Privacy Policy

1. Controller

WhispaWave UG (haftungsbeschränkt)
Amsterdamer Weg 7, 44269 Dortmund, Germany
Represented by the managing directors: Michail Koutchiach, Nils Löchterfeld
Register court: Amtsgericht Dortmund (Local Court of Dortmund), HRB 38625
VAT ID: DE464295825
Email: support@whispawave.de
Data protection requests: privacy@whispawave.de

2. Overview of processing operations

Categories of data processed: account data (email address as the only mandatory field; name, profile picture, professional field, job title, company and a short description of your company voluntary; language of your app) · content data (dictation texts, conversation transcripts, meeting notes and documents from conversations, your own templates for meeting notes and what you give the template assistant, blank forms you set up as a template, templates published in the community and reports about them, text of documents you attach to a conversation, questions and answers in the meeting chat, search terms of the web search in the Meetings chat, preparations before appointments and appointment proposals from your conversations, entries in your memory — details about you and your work —, notes, dictionary, snippets, style samples, support requests) · contract and payment data (plan, subscription status, invoice data — we never see your card details) · usage data (word count, dictation duration, conversation hours and number of notes per month, use of templates, AI allowance usage, the 7-day challenge's daily figures — without content) · feedback ratings (thumbs up/down on chat answers and meeting notes, without content — section 11) · metadata and log data (consent records, security events, random installation ID) · calendar details (locally; with the switch turned on, as context, for questions in the chat also your events of the next seven days; the title and participants of a linked event as part of the conversation; with a direct Google connection, the events of a short period, the email address of your Google account and the access keys; events you create through the app — sections 11 and 23) · audio data (only in the cases described in sections 10, 11 and 20 — never permanently on our servers) · website form data (contact requests, job applications, cancellation notices, newsletter sign-ups — section 22) · ad measurement data of the website (pseudonymous cookie IDs, pages visited and events such as a newsletter sign-up, only after your consent in the cookie banner — section 22) · audience measurement data of the website (page visited, referring page, browser and device type, approximate location — without cookies and without a persistent identifier, section 22). Content data may contain health data and other special categories of personal data when you or others say them or you type them; section 26 applies in addition.

Additionally in the iPhone app (section 25): audio data of your dictations and conversation recordings (on the iPhone, speech recognition runs in the EU cloud) · text you select or copy and have edited with “Compose” or “Rewrite” · only with “Context from the text field” turned on: up to 500 characters before the cursor in the text field you dictate into · details of your installation (device model, operating system and app version) · record of your consent to AI processing · purchase data from the App Store (transaction and product IDs, subscription status and term) · your answers to the setup questions and, voluntarily, your answer on how you heard about WhispaWave · only with your consent to “Learn words from corrections”: words you correct with the WhispaWave keyboard after a dictation, with a little surrounding text · events from your iPhone calendar if you connect it (title, time span and participants; with “Include events” turned on, as context for notes and chat) · words the WhispaWave keyboard learns from you on the iPhone. In all our apps, technical connection data from the security check at sign-in is added (section 9).

Data subjects: users · team members · people invited to a team (even without an account of their own) · conversation participants in Conversation mode (third parties) · people who contact us · job applicants · website visitors.

Purposes: provision of the dictation and AI functions (including meeting notes, meeting chat with web search, preparation before appointments and memory) · account and contract management · billing · enforcement of allowances · abuse and fraud prevention · IT security and error analysis · communication · recruitment procedures · newsletter only with consent or within the limits permitted by law · measuring the success of our ads on Meta (Facebook, Instagram) only with consent (section 22) · cookieless audience measurement of the website (section 22).

3. Legal bases

We process personal data on the basis of: performance of a contract (Art. 6(1)(b) of Regulation (EU) 2016/679 (GDPR) — core functions, account, payment, allowances), consent (Art. 6(1)(a) — e.g. context awareness, newsletter, original audio in support, crash reports), legitimate interests (Art. 6(1)(f) — abuse and fraud prevention, IT security) and legal obligation (Art. 6(1)(c) — in particular retention under commercial and tax law and the confirmation duties for online cancellation). In addition, the German Federal Data Protection Act (BDSG) applies, and for users in Switzerland the Swiss Federal Act on Data Protection (DSG).

Overview: legal basis per processing operation (details in the section named in each case):

4. Security measures

We take technical and organizational measures appropriate to the risk. These include in particular:

• consistent transport encryption (TLS) for all connections;
• access control at database row level: each account can technically read only its own data;
• AI connection exclusively via our own servers — the app contains no access keys to AI services;
• local storage of your conversation data on your device, encrypted as a rule (section 23);
• storage of sign-in information in the macOS Keychain; optional two-factor authentication; heightened sign-in requirements for security-critical changes; mandatory confirmation at the oldand the new address when the email address is changed;
• security logs of your account: in our own security log we store IP addresses only pseudonymized with a key that changes daily. Our sign-in service, by contrast, logs sign-ins and changes to your account with your IP address in plain text to detect attacks on your account (Art. 6(1)(f) GDPR); we delete these entries after 90 days, and entries about security-critical changes (password, e-mail address, two-factor methods, emergency codes, passkeys, linked sign-ins with Apple, Google or Microsoft, account deletion) after one year. To defend against attacks, our AI server logs every request with its IP address, but without content and without sign-in data, and deletes this log after 7 days; if rejected requests without a valid sign-in accumulate from one address, it automatically blocks that address for 10 minutes. Against mass requests, the AI server (in memory only) and our sign-in service count requests per IP address at individual points; the sign-in service generally keeps these counters for at most one day;
• tamper-evident, append-only logging of consents and withdrawals;
• Default settings: new accounts start with context awareness turned off, the calendar context of Conversation mode turned off and without newsletter consent. By default, dictations are deleted automatically; when you set up WhispaWave in the Mac app, it asks whether it should keep your history (“Save history (recommended)”) or whether you use Private Mode (section 10). Automatic dictionary learning is turned on for accounts created since 27 August 2026 (section 13). Since version 1.0.8, the Mac app stores conversations in your account by default (section 11). The web search in the Meetings chat, the preparation before appointments, the appointment proposals from summaries and the suggestions from conversations for your memory are switched on by default; you can switch off each of them (section 11).
• in the iPhone app: storage of sign-in information and identifiers in the iOS Keychain; locally stored conversations and chat histories encrypted as a rule (section 25); new conversations stay only on the iPhone by default (“Storage location for meetings”, section 25); “Context from the text field” is off until you turn it on, and “Learn words from corrections” runs only with your consent; the WhispaWave keyboard contains no network functions and sends nothing to the internet itself.

5. Recipients and processors

We use the following service providers.

We will inform you of changes to this list of service providers at least 30 days in advance on our list of subprocessors (subprocessors page) and will additionally inform you actively in the app or by email, before a new service provider processes content data; for the objection period of the data processing agreement (AVV), receipt of this notice is decisive (§ 8 no. 2 of the agreement). Only if we have to replace a service provider immediately for compelling security or availability reasons (for example after a security incident or a sudden outage), we will inform you without undue delay, at the latest within 10 days afterwards; your right to object remains unaffected (§ 8 no. 2 of the data processing agreement).

No AI training — with none of our AI providers, in no plan: We only use AI providers that do not use your content to train or improve AI models; this also applies to every AI service used in future and in all plans: also in the free Free plan and in the trial period. For the standard service (Mistral), the Zero Data Retention agreement confirmed in writing excludes storage and training (see below). IONOS (fallback service) and Scaleway (speech recognition for dictation, see the table) exclude training with your content and its permanent storage according to the published privacy terms of the respective provider; under these terms, Scaleway keeps individual requests for up to two weeks when it investigates errors or abuse. Linkup is not an AI provider but a search service; what applies to the search terms Linkup receives is set out in section 11 in the paragraph “Web search in the Meetings chat”.

What is transmitted to Mistral: depending on the function, your dictation text together with style settings, your dictionary terms and — only with your consent — context text (section 12); in the cloud cases (Intel Macs, Conversation mode) also the audio recording; in Conversation mode additionally the content of the meeting chat assistant described in section 11 (question, transcript, meeting note, chat history) together with context details; for a form without form fields, the form file for text recognition (section 11). Three things apply to processing at Mistral: (1) No training — Mistral does not use your content to train AI models. (2) No storage — Mistral does not store your inputs and outputs after processing (Zero Data Retention, active for our account; confirmed in writing on 20 August 2026). Processing runs via the provider's contractual EU regional endpoint. (3) Only to perform the function — Mistral processes your content exclusively to perform the respective function for you.

Additionally from the iPhone app (section 25): the audio recordings of your dictations (there is no on-device speech recognition on the iPhone); only with “Context from the text field” turned on, up to 500 characters before the cursor, scrubbed of recognizable access credentials, IBANs and card numbers (section 12); for “Compose” and “Rewrite” your spoken instruction, in the keyboard the selected or copied text, your first and last name from your profile (if entered) and, for a follow-up instruction, the previous instructions and drafts of the same operation; for the search index the content of the conversations stored in your account; only with your consent to “Learn words from corrections”, the recognized and the corrected word with up to 120 characters of surrounding text; only with “Include events” turned on, the title and time span of an event linked to the meeting and the names and companies of the other participants (section 25). Dictations in a language that Mistral does not recognize are recognized by Scaleway (see the table); if the standard service is temporarily unavailable, other requests from the iPhone app can also go to the EU fallback services named in the table.

Not used: analytics or tracking services in the app, advertising networks or user profiles on the website, US AI providers in standard operation. On the website, only the cookieless audience measurement with Plausible (without cookies, without a persistent identifier — section 22) and the ad measurement via the Meta Pixel, which runs only after your consent in the cookie banner (section 22), are active. Crash reports run exclusively via our own infrastructure (section 21).

6. International data transfers

Our infrastructure is oriented towards EU locations (Frankfurt, Falkenstein, Paris; update delivery: Slovenia). Important for context: In the dictation and conversation path, only EU services process your content (Supabase Frankfurt, Hetzner, Mistral, Scaleway and the EU fallback service IONOS); the only exceptions are support diagnostics that you yourself attach to a ticket — they may contain short dictation excerpts and run via our email service provider (section 20) —, events you create through the app in your Google Calendar; we transmit these to Google (section 11), and the search terms of the web search in the Meetings chat, which Linkup can also process outside the EU (below). To services with a US parent company (Stripe, Resend, Vercel, Supabase Inc.), account, payment, email and website form data normally flows; however, access from the USA (for example remote support access by the parent company to EU-hosted systems) cannot be entirely ruled out — this also concerns the transcripts stored at Supabase in Frankfurt (see the identical description in § 8 no. 4 of the data processing agreement (AVV)). For context on the storage infrastructure: the EU region of our database runs on the data center infrastructure of Amazon Web Services (AWS eu-central-1, Frankfurt) — AWS provides exclusively this infrastructure for database storage; the AI processing of your content does not take place on AWS, but at the EU AI services named in section 5 via our own relay server.

We base such transfers on the EU standard contractual clauses under Art. 46(2)(c) GDPR (Decision (EU) 2021/914), which form part of the data processing contracts with the respective service providers; according to its own statement, our email service provider Resend is additionally certified under the EU-US Data Privacy Framework (Art. 45 GDPR). Our list of subprocessors shows the current status of the safeguards per service. You can obtain a copy of the safeguards used in each case (for example the standard contractual clauses) on request at privacy@whispawave.de (Art. 46(1) GDPR).

Ad measurement (only after consent): If you consent to ad measurement in the cookie banner, Meta Platforms Ireland Limited receives the data described in section 22. Meta may transfer it to its parent company Meta Platforms, Inc. in the USA. This transfer is based on the European Commission's adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), under which Meta Platforms, Inc. is certified, and additionally on the EU standard contractual clauses. Without your consent, this transfer does not take place.

iPhone app and security check at sign-in: Apple handles purchases in the App Store under its own responsibility (section 16); whether and how Apple transfers data to third countries in doing so is explained in Apple's Privacy Policy. The iPhone app does not transmit the content of your dictations and conversations to Apple. For the security check at sign-in (section 9), Cloudflare, Inc., based in the USA, receives technical connection and browser characteristics; the processing may also take place in the USA.

Web search in the Meetings chat (Linkup): A data processing agreement (Art. 28 GDPR) has been in place with Linkup since 24 October 2026. Linkup has its registered office in France but operates servers in the EU, in the USA, in Canada and in the Asia-Pacific region and, according to its own statement, can process a search query in any of these regions. Linkup commits to processing in the EU only under an enterprise agreement; we have requested one, but it is not yet in place. A search term can therefore reach a country outside the EU, including one without an adequacy decision of the European Commission. We will name a safeguard under Art. 46 GDPR for such a transfer (for example EU standard contractual clauses) here only once we can evidence it. We have requested a commitment that Linkup does not store search queries (Zero Data Retention); it is not yet in place. Linkup receives only the search term (section 11), neither your conversation nor details of your account. If you do not want this, switch off the web search (section 11, paragraph “Web search in the Meetings chat”); the chat then answers your questions without a web search.

Google Calendar: If you connect Google Calendar directly (section 11), our server reads your events at Google and transmits the events you create through the app to your Google account. Google acts under its own responsibility for your Google account; whether and how Google transfers data to third countries is explained in Google's Privacy Policy.

