Privacy Policy for Voice Recorder: Audio Memos

Our privacy policy was last updated on November 11th, 2026. 
See previous versions here.

1. Introduction.

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information if You use our Application Voice Recorder: Audio Memos (shown on Your Device as “Voice Recorder”; Android package name voice.memo.audio.recorder). The Policy tells You about Your privacy rights and how the law protects You.

We use Your data to provide and improve the Services. When installing, running, and using Voice Recorder: Audio Memos, You agree to the collection and use of information in accordance with this Privacy Policy.

In short:

• You do not create an account, and We do not ask for Your name, e-mail address or phone number.
• Your recordings, transcripts, markers, place tags and settings are stored on Your Device. Appvestor does not operate a server that receives them, and transcription runs entirely on Your Device.
• The free version of the App shows advertisements delivered by Google. Where the law requires it, You are asked for Your consent first. Google and its advertising partners then process technical data such as Your IP-address and Your Device’s advertising ID.
• Location, notifications and access to audio from other apps are optional. Location is only used to save where a recording was made.
• We do not sell Your personal data.

Voice Recorder: Audio Memos is not intended for or designed to attract anyone under the age of 18.

2. Interpretation and Definitions

Interpretation
Unless otherwise stated in the context, the following terms have the following meanings, and they shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions
For the purposes of this Privacy Policy:

• “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to:
      Appvestor ApS
      DK37614904,
      Gladsaxevej 342, 2860 Soeborg
      Denmark
• “Country” refers to Denmark.
• “Device” means any device that can access the Service.
• “Data” is any information that relates to a User of any of Our Services.
• “App” or “Application” means Voice Recorder: Audio Memos, the Android application with the package name voice.memo.audio.recorder that is published by the Company.
• “Service” refers to the App and its features.
• “Data Partner” means any natural or legal person to whom data is transferred making it possible for the Data Partner to – via Appvestor’s Services – provide advertising to the end-user.
• “Service Provider” means a third party that processes limited technical data on Our behalf, or whose technology the Service uses to deliver a feature to You (for example address lookup, the download of speech models or the delivery of the App’s configuration), for that purpose only.
• “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. You can be referred to as the Data Subject or as the User as You are the individual using the Service.

3. Data Collection and Processing

No account is required
The App does not require You to create an account or to sign in. We do not ask for Your name, e-mail address, phone number, contacts or call history, and Appvestor does not operate a server that receives Your recordings or transcripts.

Your recordings stay on Your Device
Everything You create in the App – audio recordings, their titles, categories, favourites and markers, transcripts, place tags and Your settings – is stored in the App’s own storage on Your Device. Appvestor does not have access to this content and does not upload it to any Appvestor server. Recordings You delete are moved to the App’s Trash and are removed permanently after 30 days, or earlier if You empty the Trash. Your content leaves the App only when You choose so – when You share or export it or turn on “Visible recordings” – or through the Android backup described below.

Microphone – recording
The App asks for microphone access, only with Your explicit consent, the first time You start a recording. The microphone is used only while a recording that You started – in the App, from its home-screen widget, from its Quick Settings tile or from its launcher shortcut – is in progress. While recording, the App shows a notification, and a foreground service keeps the recording going while the screen is off or You use other apps. The recorded audio is written to an audio file on Your Device and is not sent anywhere.

The App is not a call recorder: it pauses a recording while a phone call is in progress. To notice a call, the App only reads the audio state of Your Device; it does not access Your phone number, Your call history or Your contacts.

Transcription and speech models
Transcripts are created on Your Device by an open-source speech recognition engine (whisper.cpp), both for saved recordings and for the live transcript shown while You record. Your audio and Your transcripts are not sent to Appvestor or to any speech recognition service. Transcripts are stored with the recording on Your Device so that You can read, search, copy and share them.

The engine needs a speech model, a file of roughly 75 to 470 MB that the App downloads once from Hugging Face, a public hosting service for such models, when You first use transcription or choose a model under “Speech model” in the App’s settings. The download request contains Your IP-address and standard technical request information, but no audio, text or other content from the App.

