Privacy Policy

Last updated: April 16, 2026

Facet ("we", "our", "the app") is a personal journaling app for iOS. Your privacy is fundamental to how we built Facet. This policy explains what data we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

Data Controller

Data controller in the sense of Art. 4 (7) GDPR is:
Michael Becker
Obere Dorfstr. 6B
90427 Nuremberg, Germany
Email: support@facetjournal.app

1. Data Storage

Your journal entries, mood data, streaks, achievements, and time capsule letters are stored locally on your device using Apple's SwiftData framework. If you have iCloud enabled, this data syncs to your personal iCloud account via Apple's CloudKit. We never have access to your iCloud data.

2. Data Sent to External Services (Sub-Processor: Anthropic)

Facet uses AI to provide mood analysis, weekly and monthly insights, personalized prompts, and chat functionality. When these features are used, the following data is sent to our secure API proxy server, which forwards it to the AI service for processing:

Your journal entry text and mood level
AI-generated tags associated with your entries
If Apple Health is connected: aggregated sleep hours, step counts, and workout minutes for the relevant period

Sub-Processor: Anthropic, PBC, 548 Market Street PMB 90375, San Francisco, CA 94104, USA (provider of the Claude API).

Legal basis: Art. 6 (1)(b) GDPR (performance of contract — providing AI features you requested) and Art. 6 (1)(f) GDPR (legitimate interest in offering functional journaling features).

Third-country transfer: Data is transferred to the United States. The transfer is based on the EU Standard Contractual Clauses (SCCs) concluded with Anthropic and the EU-U.S. Data Privacy Framework (Anthropic is certified participant).

Retention: Anthropic does not retain API inputs or outputs beyond processing (per Anthropic's Commercial Terms: zero-retention for API traffic by default; up to 30 days for Trust & Safety review in case of abuse). Our proxy server does not log or retain your journal content. Data is transmitted using HTTPS / TLS encryption.

3. Health Data

If you choose to connect Apple Health, Facet:

Reads sleep duration, step count, and workout minutes to correlate with your mood
Writes mindful session entries to Apple Health when you save a journal entry (tracking your journaling time as mindfulness)
May include aggregated health metrics (sleep, steps, workouts) in AI insight requests as described in Section 2
Never uses health data for advertising or marketing
Never shares health data with third parties beyond the AI processing described above

4. Data We Do NOT Collect

We do not collect your name, email, or any personal identifiers
We do not use analytics or tracking SDKs
We do not show advertisements
We do not sell or share any data with third parties
We do not use cookies or cross-app tracking

5. Subscriptions

Facet Pro subscriptions are handled entirely by Apple's App Store. We do not process or store any payment information. Subscription management is available through your Apple ID settings.

6. Data Storage and Security

All personal data is stored on your device and optionally in your personal iCloud account. Data transmitted to the AI service uses HTTPS encryption. We do not operate databases that store your personal information.

7. Children's Privacy

Facet is not directed at children under 13. We do not knowingly collect personal information from children.

8. Your Rights under GDPR

Since your journal data lives on your device and your personal iCloud account, you already have technical control. In addition, under the GDPR you have the following rights regarding any personal data we process (e.g. temporary processing via the AI service):

Right of access (Art. 15 GDPR) — request information about any data processed about you.
Right to rectification (Art. 16 GDPR) — have inaccurate data corrected.
Right to erasure (Art. 17 GDPR) — request deletion; exercisable directly by deleting the app (local + iCloud data) and by email request for any other data.
Right to restriction of processing (Art. 18 GDPR).
Right to data portability (Art. 20 GDPR) — your journal entries remain on your device in a portable format; on request we assist with export.
Right to object (Art. 21 GDPR) — object to processing based on legitimate interest at any time.
Right to withdraw consent (Art. 7 (3) GDPR) — where processing is based on consent, you may withdraw consent at any time with effect for the future.

To exercise any of these rights, contact support@facetjournal.app. We respond within 30 days as required by Art. 12 (3) GDPR.

9. Right to Lodge a Complaint

Under Art. 77 GDPR you have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

10. Changes to This Policy

We may update this policy from time to time. Changes will be posted on this page with an updated date.

11. Contact

If you have questions about this privacy policy, contact us at:
support@facetjournal.app

12. Legal Notice

For provider information required under German law (§ 5 TMG), see our Impressum.