7. Retention periods and deletion

We delete personal data as soon as the purpose ceases to apply and no statutory retention obligations exist. Specific periods:

What survives an account deletion (and why): pseudonymized invoice data at Stripe (statutory retention); anonymized technical usage summaries without any personal reference; a record of your deletion request (type, status, date of receipt and completion) together with your email address, so that we can prove the deletion was carried out on time — we delete it 6 years after the end of the year in which your request reached us (a deletion request ends your contract with us, so we keep it as a received business letter, Section 257 of the German Commercial Code (HGB)), but no earlier than 3 years after the end of the year in which we completed it; your pseudonymized records of consent and order declarations (e.g. acceptance of the Terms of Service and this Privacy Policy, context-awareness consents including their withdrawal, and your declarations in the order process on the early start of performance and on the obligation to pay a proportionate amount if you withdraw from the contract); and a technical hash value of your email address, which we use exclusively to prevent free trial periods from being obtained multiple times through ever new accounts.

For the consent and order records, we replace your account ID with a technical hash value at account deletion; the content and time of the respective declaration remain unchanged. The purpose is our legal obligation to be able to demonstrate consents given and withdrawn as well as your declarations in the order process (Art. 7(1) GDPR). This hash value, too, remains pseudonymized personal data: it can be re-attributed to you insofar as your account ID is lawfully retained elsewhere (for example in the billing records that must be retained by law). We delete these records automatically, each period counted from the end of a calendar year: consents including their withdrawal and your acknowledgement of this Privacy Policy 3 years after the year in which you decided anew, accepted a newer version or deleted your account; your acceptance of the Terms of Service and your declarations in the order process 6 years after the year in which you made them (statutory retention of business letters, Section 257 of the German Commercial Code (HGB), Section 147 of the German Fiscal Code (AO)) — your acceptance of the Terms of Service, however, not before 3 years after the year in which you accepted a newer version or deleted your account; the record of our notice of your right to object to advertising to existing customers (Section 7(3) of the German Act against Unfair Competition (UWG)) 3 years after the year of your account deletion, but not before the 6 years have passed.

Your address cannot be reconstructed from the email hash value; it nevertheless remains pseudonymized personal data, because it makes it possible to recognize the same email address again. We create it as soon as your account — also for a team — receives a free trial period, and check it at every new trial period. We retain it on the basis of our legitimate interest in preventing multiple trial periods (Art. 6(1)(f) GDPR) for the lifetime of your account and for at most 24 months after account deletion; after that we delete it automatically as well — we put this automatic deletion into technical operation on 8 July 2026. You can object to this processing under Art. 21 GDPR.

iPhone app: Beyond an account deletion, the logs on App Store purchases named in the table are also retained. As soon as you request the deletion of your account in the app, the app removes your conversations, “My notes”, the events linked to meetings, chat histories, dictations not yet transmitted, their key and the diagnostic log from the iPhone; your settings remain until you remove the app. A subscription from the App Store does not end through the account deletion — cancel it in your App Store settings.

8. Your rights

You have the rights under Art. 15 to 21 GDPR: access, rectification, erasure, restriction, data portability and objection; you can withdraw consent you have given at any time with effect for the future — the lawfulness of the processing carried out up to the withdrawal remains unaffected (Art. 7(3) GDPR). Withdrawing is as easy as giving consent (switch in the settings).

We answer requests concerning your rights within one month; in complex cases, the period may be extended by up to two months — we will inform you of this within the first month (Art. 12(3) GDPR).

This is how we implement it in practice:

• Data export directly in the app: In the Mac app (Settings → Privacy → “Export Data”) you receive your data as a machine-readable file via a protected download link valid for 48 hours. Not included in the file are, among other things, derived technical data (search index, check values for meeting notes, daily usage totals), event data of the payment providers and team activity logs; on request, you receive information about these as well.
• Account deletion directly in the app with a 30-day undo window (section 7). The window protects you against accidental or abusive deletion. If you expressly want immediate, permanent deletion, contact privacy@whispawave.de — then we delete without the window. If you are the owner of a team with other active members, you must first dissolve or transfer the team.
• Consents are managed in the settings; you receive a confirmation email for every withdrawal.
• For all matters: privacy@whispawave.de.
• In the iPhone app: You start the account deletion in the menu under “Account” → “Start account deletion” (you reach the same page via Settings → “Account & subscription” → “Account”; 30-day window as above); you delete individual stored dictations in the app's history. The iPhone app does not offer a data export; you receive it in the Mac app or on request to privacy@whispawave.de. You withdraw your consent to AI processing under Settings → Data & Privacy → “AI processing in the EU” → “Withdraw”; the withdrawal takes effect as soon as the app has been able to save it (it needs an internet connection for that). We currently do not send a confirmation email for this withdrawal. In the same place you withdraw “Context from the text field” with the switch (section 12). You change the app's permissions (microphone, Full Access for the keyboard, notifications) in the iOS Settings.

You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us: the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte/r für Datenschutz und Informationsfreiheit Nordrhein-Westfalen), Kavalleriestraße 2-4, 40213 Düsseldorf (registered office of the company: Dortmund).

9. Registration and user account

You register with an email address and password (with a confirmation email) or by signing in with Apple, Google or Microsoft (in the browser; Apple transmits your email address to us — on request a private relay address — and no name; Google and Microsoft transmit your email address and your name to us, Google also a link to your profile picture). The app uses your name to prefill your profile. Information we receive through signing in with Google is also covered by the statement on the Google API Services User Data Policy in section 11 (“Connecting Google Calendar directly”). We reject disposable email addresses at registration; privacy-friendly providers (Proton, Tutanota, iCloud and others) are expressly permitted. Optionally, you can enable two-factor authentication. We store your acceptance of the Terms of Service and your acknowledgement of this Privacy Policy with date and version.

Language of your app: After you sign in and on every change of language, the Mac app tells us which language you use it in (German, English, Spanish or Russian). We store this in your account so that our emails to you, Stripe's payment pages and your invoices and receipts appear in that language, as far as we offer it — otherwise in German (legal basis: performance of the contract, Art. 6(1)(b) GDPR). For this, Stripe receives your preferred language on your customer record (section 16). With every consent and every acceptance of the Terms of Service or this Privacy Policy we also record the language in which the text was shown to you — as evidence of what you consented to. This information is kept for as long as your account.

Obligation to provide data (Art. 13(2)(e) GDPR): For a contract with us, only your email address is required — without it we cannot create an account or provide the service. All other details (name, profile picture, professional field) are voluntary; not providing them has no disadvantages other than the loss of the respective additional function.

Minors: WhispaWave is aimed exclusively at adults. We do not knowingly process data of persons under 18 years of age; if we become aware of such data, we delete the account.

Signing in in the iPhone app: In the iPhone app you need an account before you can dictate. There you sign in with an email address and password, with “Sign in with Apple” or with Google; the iPhone app does not offer sign-in with Microsoft. “Sign in with Apple” runs directly via iOS, without a browser: the app passes the sign-in token issued by Apple to our sign-in service, which takes your email address or the private relay address you have chosen from it; the app does not read your name in the process. If the revocation of Sign in with Apple is turned on on our side, the app also passes the one-time authorization code that Apple issues to it in the process to our server; with it, the server requests a token from Apple and stores it encrypted so that we can revoke the connection to Sign in with Apple at Apple when your account is finally deleted; after that, we delete the token. If there is then no such token for your account, the app asks you, when you delete your account, to confirm the deletion once with Apple; it again passes on only such a code, and you can also delete without this confirmation. As long as this revocation is not turned on, the app does not transmit the code to us, and no such token is created. The app stores the identifier of your Apple sign-in on the iPhone in order to detect whether you have revoked Sign in with Apple. Signing in with Google opens a browser window that stores no sign-in data; if you sign in with Google during setup and have not yet entered a name, the app takes your name from your Google account into your profile. You cannot set up two-factor authentication in the iPhone app; if it is active for your account, the app asks for the code. If you create your account in the iPhone app, we store, with the date, which version of the Terms of Service and this Privacy Policy applied at the time. The minimum age of 18 also applies to the iPhone app.

Security check at sign-in (all apps): For requests to our sign-in service — for example when you register by email, sign in with email address and password, request a confirmation email again or reset your password — our apps check, usually invisibly, whether the request comes from a human. For this we use Turnstile from Cloudflare, Inc. (USA): the app loads a verification script in the background from Cloudflare's servers; in doing so, Cloudflare receives technical connection and browser characteristics such as your IP address, but from us neither your email address nor your password or content. The result, a single-use verification token, goes with your request to our sign-in service, which has it confirmed by Cloudflare; without a valid check, it rejects these requests. For “Sign in with Apple” and sign-in with Google or Microsoft, the check does not take place. The legal basis is our legitimate interest in protecting accounts and sign-in against automated attacks (Art. 6(1)(f) GDPR); the access to your device required for this is strictly necessary for the sign-in you have requested (Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG)). For the transfer to the USA, see section 6.

10. Dictation: speech and text processing (core function)

iPhone app: The following paths a) and b) describe the Mac. In the iPhone app, your device does not recognize your speech: the app transmits your recordings for recognition to our AI providers in the EU; recordings in which it detects no speech on the iPhone are, as a rule, discarded beforehand (section 25). Text improvement (point c) also runs via our EU servers there, but without any indication of the application you dictate into and without context text, unless you have turned on “Context from the text field” (sections 12 and 25). How the iPhone app stores dictations (point d) and what the AI transparency notice looks like there is described in section 25.

We describe the processing separately for the four paths that exist technically:

a) Dictation on Macs with Apple silicon (standard). Speech recognition runs entirely on your device; your audio recording does not leave your device. If local recognition fails, the app does not secretly fall back to the cloud — you receive an error message, and the recording stays local.

b) Dictation on Intel Macs. Here, the audio recording is transmitted to Mistral (EU) for speech recognition; for a dictation language that Mistral does not recognize, it goes as the first service to Scaleway (France, EU), and during a temporary outage of Mistral likewise to Scaleway (section 5). We do not store it on our servers; for processing at the AI provider, section 5 applies (at Mistral no storage — Zero Data Retention, confirmed in writing; at Scaleway no permanent storage according to the provider's published privacy terms).

c) Text improvement (all paths). The recognized text is transmitted via our own server in the EU to Mistral for AI post-processing (filler words, formatting, style, translation on request). This also applies when Private Mode is enabled and in Professional Secrecy Mode — these settings control what gets stored — not what gets transmitted for text improvement. Style and format settings, your dictionary terms and — only with separate consent — context text (section 12) are transmitted as well. If our AI provider is temporarily unavailable, an EU fallback service takes over automatically (section 5) — even then, processing remains entirely within the EU.

d) Storage. In the settings of the Mac app you choose between “Keep permanently”, “Auto-delete (24 h)” (default setting; if you choose “Save history (recommended)” when setting up the Mac app, “Keep permanently” applies) and “Never store” — periods in section 7. With “Never store”, your dictation text is stored nowhere — neither in your history nor in your account; the brief transmission for text improvement (point c) still takes place here too. On our servers, the text is discarded after processing; for processing at the AI provider, section 5 applies (no permanent storage). For every stored dictation, we remember as additional information the application you dictated into (e.g. “Mail”) — this detail improves style adaptation and is not transmitted to Mistral.

Reprocessing dictations. In your history, you can have a stored dictation improved once more with “Reapply AI formatting”: for this, we transmit the stored recognized text with category, style, cleanup level, language and your dictionary terms for text improvement as under point c), and the result replaces the improved text. With “Retry transcription”, you have speech recognition run again, as long as the app still has the recording for it. Each is possible at most five times within 24 hours; we log every attempt with the dictation, on success together with the new text, until the dictation is permanently deleted.

Content containing third-party data: The content of your dictations belongs to you. If it contains personal data of third parties (for example patient or client data), you are the controller under data protection law for it; we process this content exclusively to perform the respective function.

Professional Secrecy Mode (Section 203 of the German Criminal Code (StGB)). For professions bound by a statutory duty of confidentiality (e.g. physicians, lawyers, tax advisors, therapists), we offer a special mode that permanently enforces: no dictation storage (“Never store”), Private Mode, no context awareness. Activation can only be reversed by a complete account deletion. In this mode, too, the recognized text is transmitted to Mistral (EU) for text improvement (point c); whether this is compatible with your professional duty of confidentiality is something you must assess for your individual case yourself.

AI transparency (EU AI Act): At first launch, we inform you that WhispaWave uses AI systems and that results can be incorrect — this concerns all AI results, including the answers and note edits of the meeting chat assistant (section 11). Our AI functions are assistance tools: they make no decisions about you that produce legal effects or similarly significantly affect you (Art. 22 GDPR) — you check and adopt every result yourself (Terms of Service section 3); for automated abuse detection, see section 15.

11. Conversation mode, meeting chat assistant and third-party data

In Conversation mode (meeting notes), the app records your microphone and the system audio — in video conferences, therefore, also the voices of the other participants. The recording is transmitted to Mistral (EU) for transcription with speaker separation; we do not store the recording on our servers, for storage at the AI provider, section 5 applies (no permanent storage). If processing fails, the app keeps the recording for up to 24 hours locally on your device (so that nothing is lost) and then deletes it automatically.

The resulting text transcript (with speaker labels such as “Speaker 1”) is initially available to you as a working copy in the current session. Where conversations are stored permanently is your own decision (Settings → Privacy → “Conversations & Meetings”) in three tiers: “Only on this Mac” — storage exclusively locally on your device (encrypted as a rule, section 23); “In the cloud (all devices)” (default since version 1.0.8) — we additionally store the text in your account so that your other devices can access it (only text reaches your account in the process — the audio recording itself is, as described above, transmitted only for transcription and stored neither with us nor permanently at the AI provider); “Never store” — it stays with the transient working copy, which disappears when you quit the app. For new installations of the Mac app, the cloud tier has been preselected since version 1.0.8, without us obtaining separate consent for it; if you yourself switch into or out of the cloud tier, we log that as a record. Switching out of the cloud tier ends cloud storage for the future; conversations already stored we continue to keep available for you — including your later edits — until you delete them (performance of a contract: you should keep your content and decide for yourself).