Location – place tags
If You allow it – the App asks during its introduction, and You can answer “Not now” – the App looks up where Your Device is when You start a recording, in order to save where the recording was made (for example “City Center Garage”). Depending on the choice You make in Android’s permission dialog, this is Your precise or Your approximate location. The location is provided by Google Play services on Your Device. To turn the coordinates into a place name, the App uses the geocoding service of Your Device (on most Devices provided by Google), which receives the coordinates for that purpose. The coordinates and the place name are stored with the recording on Your Device.

The App reads Your location only when a recording starts. It does not use background location, it does not track or record where You go, and Appvestor does not receive Your location. The App does not pass Your location to Data Partners for advertising or analytics purposes; Our advertising Data Partner may estimate Your general location (such as Your country or city) from Your IP-address. You can withdraw the location permission at any time in Your Device’s system settings; new recordings are then no longer tagged with a place.

Audio from other apps
If You turn on “Show audio from other apps” in the App’s settings, the App asks for access to the audio files on Your Device. It then reads the list of recordings and other non-music audio files made by other apps – their title, file name, length, size, date and type – to show them under “Listen” so that You can play them in the App. These files are processed only on Your Device; the App does not change or upload them. The setting is off by default.

Sharing, export and “Visible recordings”
When You share a recording or a transcript, the file or the text is handed to the app You select, under that app’s privacy policy; copying a transcript places it on the clipboard of Your Device. “Export to Music” and the setting “Visible recordings” copy recordings to the shared folder Music/Voice Memo on Your Device, where other apps that You have given access to Your audio files (for example music players, file managers or cloud backup apps) can read them. These copies stay there until You delete them, also after You turn the setting off or uninstall the App.

Text to speech
“Text to speech” turns text that You type, paste or import from a file You pick into a spoken recording. The text is handed to the text-to-speech engine installed on Your Device (on most Devices Speech Services by Google). Depending on that engine and the voice You select, the text is converted on the Device or on the engine provider’s servers, under that provider’s privacy policy. The App does not send the text anywhere else, and the resulting audio is saved as a recording on Your Device.

Technical Information
When advertisements are shown in the free version of the App, Our advertising Data Partner may collect technical information from Your Device so that advertisements can be served, measured and protected against fraud. Technical information may include, but is not limited to: IP-address (from which Your country and general location can be estimated), Usage Data such as app launches and interactions with advertisements, diagnostic information, device language, device type and model, operating system version, network type, the Advertising Identifier (Advertising ID) of Your Device and the app set ID. Appvestor may access and use the documentation of the consent to advertising that You have given through the consent dialog in the App.

Advertising and consent
The free version of the App shows banner, native and full-screen advertisements delivered through Google’s advertising services (Google AdMob and Google Ad Manager). Before the advertising SDK is started, the App shows You a consent dialog (Google User Messaging Platform) where required by law, for example in the EEA, the United Kingdom, Switzerland and certain US states. The dialog names the advertising partners involved and lets You choose whether advertisements may be personalised; if You decline, only non-personalised or limited advertisements are requested. Where a consent dialog applies to You, You can change Your choice at any time under “Privacy options” in the App’s settings. You can remove the advertisements by subscribing to Voice Recorder Pro.

App configuration
The App receives its advertising configuration – which advertisement placements are active – from Google Firebase Remote Config. When the configuration is fetched, Google receives a Firebase installation ID (a random identifier of the App installation on Your Device that does not contain Your name or contact details), Your IP-address and technical information such as the App version, device language, country and operating system version. Google processes this data on Our behalf. The App does not use Firebase Analytics or crash reporting; Appvestor receives only aggregated statistics from Google about advertisements, installs and purchases.

Purchases
Voice Recorder Pro is a subscription (monthly or yearly, which may start with a free trial) that is purchased and managed through Google Play Billing. Google processes the payment and Your payment details under its own privacy policy; Appvestor never receives Your payment card details. The App receives only the product identifier, a purchase token and the purchase status, and keeps the status on Your Device to unlock the Pro features and to remove the advertisements. “Manage subscription” in the App’s settings opens Google Play.

Notifications
With Your permission, the App shows notifications with recording controls while a recording is in progress, the progress of transcriptions and speech model downloads, a warning when the storage of Your Device is running low, and occasional tips about the App’s home-screen widget. These notifications are generated on Your Device; We do not send push notifications from a server.

