FALA Privacy Policy
Version 1.5 • 26 September 2026
1. Controller and contact
The controller for processing related to providing and operating the FALA app is Rafał Hordij, an independent app developer. Most user data and content is processed exclusively on the user’s device. The FALA developer does not receive this data, store it on proprietary servers, or have access to it. Data transmitted when optional iCloud, PRO purchase, or analytics services are used is described in the following sections of this Policy. For privacy-related matters, contact: rhordij@icloud.com.
2. Data processed by the app
Depending on the features used, FALA may store: your name and selected form of address, profile photo, Wave and journal content, fear and reality ratings, life areas, moods, timer history, settings, and photos, voice recordings, or videos selected by you. Providing your name, adding media, and enabling iCloud synchronization are voluntary. Choosing not to provide this data or enable synchronization limits only the features that directly require it.
3. Data stored locally
Core data is stored on your device. Deleting the app or clearing its data may permanently delete information that has not been exported or synchronized.
4. iCloud
When you voluntarily enable synchronization, FALA data is stored in the private iCloud database associated with your Apple ID. Synchronization may include Waves and their photos, journal entries and media, moods, timer history, your name, profile photo, and settings required to keep devices consistent. This data uses your iCloud storage. Disabling synchronization stops future operations but does not automatically delete data previously stored in iCloud. Use of iCloud is subject to Apple’s Privacy Policy.
5. Device permissions
FALA requests access only when a selected feature requires it: camera access when taking an evidence photo for a Wave, adding a photo to a journal entry, or taking a profile photo; access to the photo library and files when selecting or saving media; microphone access when recording a voice note; notifications when reminders are enabled; and Face ID or Touch ID when biometric locking is enabled. Refusing a permission does not prevent use of other features, except the feature that requires that permission.
6. Purposes and legal basis
Data is used to provide features selected by you, personalize the interface, create on-device statistics, synchronize data, secure the app, process purchases, and perform limited product analytics. The legal bases are performance of a contract or steps taken at your request (Article 6(1)(b) GDPR), consent for optional transmission to iCloud (Article 6(1)(a) GDPR), compliance with a legal obligation where applicable (Article 6(1)(c) GDPR), and the legitimate interest in securing the app, preventing misuse, and improving its features (Article 6(1)(f) GDPR).
7. Purchases
PRO purchases and subscriptions are processed by Apple through the App Store and StoreKit. The app uses RevenueCat to retrieve offerings and verify PRO entitlements. RevenueCat may receive an anonymous app user identifier, technical app and device information, and product, transaction, and subscription-status information. It does not receive the content of Waves, journal entries, or your photos. FALA does not receive your complete payment card details. See the RevenueCat Privacy Policy.
8. Product analytics (Google Analytics for Firebase)
FALA uses Google Analytics for Firebase solely for anonymous product analytics: to understand returns to the app, onboarding completion, use of core features, and interactions with the PRO offering. The data transmitted includes app-use events, basic technical information about the app and device, and a pseudonymous app-instance identifier. Analytics may also include automatic Firebase events, including session starts and confirmed StoreKit subscription events. Firebase does not receive the content of Waves, journal entries, reflections, notes, fear or reality ratings, moods, photos, recordings, your name, email address, or other content or personal data entered by you. FALA does not set a Firebase user ID and does not use IDFA, AdSupport, Google Ads, remarketing, or cross-app tracking. Details of Google’s data processing are set out in the Google Privacy Policy.
9. Website analytics (Vercel Web Analytics)
On the FALA website, we use Vercel Web Analytics to anonymously analyze website traffic and improve its operation. The tool records aggregated technical and visit information, such as the page viewed, referral source, approximate location, device type, operating system, and browser. We do not use cookies for this purpose or use data to identify users or track them across websites. Details of Vercel’s data processing are set out in the Vercel Privacy Notice.
10. Technical support
In Settings → About, FALA may display a shortened purchase support ID. The full ID is available to copy at your request. When you choose “Technical support”, the app may prepare an email draft containing your full RevenueCat ID, app version, device model, operating-system version, and Storefront country code. The message is not sent automatically; you can review, edit, and send it yourself. This data is used solely to handle your support request. Do not post the full ID publicly.
11. Retention and deletion
Local data is retained until you delete it, clear the app’s data, or uninstall the app. Items in trash remain there until permanently removed using the feature provided in the app. Synchronized data may remain in iCloud until deleted from the app or your iCloud account. Google, Vercel, and RevenueCat retain received data for periods determined by their policies and legal obligations; FALA does not control those periods.
12. Your rights
You can access, export, correct, or delete your data in the app. Where provided by law, you also have the right to restrict processing, data portability, object to processing, and withdraw consent at any time without affecting the lawfulness of earlier processing. For questions about data or exercising your rights, contact the developer at the address above. You may lodge a complaint with the President of the Polish Personal Data Protection Office or another competent supervisory authority.
13. Recipients and transfers outside the EEA
Depending on the features you select, recipients may include Apple (iCloud, App Store, and StoreKit), RevenueCat (purchase entitlement management), Google (Firebase product analytics), and Vercel (website analytics). These providers are required to provide a level of data protection at least equivalent to that described in this Policy and required by applicable law. Google, Vercel, and RevenueCat may process data outside the European Economic Area. The safeguards described by the providers apply, including appropriate transfer mechanisms required by law. FALA does not sell user data or use it for advertising or cross-app tracking.
14. Children and sensitive data
FALA is not directed to children under 13. Entries may contain information about wellbeing or health; you decide what to record in the app.
15. Automated decision-making
FALA does not make decisions that produce legal effects or similarly significantly affect you based solely on automated processing. Statistics are informational and supportive.
16. Changes to this policy
This policy may be updated when features or applicable laws change. The version number and date will be shown at the beginning of the document.