Event details on the conversation. If the app links a recording to a calendar event (section 23, on the iPhone section 25), its participants (name, e-mail address) belong to the conversation; the app never takes the title of the event as the title of the conversation. We store these details with the conversation in the tier you have chosen — in the cloud tier, therefore, also in your account. You can change the title at any time; if you delete the conversation, you delete these details with it (legal basis: for your own details, performance of a contract, Art. 6(1)(b) GDPR; for the details of the other participants, our and your legitimate interest in a complete meeting note, Art. 6(1)(f) GDPR).

Meeting chat assistant (questions about your conversations). For every conversation, you can ask the AI assistant questions and request analyses — also during an ongoing recording. For every question, we transmit via our own EU server to Mistral (EU): your question, the transcript of the conversation concerned, the associated meeting note, the previous chat history and — during an ongoing recording — the most recent segment of the live transcript. We never store the chat history on our servers — regardless of your storage tier, it is only on your Mac (section 23). For processing at Mistral, section 5 applies (no training, no permanent storage).

Search index for questions across multiple conversations. If you store conversations in your account (cloud tier) and use a paid plan or a trial period, the Mac app creates a search index over these conversations by default; you can turn the function off under Settings → Privacy → “Ask across conversations”. For this, we transmit segments of your transcripts together with speaker names and the sections of your meeting notes via our own EU server to Mistral (EU), which calculates numeric vectors from them (section 5); in your account, we store these vectors, the word stems of the segments and the subheadings of your notes. If you ask a question across multiple conversations, we also calculate such a vector from your question in order to find matching passages. If you delete a conversation, we remove its index entries immediately. If you turn the function off, indexing pauses; the existing index remains until you remove it under Settings → Privacy → “Delete search index” or delete your account.

Editing of your meeting notes by the assistant. On your instruction, the assistant can edit your meeting note (e.g. rephrase or add sections). The following applies: changes are adopted into the note only after your confirmation; you can undo each change individually; a complete revision is created as a second version — your original note is preserved. The assistant never writes to your notes without your action. This creates no additional data outflow (the note is, as described above, transmitted with every chat question anyway).

Web search in the Meetings chat (Mac app). If a question in the Meetings chat needs current information from the internet, the assistant can search the web. For this, it formulates a short search term of at most 300 characters — which can be derived from your question and the conversation and can contain, for example, the name of a company or a product —, and our own server at Hetzner in Falkenstein (Germany) sends only this search term to our search service Linkup (section 5). Linkup does not receive the transcript, the note or details of your account. The assistant searches at most twice per message. The results (title, address and a short excerpt of the web page) go to Mistral (EU) together with your question so that the assistant can use them in its answer; the answer names the sources. We do not store the search term or the results on our servers. The web search is switched on by default; you switch it off in the settings under “Meetings” with the switch “Web search in the Meetings chat”. Section 6 applies to Linkup: a data processing agreement is in place with Linkup, but Linkup can also process search queries outside the EU, and we have requested the commitment not to store search queries; it is not yet in place. (Legal basis: as for the meeting chat, section 3.)

Context details for better results. So that meeting notes and chat answers match you and your conversation, we transmit — if this function is active in your app — as additional context: the names of the speakers, your profile name and your voluntarily entered professional field (section 13), from your details in the settings under “Profile” your job title and your company — in the meeting note the company only if the conversation itself names it; in the chat also the description of your company and the entries of your memory (paragraph “Memory”) —, your personal dictionary terms, a short summary of your last meeting with the same person or the same title, and the date, time and time zone. Calendar details (title, time slot and participants of the matching event; for questions in the chat your events of the next seven days; for event suggestions in the chat also the names of your calendars — where two share a name, with the account they belong to —, whether you can create events in them and which one is your calendar for new events) are only sent along if you have turned on the calendar switch in the settings (paragraph “Calendar”, below; section 23). Conversations with the setting “Never store” are never used as context for later requests. Mistral processes these context details, too, only to perform the function (section 5).

Memory. So that answers in the Meetings chat match you, WhispaWave remembers details about you and your work. An entry comes about in two ways: (1) You ask for it in the chat (“Merk dir, dass …”, in German); the assistant turns this into a statement in your words, which we store. (2) With the switch “Suggestions from conversations” (switched on by default), WhispaWave recognizes, when creating a meeting note you request, sentences in which you yourself describe your work — only your own voice, never that of other speakers —, and, for your questions in the chat, what you tell about yourself there of your own accord. This involves no additional AI call: the suggestions are made in the same call as the note or the answer. WhispaWave keeps a clear, general statement on its own; it presents any other one to you for 72 hours for a decision (“Keep” or discard). We store an entry in your account (Supabase, Frankfurt) with its origin (the chat, your edit or the conversation with the passage it comes from). To recognize duplicate and discarded entries, we have Mistral (EU) calculate comparison values (vectors) from each entry and store them with it. Entries that you have not switched off with “Stop using” go to Mistral (EU) as context with your questions in the chat; we never use them in meeting notes, for dictation or in Command Mode. Sensitive details: If WhispaWave recognizes in an entry details about health, finances, family, religion, origin or intimate matters — using a fixed word list and the model's assessment —, it never keeps the entry on its own but only presents it to you for a decision. If you keep it or explicitly ask for it with “Merk dir …”, we store it marked, show it to you with the reason and never pass it on to the AI. The detection can miss a detail; a missed entry is used like any other. We do not store access data such as passwords, PINs or TANs. You see all entries in the settings under “Profile” › “Memory”: there you change them, switch them off with “Stop using”, delete individual ones or all of them with “Delete all”; in the chat, “Vergiss …” (in German) is enough. No entry is created in Private Mode, with “Never store”, in Professional Secrecy Mode (Section 203 of the German Criminal Code (StGB)) and if your team has switched off “Merk dir”; suggestions from conversations exist only for conversations in the cloud tier. Section 7 sets out how long we store entries. We store your details on the “Profile” page (job title, company, description of your company) in your account; if you change them, we keep the earlier versions until your account is deleted. (Legal basis: performance of a contract, Art. 6(1)(b) GDPR; for an entry marked as sensitive, your explicit consent, Art. 9(2)(a) GDPR, which you give with “Merk dir …” or “Keep” for exactly this entry and withdraw by deleting it — section 26.)

Calendar (optional, Mac app). In the Mac app you can let WhispaWave use your calendars: through your Mac's Calendar app (paragraph “Apple Calendar”) and, where available in your app, through a direct connection to Google Calendar (paragraph “Connecting Google Calendar directly”). The switch “Include calendar events” in the settings under “Calendar” applies to both ways; while it is off, the app uses no events. With your events the app shows your next meetings under “Coming up”, reminds you before events, links a recording to the matching event, gives your meeting note and the chat context, prepares you for follow-up meetings (paragraph “Preparation before appointments”) and prepares event drafts that are only created once you confirm them (also from your summaries, paragraph “Appointment proposals from summaries”). For this it reads the same details for every event, whichever calendar it is in: title, start and end (also all-day), location and video-conference link, participants and organizer (name, email address, response status) and the name of the calendar. WhispaWave does not read an event's description in any calendar.

What goes to our server and to Mistral. The app handles “Coming up”, the reminders and the linking on your Mac. For the meeting note we send the title, time slot and participants of the matching event with the request to our server at Hetzner in Falkenstein (Germany) and to Mistral (EU), as described under “Context details for better results”. When you ask a question in the chat, then — where available in your app — your events of the next seven days also go with the request to our server and to Mistral, at most 20 and without cancelled events, from the calendars you have switched on under “Visible calendars”, so that the assistant can take them into account in its answer: for each event its title, time, location, the name of its calendar and its participants (their name or, where none is stored, their email address). The app sends the events from Apple Calendar along for this; those from Google Calendar our server reads from its copy (paragraph “Connecting Google Calendar directly”). Our server and Mistral process these details only to answer the request: we do not store them, not even in logs, and Mistral does not store them (section 5). Event details are stored only when the app links a recording to an event — the paragraph “Event details on the conversation” then applies — and, for the direct Google connection, as described there.

Apple Calendar (optional, Mac app). If you connect Apple Calendar in the settings under “Calendar”, macOS asks you whether WhispaWave may have full access to your calendars. The app then reads, on your Mac, the events of your Mac's Calendar app — from every account set up there, such as iCloud, Exchange or Outlook, or a Google account from the macOS System Settings — but only from the calendars you have switched on under “Visible calendars”; a Google account you have also connected directly is read only through that connection. We do not store your calendars on our servers. The app creates an event in your calendar only after you have confirmed it on the event card — or, if you turn on “Create events automatically” in the settings, for events that were clearly agreed in the chat; it writes the event through macOS directly into the chosen calendar, without our server, and invites no one. With “Undo” the app deletes exactly this event within 24 hours, as long as it has not been changed since; WhispaWave does not change or delete other events. Whether a time is free is checked by the app on your Mac. You can end this at any time: in the settings under “Calendar” with “Disconnect” at Apple Calendar (the app then no longer reads your calendars) or in the macOS System Settings under “Privacy & Security” → “Calendars”, where you withdraw WhispaWave's access.

Connecting Google Calendar directly (optional, Mac app). Where available in your app, on the Pro+ and Team+ plans you can connect your Google account directly to WhispaWave in the settings under “Calendar” — without an account in the macOS System Settings. Our own server at Hetzner in Falkenstein (Germany — section 5) then uses the Google Calendar API to read the list of your calendars and the events of the calendars you select, for the period from six days before to two days after today: title, start and end, location, participants and organizer (name, email address, response status), the video-conference link and the link to the event. Connecting only allows this reading; WhispaWave can create events only once you additionally allow it (paragraph “Creating events”). We do not read an event's description, and we do not take over events you have declined. In your account (Supabase, Frankfurt — section 5) we store these events, the list of your calendars and your selection, your time zone, the email address of your Google account (so the app can show which account is connected) and the access keys Google issues for the connection. We store the access keys encrypted (Supabase Vault); they never leave our servers, not even to your app.

What for. With these events the app recognizes the meeting that matches a recording, reminds you before events and shows them in your meeting overview — like events it reads through macOS (section 23), and only while the calendar switch in the settings is turned on. As context for the meeting note and for questions in the chat, we send details of these events to Mistral (EU), as described above in the paragraph “Calendar” (section 5). If the app links a recording to an event, the paragraph “Event details on the conversation” applies to its title and participants.

Creating events (optional). Where available in your app, you can additionally allow WhispaWave to create events in your own Google calendars. The app asks for this only when you want to create an event in a Google calendar for the first time; you can also allow it beforehand in the settings. Google shows you a separate permission screen for it. Once allowed, our server creates an event only when you confirm it in the chat on the event card with “Create” — or, if you have turned on “Create events automatically” in the settings (it is off at first), for events that were clearly agreed in the chat. The app shows every event created this way in the chat with “Undo”. For this, our server transmits to Google the title, start and end and — if given — the location and description of the event, as well as technical markers by which we recognize it as created by WhispaWave. WhispaWave does not invite guests. With “Undo” we delete exactly this event within 24 hours, as long as it has not been changed since; WhispaWave does not change or delete any other events. So that no event is created twice and “Undo” works, we store only technical details for each event created (its ID at Google, the calendar, when and how it was created) — not its content — and delete them after 30 days. We store your settings for this (“Calendar for new events”, “Create events automatically”) in your account so that they apply on all your devices. Before an event is created, our server checks whether the time is free: for the period around the proposed event (at most 14 days) it reads the start, end, status, your response and title of the events in the target calendar and in the calendars you have selected. We do not store this information or pass it on to AI services; the app shows you only the titles of events that overlap with the proposal, and then does not create the event but offers you free times instead.

How long. We keep events only for the period named above: if an event falls out of the period or you delete it at Google, the next sync removes it; we delete it for good at the latest seven days after it ends. If you disconnect in the app (“Disconnect”), we delete the events, the list of calendars, the email address of your Google account and the access keys at once and ask Google to revoke the access; this also ends the permission to create events. We delete the technical details of created events once their 30 days are over. If you delete your account, we delete the events, the list of calendars, the technical details of created events and your settings together with the account; after that we use the access keys only to ask Google to revoke the access, and we delete them at the latest 72 hours after the account deletion, even if Google does not respond. You can also withdraw the access at any time in your Google Account under “Security” → “Third-party apps & services”.

No sharing, no training. We do not sell this data, do not use it for advertising or to assess your creditworthiness, and do not train AI models with it — nor do our service providers (section 5). Nobody at WhispaWave looks at it unless you expressly ask us to in support, or it is necessary for the security of the service or required by law. Legal basis: for your details, performance of the contract (Art. 6(1)(b) GDPR — the feature you chose); for the details of the other participants of your events, our and your legitimate interest in recognizing the matching meeting and finding free times (Art. 6(1)(f) GDPR).

WhispaWave's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. The use of information received from Google Workspace scopes will adhere to the Google User Data Policy, including the Limited Use requirements.