Backup and transfer to a new Device
The App takes part in Android’s own backup, which is provided by Google under Google’s privacy policy and can be turned off in Your Device’s system settings. The App’s settings are included in the backup to Your Google account. Recording files can be included as well, but only as long as the App’s backup stays within Android’s size limit of 25 MB per app. The App’s database – titles, categories, markers, transcripts and place tags – and downloaded speech models are not included in the backup to Your Google account. When You copy Your data directly to a new Device (device-to-device transfer), Your recordings and the database are transferred as well. Appvestor does not host, copy or read these backups.

Feedback
“Customer feedback” in the App’s settings opens Your e-mail app with a message addressed to Us; what You write is sent only when You send it. We use Your e-mail address and Your message only to answer You.

4. Use of Your Data

Appvestor commits itself to the terms of the Google Play Developer Program Policies and reserves the right to use anonymous data for statistics and user support without restrictions regarding applicability in time.

Appvestor may use Your Data for the following purposes:

• To provide and maintain Our Service, including providing You with the Application features You use, such as recording, playback, transcription, place tags and text to speech.
• To show advertisements: To show advertisements in the free version of the App and, only with Your consent, to personalise them.
• To process purchases: To unlock Voice Recorder Pro after a subscription purchased through Google Play.
• To manage Your requests: To attend to, and manage feedback and requests from You, including a request on the deletion of the App and all Your personal data.
• To comply with legal obligations: To fulfill obligations under applicable law, including GDPR, CCPA/CPRA, LGPD, and PIPA.

We may share Your Data in the following situations:

• With business partners (Data Partners): We may – with Your consent – share Your information with Our advertising partner in accordance with its stated purposes in its privacy policy.
• With Service Providers: Only the technical data necessary to deliver a feature You are using (for example the address lookup for a place tag, the download of a speech model or the App’s configuration) is sent to the Service Provider, as described in section 3.
• With authorities: Where required by applicable law or valid court order, We may disclose Your data to public authorities.

We do not sell Your personal data to third parties for monetary compensation. We do not share Your personal data for cross-context behavioural advertising without Your explicit consent.

5. Legal Basis for the Processing of Your Data

Appvestor processes personal data to pursue Our legitimate interest in managing Our business – including being able to handle contracts and purchases of various products and licenses for Our business and to improve, develop and market Our Services, and comply with Our legal obligations. The legal basis for Our processing is thus the following articles in the GDPR:

• Article 6(1)(a): Personal data may be processed with express consent.
• Article 6(1)(b): Personal data may be processed if necessary to fulfill a contract.
• Article 6(1)(c): Personal data may be processed if this is necessary to comply with a legal obligation.
• Article 6(1)(f): Personal data may be processed if necessary to pursue a legitimate interest unless the interests of the data subject precede this.
• Article 9(2)(a): Where processing involves Sensitive Personal Data (e.g. precise location data that may indirectly reveal sensitive characteristics), processing is based on explicit consent only.

Note: Because We process Your data partly on basis of Article 6(1)(f) (legitimate interests), You may in certain cases object to Our otherwise lawful processing of Your personal data, cf. Article 21 GDPR. 

6. Retention of Your Data

• Data on Your Device (recordings, transcripts, markers, place tags, categories and settings) is kept until You delete it in the App, clear the App’s storage or uninstall the App. Recordings You delete are kept in the Trash for 30 days and are then removed permanently.
• Copies outside the App – recordings copied to Music/Voice Memo by “Export to Music” or “Visible recordings”, and files or text You shared with other apps – stay where they are until You delete them there.
• Speech models are kept on Your Device until You delete them under “Speech model” in the App’s settings or uninstall the App.
• Advertising data is retained by Our advertising Data Partner in accordance with its privacy policy.
• The Firebase installation ID is retained by Google in accordance with its Firebase terms.
• E-mail correspondence is kept for as long as needed to handle Your request and any follow-up.

Appvestor will process and retain anonymized Usage Data for analysis purposes. Your Data will be retained until the purpose of use is achieved or You choose to have it deleted.  As a general rule, personal data linked to a specific device or user is retained for no longer than 24 months from the date of collection, after which it is anonymized or deleted, unless a longer retention period is required by applicable law. We will delete your personal data in accordance with applicable law.

7. Transfer of Your Data

Your Data may be transferred to — and maintained on — servers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

If Your data is transferred to a country outside the EU/EEA, and if the country in question has not been approved by the European Commission as providing adequate protection, Our data transfers will be based on Standard Contractual Clauses (SCC) approved by the European Commission.

