Last Updated: Jul 5, 2026
Effective Date: Feb 19, 2026
Data Controller: FeelEase (individual developer / sole proprietor)
Under GDPR Article 37, a Data Protection Officer is required for large-scale processing of special category data or large-scale systematic monitoring. FeelEase's processing does not meet either threshold, so we are not required to appoint a Data Protection Officer. For privacy inquiries contact contact@feelease.app.
Key Principle: Personal content stored locally on your device is controlled by you. We do not collect, access, or process your local journal entries, drawings, or saved insights on our servers.
We act as a data controller for processing that occurs when you opt in to use AI Companion features, as well as for support messages and voluntary feedback forms you submit.
FeelEase ("we", "us", "our") is committed to protecting your privacy and complying with applicable laws including the EU General Data Protection Regulation (GDPR), UK GDPR, CCPA/CPRA, COPPA (where applicable), and other international privacy regulations.
Our privacy-first approach:
The following data is stored only on your device and never transmitted to our servers:
| Data Category | Includes | Purpose | Storage |
|---|---|---|---|
| Mood & emotional data | Mood check-ins (mood state, optional notes, time of day, context), emotion tracking (emotion label, body location, intensity), mood history | Emotional self-awareness and tracking | Device only |
| Personal reflections | Journal entries, saved insights (from exercises and AI conversations), writing drafts, custom greetings | Personal expression and growth tracking | Device only |
| Visual content | User-created drawings (full-size images and thumbnails), card image snapshots saved with AI conversation insights | Visual emotional expression | Device only (local files) |
| AI conversation history | Chat message history and session context, stored locally during active sessions and in saved insights | Conversation continuity and personal reference | Device only |
| App preferences | Language, tone preference (Ukrainian language only), onboarding state, UI settings | App personalization | Device only |
| Usage statistics | Session count, app open timestamps, engagement actions count | App functionality (e.g. showing relevant prompts) | Device only (local, not sent to any server) |
| Self-care activity log | Which day you engaged in a self-care practice (mood check-in, journaling, cards, drawing, exercises) and its type | Powers the on-device day count shown in My Dynamics | Device only |
| Notification preferences | Whether reminders are turned on, your chosen daily check-in time, and which Week Review or Month Review already has a reminder scheduled | Remind you locally when a daily check-in or a saved Week/Month Review can actually be created | Device only, via iOS's local notification scheduler. These are local notifications only — nothing is sent to a push server. Notification text is fixed, app-provided wording; it never includes your mood, journal, or AI conversation content. |
My Dynamics (available with an active Subscription) shows patterns in what you've already saved — recurring themes, feelings, and what's helped — across your saved Week Review and Month Review content, together with the self-care activity count above. This view is generated entirely on your device: no AI model is used, and nothing is transmitted to us or to any third party to produce it. My Dynamics only reads data already described in this section (mood & emotional data, personal reflections, self-care activity log) — it does not collect any new category of data.
When you opt in to use optional AI features, the following limited data may be transmitted from your device to third-party AI services to provide responses or summaries:
| Data | Includes | Recipient(s) | Purpose | Retention |
|---|---|---|---|---|
| Chat messages | Messages you send to AI Companion | OpenAI (processor) | Generate AI responses | Up to 30 days (OpenAI policy) for abuse monitoring |
| Card selection & metadata | Which card you reference | OpenAI (processor) | Context for responses | Up to 30 days (OpenAI policy) for abuse monitoring, same as other API data |
| Conversation context | Recent messages needed to maintain context | OpenAI (processor) | Maintain coherence in conversation | Up to 30 days (OpenAI policy) for abuse monitoring, same as other API data |
| Drawing image (AI Art Companion only) | The drawing you created, sent on each turn of the AI Art Companion session | OpenAI Vision API (processor) | Understand the visual content of your drawing to guide the reflection conversation | Up to 30 days (OpenAI policy); not used for model training by default under OpenAI's API data usage policy |
| Review digest (Week Review and Month Review) | A brief digest based on what you saved or recorded in the App during the selected week or month: saved insights, practices, mood data, MAC card work, and drawings. Before sending, common personal identifiers you may have typed — email addresses, phone numbers, links, and long ID-like number sequences — are automatically removed. Content you do not save is not included in a Week Review or Month Review. The digest is sent to OpenAI only when you request a review in Your Journey. | OpenAI (processor) | Generate an AI-written Week Review or Month Review | Up to 30 days (OpenAI policy); not used for model training by default under OpenAI's API data usage policy |
Important: We do not store AI Companion conversations on our servers. However, data you send to third parties (OpenAI, Google) is processed by those services and is subject to their retention policies — OpenAI may retain API data for up to 30 days for abuse monitoring. API data is not used for model training by default under OpenAI's API data usage policy.