Preparation before appointments (Mac app). If the calendar is switched on and you store conversations in the cloud tier, WhispaWave prepares you for follow-up meetings: one hour before an event starts (selectable in the settings: 30 minutes, 1 hour, 2 hours or “Never”), the Mac app automatically, without you having to do anything, sends details of this event to our server at Hetzner in Falkenstein (Germany): start and end, time zone, title, the participants (name, email address) and technical identifiers of the event as well as which of your recorded conversations belong to the same event series. Our server checks whether the event continues an earlier recorded conversation — via an agreed follow-up meeting, the same event series, the same external participants or a similar topic; for the topic comparison, it has Mistral (EU) calculate a comparison value from the title of the event. From up to three matching conversations, it puts together a package: the title and day of your last conversation and the overview of its meeting note, its open questions, the open commitments of both sides with their verbatim quotes from the transcript, an agreed follow-up meeting and up to three matching passages from your transcripts. It automatically sends this package to Mistral (EU) in one call, which writes up to five short sentences of preparation from it; if that does not succeed, the card shows the package without these sentences. In your account (Supabase, Frankfurt) we store the start and end of the event, a key calculated from its identifier and its start (not the identifier itself), the identifiers of the conversations the preparation comes from, the package and the sentences — not the title and not the participants of the event. We delete the preparation 24 hours after the end of the event (section 7). You can switch it off in the settings under “Meetings” › “Preparation before appointments” with “Never”; your team can switch it off for everyone. No preparation is created in Private Mode, with “Never store”, in Professional Secrecy Mode and if your conversations are not in the cloud. (Legal basis: as for Conversation mode, section 3; for the event details, your calendar switch, Art. 6(1)(a) GDPR.)

Appointment proposals from summaries. If you request a meeting note, the model at Mistral (EU) checks in the same call whether a follow-up meeting was agreed in the conversation; there is no additional AI call for this. If one was agreed, the app shows an appointment proposal below the note: title, description, location, the times discussed with time zone, the other party and a short verbatim quote from the conversation as evidence. We store this proposal with the conversation in your account (Supabase, Frankfurt) so that it is the same in the app and in the chat. The app only creates an event once you confirm it with “Create” — through Apple Calendar on your Mac without our server or through the direct Google connection (paragraphs “Apple Calendar” and “Creating events”); afterwards we note on the proposal where the event was created (calendar, identifier and link of the event). There is a proposal only if the calendar is switched on and your conversations are in the cloud; you can switch it off in the settings under “Calendar” with the switch “Appointment proposals from summaries”, and your team can switch it off for everyone. (Legal basis: as for Conversation mode, section 3.)

Documents and earlier conversations as context. Where available in your app, you can attach up to five files to a conversation under “My notes” (Word documents, PDF, PNG and JPG images, up to 20 MB each) and link up to three earlier conversations that have a note. WhispaWave reads the text of a file on your Mac — for images and scanned PDF pages with your Mac’s text recognition; the file itself does not leave your Mac. If the conversation is stored, the app keeps with it on your Mac, encrypted as a rule (section 23): the extracted text (up to 6,000 characters per file), the file’s name, type and size, and which conversations you linked. None of this goes into your account, not even in the cloud tier, and we do not pass it on through share links, invitations or exports of a conversation. When you create the whole note of a conversation (not when you revise individual sections, in the meeting chat or when asking about conversations), the app sends the extracted text of each file — not the file and not its name; we refer to the files only by their position (such as “Attachment 1”) — and, for each linked conversation, its title, date and finished note (up to 2,400 characters, never the transcript) to our own server in the EU. That server adds the text and notes as additional context to the request to Mistral (EU) (section 5) and stores none of it. What flows from it into the note is part of the note. If your storage setting for conversations is “Never store”, you cannot link earlier conversations, and none is sent. If you remove a file or a link or delete the conversation, the stored context is gone as well.

Short-term technical caching. So that an ongoing chat answer is not lost if the connection drops, our relay server keeps ongoing and just-completed answers in memory for up to 15 minutes — retrievable exclusively for your account and discarded automatically afterwards; no permanent storage takes place (section 7).

Feedback on chat answers and meeting notes. You can rate the assistant's answers with thumbs up/down and, for a negative rating, choose a category. Where available in your app, it also asks you under a finished meeting note “Was this note helpful?”; if you choose “Not helpful”, you give a reason. Whether you rate is up to you. We use the ratings to improve our meeting notes and chat answers (legal basis: our legitimate interest in improving our product, Art. 6(1)(f) GDPR); you can object to this processing at any time (Art. 21 GDPR, contact in section 1).

We store each rating, assigned to your account and with the time, in a dedicated table of our database (Supabase, Frankfurt — section 5); what we store is exclusively:

• the rating and, for a negative rating, the category or reason;
• for chat answers, whether you rated in the chat of a conversation or with questions across multiple conversations;
• for meeting notes, the template the note was created with (for our built-in templates, their identifier; for your own templates and team templates, only whether it was your own or a team template), where applicable the template's variant and level of detail, and the platform of your app (such as Mac or iPhone).

We never store your question, the answer, the text of the note, the transcript or any other content, nor any identifier of the conversation or the note. Which note you rated and how is remembered only by the app on your device, so that you rate each note only once. These signals remain in our own systems and are never passed on to AI providers or for the training of AI models (standing rule, see also section 5). Once a rating is 12 months old, we delete it automatically in the next nightly deletion run; if you delete your account before then, we delete it together with the account (section 7). Your ratings are included in the data export (section 8).

Templates for meeting notes. Where available in your app, you can create and manage your own templates for meeting notes. For this, we store in your account (Supabase, Frankfurt — section 5), for each template, its title, context, sections, icon, type, description and example, and a version each time you save (up to 50 per template; the oldest is dropped), as well as your favorite templates and up to five templates the app is to “Create automatically in every conversation” — it creates them together with a conversation's first note. If you share one of your own templates with your team, all active team members see it with its title, context, sections, description, example and your profile name (never your email address) and can use and copy it (section 18). If you delete a template, it disappears from your library; 30 days later we delete it for good, together with its versions. For every template you create a note with, including our built-in ones, we store in your account, without any content, when you last used it and how often, so that your library can show “Recently used” on all your devices. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Creating templates with the assistant. Where available in your app, the assistant drafts a template for you (“What would you like to create?”), changes one of your own templates as you instruct (“What would you like to change?”) and writes an example for it (“Draft an example”); after a template is created, it drafts the example by itself. For this, we transmit to Mistral (EU) via our own server in the EU (section 5): your description (up to 2,000 characters, with your answers to a short follow-up question) and, if you add example files, their text, which the app reads on your Mac (up to 12,000 characters per file, up to 60,000 in total), without the file names; when changing, your instruction (up to 1,000 characters) and the template concerned; for the example, the template. We do not store your description, the example texts or your instruction, and the example files stay on your Mac; only the result is stored, as your own template with a new version or as its example. If your example files contain details about other people, these also go to Mistral; section 5 applies there (no training, no permanent storage).

Documents instead of notes. Where available in your app, you can use a template of the type “Document” to have a standalone piece of writing created from a conversation instead of a note, such as a letter. For this, we transmit the same details to Mistral (EU) via our own server in the EU as for a whole meeting note (section 5): transcript, template, context details and, where present, the documents and linked conversations from “My notes”. Your name and the date fill the sender line and the date line; your own bullet points under “My notes” go along as additional context. We store the document like a note with the conversation, so in the cloud tier also in your account; it counts toward your allowance like a note.

Filling in forms. Where available in your app, you can set up a template from a blank form (PDF or Word file, up to 10 MB). The app reads the fields of a fillable PDF or Word form on your Mac. If a PDF has no form fields, for example because it was scanned, we send the whole file (up to 30 pages) via our own server in the EU to the text recognition of Mistral (EU), which recognizes the fields (section 5). We store the blank form and its field list in your account (Supabase, Frankfurt); if you share the template with your team, the team members can retrieve and use the form (section 18). To fill it in, we transmit the field list and the conversation's transcript with the speakers' names and the note — or a text you paste — to Mistral (EU); anything that does not appear there stays empty. The filled-in form is created on your Mac and stays there, encrypted with the conversation; it does not reach us. If you delete the template, we delete the blank form and the field list for good 30 days later.

Template community. Where the community is available in your app, you can publish your own templates for everyone who uses WhispaWave and add other people’s templates to your library (section 16a of the Terms of Service). When you publish a template, we store (Supabase, Frankfurt — section 5) a copy of its content (type, title, description, context, sections, example, icon), your details on field, category, country and up to five keywords and — if you choose so — your profile name; otherwise, the template appears anonymously. We never show your email address. Before publication, our server automatically checks the template using fixed patterns, without AI, for typical personal details such as email addresses, phone and account numbers, postal addresses, names with a form of address and dates of birth; we show the matches only to you. After that, a person from our team reviews the template before it appears. Published templates are visible to all signed-in users of WhispaWave, also from other organizations: with title, description, your details, your name or “Anonymous”, the number of additions and the date, and in the detail view also with context, sections and example. If someone adds your template, a separate copy without your name is created in their library; we store who added it and when, and show only the number. If you hide a template for yourself, we remember this in your account. If you withdraw a template, it disappears from the community; copies that others have already added stay with them — even if you delete your account. We delete withdrawn or rejected publications for good 30 days later. Legal basis: performance of the contract (Art. 6(1)(b) GDPR); we base the check for personal details and the review by our team on our legitimate interest in protecting the rights of others (Art. 6(1)(f) GDPR).

Reports and moderation in the community. If you consider a published template illegal or a breach of the community rules, you can report it in the app. For this, we store your reason, your description (up to 500 characters, optional), your statement that your details are accurate to the best of your knowledge, your account and the times; you can send up to 20 reports within 24 hours. The person who published the template does not learn who reported it. One report about personal data, or reports from three different people, hide the template automatically until our team has decided. We inform you about the decision in your notifications in the app; the publishing person receives a statement of reasons for every restriction. We accept reports from people without an account by email (section 17). We record decisions with the person handling them, the template, the publishing person and the reasons in a log. Open reports stay stored until the decision, resolved ones for 12 months; the log for 12 months. If you delete your account, we remove you and your description from your reports at once (reason and decision remain) and your reference and name from the log. If content indicates a criminal offence that threatens the life or safety of people, we inform the competent authorities. Legal basis: for reports of illegal content, statements of reasons and reports to authorities, our legal obligation under Art. 16 to 18 of Regulation (EU) 2022/2065 on digital services (Art. 6(1)(c) GDPR); otherwise our legitimate interest in a community in which the rules are observed (Art. 6(1)(f) GDPR).

Your responsibility and the allocation of roles: For conversation recordings, you need the consent of everyone involved; secretly recording the non-public spoken word is a criminal offense (§ 201 StGB). If you use Conversation mode professionally or for business, you are the controller under data protection law for the content of your recordings; we process it — including the chat and assistant functions of this section — exclusively on your behalf as processor. The terms of this processing on our behalf are governed by our data processing agreement (AVV) (in German), which applies with the use of Conversation mode.

If you use Conversation mode purely privately (e.g. for a private conversation), the household exemption under data protection law (Art. 2(2)(c) GDPR) applies to you — you are then not a “controller” within the meaning of the GDPR. For the technical processing of the recording, in this case we remain responsible: the legal basis is the provision of the function you have invoked (Art. 6(1)(b) GDPR) and — for the voices of the other participants — our legitimate interest in providing the function with the safeguards described (Art. 6(1)(f) GDPR: no audio storage on our servers, no permanent storage at the AI provider, processing only upon your express start). Your obligation to inform everyone involved and to obtain their consent applies unchanged in both cases.

Conversations in the iPhone app: On the iPhone, the app records conversations only via the microphone — so also the voices of others, insofar as the microphone picks them up — but not directly the audio of other apps. Storage, synchronization, calendar, meeting chat assistant and context details differ there from this section; the details are described in section 25. Your obligation to inform everyone involved before the recording and to obtain their consent, and the allocation of roles in this section, apply unchanged on the iPhone.

12. Context awareness (only with consent)

By default, context awareness is turned off. If you turn it on, the app reads, when you start a dictation, the name of the active application and the text around the currently focused input field (up to 500 characters — the complete field content, not just a selection), so that the AI can phrase your dictation text to match the context. This context text is transmitted to Mistral (EU) together with your dictation. We do not store it on our servers after processing; for processing at Mistral, section 5 applies (no permanent storage).

Safeguards: password fields are never read; a block list of sensitive applications (password managers, terminals, development environments) is built in permanently; recognizable access credentials and keys are removed automatically before transmission. We log your consent and every withdrawal in a tamper-evident way; you can change both at any time in the settings.

iPhone app (“Context from the text field”): On the iPhone, the app reads neither the active application nor other windows. Instead, you can turn on “Context from the text field” under Settings → Data & Privacy (default: off). Then, when you start a dictation, the WhispaWave keyboard reads once up to 500 characters of the text before the cursor from the text field you dictate into, and the app sends this excerpt together with the dictation to our AI providers in the EU for text improvement (section 5), so that names and spellings match the existing text. It does not read text after the cursor, selections or your keystrokes for this; in password, code, username, card, web address, email and number fields it reads nothing. The app removes recognizable access credentials, IBANs and card numbers before transmission. We do not store the excerpt; for the dictation we only remember whether context was sent along. Before the switch takes effect, the app shows you the consent text and asks you to confirm it on this iPhone; we log your consent and every withdrawal as on the Mac. The switch applies to your account, the confirmation to each iPhone. In Private Mode, with “Never store”, in Professional Secrecy Mode and for the practice dictations during setup, the context stays off.

13. Dictionary, snippets, notes, style samples and app assignments

In your account (Supabase, Frankfurt), so that your content is available across devices, we store (legal basis: performance of a contract, Art. 6(1)(b) GDPR — synchronization is part of the contractual service described):

• your personal dictionary — the terms additionally flow into the AI processing so that they are recognized and written correctly; this applies to dictation and — as a context detail — to meeting notes and the meeting chat (section 11);
• your snippets — they are not transmitted to AI services; the supplied standard snippets contain your name and your email address;
• your notes (Scratchpad) including version history and folders;
• up to five style sample texts and your own transformation instructions — they are transmitted to Mistral for style adaptation;
• your style assignments per application (e.g. “write formally in Mail”) — together with the target application detail from section 10 d), this results in a list of the applications you dictate into; we use it exclusively for style adaptation and your history filters.