Where data is transferred to the United States, We rely on Standard Contractual Clauses (SCCs) as the applicable transfer mechanism in accordance with GDPR Chapter V, or on the recipient’s certification under the EU–US Data Privacy Framework. We conduct Transfer Impact Assessments (TIAs) where required.

We work with the following Data Partners and Service Providers, to whom Your data will be transferred as described in this Privacy Policy:

Our Data Partners and Service Providers process the transferred information in accordance with their own stated privacy policies. Data is transferred to Data Partners for advertising only with Your specific consent; Service Providers receive only the technical data necessary to deliver the feature You are using. Where advertisements are personalised or measured, Google may work with further advertising partners. They are named in the consent dialog, where You can allow or refuse each of them. 

8. Other Disclosure of Your Data

Law Enforcement

Under certain circumstances, Appvestor may be required to disclose Your Data in accordance with law or in response to valid requests from public authorities (e.g. a court or a government agency). Appvestor will comply with all applicable data protection provisions, including section 5 of the Danish Act on Personal Data.

Opt-Out from Data Collection and Inquiries

Users have the right to ask Appvestor not to continue the processing of Personal Data. Users can exercise their rights to prevent processing by contacting Appvestor at privacy@appvestor.com, by changing Your advertising choices under “Privacy options” in the App’s settings (shown where a consent dialog applies to You), by resetting or deleting the Advertising ID in Your Device’s system settings, or by revoking the App’s permissions in Your Device’s system settings. 
California residents (CCPA/CPRA): You have the right to opt out of the “sale” or “sharing” of Your personal information for cross-context behavioural advertising. To exercise this right, contact us at privacy@appvestor.com or use the opt-out mechanism within the app settings.

The App does not use user accounts. To delete Your recordings and transcripts, delete them in the App or uninstall the App – see section 19 below.

Security of Your Data

The security of Your Data is important to Us. We have implemented the appropriate technical security measures to ensure data protection in all contexts. We have further ensured contractual-based instructions to Our Data Partners regarding necessary security measures to supplement the Standard Contractual Clauses approved by the European Commission.

We implement appropriate Technical and Organisational Measures (TOMs) in accordance with GDPR Article 32, including encryption of data in transit, access controls, and regular security reviews. Your recordings and transcripts are kept in the App’s own storage on Your Device and are not uploaded by the App.

9. SDK Data Collection and Consent Requirements

In accordance with Google Play Developer Program Policies and applicable data protection law (including GDPR and ePrivacy), Appvestor ensures that no third-party SDK integrated into Our Applications will collect, transmit, or process personal data before the user has been presented with a clear consent interface and has actively provided their consent.

This means:

• No SDK initialises in a data-collecting mode prior to consent being obtained. The advertising SDK (Google Mobile Ads) is only started after the Google User Messaging Platform consent flow has completed and Your choice allows advertisements to be requested.
• Functions that are strictly necessary to run the App – the consent check itself and the purchase status from Google Play – do not depend on Your advertising consent.
• Consent is granular — users are offered individual choices per purpose and cannot be forced to accept all-or-nothing.
• If a user declines consent, no non-essential tracking or data collection takes place.
• Users may withdraw consent at any time under “Privacy options” in the App’s settings or by contacting privacy@appvestor.com.
• Consent records, including the timestamp, the version of the consent notice shown, and the user’s choice, are maintained in accordance with GDPR Article 7(1).

Appvestor accepts full responsibility as data controller for the data collection practices of all SDKs integrated into Our Applications.

10. Prominent Disclosure – Sensitive App Permissions

Voice Recorder: Audio Memos may request access to certain sensitive device permissions in order to deliver its features. The App asks for a permission only when You use the feature that needs it or, for location and notifications, on a screen of the App’s introduction that explains what the permission is used for. In accordance with Google Play Developer Program Policies and GDPR, We provide the following explicit disclosures:

Microphone Permission

• RECORD_AUDIO: Used to make the audio recordings You start, and to create the live transcript on Your Device while You record. Recordings are stored only on Your Device and the audio is not sent to Appvestor or to any third party.
• FOREGROUND_SERVICE_MICROPHONE: A foreground service with a visible notification keeps a recording going while the screen is off or the App is in the background. The microphone is never used without a recording that You started.

