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Privacy Notice (GDPR)

herapy — Voice & Text Wellness Support For Users in the European Economic Area and United Kingdom

Effective date: June 02, 2025 Last updated: June 02, 2025


1. Introduction

ICI Tech Teknoloji A.Ş. processes your personal data in compliance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and, where applicable, the UK GDPR.

Data Controller ICI Tech Teknoloji A.Ş.
Website https://herapy.app/
Email app@icitech.com.tr
Country of establishment Republic of Turkey

EU Representative (Article 27 GDPR): As a company established outside the EEA offering services to EEA residents, we are in the process of designating an EU representative per Article 27 GDPR. Updated contact details will be published at https://herapy.app/privacy once appointed. In the meantime, contact app@icitech.com.tr.

Data Protection Officer: We do not currently meet the threshold for mandatory DPO appointment under Article 37 GDPR. All data protection enquiries: app@icitech.com.tr.

Important Disclaimer: herapy is not a therapy service, clinical diagnosis tool, medical device, or licensed mental health treatment. It is a personal support companion for everyday stress, anxiety, and overwhelm. Consult a qualified healthcare professional for clinical-level support.

herapy is free. We do not collect payment information.


2. Special Category Data — Mental Health and Emotional Data

Under GDPR Article 9, the following data processed by herapy may constitute data concerning health, specifically mental health and psychological wellbeing:

Data Category Why It May Qualify
Daily mood selections Relates to emotional and psychological state
Emotional self-reports and check-in entries Contains mental health context
Text session content May contain sensitive personal disclosures about mental wellbeing
Recurring emotional themes Derived analysis of psychological patterns

We process all special category data only on the basis of your explicit consent under GDPR Article 9(2)(a). You provide this consent when you:

  • Complete your first mood check-in
  • Start your first text coaching session
  • Enable memory/personalization features

You may withdraw consent at any time through Settings → Privacy → Manage Consents without penalty. Withdrawal will restrict access to features that depend on this data.

Voice content is never stored or transmitted and is therefore not subject to data protection law on our end — it never reaches us.


3. Data We Process

3.1 Account Information (Optional)

Email address, password (hashed), optional display name and profile photo. Account creation is not required — herapy can be used as a guest.

3.2 Mood and Emotional Check-in Data (Special Category)

Daily mood selections, emotional self-reports, check-in history, recurring emotional themes.

3.3 Voice Session Data

Session timestamps and duration only. Voice audio is processed on-device and never transmitted. No audio content, transcript, or spoken word reaches our servers.

3.4 Text Session Content (Special Category)

Text you type during coaching sessions, session timestamps.

3.5 Memory and Personalization Data

Personal context and preferences you save in the app's memory controls.

3.6 Weekly Insights and Analytics

Mood trend summaries, session consistency scores, progress highlights.

3.7 Device and Technical Data

Device type, OS version, app version, IP address (truncated), time zone, crash logs.

3.8 Push Notification Data

Device push token and notification interaction events (if permission granted).

3.9 Communications Data

Email and message content from support contacts.


4. Legal Bases for Processing (GDPR)

Purpose GDPR Legal Basis
Account creation and management (optional) Art. 6(1)(b) — Performance of contract
Daily mood check-ins and emotional data Art. 9(2)(a) — Explicit consent (special category)
Text session content Art. 9(2)(a) — Explicit consent (special category)
Voice session timing metadata Art. 6(1)(b) — Performance of contract
Memory and personalization Art. 6(1)(b) / Art. 6(1)(a) — Contract / Consent
Weekly insights and analytics Art. 6(1)(b) — Performance of contract
App quality and crash analysis Art. 6(1)(f) — Legitimate interests
Security monitoring Art. 6(1)(f) — Legitimate interests
Support requests Art. 6(1)(b) — Performance of contract
Legal obligations Art. 6(1)(c) — Legal obligation
Marketing communications Art. 6(1)(a) — Consent

Legitimate interests: Where we rely on Art. 6(1)(f), we have balanced our interests against your rights. You may object — see Section 8.


5. Voice Data — GDPR Clarification

Voice audio is processed entirely on your device and is never transmitted to our servers. As such:

  • We do not hold your voice recordings
  • You cannot submit an access request for audio we do not hold
  • Voice data does not form part of our data processing under GDPR
  • We receive only session start/end timestamps — no audio content whatsoever

This is a foundational privacy design decision, not a policy choice.