Automatic dictionary learning (on by default for accounts created since 27 August 2026, for older accounts only with consent; can be turned off in the settings): After a dictation, the app detects for a short time whether you correct a word in the text. Whether the corrected word belongs in the dictionary is checked on our server in the EU; for this, we transmit only the recognized and the corrected word with a little surrounding text and do not store it there. If you delete a learned word again, we note that in your account so that it is not learned again — you can lift this at any time in the settings.

Team sharing: Dictionary entries and snippets that you share with your team are visible to all active team members (section 18).

If you voluntarily enter a professional field in your profile (e.g. medicine, law, therapy), we store this detail in order to adapt text processing to the subject; in Conversation mode, it is sent along as a context detail for meeting notes and chat answers (section 11). You can remove it at any time.

Mac app — your name and email address in the dictionary: After you sign in, the Mac app adds your first and last name and your email address from your account once as terms to your dictionary so that they are written correctly in your dictations; like all terms, they are then held in your account, available on all your devices and used in the processing of your dictations (section 10). If you change your name in your account, the app adds the new name as well. If you delete one of these terms, the app does not add it again — on none of your devices. There is no separate switch for this; as long as your account does not store dictations (Private Mode or “Never store”), the app adds nothing, and it never adds a private relay address from Apple. The Mac app also writes your name in the sign-offs of your own texts in the spelling of your account — it performs this step on your Mac.

iPhone app: The iPhone app, too, synchronizes notes, dictionary and snippets with your account. When the dictionary is opened for the first time, the iPhone app adds your first and last name and your email address from your account as terms so that they are written correctly in your dictations; like all terms, they are then available on all your devices and are used in the processing of your dictations (sections 10 and 25). If you delete them, the app does not add them again. This does not happen as long as your account does not store dictations (Private Mode or “Never store”), and not for a private relay address from Apple. Your account also holds Private Mode, your default and favorite templates for conversation notes and the languages and answers adopted during setup (section 25). Style, category, cleanup level, translation target, your favorite languages and the other settings of the app and the keyboard, by contrast, are stored by the iPhone app only on the iPhone; style assignments per application and a list of the applications you dictate into do not arise there. The iPhone app displays automatically learned dictionary entries. With its own function “Learn words from corrections”, it learns from words you correct with the WhispaWave keyboard after a dictation. The function runs only with your consent, which applies to your account, so also if you gave it in the Mac app, and never in Private Mode, with “Never store” or in Professional Secrecy Mode; what it transmits for this is described in section 25.

14. Usage statistics and allowances

To enforce the plan allowances, we record server-side the number of words you dictate and the dictation duration — as a daily and monthly summary and, for the Free allowance, as two separate weekly counters (2,000 words on the computer, 1,000 words on the iPhone): with your first counted dictation, a fixed weekly period of 7 days begins for both counters, followed by the next one each time; we store the start of this period in your account. So that we can assign each dictation to the right counter, we store with every stored dictation the platform it came from (such as “mac” or “ios”), and for dictations in Private Mode and with “Never store”, in addition to the word count, how many of these words you dictated on the iPhone. We delete the platform information together with the dictation (section 7); the legal basis is Art. 6(1)(b) GDPR (enforcing the agreed Free allowance). These figures also arise in Private Mode and with “Never store” — what is stored then is exclusively numeric values, never text (for the short-term text processing, see section 10 c). Deleting dictations does not reduce the counters (otherwise the allowance could be circumvented by deleting).

For Conversation mode, we additionally record the conversation hours used per month and the number of meeting notes created per account — likewise exclusively as numeric values without content — in order to enforce the monthly plan allowances. We publish the applicable allowance values per plan on our Fair Use page.

7-day challenge “100 words a day”: If you start a personal free trial period of Pro without providing payment details, you take part in the challenge. For each consecutive day in the first week of your trial period on which you dictate at least 100 words outside WhispaWave (currently with the iPhone app), we extend your trial period by one day, by at most seven days. For this, we count per calendar day and device class (phone or computer) how many words you dictated in total and how many of them outside WhispaWave; at the end of the trial period we show you your usage. For each dictation during the trial period, we keep for this only whether it was made outside WhispaWave and when you dictated it, no app name and no text. We delete these two items as soon as the challenge ends, at the latest when your trial period ends. So that no dictation counts twice, we record for each counted dictation its identifier, its day and its word count; so that the days count in your local time, we store your device's time zone at the start of your trial period. We delete the daily figures, these records, the time zone and the information on which days were counted, credited or shown to you 90 days after the challenge ends. That you took part and how many days the challenge earned you stays in your account until you delete it, so that each account takes part only once. The legal basis is Art. 6(1)(b) GDPR (performance of the trial period and its extension).

For every cloud AI request, we log content-free technical values (time, function, model, amount of text/audio, response time) as well as a random installation ID of your app. This identifier is a random number generated at installation — not a hardware fingerprint. In our device registry, we store it together with the device model (such as “Mac14,10”), the operating system and app version and the time of last use, in order to operate the service, provide support and evaluate on which platforms WhispaWave is used (Art. 6(1)(f) GDPR); the app does not transmit the serial number or hardware identifier of your device. We consolidate individual logs into monthly values after 12 months.

No tracking in the app; on the website only cookieless audience measurement and ad measurement with consent: The WhispaWave app contains no analytics, advertising or tracking services; there is no click-path analysis and no open or click measurement in our emails. On the website, we count page views with Plausible Analytics — without cookies, without a persistent identifier and without user profiles (section 22); the website does not measure load times. Whether our ads on Meta lead to visits and sign-ups is measured exclusively if you consent in the cookie banner; before that, the Meta Pixel does not load (details: section 22).

iPhone app: The iPhone app and the WhispaWave keyboard, too, contain no analytics, advertising, tracking or crash-analysis services; they use no advertising identifier and do not track you across other providers' apps and websites, which is why the app does not ask for tracking permission either. For AI requests, the iPhone app transmits, in addition to the values named above, the platform (“iOS”) and its version number; we log the platform as well, and in your profile we record once from which platform you first used our AI relay server. At launch, also before sign-in, the app asks our server which functions are enabled and transmits the installation ID and the app version for this. As soon as the app loads your account, it enters your installation into the device registry described above (with the device model, such as “iPhone17,3”).

15. Abuse detection (automated protective measures)

To protect against account sharing, automated mass use and fraud, we check the use of every account automatically. So that you know exactly what happens there, we disclose how it works:

How the check works (the logic): From six purely technical signals — the number of installations used simultaneously, the request frequency, the dictation audio minutes and the conversation audio minutes per day (for conversations with thresholds depending on the plan), the repeated processing of the same recording and the use of the same installation by other accounts in the last 30 days (section 14) — we automatically calculate an internal risk score per account every 15 minutes (so-called profiling within the meaning of Art. 4(4) GDPR). Your content is never included — neither dictation texts nor transcripts, meeting notes or chat messages.

Scope and possible consequences: Above certain thresholds, graduated measures take effect automatically: slight delay of requests → temporarily reduced allowances → temporary pause of the AI functions, which ends automatically → blocking of the AI functions with referral to support. The risk score decreases again by itself when the conspicuous behavior ends.

Legal basis: The automated decision is necessary for the performance of our contract with you (Art. 22(2)(a) GDPR), because we can provide the service for everyone only with use in accordance with the contract; we additionally base the underlying processing of the technical signals on our legitimate interest in protecting the service (Art. 6(1)(f) GDPR).

Your rights with every automated protective measure (Art. 22(3) GDPR): You have the right to request a review by a human, to express your own point of view and to contest the decision. To do so, contact privacy@whispawave.de or support@whispawave.de — we examine your case individually and lift the measure if it was unjustified.

16. Payment processing

Payments run exclusively via Stripe. We receive no credit card or bank account data, only confirmations and the subscription status. In the order process, Stripe collects your billing address and — for businesses — the VAT identification number; we check the latter automatically via the EU system VIES. On account deletion, your data at the payment service provider is pseudonymized; invoices remain retained for legal reasons (section 7). So that payment pages, invoices and receipts appear in your language, we pass the language of your app to Stripe as the preferred language of your customer record (section 9).

Purchases in the iPhone app: In the iPhone app, you buy subscriptions via Apple's App Store; Stripe is not involved. Apple handles the order, payment, invoice, cancellation and refund under its own responsibility (section 5; Terms of Service section 23); we do not receive your payment data. On purchase, the app passes the ID of your WhispaWave account to Apple so that the purchase can be assigned to your account. After a purchase, when restoring purchases and when the app finds pending or changed purchases, it sends the purchase receipt signed by Apple to our server, which verifies it and enables your subscription; in addition, Apple sends us notifications about your subscription (such as renewal, cancellation or refund). From these we store transaction and product IDs, subscription status, term and the result of the verification, but neither prices nor the country of your App Store account (retention period: section 7). The legal basis is Art. 6(1)(b) GDPR.

17. Email communication and newsletter

We distinguish four types of email:

1. Contract emails (e.g. purchase confirmation, payment problems, changes to prices or the Terms of Service, deletion confirmations, acknowledgements of receipt of your online cancellation — section 22) and
2. Security emails (e.g. sign-in warnings, change confirmations) — both are necessary for the performance of the contract and cannot be unsubscribed;
3. Team notifications (e.g. the notice that a new member has joined your team) — active by default, can be unsubscribed at any time (unsubscribe link in every email and switch in the settings);
4. Newsletter — only with your consent (off by default). After signing up — in the app or via the website (section 22) — you receive a confirmation email; only after you click the confirmation link do we send newsletters to you (double opt-in). Every newsletter contains an unsubscribe link (one-click unsubscribe). We log your consent, the confirmation and every withdrawal. The subscriber list is kept with our sending service provider (section 5).

We may send existing customers with an active paid subscription information about similar services of our own within the limits permitted by law (Section 7(3) of the German Act against Unfair Competition (UWG)); you can object to this at any time — a newsletter withdrawal automatically also counts as this objection. We do not use open or click measurement. The sending service provider is Resend (section 5).

18. Team features

If you create or join a team:

• All team members see each other's name, profile picture and email address.
• The team owner additionally sees join requests (email, name, message) and the billing data of the team.
• For invitations, we store the email address of the invited person — even if they do not yet have an account — in order to deliver the invitation and verify its acceptance. In the invitation email, we inform the invited person from whom we received their address, what we use it for and what rights they have (Art. 14 GDPR).
• If the owner enables automatic joining via the company domain, new users with a matching company email address automatically become members at registration; we inform them of this in the join context.
• We log team actions (invitations, joins, removals) in a team history for traceability by the owner.
• Dictionary entries and snippets shared with the team are visible to all members — share only what the team is allowed to see. The same applies to further content that you share with your team in future (e.g. your own templates and chat flows of Conversation mode, once this function is active).

19. Referral program

When a referral link is opened, we first ask you on the referral page whether we may attribute the referral to you — and only where the attribution cookie can be used at all (in the browser of your Mac); on other devices, we show you the referral code directly without storing anything. Only if you choose “Yes” do we set the attribution cookie (lifetime 30 days, for our website only), so that the referral can be attributed to the referring person; on the referral page, you can remove the attribution again at any time. If you choose “No”, we instead set a decline marker, likewise valid for 30 days, which records your no together with the referral code concerned, and delete an attribution previously set for the same code; we continue to show you your code. Both decisions apply per code — with a referral link carrying a different code, we ask again. Storing your decision itself is technically necessary and requires no separate consent (Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG)). We additionally log your decision server-side with referral code, decision and time — without your IP address and without any link to your account. This makes the log not traceable to you personally, but attributable via the referral code to the referring person and therefore personal data of that person; we delete these log lines automatically after 24 months. You send invitations exclusively yourself via your own email program — we do not store or contact the invited addresses. For the abuse check of the program, we evaluate the technical usage values from section 14 (e.g. whether a referred person carries out real dictations). If a referred person withdraws from their purchase within the withdrawal period, a reward already granted is reversed for the referring person — we inform them of this by email.

Names and addresses in the referral program: If someone registers with your referral code, you see in the app the email address of their account, the status of the referral and the date; we inform you about progress and rewards using their first name. Conversely, we show your first name to every person who opens your referral link or code — on the referral page of our website and in the app — and mention it to the referred person in the welcome message; older referral codes contain your first name themselves. How long we retain referral records is stated in section 7.

Referrals in the iPhone app: In the iPhone app, you share your referral link via the iOS share sheet with apps of your choice or copy it; we send nothing in the process. The iPhone app does not accept a referral code and does not store one. If you have a subscription via the App Store, we cannot apply a reward there; it remains noted in your account.

20. Support and contact

Support, feedback and report requests from the app are transmitted by us with your account email address to our support mailbox; you receive a confirmation email. We store attachments (e.g. screenshots) for 90 days in access-protected storage. Original audio of a faulty dictation is transmitted only if you expressly select it when sending (off by default; 90 days of storage). A voluntarily attached diagnostic log can contain technical events, your account email and short text excerpts of recent dictations — send it along only if that is okay for you; if your dictation contains third-party data (e.g. patient or client data), check this particularly carefully. Replies to our emails are processed by our sending service provider (section 5).

iPhone app: In the iPhone app, you reach support via “Contact support”; the app then opens an email to our support address in which it already fills in the app and iOS version and your device model. You can also report a stored dictation to us from the app's history via “Report”: the app then transmits the ID of the dictation, your message, app and iOS version and the language and region setting of your iPhone; our server reads the recognized and the improved text of the dictation from your account for this, and we handle the report as described above. The app shows you the status of your report and our answer with the dictation. Where available in your app, it also asks you “Do you like WhispaWave?”: “Rate” opens Apple's own rating prompt; if you write us a message with “Give feedback”, the app transmits it with the app and iOS version and the language and region setting of your iPhone, and we handle it as described above. The app remembers on the iPhone when it asked and how you answered. The iPhone app does not transmit attachments, original audio or diagnostic logs to us; what you attach to your email yourself is up to you.

