated, the start of your trial period, when you gave your AI consent, and your device's time zone. We never receive your password.

Your content. Everything you record or confirm in Relate:

• Contacts with name, photo, category, priority, tags, phone numbers, email addresses, messenger and social media details, and addresses
• Facts about your contacts and their relationships with one another, events such as birthdays and appointments, and reminders
• Notes that you type, dictate, share, or send via a bot, together with the text created from them
• AI suggestions regarding your notes and your decision on them
• Chat histories with the AI about individual contacts, and message drafts
• A change log of your data and the notifications that Relate shows you

Voice recordings. When you record a voice note, the recording is transmitted to our server and converted into text there. We store only the text, not the recording. If you use your device's dictation feature instead, speech recognition is performed by your operating system (Apple or Google) under their terms.

Address book. Relate accesses your address book only if you allow it. When importing, we transfer only the contacts you select. Profile picture matching is optional and can be turned off: the matching takes place on your device, and only new or changed photos of contacts that already exist in Relate are uploaded. The rest of your address book does not leave your device.

WhatsApp and Telegram bot. If you link Relate with one of the bots, we store your WhatsApp phone number or your Telegram chat ID, respectively, the linking code, and the state of the ongoing conversation. We process what you send to the bot (text, voice messages, images such as chat screenshots) like a note. To avoid processing messages twice, we retain the identifiers of incoming messages for a short time.

Notifications. For push notifications, we store your device's push token, its platform, and your notification settings. The text of a notification may contain names of your contacts, for example in the daily overview.

Subscription. If you subscribe to a plan, we receive your plan, the purchased product, and the expiration date from the subscription service. The payment itself is processed by Apple or Google. We do not receive payment data such as card numbers.

Referrals. If you invite someone with your link or accept an invite, we store your invite code, which accounts are connected, whether the invited person subscribed (term, time of the first payment, purchase identifier), and the free time that results from it. The person who invites only sees numbers, no names and no purchase details. The app only reads your clipboard when you tap “Paste”.

AI usage. For each AI request, we store the type of request, the model, the amount of processed text units (tokens), and the cost. This log does not contain any content. We need it to calculate your quota.

Technical data. When you access our server, connection data such as your IP address, the time, and the requested address are generated. Our server logs contain technical metrics and error messages.

On your device. The app stores your sign-in token in your device's protected storage (valid for 90 days) and the status of profile picture matching. The web interface sets a sign-in cookie and a cookie containing your time zone (valid for one year) and remembers your accent color in the browser. This storage is necessary for operation.

We do not use any analytics, tracking, or advertising services.

• Providing Relate and its features, such as reminders, bots, subscription management, and referrals: performance of the contract with you (Art. 6(1)(b) GDPR)
• Disclosure of content to external AI providers (analysis of notes, chat, message drafts, speech to text, screenshots): your consent, which you can withdraw at any time in the settings (Art. 6(1)(a) GDPR)
• Access to your address book and microphone, push notifications, and linking with a bot: your consent, which you can withdraw at any time in the settings of the app or your device (Art. 6(1)(a) GDPR)
• Security, troubleshooting, backups, cost control, and protection against misuse of the trial period and of referrals: our legitimate interest in secure and economically viable operation (Art. 6(1)(f) GDPR)
• Compliance with legal obligations, such as tax-related retention obligations (Art. 6(1)(c) GDPR)

In Relate, you record information about people around you. You use Relate for this exclusively for personal or household purposes. We process this data on your behalf in order to provide you with Relate's features, and we do not use it for our own purposes.

Please record only what you would otherwise note down about these people, and handle sensitive information with care, for example regarding health, religion, or political views. You are responsible for the content you record.

Relate uses AI models from external providers to analyze notes, answer questions about your contacts, write message drafts, convert voice recordings into text, and read chat screenshots.

For this purpose, we transmit to the respective provider what the task requires: the text of your note or question, the names of your contacts as a recognition aid, the knowledge stored about the contact concerned, your name, and, for voice notes, the recording and, for screenshots, the image.

This happens only with your consent. Relate asks for your consent before any content is sent to an AI provider for the first time; we store when you gave it. You can withdraw your consent at any time in the settings of the app or the web interface. The withdrawal takes effect for the future: after that, we no longer pass on any content. Because AI analysis is at the core of Relate, the app cannot be used without consent; after a withdrawal, it remains locked until you consent again. Your data is retained, and you can delete your account at any time.