Under GDPR Article 6, processing must have a legal basis. Below are the bases that apply to our activities.
Journal entries, drawings and other content stored only on your device are not processed by FeelEase; therefore we do not assert a legal basis for those local-only items.
Legal basis: Legitimate interest (Art. 6(1)(f)) — necessary to provide the app experience.
Legal basis: Consent (Art. 6(1)(a)). You must explicitly opt in to use AI Companion. Consent can be withdrawn by stopping use of AI Companion.
If you email support we will process the details you provide (including your email address and content of your message) to respond. Legal basis: Legitimate interest and/or your consent when applicable.
You may withdraw consent for AI Companion at any time simply by not using the feature again — there is no separate opt-in step to undo, since each AI feature is used one request at a time. Withdrawal does not affect lawfulness of processing that occurred before withdrawal. Data already transmitted to third parties remains subject to their policies.
Your personal content is stored locally on your device. By default, your journal entries, drawings, saved insights, and other personal content are not stored on FeelEase's servers.
When you use AI features (AI Companion, AI Art Companion, Week Review or Month Review), part of that content is temporarily sent to the AI provider for processing — see Section 6, "Third Parties & Data Recipients".
Note: iOS device backups (iCloud or local encrypted backups) may include FeelEase data if you have backups enabled in iOS. These backups are controlled by Apple and/or by your backup settings.
Your data moves between your iOS devices via Apple mechanisms (Quick Start, iCloud restore, iTunes/Finder). We plan to add an explicit export feature in a future release to make portability easier.
Deleting the app removes most local data from that device. We do not retain backups of your personal entries on our servers. We cannot recover data you delete from your device.
Exception — iOS Keychain: A small piece of data (the free trial message counter) is stored in the iOS Keychain, which is designed by Apple to persist across app deletions and reinstalls. This counter is stored solely to prevent the free trial from being reset by reinstalling the app. It contains no personal information — only a usage count.
We use a minimal set of third-party services. Data is only shared with them when you explicitly use optional features.
| Service | Purpose | Data Shared | When Shared | Role |
|---|---|---|---|---|
| Firebase (Google) | Deliver public card images (Firebase Storage) and app configuration such as AI prompt text and feature flags (Firestore, Remote Config) | Network requests for this content; may log IP/time as part of standard service operation | When you view cards or the app fetches configuration | Processor for app content delivery; Google's own role for its standard technical/service logs is governed by Google's terms — see Section 6.1 |
| OpenAI | AI conversation processing (AI Companion & AI Art Companion); image analysis via Vision API (AI Art Companion); review digest processing (Week Review and Month Review) | Chat messages, limited context, card metadata; drawing images (AI Art Companion only); review digest based on saved insights, practices, mood data, MAC card work, and drawings, with common personal identifiers (emails, phone numbers, links, ID-like numbers) automatically removed before sending (Week Review and Month Review) | Only when you use AI Companion, AI Art Companion, or request a Week Review or Month Review in Your Journey | Processor (processing on our behalf) — see details below |
| Tally.so | Voluntary feedback and bug report forms | Text you submit in forms (no personal identifiers required) | Only when you submit a feedback or bug report form | Processor (processes form submissions on our behalf, under Tally's Data Processing Agreement) |
We use Firebase (Google) as our processor to deliver public card images and app configuration content. As part of operating that infrastructure, Firebase/Google may collect standard technical logs (e.g., IP address, request time). IP addresses are treated as personal data under GDPR. For these standard technical/service-operation logs, Google's own role is governed by Google's published terms for Firebase — we do not link such logs to your identity for profiling purposes.