21. App updates, crash reports and error analysis

The app regularly checks for updates against our European update server (Hetzner/bunny.net). Only technically necessary details are transmitted in the process (app version, update request); a system profile transmission is deactivated. Updates are cryptographically signed.

Crash reports (only with your consent, off by default). If you turn on crash reports, after a crash the app sends a technical error report to our own error-analysis server — it runs on our own infrastructure at Hetzner in Germany; no external analysis service provider is involved. Before sending, the app removes personal details such as usernames and private file paths; no user identifier is transmitted. You can withdraw your consent at any time in the settings.

Server error logs. For the stability and security of our AI relay server, we record technical errors occurring there on the same own error-analysis server (legal basis: legitimate interest in IT security and troubleshooting, Art. 6(1)(f) GDPR). These logs are limited to technical details; dictation and conversation content does not belong in them.

iPhone app: You receive updates of the iPhone app via the App Store; our update server is not involved. The iPhone app contains no crash-report function of its own and sends no error reports to us. If you have agreed in the iOS Settings to share analytics data with app developers, Apple provides us with crash reports and aggregated usage statistics for the app; you control this sharing in iOS. If you take part in a test of the iPhone app via Apple's TestFlight, we receive from Apple the feedback, screenshots and crash reports that you send in the process, as well as the details that Apple makes available to us about testers.

22. Website, forms, server logs and cookies

Hosting and server logs. Our website is hosted at Vercel; delivery takes place via the EU region Frankfurt. When you visit, technically necessary access data is generated (IP address, time, page retrieved) — the legal basis is our legitimate interest in the secure operation of the website (Art. 6(1)(f) GDPR). The image files in our emails (for example small icons) are loaded, when you open them, from our own European server at Hetzner in Germany (section 5) — not from Vercel; your IP address is generated there in the process, we do not carry out any personal open measurement. Fonts are delivered with the website itself; no fonts are loaded from third-party servers (such as Google) at runtime.

Contact form. If you use our contact form, we process your details (email address, message, name if provided) in order to answer your request (Art. 6(1)(b) or (f) GDPR). Sending runs via our email service provider (section 5) into our contact mailbox. The retention period is governed by the table in section 7 (row “Contact form requests”).

Download link by email. If you open the download page on a device without macOS, you can have the download link sent to your email address. We use the address exclusively for the one-time sending of this email via our processor Resend (section 5) and do not store it beyond that; no sign-up to a newsletter takes place. The legal basis is Art. 6(1)(b) GDPR (fulfillment of your request). To protect against abuse, we limit requests per address and IP address (as a hash only, see section 4).

Job applications. If you apply via our careers page, we process your application data (name, email address, message or documents) exclusively to carry out the recruitment procedure (Section 26(1) of the German Federal Data Protection Act (BDSG), Art. 6(1)(b) GDPR). Transmission runs via our email service provider (section 5) into our applications mailbox. After the procedure is completed, we delete your application at the latest six months after the notification of completion; longer retention — for example for future positions — takes place only with your separate consent.

Newsletter sign-up via the website. For the newsletter sign-up via the website, the double opt-in procedure from section 17 applies: only after you click the confirmation link do we send newsletters. Until confirmation, we keep your address as an unconfirmed entry; if you do not complete the confirmation, we delete the entry (period: table in section 7). The subscriber list is held with our email service provider (section 5).

Online cancellation (Section 312k of the German Civil Code (BGB)). Via the cancellation page of our website, you can cancel ongoing contracts without signing in. For this, we process the details you enter (name, account email address, contract concerned, type of cancellation and — only for extraordinary cancellation — the reason, desired end date) in order to process your cancellation and to confirm receipt to you electronically without undue delay, with date and time (Art. 6(1)(b) and (c) GDPR in conjunction with § 312k BGB). You receive the acknowledgement of receipt on screen and by email; sending runs via our email service provider (section 5). We retain the cancellation notice and the acknowledgement of receipt as a contract document (period: table in section 7).

Account deletion without signing in. Via the “Delete account” page of our website, you can request the deletion of your account without signing in. If the email address you enter belongs to an account, we store your request (email address, time, result) and send you a confirmation link that is valid for 24 hours. Only after you click it do we start the deletion — as in the app, with the 30-day undo window (Art. 6(1)(c) GDPR in conjunction with Art. 17 GDPR). We keep the request as a received business letter, even if you do not confirm it (period: table in section 7).

Overload protection of the forms. To prevent automated abuse of our forms, we count requests per sender in short time windows. The rate limiting runs via our own EU database (Frankfurt, section 5); only pseudonymized check values (hash values) are stored — formed from your IP address (for IPv6 only from the network part) and, only for the newsletter sign-up, from a normalized form of your email address — no plain-text IP address and no plain-text email address. The counters expire automatically after a short time (seconds up to a maximum of 24 hours) and are deleted automatically at the latest on the following day; no evaluation for other purposes takes place. Legal basis: legitimate interest in preventing abuse (Art. 6(1)(f) GDPR).

Audience measurement (Plausible Analytics). To understand which pages of our website are visited and where visitors come from, we use Plausible Analytics from Plausible Insights OÜ (Tartu, Estonia). Plausible works without cookies, without access to your browser's storage and without a persistent identifier; we therefore do not ask for consent for it in the cookie banner (Section 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG) does not apply). Recorded per page view: page visited, referring page (referrer), browser and operating system family, device type and the approximate location (country, region, city), as well as clicks on external links and file downloads (such as the app installation file). Your IP address and your complete browser identifier are not stored; to recognize recurring visits within one day, Plausible forms a hash value from them with a random key that changes daily and is discarded after 24 hours. Processing takes place on servers in Germany (Falkenstein) and does not leave the EU; Plausible is our processor (Art. 28 GDPR). Script and measurement data run via our own domain. Legal basis: legitimate interest in evaluating and improving our website (Art. 6(1)(f) GDPR). You can object to the measurement at any time (Art. 21 GDPR, contact in section 1); only aggregated statistics without any personal reference remain with us.

Cookies. We use the following cookies on the website; the cookies of the ad measurement only after your consent in the cookie banner:

We do not use analytics cookies; the audience measurement with Plausible works without cookies (see above). For the attribution cookie, we obtain your consent directly when the referral link is opened (section 19). For the ad measurement, a cookie banner asks you on your first visit; as long as you do not consent, no advertising script loads and no advertising cookie is set.

Cookie banner and record. The banner offers you “Accept all” and “Necessary only” as equal options; under “Settings” you can select the category “Ad measurement” individually. We store your decision in the cookie ww_consent (182 days) and as a record on our server: a random ID of the banner, the chosen categories, the version of the prompt and the time, without IP address and without any link to your user account (Art. 7(1) GDPR; retention period: table in section 7). You can change or withdraw your decision at any time via “Cookie settings” in the footer of the website; on withdrawal, we delete the advertising cookies and stop the transmission to Meta. If we change the categories or texts of the banner, we ask you again.

Ad measurement with the Meta Pixel (only after consent). The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (“Meta”). If you consent, our website loads the Meta Pixel script from Meta's servers. When you visit our pages, Meta then receives: your IP address, browser and device details, the page visited and the referring page, the time, events such as the page view or a completed newsletter sign-up, and the pseudonymous cookie IDs _fbp and, if you came via a Meta ad, _fbc with the click ID of that ad. We do not transmit email addresses, names or other contact details to Meta and do not use Advanced Matching. Purposes: measuring whether and which of our ads on Facebook and Instagram lead to visits and sign-ups; improving the delivery of our ads; re-addressing visitors of our website with our ads. The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG), which you can withdraw at any time with effect for the future.

Server-side transmission (Conversions API). We additionally send the same events from our server to Meta so that the measurement is complete even if your browser blocks requests to Meta. The same details as via the pixel are transmitted in the process: IP address, browser identifier, page visited, event and time, as well as the cookie IDs _fbp and _fbc, supplemented by a random event ID with which Meta merges events reported twice. This transmission, too, takes place exclusively as long as your consent exists; our server checks it before every sending against your stored decision. We do not transmit email addresses or other contact details via this route either.

For the collection of this data on our website and its transmission to Meta, we are joint controllers with Meta (Art. 26 GDPR). The basis is Meta's addendum for controllers (Controller Addendum, facebook.com/legal/controller_addendum). Under it, Meta informs about the joint processing and enables your data subject rights (Art. 15 to 20 GDPR) for the data stored at Meta; you can contact Meta or us for this, we forward requests. The subsequent processing, in particular the assignment to your Meta account and the selection of ads, is Meta's sole responsibility; details, retention periods at Meta and your ad settings can be found in Meta's Privacy Policy at facebook.com/privacy/policy. For the transfer to the USA, see section 6.

23. Local data and permissions on your device

For full transparency — this data stays on your Mac and does not reach our servers:

• Permissions: WhispaWave uses your microphone (recording only while you hold down the dictation key or actively start the recording — no continuous recording), the macOS Accessibility features (to insert the text, to detect the dictation key, for the optional context awareness, to arrange your browser window next to the note window when you join a meeting, and for meeting detection to check Firefox window titles — next point) and, in Conversation mode, screen/system audio recording (section 11). Your other keyboard input is not recorded.
• Meeting detection (optional): So that WhispaWave can ask you whether you want to take notes of a conversation, the app checks on your Mac which app is currently using your microphone. If a browser is using the microphone, the app checks the addresses of the open tabs of your running browsers once for meeting links (Google Meet, Zoom, Microsoft Teams, Webex) — in Firefox only the window titles — and remembers for a short time only whether a meeting service is open. It does not read page content, your history or other addresses, none of this is stored or transmitted, and nothing is listened to. The tab check in Safari, Chrome, Edge, Brave, Arc, Dia, Opera and Vivaldi requires the macOS “Automation” permission for the respective browser; WhispaWave does not ask you for it on its own — without it, the tab check is skipped and the app only asks in general whether you want to take notes. For Firefox it uses the Accessibility features. You can turn meeting detection off in the settings under “Meetings” with “Detect meetings automatically”.
• Calendar (optional): If you connect Apple Calendar, the app reads the events of your Mac's Calendar app on your Mac; when a recording starts, a one-time snapshot of the matching event is stored locally with the conversation. Event details are transmitted to our servers or the AI provider only if you have turned on the calendar switch in the settings — which ones, what for and how you end the access is described in section 11 (“Apple Calendar”). The app writes entries to your calendar only after you have expressly confirmed the specific suggestion — or, if you turn on “Create events automatically” in the settings, for events that were clearly agreed in the chat; it shows every event created this way in the chat with “Undo”. Whether a time is free in your calendar on the Mac is checked by the app on your Mac. If the app reads your calendar through macOS, we do not store it on our servers; if you connect Google Calendar directly, section 11 applies (“Connecting Google Calendar directly”). If the app links a recording to an event, the title and participants of that event become part of the conversation and are stored with it — in the cloud tier, also in your account (section 11).
• Suggestion for recurring events: If you create a note with a template you chose for an event that belongs to a series, the Mac app remembers this only on your Mac and only for the signed-in account: the series and the event as hash values (SHA-256), the template, how often you used it for this and whether you hid the suggestion — without a calendar identifier, without any date or time and for at most 300 series. This lets the app suggest the same template for the next event of the same series; the template is applied only when you click. None of this reaches us. When you sign out or switch accounts, the app deletes this information.
• Clipboard: To insert text, the app briefly saves the previous content of your clipboard in memory and restores it afterwards; it is neither stored nor transmitted.
• Local files: notes database, conversation data (transcripts, meeting notes and chat histories — stored encrypted as a rule; the key is in your macOS Keychain) and a technical diagnostic log (limited in size; leaves your device only if you attach it to a support ticket — section 20). If the Keychain is exceptionally unavailable, the app stores your conversations unencrypted so that nothing is lost; it then keeps chat histories, filled-in forms and the details of files you attached under “My notes” only while it is running. For conversations, your 3-tier storage choice from section 11 additionally applies — with “Never store”, nothing is stored permanently locally either. Via “Reset app” in the settings you can delete this local data; sign-in and settings are retained in the process.
• Installation and device IDs: Two randomly generated identifiers that are not derived from characteristics of your hardware: one for allowances, abuse protection (strictly necessary for the secure operation of the service) and the gradual rollout of new functions, which we store in our device registry together with the device model (section 14), and a second one that serves exclusively for the security notification when signing in from a new device (random identifier from your macOS Keychain, stored with us only as a hash value).

iPhone: Which data the iPhone app and the WhispaWave keyboard store on your iPhone, which permissions they use and which information they read on your device is described in section 25. The statements in this section on the microphone, the macOS Accessibility features, meeting detection, the calendar, the clipboard, the local files and the identifiers apply only to the Mac; on the iPhone, the microphone can remain ready after a dictation (“Wave”), and how the iPhone app uses your calendar is also described in section 25.

24. Changes to this Privacy Policy

We adapt this Privacy Policy as soon as changes to our data processing require it. We inform you of material changes by email; the current version can always be found at whispawave.de/datenschutz. We store the version you have acknowledged, with the date.

25. Additional information for the iPhone app and the WhispaWave keyboard

Scope. This section supplements the other sections for the WhispaWave app for the iPhone and the WhispaWave keyboard installed with it; where it says something different, it takes precedence for the iPhone. Everything not described differently here — such as the controller, recipients, your rights, abuse detection and minimum age — applies unchanged to the iPhone app. The direct connection to Google Calendar, the crash-report function and the update function of the Mac do not exist in the iPhone app; it includes the calendar of your iPhone in its own way (below, “Calendar on the iPhone”). The switch “Context from the text field” (section 12) takes the place of the Mac's context awareness, and the function “Learn words from corrections” takes the place of the Mac's automatic dictionary learning (below and section 13).

