last updated: 15 Dec, 25

Privacy Policy

1. Introduction

This Privacy Policy explains how Surelity (“the App”), operated by Oksana Omelchenko, Sole Proprietor in Kyiv, Ukraine, collects, uses, stores, and shares personal data when you use our mobile application and related services.

By using Surelity, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with the practices described herein, please do not use the App.

You may contact us at [email protected] with any questions about data protection.

2. Data We Collect

We may collect the following categories of data when you use Surelity:

2.1. User-Provided Data

  • Text input (notes, signs, descriptions)

  • Voice recordings used for speech recognition

  • Images you upload (if applicable)

  • Date of birth (optional, for personalization)

  • Email (if login uses email)

2.2. Automatically Collected Data

  • Device information (model, OS version, limited device identifiers)

  • Approximate location (country-level, for pricing and analytics purposes)

  • App usage data (screens visited, interaction patterns)

2.3. Payment Information

All payment and subscription data is processed by:

  • Apple App Store

  • Google Play

  • RevenueCat

Surelity does not store or have direct access to your credit card or full payment details.

2.4. AI Processing Data (Required by Apple 5.1.2(i))

To generate AI-based interpretations and images, the App may transmit the following user-submitted data to OpenAI via secure API calls:

  • Text you enter

  • Transcribed voice input

  • Limited technical metadata required for processing (such as language settings)

    This data is primarily used to generate the requested output and may be temporarily processed or retained by OpenAI for safety, monitoring, abuse prevention, or compliance purposes in accordance with OpenAI’s policies.

    1. User Consent for AI Processing

    Before any user-submitted content is transmitted to OpenAI for AI processing, the App provides a clear disclosure explaining:

    What data will be transmitted

    That the data will be sent to OpenAI

    The purpose of such transmission

    Users must actively provide consent before AI-based features are used.

    If consent is not granted, AI-driven functionality will not operate.

This data is used primarily to generate the requested output and may be temporarily processed or retained by OpenAI for safety, monitoring, or compliance purposes in accordance with its policies.

4. How We Use Your Data

We use your data to:

  • Generate AI interpretations, insights, and metaphorical images

  • Provide optional personalization (e.g., based on date of birth or past entries)

  • Maintain your signs/journal history

  • Process purchases and subscriptions

  • Improve the App and enhance user experience

  • Ensure security, detect misuse, and prevent fraud

We do not intentionally use personal data to train proprietary models.
We do not sell or rent personal data for marketing purposes.

5. AI Disclosure (OpenAI)

Surelity uses OpenAI’s GPT, DALL·E, and Whisper models to generate responses and visuals.

When you submit text or voice:

  • The content is securely transmitted to OpenAI

  • OpenAI processes the data to generate a response

  • The response is returned to the App

The generated response is returned to the App. OpenAI may temporarily process or retain submitted content for safety monitoring and compliance purposes according to its policies.

OpenAI Privacy Policy: https://openai.com/privacy

You may withdraw consent at any time by deleting your account or uninstalling the App.

6. Third-Party Services

Surelity uses several trusted third-party providers:

6.1. OpenAI

AI text, speech, and image generation
https://openai.com/privacy

6.2. Firebase (Google)

6.3. RevenueCat

Subscription and purchase management
https://www.revenuecat.com/privacy/

6.4. App Store / Google Play

Billing, subscription renewals, refunds

Each provider processes your data according to its privacy policy and applicable laws.

7. iOS Permissions Disclosure

To comply with Apple’s app privacy rules, we disclose the following:

7.1. Microphone Access (Optional)

Used only to capture your voice when you choose to submit audio interpretations.

7.2. Speech Recognition Access

Used to convert your voice input into text.
Processed either locally or via Whisper API (OpenAI).

7.3. Photo Library (If applicable)

Used only when you upload an image for interpretation.

7.4. Push Notifications (Optional)

Used for reminders and app updates.
You may disable notifications at any time.

No data from these permissions is used for tracking or marketing.

8. Legal Basis for Processing (GDPR)

If you are located in the EU/EEA, we rely on:

  • Consent — for AI processing, voice input, and optional personalization

  • Contract performance — to provide access to the App

  • Legitimate interest — to improve services and security

You may withdraw your consent at any time.

9. Data Storage & Retention

Your data is stored securely in Firebase (Google Cloud).
We retain data only as long as needed to provide the service.

You may request deletion of your data at any time by contacting [email protected].

10. Children’s Privacy

Surelity is intended for users 18 years and older.
We do not knowingly collect data from individuals under the age of 18 and take reasonable steps to delete such data if discovered.
If we learn that data was collected from a minor, it will be deleted promptly.

11. Data Sharing & Security

We share data only with the third-party services listed above.
We implement reasonable and industry-standard technical and organizational security measures; however, no system can be guaranteed to be fully secure:

  • Encryption in transit (HTTPS/TLS)

  • Controlled access to Firestore

  • No third-party marketing SDKs

  • No tracking for advertising

12. Your Rights

You have the right to:

  • Access your data

  • Request deletion

  • Request correction

  • Withdraw consent

  • Export your data (if supported)

Contact [email protected] to exercise your rights.

13. International Transfers

Data may be processed outside your country due to our use of OpenAI, Firebase, and RevenueCat.
We rely on GDPR-compatible mechanisms such as Standard Contractual Clauses.

14. Updates to This Policy

We may update this Privacy Policy periodically.
Changes become effective when posted at https://surelity.com/privacy.

15. Contact

Legal Owner: Oksana Omelchenko, Sole Proprietor
Email: [email protected]
Location: Khreschatyk St, 22, PO Box 189, Kyiv, 01001, Ukraine

Nothing in this Privacy Policy is intended to limit any statutory rights available to data subjects under applicable data protection laws.