When you use AI Companion, we transmit the minimal data needed to provide AI responses. We use OpenAI as data processors that process data on our behalf according to our instructions and their processing terms. Where applicable, we rely on Data Processing Agreements and Standard Contractual Clauses (SCCs) to provide safeguards for cross-border transfers.
Note: For some limited services and legal jurisdictions, OpenAI or Google may process certain data under their own policies for abuse monitoring or security; these limited activities are described in their public policies. API data is not used for model training by default under OpenAI's API data usage policy.
AI responses are generated using third-party AI services. The underlying AI model may change over time to ensure quality and availability.
AI Art Companion — image processing: When you use the AI Art Companion feature, your drawing is sent to OpenAI's Vision API on each message turn to help the AI understand its visual content. This image is transmitted solely to generate reflective responses and is not stored by FeelEase on our servers. OpenAI may retain it for up to 30 days for abuse monitoring, consistent with their API data policy.
See OpenAI Privacy Policy and OpenAI API Data Usage Policies.
Users should avoid entering sensitive personal information in AI conversations.
We use Tally.so to host voluntary feedback and bug report forms accessible from the app's Profile section. When you submit a form, Tally.so processes the text you enter. We do not require personal identifiers (name, email) in these forms; however, any information you voluntarily provide will be processed by Tally.so under its own privacy policy. See Tally.so Privacy Policy.
Subscriptions are purchased and processed entirely by Apple through StoreKit. FeelEase does not receive, store, or process any payment card details or billing information. We receive only your subscription entitlement status (active / expired) via Apple's StoreKit framework, which is used solely to unlock premium features. Apple's handling of payment data is governed by the Apple Privacy Policy.
In some cases, to enable AI features, data may be temporarily processed on service provider servers located outside your country, including the United States. This processing is governed by our service providers' own data protection terms, which may include Standard Contractual Clauses or equivalent safeguards where offered.
Local data (journal entries, drawings, saved insights) is retained until you delete it or delete the app.
| Location | Retention | Notes |
|---|---|---|
| On your device (chat session) | Session only (temporary) Not stored permanently by FeelEase | Closing chat clears session |
| OpenAI | Up to 30 days (abuse monitoring) | Subject to OpenAI policies — not used for model training by default |
Deleting the app removes local data from your device. We maintain no backups of your personal content on our servers.
You have rights under GDPR, UK GDPR, CCPA/CPRA and other laws. These include access, rectification, erasure, restriction, data portability, objection, and withdrawal of consent where applicable.
Please direct your request to us first at contact@feelease.app, even for data processed by OpenAI or our other processors on our behalf — as the data controller, we will coordinate with those processors as needed to fulfill your request.
California residents have rights including the right to know, delete, and opt-out of sale (we do not sell personal information). To submit a request, email contact@feelease.app. Response time: 45 days (may be extended once by 45 days).
FeelEase does not use automated decision-making that produces legal effects or significantly affects users. AI Companion is a conversational AI tool that provides reflection prompts and responses; it is not a medical device, diagnostic tool, or replacement for professional care.
My Dynamics performs simple, deterministic, on-device aggregation of your own previously saved data to show recurring patterns (e.g., which themes or feelings recur across months). This is not AI-driven, is never shared with us or any third party, produces no legal or similarly significant effect, and is not automated decision-making within the meaning of GDPR Article 22.
FeelEase is intended for users aged 16 and older. Personal reflection content is stored locally on your device by default; AI features involve third-party data processing as described in Section 3.4 and Section 6. If we become aware that a user under 16 has used AI features, we will take steps to restrict access and notify parents/guardians where required by law.
We do not target users under 16. Parents/guardians who believe a user under 16 has accessed AI features should contact contact@feelease.app.
In the unlikely event of a security breach affecting personal data under our control, we will notify affected users and applicable supervisory authorities without undue delay and in accordance with law (e.g., within 72 hours under GDPR where required).
FeelEase adapts widely used and evidence-based techniques from psychology and wellbeing practices (CBT, DBT, ACT, somatic techniques, positive psychology). These are educational and self-help in nature.
We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will update the "Last Updated" date and, for material changes, provide an in-app notice and request renewed consent if required.
Privacy inquiries:
Important: FeelEase is not a replacement for professional mental health care. AI Companion is not a therapist.
If you are in crisis, contact local emergency services immediately. See the helplines below for example resources.