Consent before the first AI processing. Before the iPhone app transmits audio or text to our AI providers for the first time, it explains the AI processing to you and asks for your consent. Without consent, the app transmits nothing for AI processing; dictation, conversations and the other AI functions are then not available. The consent expressly also covers information about your health and other special categories of personal data about you, insofar as you dictate or record them (Art. 9(2)(a) GDPR, section 26). We store your consent and a withdrawal with time and version in our consent log; they apply to the iPhone app on all your devices. If you consented to an earlier version of the consent text, the app asks you once again. Before the app uploads a recording or starts a new AI request, it checks again whether your consent exists. You can withdraw it at any time under Settings → Data & Privacy → “AI processing in the EU” → “Withdraw”, as soon as the app has an internet connection for it; after that, the app starts no new AI processing until you consent again. An analysis already in progress, such as the note for a conversation just transmitted, may still be completed. The lawfulness of the processing carried out up to the withdrawal remains unaffected (Art. 7(3) GDPR). Before the first chat, the app additionally points out to you that you are chatting with an AI assistant and that answers may contain errors, and shows a corresponding notice in the chat permanently.

Dictation on the iPhone. You start a dictation in the app, via the WhispaWave keyboard, via “Quick Dictation” (as a Shortcut, for example on the Action button, or as a control in Control Center or on the Lock Screen), via the “Dictation” widget on the Lock Screen or via “Record note” in the expanded view of the Live Activity in the Dynamic Island (both open the app). The app then records via the microphone and first checks on the iPhone whether the recording contains speech: if it finds neither speech nor a signal that sounds like quiet speech (such as whispering), it discards the recording without transmitting it; if it cannot check the recording, it transmits it anyway. Otherwise it transmits the recording, the chosen dictation language and up to 100 terms from your dictionary via our AI relay server to our AI providers in the EU (section 5), which recognize text from it. The app then has the recognized text improved or translated (section 10) and additionally transmits for this your chosen style, the category, the cleanup level, up to 500 terms from your dictionary and, for a translation, the languages. The iPhone app does not transmit, at dictation, which application you dictate into; text from the text field you dictate into only if you have turned on “Context from the text field” (section 12).

Storage of your dictations. The iPhone app does not create a dictation history on the device. Only if it cannot store a dictation in your account for lack of an internet connection does it keep it, with its texts and technical details but without the recording, encrypted in a queue on the iPhone and transmits it as soon as it is online again; if the key for this is not available at the moment, it keeps it only in memory. Such dictations remain at most for as long as your history would keep them (with “Auto-delete (24 h)” 24 hours, with “Keep permanently” 30 days); on sign-out and with a request for account deletion, the app deletes them immediately, and it does not include them in the backup of your iPhone. In Private Mode, with “Never store”, for practice dictations and for “Compose”, this does not happen. In your account, it stores a dictation according to the storage setting of your account (sections 7 and 10); the choice between “Keep permanently”, “Auto-delete (24 h)” and “Never store” is not offered by the iPhone app itself. If you have not chosen a different setting (for example on the Mac), “Auto-delete (24 h)” applies. Stored are the recognized and the improved text, language, duration, the chosen category and technical details of the processing (such as models used and processing times). If you turn on “Private Mode” under Settings → Data & Privacy — this also happens if you choose “Private Mode” during setup —, the app no longer stores dictation texts in your account, only word count and duration (section 14), and we delete your dictations already stored (permanently within 30 days). We never store practice dictations during setup. If you dictate into a note or use “Record note” in the Dynamic Island, the app stores the text as a note in your account (section 13), also in Private Mode, because you are creating a note yourself in doing so.

History. The iPhone app displays the dictations stored in your account in its history. There you can copy a dictation, delete it (it then disappears on all your devices), report it (section 20), restore a dictation that was canceled on another device or have a dictation reformatted with your current style. When reformatting, the app transmits the stored recognized text with style, category, cleanup level, language and terms from your dictionary via our AI relay server to our AI providers in the EU (section 5) and replaces the improved text in your account. This is possible at most five times within 24 hours; we log every attempt with the dictation, on success together with the new text, until the dictation is permanently deleted.

The WhispaWave keyboard. The keyboard is an iOS keyboard extension of the app and contains no network functions: it sends nothing to the internet itself and does not record your input. What you type, it enters into the respective text field; of that, it remembers only the individual words named below. It reads the text before and after the insertion point exclusively on the iPhone in order to enable capitalization, autocorrection, text replacements, deleting whole words and undo; it does not transmit it, with two exceptions: if you have turned on “Context from the text field”, it passes up to 500 characters before the cursor to the app when you start a dictation (section 12); if you have consented to “Learn words from corrections”, it passes individual words that you correct in a dictation after it was inserted (below, “Learn words from corrections”). For autocorrection, it uses the spell checker and the word suggestions of iOS as well as its own word lists on the device. With full access, it remembers in the storage area shared with the app words whose correction you immediately undo and words that you write three times and leave in place although the correction would change them (at most 500 each, plus up to 300 words on the way there), as well as a copy of your dictionary terms, so that it no longer corrects these words. All of this stays on the iPhone; you delete the remembered and learned words under Settings → Keyboard → “Reset keyboard dictionary”, and on sign-out the app deletes all of it. It offers undo for an inserted dictation, draft or Action button result for at most five minutes; the details remembered for this — the inserted text and the selected text it replaced — it keeps only in memory, until you start the next dictation, sign out or iOS terminates the keyboard. The text replacements and the names from your contacts that iOS makes available to every keyboard, it uses only in memory, for example so that it does not correct names. In password fields, iOS always uses the system keyboard.

Full Access. For typing, the keyboard does not need “Full Access”. The full access that you grant in the iOS Settings, it uses for dictations and the collaboration with the app: via a protected storage area that only the components of the WhispaWave app on your iPhone share, it exchanges dictation starts (each with a single-use start ID) and results, drafts, your settings (such as category, languages and translation target), Action button results, the time since which it has been shown, for “Compose” the selected text, a selected word that you add with “Add to dictionary” and, with your consent to “Learn words from corrections”, the corrected words with the app; it also uses it to give haptic feedback and to remember the words named above there. Even without full access, it reports to the app, without content, when it is shown or hidden. The keyboard transmits nothing to the internet even with full access. If you tap the microphone in the keyboard and the microphone is not already ready (see “Wave”), it opens the WhispaWave app, because iOS does not allow keyboards to record from the microphone; the app records and passes the result via the shared storage area to the keyboard, which inserts it into your text field. When the keyboard opens the app in this way, the app shows you how to get back to your app. If iOS tells the app the identifier of the app you are coming from (newer iOS versions do not), the app keeps this detail in memory for at most one minute in order to bring you back after the dictation: for known apps from a fixed list, it opens their app address for this without passing any data (the first time, iOS asks you for permission). The detail is not transmitted; in the diagnostic log on the device, the app notes the identifier (such as “com.apple.mobilenotes”).

Compose and Rewrite. Where available in your app, WhispaWave composes texts with “Compose” (in the keyboard and in the note editor) according to your spoken instruction; with “Rewrite”, it rephrases in the keyboard a text that you have selected, that you have copied or that you have just dictated. The keyboard receives a selected text from iOS; for longer selections, iOS provides it only incompletely. The keyboard then asks you to copy the selected text and, the next time you tap “Rewrite”, reads the clipboard once, but only if iOS reports that there is text there, only in ordinary text fields and only if the content demonstrably matches your selection and is no longer than 5,000 characters; iOS may ask you for permission to paste in the process. At other times, the keyboard does not read the clipboard, and it does not store or log its content. The keyboard passes the selected or copied text via the shared storage area to the app. The app transmits your spoken instruction (as audio for speech recognition), where applicable the selected or copied text, your first and last name from your profile (if entered, for texts in your name), the chosen form (such as length and tone) and, for a follow-up instruction, the previous instructions and drafts of the same operation (at most ten minutes after your last instruction) to our AI providers in the EU (section 5). We do not store the instruction and the draft in your account; a draft reaches your text field or your note only when you insert it.

Ready microphone after a keyboard dictation (“Wave”). So that you can start further dictations directly in the keyboard without switching to the app every time, the app keeps the microphone ready after a dictation via the keyboard; on the app's home screen, you can also turn this on with “Wave”. If you select an app when trying things out, the app turns Wave on before the switch and off again if you return without a dictation. As long as the microphone is ready, iOS shows the orange microphone indicator, and the app shows “Ready to dictate” on the Lock Screen, provided you allow Live Activities. During this time, the app continuously discards the microphone audio in memory: it stores nothing and transmits nothing; recording only begins when you start a dictation. The readiness ends when you end Wave in the app, in the keyboard or via the Live Activity, on an interruption by iOS (such as a call), on sign-out and, after a dictation, automatically after the set time (Settings → Dictation → “End Wave”: immediately, after 5 minutes, after 15 minutes, after 1 hour or never; default: after 15 minutes).

Shortcuts, Action button and Live Activity. With “Quick Dictation”, which you can assign to the Action button, for example, or place as a control in Control Center or on the Lock Screen, you record a dictation without opening the app. If the WhispaWave keyboard is shown at that moment, the app passes the result to it, and the keyboard inserts it into the text field. Otherwise, the app copies the result to the iOS clipboard if it is open at that moment; it does not restore the previous content of the clipboard in the process. If it is running in the background, iOS does not allow it to do so: the Dynamic Island then shows “Not copied”, and a tap on it opens the text in the app, where you move it to the clipboard with “Copy”; until then, the app keeps it only in memory, for at most ten minutes. If the text is not in the text field or your Shortcut asks for a copy, the app also returns it to the Shortcut. The app itself reads nothing from the clipboard; the keyboard only in the case described above under “Compose and Rewrite”. The Live Activity on the Lock Screen and in the Dynamic Island shows only the status (such as “I'm listening”), the duration and controls, but no dictated text.

Conversations on the iPhone. The app records conversations via the microphone, even if you lock your iPhone or switch apps; you can also start a meeting via the control or the “New note” widgets. After you stop, it transmits the recording for transcription with speaker separation to our AI providers in the EU (section 5), without terms from your dictionary, then the beginning of the transcript so that they suggest a title for the meeting, and then the transcript with the chosen template and the context details named below under “Questions about conversations” for the creation of the meeting note. What you write under “My notes” for a meeting, the app stores only encrypted on your iPhone, never in your account, and transmits it only with your own requests for the note and the chat of this meeting. The app deletes the recording after successful processing; if processing fails, it keeps it on the iPhone so that you can try again or export the recording, until you discard it, sign out or open the app again after 24 hours have elapsed (section 7). The app stores transcripts, notes and chat histories encrypted as a rule on your iPhone, also in Private Mode. If you choose “Never store” as the storage location (below), it keeps a conversation only in memory until you leave the app or iOS terminates it.

Storage location for meetings. Under Settings → Data & Privacy → “Storage location for meetings”, you choose between “Only on this iPhone” (default on a new iPhone), “In the cloud (all devices)” and “Never store”. This choice applies to your account, so also on the Mac (section 11): a stricter choice on another device is adopted by the iPhone automatically, a less strict one only with a notice to you. If you choose “In the cloud (all devices)”, we store the title, transcript with speaker labels, notes, tasks, speaker details, the participants (name, e-mail address) and the language of your conversations in your account, including those already existing, so that they are available on your other devices; the audio recording does not reach your account. We log every change of this choice as a record of consent (section 11); if that is not possible at the moment, the app catches up as soon as it is online again. In Professional Secrecy Mode and with a team policy against the cloud, the cloud is not available as an option; after a request for account deletion, synchronization pauses. The iPhone app does not synchronize chat histories. The iPhone app has a search index over your conversations stored in the cloud (section 11) created only if you have agreed to search across conversations, in the iPhone app under Settings → Data & Privacy → “Questions about meetings” or in the Mac app; if you turn off “Questions about meetings” on the iPhone, this iPhone no longer creates an index. The index has the conversation content converted segment by segment into sequences of numbers (vectors) by our AI provider and stores these together with position details, check values, the word stems per segment and the subheadings of your notes in your account; the index does not additionally store any further text (retention period: section 7).

Questions about conversations. Where available in your app, you can ask questions about a conversation. For this, the app transmits your question, the transcript, the note with its tasks, your notes under “My notes”, the shortened previous chat history, the language of your app and, where applicable, a summary of older messages created by our AI providers, as well as, insofar as this function is active, context details: the names of the speakers and which of them is you, your first and last name, your professional field and your role from your profile (if entered), the date, time and time zone, the date of the recording and, only with “Include events” turned on, the details of the linked event (below, “Calendar on the iPhone”; section 5). The iPhone app does not send your dictionary terms, a live transcript segment or summaries of earlier meetings in the process. The app transmits the same context details when it creates a meeting note. You can also ask questions about all your meetings: for this, the app transmits your question and the previous history of this chat, and our server uses the search index to find matching passages in the meetings stored in your account (section 11); the app stores the histories of this chat only on the iPhone, at most 30. You can also rate answers and meeting notes (“Was this note helpful?”) with thumbs on the iPhone; section 11 applies to these ratings — we store them without content and delete them after 12 months.