Notes initially result only in suggestions. They become part of your knowledge about a contact only once you confirm them. The AI can make mistakes. No automated decision-making with legal effect within the meaning of Art. 22 GDPR takes place.

We ourselves do not train any AI models with your data. According to their terms for the paid use of their interfaces, the providers do not do so either:

• Anthropic does not use content transmitted via the API to train its models and generally deletes it within 30 days. It is retained longer only if a violation of the usage policies is being investigated or if required by law.
• Google does not use content transmitted via the paid Gemini API to improve its products and stores it only for a limited period in order to detect abuse.

We do not pass on your data to third parties for their own advertising purposes. We use the following service providers for operation:

• Railway Corporation (USA): hosting of the server, the databases, and the backups. Server location: US West (USA)
• Anthropic PBC (USA): AI model Claude for analyzing notes, the chat, and message drafts
• Apple (Apple Distribution International Ltd., Ireland / Apple Inc., USA): sign-in with your Apple account
• Google (Google Ireland Limited / Google LLC, USA): sign-in with your Google account, as well as the AI model Gemini for converting speech into text and reading screenshots
• Meta Platforms Ireland Limited: WhatsApp Business Platform, if you link the WhatsApp bot
• Telegram: bot interface, if you link the Telegram bot
• Expo (650 Industries, Inc., USA) as well as Apple and Google: delivery of push notifications
• RevenueCat, Inc. (USA): subscription management. Your internal account identifier is transmitted, not your name or email address
• Apple and Google as operators of the app stores: processing of purchases and payments under their own responsibility

We have concluded data processing agreements pursuant to Art. 28 GDPR with the service providers that process data on our behalf (Railway, Anthropic, Google for Gemini, RevenueCat, Expo, and Meta for the WhatsApp Business Platform). Apple and Google, as providers of the sign-in services and the app stores, act under their own responsibility.

Some of the service providers listed are based in the USA or process data there. The transfer is based on the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework, insofar as the provider is certified, and otherwise on the European Commission's Standard Contractual Clauses.

Relate's servers, databases, and backups are hosted by Railway in the USA (US West (USA)); the basis there is the European Commission's Standard Contractual Clauses or the EU-U.S. Data Privacy Framework, insofar as Railway is certified. On request at office@fdm-software.at, we will tell you which basis applies to which other provider and provide you with a copy of the respective safeguards.

We store your data for as long as your account exists. You can change or delete individual content in the app at any time.

If you delete your account in the settings, we immediately remove your database with all its content, your contact photos, your account record, your device tokens, and your bot links.

In backups, the data remains for no more than 14 days. We delete older backups automatically.

After deletion, we retain for 24 months an irreversible check value (hash) of your Google or Apple sign-in identifier and of your email address, as well as the start date of your trial period. We no longer store your email address itself. This allows us to recognize when the same person signs up again and to prevent the free trial from being used more than once. After that, we delete the check values automatically. Your AI usage is retained as an aggregate total for our cost accounting and can then no longer be attributed to anyone.

Referrals: your invite code and any free time you have not redeemed expire with your account. In other people's invites, your account is then replaced by a pseudonym, which disappears together with the other check values.

Data that we are required to retain for legal reasons, for example relating to billing, is deleted once the respective retention period has expired.

Under the GDPR, you have the following rights:

• Access to the data we process about you (Art. 15)
• Rectification of inaccurate data (Art. 16)
• Erasure (Art. 17) and restriction of processing (Art. 18)
• Data portability (Art. 20). You can find a complete export of your data as a JSON file in the settings under “Your data”
• Objection to processing based on our legitimate interest (Art. 21)
• Withdrawal of consent with effect for the future (Art. 7(3))

To exercise these rights, write to us at office@fdm-software.at.

You can also lodge a complaint with a supervisory authority. In Austria, this is the Austrian Data Protection Authority (Österreichische Datenschutzbehörde), Barichgasse 40-42, 1030 Vienna, www.dsb.gv.at.

The connection between the app and the server is encrypted. The content of each account is stored in its own database, separate from other accounts. Access to the servers is limited to persons who need it for operation.

Relate is intended for persons aged 14 and older. Younger persons may not use Relate.

If Relate or the legal situation changes, we will update this policy. We will inform you about material changes in the app. You can always find the current version here.