Location Permissions

• ACCESS_FINE_LOCATION / ACCESS_COARSE_LOCATION: Used to look up where Your Device is when a recording starts, so that the recording can be tagged with the place where it was made. The coordinates are stored with the recording on Your Device and are sent to Your Device’s geocoding service only to look up the place name. The App does not send Your location to Appvestor or to any Data Partner.
• The App does not request background location (ACCESS_BACKGROUND_LOCATION) and does not record Your movements.

Audio Files Permission

• READ_MEDIA_AUDIO (READ_EXTERNAL_STORAGE on Android 12 and older): Requested only when You turn on “Show audio from other apps”. Used to list and play recordings made by other apps under “Listen”. The files are only read on Your Device and are not uploaded.

Notification Permission

• POST_NOTIFICATIONS: Used to show recording controls, the progress of transcriptions and speech model downloads, low-storage warnings and tips about the home-screen widget. No marketing push notifications are sent from a server.

Other Permissions

• Advertising ID (AD_ID): Declared by Google’s advertising SDK so that the Advertising ID of Your Device can be used for advertising and measurement, subject to Your consent choice and Your Device’s advertising settings.
• READ_BASIC_PHONE_STATE: Declared by Google’s advertising SDK to read basic network information such as the type of mobile network. It does not give access to Your phone number, Your calls or Your call history.

Location access, access to audio files and notifications are always optional and consent-based. The App works without them; only the features that depend on them are unavailable. Microphone access is needed to make a recording. You can review and revoke each permission in Your Device’s system settings at any time.

11. Data Breach Notification

In the event of a personal data breach, Appvestor will act in full accordance with GDPR Articles 33 and 34 and any other applicable data breach notification requirements.

Notification to the Supervisory Authority (Datatilsynet)

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, Appvestor will notify Datatilsynet without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, in accordance with GDPR Article 33.

The notification will include: a description of the nature of the breach; the DPO’s contact details; the likely consequences; and the measures taken or proposed to address the breach.

Notification to Affected Users

Where a personal data breach is likely to result in a high risk to the rights and freedoms of the affected individuals, Appvestor will notify those individuals directly, without undue delay, via one or more of the following methods:

• In-app notification displayed prominently when the user next opens the Application
• Push notification to affected devices, where technically possible
• Publication of a prominent notice on legal.appvestor.com

The notification to affected users will be in plain language and will include: a description of the breach; the DPO contact details (John Lisek, dpo@appvestor.com); the likely consequences; steps Appvestor is taking to address the breach; and recommended actions the user can take to protect themselves.

Internal Breach Response

All suspected or confirmed breaches must be reported immediately to the DPO (dpo@appvestor.com) who is responsible for assessing the breach, determining notification obligations, and coordinating the response.

12. Changes to the Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

Where changes are material — such as changes to the types of data collected, new third-party data sharing, changes to retention periods, or changes to user rights, We will provide prominent notice, which may include in-app notifications or, where required by applicable law, renewed consent will be sought.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from when they are posted on this page.

13. Contact Us

If You have any questions, requests, or comments about this Privacy Policy, You can contact Us by sending an e-mail to: privacy@appvestor.com
Appvestor ApS, Gladsaxevej 342, 2860 Søborg, Denmark
We aim to respond to all privacy-related enquiries within 30 days as required by GDPR Article 12.

14. Data Protection Officer (DPO)

In accordance with Article 37 of the GDPR, Appvestor ApS has appointed a Data Protection Officer (DPO). The DPO is responsible for overseeing Appvestor’s data protection strategy and ensuring compliance with applicable data protection legislation.

Name: John Lisek
E-mail: dpo@appvestor.com
Organisation: Appvestor ApS, Gladsaxevej 342, 2860 Søborg, Denmark

You have the right to contact the DPO directly at any time regarding the processing of Your personal data, to exercise Your data subject rights, or to raise any concerns or complaints relating to data protection. The DPO operates independently and is bound by confidentiality.

The appointment of the DPO has been registered with the Danish Data Protection Authority (Datatilsynet) as required under GDPR Article 37(7).

15. For Users Within the European Economic Area (EEA)

Appvestor undertakes to respect the confidentiality of Your Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law, if You are within the EU, to:

• Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
• Correct the Personal Data that We hold about You.
• Object to the processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data in a structured, commonly used, machine-readable format (data portability).
• Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data at any time.
• Restrict processing. You have the right to request that We restrict the processing of Your personal data in certain circumstances as set out in Article 18 GDPR.
• Lodge a complaint with your local data protection supervisory authority.