Calendar on the iPhone. If you connect your calendar (“Connect calendar”), iOS asks you whether the app may access it. With your permission, the app reads on the iPhone the events from now until the end of the next day: title, start and end, whether an event is all-day or canceled, the color of its calendar and the participants (name, e-mail address and whether they have declined; rooms and other resources do not count as participants). With them, it shows you upcoming events, links a recording to the event that is running or begins within the next ten minutes, and announces an event shortly beforehand on the Lock Screen and in the Dynamic Island (can be turned off under Settings → Notifications & sounds → “Upcoming events”); the app plans this announcement on the iPhone, without our servers, and the title of the event does not leave the device for it. The app does not store or transmit the calendar itself. If it links a recording to an event, it keeps that event's title, time span and participants encrypted on the iPhone; the participants (name, e-mail address, without people who have declined) then belong to the meeting, you can change them and add people yourself, and in the cloud tier we store them with the meeting in your account (section 11). The app does not take the title of the event as the title of the meeting. Only if “Include events” is turned on under Settings → Meetings (this also happens when you tap “Connect calendar”) does the app transmit, with the note and the chat of this meeting, the title and time span of the event, the names of the other participants (if a name is missing, the part of the e-mail address before the “@”), the companies their e-mail addresses belong to (as an internet domain, without general e-mail providers) and, in a conversation between two people, the name of the other person to our AI providers in the EU (section 5); if you turn it off, this ends with the next request. Legal basis: for your own details, performance of a contract (Art. 6(1)(b) GDPR); for the details of the other participants, our and your legitimate interest in a complete meeting note (Art. 6(1)(f) GDPR); for sending them as context, your consent via the switch (Art. 6(1)(a) GDPR), which you can withdraw with the switch at any time.

Learn words from corrections. Under Settings → Data & Privacy, you can turn on “Learn words from corrections”; beforehand, the app shows you the consent text. Your consent applies to your account, so also if you gave it in the Mac app; you can withdraw it with the same switch. Once it is given and the keyboard has full access, the WhispaWave keyboard watches for one minute after a dictation it inserted whether you correct a word in it with the keyboard; corrections with another keyboard do not count. It then passes only the recognized and the corrected word with up to 120 characters of surrounding text to the app, at most four such pairs per dictation, never the rest of the text field. The app has these words checked by our AI provider in the EU via our server (section 5); nothing is stored there. If the provider classifies a word as a speech-recognition error, the app adds it to your dictionary (section 13); without an internet connection, it discards the pairs. In Private Mode, with “Never store” and in Professional Secrecy Mode, the keyboard watches nothing. The legal basis is your consent (Art. 6(1)(a) GDPR).

Setup and notifications. During setup, the app suggests the languages of the keyboards you have enabled in iOS; the languages you adopt, it stores as your favorite languages on the iPhone (section 13). The app uses your answers to the setup questions (for example about your work environment) to suggest suitable default settings to you and to tailor its tips to you; if you are already signed in at that point, we store them in your account. After your account is created, the app also asks you how you heard about WhispaWave. The answer is voluntary (you can skip the question), consists only of a choice of fixed answers without free text and is transmitted for your profile together with its position in the randomly shuffled list, so that we learn through which channels users find us; currently our server does not yet accept this detail, so it is not stored. If your free trial period begins during setup, we record in your account and with the hash value of your email address (section 7) that you started it on a mobile device. To guide you through the setup of the keyboard, the app reads on the iPhone which keyboards are enabled in iOS; it does not store or transmit this list. To offer you apps to try out and to bring you back there after a keyboard dictation, the app checks on the iPhone which apps from a fixed list of common apps (such as email, messenger and notes apps) are installed; it keeps the result only in memory, and in the diagnostic log on the device it notes only the number and the app you select to try out. If you allow notifications, the app schedules individual notifications exclusively on the iPhone: one after your first dictation in another app, a reminder to set up the keyboard and a few tips in the first week, at most one a day and at most four in total; so that no tip appears during a call, the app checks on the iPhone whether a call is in progress and remembers nothing of it. During the 7-day challenge (section 14), the app also sends you a reminder on days on which you are still missing words on the iPhone; it belongs to the tips, and with it, too, at most one of these notifications comes per day. So that it fits your day, the app remembers, only on the iPhone, at which minute you first dictated outside WhispaWave on each of the last 14 days, without text and without app names; this information never leaves your iPhone, in Private Mode and with “Never store” the app learns nothing new, and the app deletes it as soon as the challenge ends, you sign out or the reminder can no longer come. If the app is running in the background, it also notifies you when the analysis of a meeting is finished or a recording reaches its limit. None of these notifications contains content of your dictations or meetings; you can turn the reminder and the tips off individually under Settings → Notifications & sounds. There are no push notifications from our servers. In the app, we additionally show you notifications about your account (such as about your team, referrals or your subscription), which our servers place in your account and which you can mark as read or archive there.

What the app stores and reads on your iPhone. In the iOS Keychain, the app stores your sign-in, the random installation ID (for allowances, abuse protection and the gradual rollout of new functions, sections 14 and 15), a random device ID for the warning when signing in on a new device (stored with us as a hash value with device type and iOS version), the key for your local conversation data and dictations not yet transmitted, and a key that protects your cached subscription status. In its files, it stores your conversations and chat histories (encrypted as a rule; if the Keychain is exceptionally unavailable, unencrypted so that nothing is lost), “My notes”, the events linked to meetings and dictations not yet transmitted (exclusively encrypted, otherwise only in memory), temporarily recordings (section 7), tutorial videos for trying things out and a technical diagnostic log that can contain device and app details (such as the device model), shortened IDs of your account and your conversations, operating states, the number of detected apps, the app chosen to try out and the identifier of the app from which you started a keyboard dictation; the log does not leave your iPhone, but the app additionally outputs its entries to the iOS system log, in App Store and TestFlight versions without readable text. In its settings and in the storage area shared with the keyboard are your settings (including those of the keyboard), cached details on subscription, allowances and usage figures of your account, today's state of your 7-day challenge with your word count of the day (until you sign out) and the minutes for its reminder (see above), the handovers between keyboard and app (including selected or copied text, the text excerpt before the cursor, Action button results, start IDs, words for “Add to dictionary” and, with your consent, corrected words for “Learn words from corrections”), the words remembered and learned by the keyboard and a copy of your dictionary terms, the time since which the keyboard has been shown, during a recording the name of the microphone used (such as your headphones), during a registration your email address until confirmation, the identifier of your Apple sign-in, which conversations have already been processed for search, which notifications, event announcements (only as hash values) and rating questions it has already shown you, and technical state details such as the setup progress and the status of your AI consent, each with the ID of your account. In addition, as described above, the app reads your calendar with your permission and, for the notifications, whether a call is in progress. For the security check at sign-in (section 9), the app uses an invisible web view in whose storage Cloudflare can place data. These storage operations and the read operations described in this section serve to provide you with the functions of the app you have requested (§ 25(2) no. 2 TDDDG), and no advertising purposes; we additionally use the installation ID and the device model to evaluate on which platforms WhispaWave is used (section 14). At the first launch after a reinstallation, the app deletes earlier entries in the Keychain; you then begin signed out and with new identifiers. After a restart of your iPhone, the app reads and writes none of this before you have unlocked the iPhone once.

Sign-out, account deletion and device backup. If you sign out in the app or request the deletion of your account there, the app removes your personal data from this iPhone: the sign-in, your conversations, “My notes”, the events linked to meetings and chat histories together with their key, recordings after failed processing, dictations not yet transmitted (before sign-out, it tries once to transmit them and tells you beforehand what may be lost), the diagnostic log, scheduled notifications, cached subscription and usage details, all handovers between keyboard and app (including selected or copied text and the text excerpt before the cursor), the words remembered and learned by the keyboard, the status of your AI consent on the device and the identifier of your Apple sign-in, and with an account deletion also when it asked you for a rating; the keyboard then also discards its drafts and the undo details. Your settings remain until you remove the app. If, by contrast, your sign-in expires without any action on your part, your encrypted conversation data is retained for your next sign-in. iOS can include your encrypted conversation data and your settings in the backup of your iPhone (such as an iCloud backup); the key for this is bound to this iPhone and cannot be transferred to another device, so the data from a backup is not readable on another device. The app excludes dictations not yet transmitted and recordings after failed processing from the backup.

Permissions. The app asks for access to the microphone and, optionally, for notifications and, if you connect your calendar, for full access to your calendar; the keyboard needs Full Access for dictations. The iPhone app does not access contacts, photos, location or camera; the keyboard uses only the names from your contacts that iOS makes available to every keyboard (see above). You can change all permissions in the iOS Settings at any time: without the microphone you cannot dictate, without full access not via the keyboard, and without calendar access the app shows no events; you can still type with the keyboard.

Your rights in the iPhone app. How you delete your account in the iPhone app, obtain a data export and withdraw your consent to AI processing is stated in section 8; all other rights from section 8 apply unchanged.

26. Health data and other special categories of personal data

(1) What this is about. Under Art. 9(1) GDPR, special categories of personal data are data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for unique identification, data concerning health and data concerning sex life or sexual orientation; for users in Switzerland this section applies accordingly to particularly sensitive personal data (Art. 5 lit. c Swiss FADP). WhispaWave never asks for such data. They can, however, appear in your content (dictations, conversation recordings, transcripts, notes, questions to the assistant) when you or others say them or you type them. Some templates for meeting notes are expressly meant for documentation in which health data regularly appear: “SOAP Note (Medicine / Therapy)”, “Informed consent discussion (§ 630e BGB)” and “BEM meeting (§ 167 SGB IX)”. You can likewise dictate, for example, findings, medical letters or therapy reports.

(2) Professional use: data of your patients, clients or employees. If you use WhispaWave professionally to process health data or other special categories of other people, for example as a physician, psychotherapist, physiotherapist, nurse or as an employer in occupational reintegration management (BEM), you are the controller for these data. We process them exclusively on your behalf and on your instructions as processor (Art. 28 GDPR); our data processing agreement (AVV) (in German) applies (§ 2 on special categories, § 6 on confidentiality under Section 203 of the German Criminal Code). The permission for the processing under Art. 9(2) GDPR lies with you, for example in health care Art. 9(2)(h) and (3) GDPR in conjunction with Section 22(1) no. 1(b) of the German Federal Data Protection Act (BDSG), or in occupational reintegration management the consent of the person concerned (Section 167(2) of Book IX of the German Social Code). It is also up to you to inform the people concerned (Art. 13 and 14 GDPR) and to obtain their consent before recording a conversation (Section 201 of the German Criminal Code, section 11). If you are bound by professional secrecy, we commit to confidentiality towards you as a contributing person under § 6 of the data processing agreement (Section 203(3) and (4) of the German Criminal Code). We recommend the Professional Secrecy Mode, which you turn on in the Mac app (section 10): we then store no dictations, and in the iPhone app the cloud is not available for conversations (section 25). Whether the use is compatible with your professional duty of secrecy in an individual case is for you to judge.

(3) Information about your own health. If your content contains information about your own health or other special categories about you, we process it as controller only to perform the function you start or turn on and to store it according to your storage settings. In the iPhone app the legal basis is your explicit consent (Art. 9(2)(a) GDPR), which you give with the consent to AI processing; the consent text names this information expressly (section 25). You can withdraw the consent at any time under Settings → Data & Privacy → “AI processing in the EU” → “Withdraw”; the app then starts no new AI processing, and the lawfulness of the processing carried out until then remains unaffected (Art. 7(3) GDPR).

(4) What we use these data for. We process such information like all other content and for no other purpose: speech recognition, text improvement, translation, creating notes, preparation before appointments and answering your questions and, if you set it so, storage in your account. The templates named in paragraph 1 record what was said in the conversation; they make no diagnoses of their own and recommend no treatment. We do not analyse such information for purposes of our own, do not use it for advertising and pass it on only as paragraph 5 describes. The memory (section 11) records details about you so that chat answers match you: an entry that it recognizes as a detail about health, finances, family, religion, origin or intimate matters is never kept on its own, but only if you explicitly have it stored with “Merk dir …” or “Keep” — your explicit consent applies to this (Art. 9(2)(a) GDPR), which you withdraw by deleting the entry —, and we never pass such an entry on to the AI; the detection can miss a detail. We do not look at your content; the only exceptions are a report or a support request that you send yourself (section 20) and a template that you publish in the community or that is reported there (section 11).

(5) Service providers and place of processing. For this content we use the same service providers as for your other content (section 5): for AI processing our own AI relay server at Hetzner Online GmbH in Germany and our AI providers in the EU, for stored content our database at Supabase in Frankfurt am Main. Section 5 applies to these services and, on possible access by parent companies in the USA, section 6. Other recipients receive content only in the cases described in sections 5, 11, 20 and 25, for example when you share a conversation or attach content to a support request yourself.

(6) Storage period. We store health data and other special categories no longer than the content in which they appear (section 7): audio recordings never permanently on our servers; dictations according to your account's storage setting, in the default “Auto-delete (24 h)” removed from your history after 24 to 48 hours and permanently from our servers about 30 days later, in Private Mode, with “Never store” and in Professional Secrecy Mode not at all; conversations in the iPhone app by default only encrypted on your iPhone, on the Mac according to your choice from section 11, in the cloud tier until you delete them (permanent removal within 30 days); notes, dictionary terms and snippets until you delete them; the search index over conversations until you delete the conversation or the index. Our AI providers do not store inputs and outputs permanently (section 5). If you delete your account, we permanently delete your content after the 30-day window (section 7).

(7) Safeguards. In addition to section 4: transmission only encrypted (TLS); stored content can technically be read only by your account unless you share it yourself (row-level access control in the database); conversations stored locally are encrypted as a rule (sections 23 and 25); no access keys to AI services in the app. The template “SOAP Note (Medicine / Therapy)” is designed to use initials instead of full names and to include diagnoses or ICD-10-GM codes only when they were named in the conversation. For controllers who process special categories we additionally observe the protection level of Section 22(2) BDSG (data processing agreement, § 5).

(8) Your rights. Your rights under section 8 apply unchanged. For data that a physician, therapist or employer processes about you with WhispaWave, contact that body as controller; we support them in this (§ 7 of the data processing agreement).