6. What We Do Not Do

  • We do not sell personal data.
  • We do not transmit voice recordings.
  • We do not share mood data, emotional check-ins, or text session content with Meta, TikTok, Google Ads, or any advertising network.
  • We do not use emotional or mental health data for ad targeting or profiling.
  • We do not use voice or text content to train any model.
  • We do not use advertising identifiers (IDFA / GAID).
  • We do not collect payment information.
  • We do not make automated decisions with significant effects based on your emotional data (Art. 22 GDPR).

7. Your Rights Under GDPR

Right Article Description
Right of access Art. 15 Obtain a copy of your personal data
Right to rectification Art. 16 Correct inaccurate data
Right to erasure Art. 17 Request deletion
Right to restriction Art. 18 Limit processing
Right to data portability Art. 20 Receive data in machine-readable format
Right to object Art. 21 Object to legitimate interest processing or marketing
Right to withdraw consent Art. 7(3) Withdraw mood/text consent or marketing consent at any time
Right not to be subject to automated decisions Art. 22 Not profiled by fully automated means with significant effects
Right to lodge a complaint Art. 77 Contact your national supervisory authority

How to exercise

Email app@icitech.com.tr — subject "GDPR Data Subject Request — herapy". We respond within one month, free of charge.

In-app controls

Action Where
Delete account Settings → Account → Delete Account
Withdraw mood/text consent Settings → Privacy → Manage Consents
Clear memory data Settings → Memory → Clear All
Export your data Settings → Privacy → Export My Data (where available)
Revoke marketing consent Settings → Privacy → Marketing Preferences
Revoke microphone permission Device Settings → Microphone → herapy

8. Right to Lodge a Complaint

Country Authority Website
🇫🇷 France CNIL https://www.cnil.fr
🇩🇪 Germany BfDI + state DPAs https://www.bfdi.bund.de
🇪🇸 Spain AEPD https://www.aepd.es
🇬🇧 United Kingdom ICO https://ico.org.uk
🇧🇪 Belgium APD/GBA https://www.dataprotectionauthority.be
🇳🇱 Netherlands AP https://autoriteitpersoonsgegevens.nl
Other EEA Your national DPA https://edpb.europa.eu/about-edpb/about-edpb/members_en

We encourage you to contact us first — most concerns are resolved quickly.


9. International Data Transfers

ICI Tech Teknoloji A.Ş. is established in Turkey. The European Commission has not issued an adequacy decision for Turkey under GDPR Article 45.

For all transfers from the EEA or UK, we rely on:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • UK IDTAs for UK transfers
  • GDPR Article 49 derogations where applicable

Voice data is never transferred internationally — it never leaves your device.

Request a copy of applicable transfer mechanisms: app@icitech.com.tr.


10. Data Retention

Data Category Retention Period
Account data (if created) Duration + 3 years after deletion
Mood and emotional check-in data Duration + 1 year; deleted within 30 days of consent withdrawal
Text session content Duration + 1 year; deleted within 30 days of consent withdrawal
Voice audio Never stored
Voice session timing metadata Duration + 1 year
Memory and personalization data Until cleared in-app or account deleted
Support communications 3 years
Crash logs 12 months
Security logs 12 months

11. Security

  • TLS 1.2+ in transit; encryption at rest
  • Mood and emotional data stored with elevated access controls
  • Voice audio never stored — no server-side audio risk
  • Breach notification: Within 72 hours to supervisory authority (Art. 33); users notified without undue delay for high-risk breaches (Art. 34)

12. Automated Decision-Making

We do not make automated decisions with legal or similarly significant effects based on your mood data, emotional entries, or text sessions (Art. 22 GDPR). Insights and trends are generated from your own data and displayed to you for personal reflection only.


13. Children's Privacy

herapy is for users 18 and older. Contact app@icitech.com.tr for immediate deletion if a child has submitted data.


14. Cookies

Our website uses cookies with a consent banner on first visit.

Type Legal Basis Opt-Out
Strictly necessary Art. 6(1)(f) Not possible
Analytics Art. 6(1)(a) — Consent Via banner
Marketing Art. 6(1)(a) — Consent Via banner

We do not use cookies to infer emotional state or mental health status.


15. Changes

Material changes notified 14 days in advance. Current version: https://herapy.app/privacy/gdpr.


16. Contact Us

Email app@icitech.com.tr
Subject "GDPR Data Subject Request — herapy"
Website https://herapy.app/

Acknowledge within 5 business days, resolve within one month.

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