Legal

Privacy Policy

Last updated 19 July 2026 · Effective 19 July 2026
Please read this before you rely on it. This is a thorough, plain-English template built around Apple's App Store requirements and the core obligations of the GDPR, UK GDPR and CCPA/CPRA. It is not legal advice. Before you publish, have a qualified privacy professional confirm it reflects exactly how Journaly is built, the vendors you actually use, and the laws that apply to you and your users. Replace every bracketed placeholder with your real details.

Journaly ("Journaly", "we", "us") makes a journaling app with an AI companion. This policy explains what personal information we collect, why, who we share it with, how long we keep it, how we protect it, and the rights and controls you have. Because a journal holds some of the most personal things you will ever write, keeping it private is central to how we build the app, not an afterthought.

For the purposes of the GDPR and UK GDPR, the data controller is [Legal entity name], [address]. If you have questions, contact us at privacy@journalyai.app.

1. Information we collect

We collect only what we need to give you a working, personal journal.

Information you provide

Information we collect automatically

Information from third parties

2. How and why we use your information

Under the GDPR we must have a legal basis for each use. The table below sets out what we do and why.

What we doLegal basis (GDPR / UK GDPR)
Create and manage your account and provide the app's core featuresPerformance of a contract with you
Store your entries and let the companion reflect on them, remember context and surface insightsPerformance of a contract; and, for content that may be sensitive, your consent
Process subscriptions and keep records of purchasesPerformance of a contract; legal obligation
Keep the app secure, prevent abuse and debug problemsOur legitimate interests in a safe, working service
Improve and develop features, using aggregated or de-identified data where possibleOur legitimate interests; or consent where required
Send you service messages, and (if you opt in) product updatesLegitimate interests; consent for marketing
Comply with the law and enforce our termsLegal obligation; legitimate interests

We do not sell your personal information, and we do not show advertising targeted using the private things you write.

3. Your entries and the AI companion

Journaly's companion is powered by artificial-intelligence models. To generate its replies and reflections, the relevant parts of your content are processed by these models, including trusted third-party AI providers who host them on our behalf.

4. Sensitive information

Because you can write about anything, your entries may reveal sensitive details, for example about your health, mental wellbeing, beliefs or relationships. We do not require you to share any of this, and we do not use it to infer categories about you for marketing. Where the law treats such content as special-category or sensitive personal information, we rely on your explicit consent to store and process it so the app can work for you, and you can withdraw that consent by deleting the content or your account.

5. How we share information

We share personal information only in these limited ways:

We never sell your personal information, and we do not share the content of your journal for anyone else's own purposes.

6. How long we keep information

We keep your information for as long as your account is active so your journal remains available to you. When you delete individual entries, they are removed from your account. When you delete your account, we delete or de-identify your personal information within a reasonable period (target: within [30–90] days), except where we must retain limited records to meet legal, tax, accounting or security obligations, or to resolve disputes. Backup copies are purged on our standard backup cycle.

7. How we protect information

We use technical and organisational measures appropriate to the sensitivity of your content, including encryption in transit and at rest, access controls that limit who can see your data to what is necessary, and monitoring for abuse. No method of storage or transmission is perfectly secure, but protecting your reflections is a core design goal and we work continuously to keep them safe.

8. International transfers

We and our providers may process your information in countries other than your own, including the United States. Where we transfer personal information out of the UK, EEA or other regions with data-export rules, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or another lawful transfer mechanism. You can ask us for a copy of the safeguards we use.

9. Your rights and choices

Depending on where you live, you may have some or all of these rights:

You can exercise most of these directly in the app (view, edit, export and delete), or by emailing privacy@journalyai.app. We will respond within the time the law requires, usually one month, and we will not discriminate against you for exercising your rights.

10. Deleting your account

You can permanently delete your account and its contents from within the app, in line with Apple's account-deletion requirement. Account deletion removes your entries, letters, goals, gratitude notes, moods, dream entries and companion history, along with the associated account record, subject to the limited legal retention described in section 6. You can also delete individual entries at any time without deleting your account. If you cannot access the app, email privacy@journalyai.app and we will help.

11. Notice for California residents (CCPA/CPRA)

In the past 12 months we have collected the categories of personal information described in section 1 (identifiers, account information, your user-generated content, commercial/subscription information, internet and device activity, and, only if you provide them, sensitive details). We collect it for the business purposes in section 2 and disclose it to the service providers in section 5.

12. Children

Journaly is not directed to children under the age of [13 / 16, per your market], and we do not knowingly collect personal information from them. If you believe a child has provided us information, contact us and we will delete it.

13. Website, cookies and analytics

Our marketing website may use a small number of essential and, with your consent where required, analytics cookies to understand traffic and improve the site. You can control cookies through your browser and any consent banner we present. The app itself does not use advertising cookies.

14. Changes to this policy

We may update this policy from time to time. If we make material changes, we will update the date above and, where appropriate, notify you in the app or by email. Your continued use after an update means you accept the revised policy.

15. How to contact us

For any privacy question or to exercise your rights, contact us at privacy@journalyai.app or by post at [Legal entity name, postal address]. If you are in the EEA or UK and we are required to have a representative or Data Protection Officer, their contact details are [insert].