Effective Date: 17 April 2026 Company: Aybilge OÜ Application: record2text

Aybilge OÜ (“we”, “us”, “our”) provides the record2text application. This Privacy Policy explains how we process personal data when you use the app. By using record2text, you acknowledge this Privacy Policy.

1. Data Controller Aybilge OÜ is the data controller for personal data processed through record2text, except where third-party providers act as independent controllers under their own terms, such as Apple or Google for store billing records. You can contact us at [email protected].

2. What Data We Process Depending on your use of the app, we may process account and identity data, including your Firebase Authentication user ID, your email address and display name if provided by your sign-in provider, and sign-in provider metadata from Google or Apple. We process audio files you record or upload for transcription, as well as transcribed text, AI-generated summaries, and related metadata like title, language, duration, status, and timestamps. We also handle subscription and entitlement data, including your plan type, billing cycle, expiry status, and in-app credit balances, along with purchase and entitlement status synchronized via Adapty and app stores. Additionally, we process local device preferences such as language preference, audio language preference, theme preference, onboarding state, and legacy local cache entries if present. Finally, we collect technical and security data, including basic logs and error information needed for service reliability, abuse prevention, and security.

3. Device Permissions (Transparent Use) record2text requests only permissions required for core functionality. The microphone permission is needed to record audio for transcription, and storage or media library access is required to let you select and upload existing audio files. We do not request unnecessary or intrusive permissions such as contacts, GPS/location, or camera.

4. Why We Process Your Data (GDPR Legal Bases) We process personal data under several GDPR legal bases. We rely on contract performance (Art. 6(1)(b) GDPR) to provide transcription, summaries, account access, and subscriptions. Legitimate interests (Art. 6(1)(f) GDPR) are used for service security, fraud prevention, diagnostics, and stability. We also process data to comply with legal obligations (Art. 6(1)(c) GDPR) regarding accounting and compliance where required, and we rely on your consent (Art. 6(1)(a) GDPR) where consent is required by platform or OS rules, such as for permission prompts.

5. AI Processing and OpenAI Statement record2text uses OpenAI API services to generate transcriptions and summaries. Your audio and text are sent to OpenAI only to deliver requested app features. Aybilge OÜ does not use your audio or text to train AI models, and we do not opt in to model training with your API content. We rely on OpenAI API terms under which API customer data is not used to train OpenAI models by default.

6. Infrastructure and Data Location Our Firebase backend architecture is configured in Europe, and Cloud Functions run in europe-west1. Core providers include Firebase for authentication, database, storage, and functions; Adapty for subscription management; OpenAI for AI transcription and summarization; and the Apple App Store or Google Play for in-app billing infrastructure. Where a provider processes data outside your country, we use contractual and legal safeguards expected under GDPR, such as standard contractual clauses where applicable.

7. Data Sharing We do not sell personal data. We share data only with service providers needed to operate record2text, and to understand how these providers handle your data, please review their respective privacy policies. These include Google Firebase and Google Cloud for backend services, OpenAI for AI features, Adapty for subscription state synchronization, and Apple or Google for the billing and store purchase lifecycle, which are subject to their standard privacy terms.

8. Retention and Deletion You can delete individual transcription records from within the app, or request full account deletion via the in-app “Delete My Account” flow. When account deletion succeeds, we remove user data from app-controlled systems, including Firebase Firestore user and transcription documents, Firebase Storage files under your user path, your Firebase Authentication account, device-side Adapty profile linkage, and local app preferences or cache. Temporary processing files are cleaned after processing workflows. Store operators and payment or subscription providers may retain transaction records as required by law or their own obligations.

9. Your GDPR Rights Subject to legal limits, you may request access to your personal data, rectification of inaccurate data, erasure or the right to be forgotten, restriction of processing, data portability, and objection to certain processing. You may also withdraw your consent where consent is the legal basis. To exercise these rights, contact [email protected].

10. Security We apply reasonable technical and organizational measures to protect personal data, including authenticated access controls and backend security rules. No system can be guaranteed 100% secure, but we continuously improve our controls.

11. Children record2text is not directed to children under the age required by applicable law in your jurisdiction for independent consent to digital services.

12. Changes to This Policy We may update this Privacy Policy from time to time. Material updates will be reflected with a revised Effective Date and, where required, additional notice.

13. Contact You can contact Aybilge OÜ via email at [email protected].