Privacy Policy

Privacy Policy for Alessja Spark

Last updated: May 2026

1. Controller

Sebastian J. Rau
c/o flexdienst – #20753
Kurt-Schumacher-Straße 76
67663 Kaiserslautern
Germany
Email: sebastian-rau1@web.de

2. Overview

Alessja Spark is a motivation and chat app. This Privacy Policy informs you about what data is collected and how it is processed.

3. What Data Is Processed?

3.1 Locally Stored Data (on your device only)

The following data is stored exclusively on your device (AsyncStorage):

  • Chat history and conversations
  • Favorited motivational quotes
  • App settings (language, theme)
  • Timer settings

This data is nottransmitted to the Provider's servers. You can remove this data at any time by uninstalling the app or clearing app data.

Note on streak and reward data: Daily-streak counters and trial-reward markers are stored primarily on-device. Additionally, they are synchronized to RevenueCat as anonymous subscriber attributes (see §3.3), so you can restore your streak after a reinstall or on a second device. Identification of you as a person from this data is excluded because RevenueCat only processes an anonymous app-instance ID.

Legal basis: Art. 6(1)(b) GDPR (contract performance)

3.2 Chat Messages and File Contents (AI Processing)

The AI language model runs exclusively on your local device. Your conversations never leave your device — unless you choose to export or share them yourself.

  • Processing: Entirely local (on-device inference)
  • No server, no cloud, no AI API
  • Data transmitted: None — chat messages, uploaded file contents, and AI responses are not transmitted to external servers
  • Third-country transfer: None — no data transfer to third countries

User-initiated export: The App provides export functions for notes, todos, and conversations. Once you export, share, or forward content, that data leaves the protected environment of the App. From that point on, all responsibility for the handling of exported data — including privacy, confidentiality, and onward distribution — lies solely with the user. The Provider assumes no liability for exported content.

Legal basis: Art. 6(1)(b) GDPR (contract performance)

3.3 Purchase Data

For in-app purchases, data is processed by the following services:

Google Play Store

  • Provider: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland
  • Data processed: Payment information, purchase history, subscription status
  • Privacy Policy: https://policies.google.com/privacy

RevenueCat

  • Provider: RevenueCat, Inc., USA
  • Data processed: Anonymous app-instance ID (no link to email, Google account, or push token), purchase tokens, subscription status, subscriber attributes (streak- and reward-cycle data including active trial status for cross-device restoration)
  • Third-country transfer: USA (EU-US Data Privacy Framework)
  • Privacy Policy: https://www.revenuecat.com/privacy

Legal basis: Art. 6(1)(b) GDPR (contract performance)

3.4 Local Notifications

Local device notifications are used for daily motivation alarms and the Pomodoro timer:

  • Service: Notifee (local notification library)
  • Data processed: None — notifications are scheduled and displayed entirely on your device
  • No push server: No push tokens are transmitted to external servers
  • Third-country transfer: None

Notifications are only activated with your explicit consent.

Legal basis: Art. 6(1)(a) GDPR (consent)

4. No User Accounts

The App does not require registration and does not create user accounts. No email addresses, usernames, or passwords are collected.

5. No Tracking or Analytics

The App does not use any tracking, analytics, or advertising services. No cookies are set.

6. Data Security

Data transmission to external services is encrypted via HTTPS/TLS. Locally stored data is subject to the security mechanisms of the Android operating system.

7. Data Retention

  • Local data: Until the app is uninstalled or app data is cleared
  • AI data: No external storage — all AI processing is local
  • Purchase data: According to the retention policies of Google Play and RevenueCat

8. Your Rights (GDPR Art. 15–22)

You have the right to:

  • Access (Art. 15 GDPR) your stored data
  • Rectification (Art. 16 GDPR) of incorrect data
  • Erasure (Art. 17 GDPR) of your data
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Object (Art. 21 GDPR) to processing
  • Withdraw your consent at any time with future effect

Since your data is stored exclusively on your device, you can view and delete it at any time (clear app data or uninstall). Notes and todos can be exported as text.

9. Right to Complain

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for you depends on your place of residence.

10. No Automated Decision-Making

No automated decision-making or profiling within the meaning of Art. 22 GDPR takes place. AI responses serve exclusively for entertainment and motivation.

11. Minors

The App is not intended for persons under 12 years of age. Use by minors is under the supervision of their legal guardians.

12. Changes

We reserve the right to update this Privacy Policy. The current version is always available in the App and at https://alessja.app/.