Privacy Policy

Last updated: February 6, 2025

1. Controller

The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

Satisphere Solutions UG (haftungsbeschränkt)
Bonn, Germany
Email: management@satispheresolutions.com

2. General Information on Data Processing

We process personal data of our users exclusively in accordance with applicable legal provisions, in particular the GDPR and TDDDG.

Sway is a web-based application for voice recording, transcription, and structured content processing. Personal data may be processed depending on the content provided by the user.

3. Types of Data Processed

Depending on how Sway is used, we process the following data in particular:

  • Registration data (e.g., email address)
  • Authentication data (Magic Link / OAuth)
  • Audio recordings
  • Transcripts and structured text content
  • Usage and interaction data
  • Payment and billing data (for paid plans)
  • Technical metadata (e.g., truncated IP address)

3.1 Audio Recordings and Privacy

Your recordings in Sway are completely private:

  • Audio recordings are stored privately and are never publicly accessible
  • Nobody listens to your recordings – including the Sway team. There is no manual review
  • Audio is processed solely by automated systems for transcription and summarization
  • You decide if and what you share (sharing is always opt-in)
  • You can delete your recordings at any time by deleting the corresponding note

4. Purposes of Processing

Data processing serves the following purposes:

  • Provision and operation of Sway
  • Authentication and user management
  • Processing of audio recordings and text
  • Improvement of features and user experience
  • Billing and payment processing
  • Security, abuse prevention, and fraud prevention
  • Compliance with legal obligations

5. Legal Basis

The processing of personal data is based on the following legal grounds:

  • Art. 6(1)(b) GDPR – Performance of a contract
  • Art. 6(1)(f) GDPR – Legitimate interest (operation, security, stability)
  • Art. 6(1)(a) GDPR – Consent (e.g., analytics cookies)

6. Cookies & Consent Management

Sway uses cookies to provide the application securely and reliably.

Essential Cookies

These cookies are necessary for the operation of the app and cannot be disabled. They are used for:

  • Authentication and session management
  • Security and abuse prevention
  • Storing language preferences

Legal basis: Art. 6(1)(f) GDPR

Statistics (Internal Analytics – Loveable Analytics)

If you provide your explicit consent, we use internal analytics ("Loveable Analytics") to evaluate aggregated usage data, such as:

  • Frequency of use of individual features
  • Number of recordings created
  • Usage of premium features
  • General interaction patterns

No personal profiling, external tracking, or advertising takes place.

Legal basis: Art. 6(1)(a) GDPR

You may withdraw your consent at any time via the cookie settings in the app.

7. Data Processors

To provide Sway, we use the following service providers:

  • OpenAI – Speech and text processing
  • Supabase – Authentication & database
  • Resend – Email delivery
  • Vercel – Hosting & infrastructure
  • Stripe – Payment processing

All service providers are contractually bound as data processors in accordance with Art. 28 GDPR.

8. Data Transfers to Third Countries

Some service providers may process data outside the EU (e.g., USA).

Transfers are made exclusively on the basis of appropriate safeguards (in particular, EU Standard Contractual Clauses).

9. Retention Period

Personal data is retained only as long as necessary for the respective purposes or as required by statutory retention obligations.

10. Rights of Data Subjects

You have the right at any time to:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Withdraw consent (Art. 7(3) GDPR)
  • Lodge a complaint with a supervisory authority (Art. 77 GDPR)

11. Amendments

We reserve the right to amend this privacy policy in case of legal or technical changes.