You may exercise Your rights by contacting Us at privacy@appvestor.com. Please note that We may ask You to verify Your identity before responding to such requests.

We will respond to all valid data subject requests within 30 days of receipt. Where necessary, this period may be extended by a further two months, and We will inform You of any such extension.

You have the right to complain to the Danish Data Protection Authority (Datatilsynet): 

Carl Jacobsens Vej 35, DK 2500 Valby | Tel: +45 33 19 32 00 | dt@datatilsynet.dk 

16. For Users Within State-Specific areas in the United States

California (CCPA / CPRA)

If You are a resident of California, You have additional rights under the CCPA as amended by the CPRA:

• Right to Know: What personal information we collect, use, disclose, and sell about you.
• Right to Delete: Personal information we have collected from you, subject to certain exceptions.
• Right to Correct: Inaccurate personal information that we maintain about you.
• Right to Opt Out of Sale / Sharing: You have the right to opt out of the “sale” or “sharing” of your personal information for cross-context behavioural advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
• Right to Limit Use of Sensitive Personal Information: You may limit Our use of sensitive personal information to purposes necessary to perform the services you requested.

Categories of personal information collected in the past 12 months: identifiers (IP address, advertising ID, app set ID and Firebase installation ID), internet and network activity information (interaction with advertisements), and inferences drawn from such information, collected by Our advertising partner when advertisements are shown and by Google Firebase when the App’s configuration is fetched. Audio recordings, transcripts and the precise geolocation used for place tags are stored only on Your Device and are not transmitted to Us; coordinates are sent to Your Device’s geocoding service only to look up a place name.

We do not knowingly sell or share the personal information of consumers under 16 years of age without affirmative authorisation.

To exercise your California privacy rights contact us at: privacy@appvestor.com or visit: /us_resident/

Other US States

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Montana (MCDPA), Oregon (OCPA) and other states with applicable privacy laws have rights including access, correction, deletion, data portability, and opt-out of targeted advertising. Contact us at privacy@appvestor.com to exercise these rights.

Supplemental information for US state residents is available at: /us_resident/

17. LGPD – For Users in Brazil

If You are a resident of Brazil, You have rights under the Lei Geral de Proteção de Dados (LGPD – Law No. 13,709/2018). Appvestor ApS acts as the data controller in relation to the processing of Your personal data.

Your Rights Under the LGPD

In accordance with Article 18 of the LGPD, You have the following rights regarding Your personal data:

• Confirmation of processing: The right to confirmation of the existence of processing of Your personal data.
• Access: The right to access Your personal data held by Appvestor.
• Correction: The right to correct incomplete, inaccurate, or outdated personal data.
• Anonymisation, blocking, or deletion: The right to request anonymisation, blocking, or deletion of unnecessary, excessive, or unlawfully processed personal data.
• Data portability: The right to receive Your personal data in a structured, interoperable format for transfer to another service provider, subject to commercial and trade secrets.
• Deletion of consented data: The right to request the deletion of personal data processed on the basis of Your consent, except where retention is required by law.
• Information about sharing: The right to information about which public and private entities Your personal data has been shared with.
• Information about consent: The right to information about the possibility of not providing consent and the consequences of refusal.
• Revocation of consent: The right to revoke Your consent at any time through a simple and free procedure, by contacting privacy@appvestor.com or through the in-app settings.
• Objection to processing: The right to object to processing carried out on grounds other than consent, where non-compliant with the LGPD.
• Review of automated decisions: The right to request a review of decisions made solely on the basis of automated processing of personal data that affect Your interests.

Legal Basis for Processing Under the LGPD

Appvestor processes personal data of Brazilian residents on the following legal bases as set out in Article 7 of the LGPD:

• Consent (Art. 7(I)): Where You have provided free, informed, and unambiguous consent for a specific purpose, such as personalised advertising or tagging recordings with a place.
• Legitimate interest (Art. 7(IX)): For purposes such as fraud prevention, service improvement, and security, provided Your fundamental rights and freedoms are not overridden.
• Compliance with a legal obligation (Art. 7(II)): Where processing is necessary to comply with applicable law.

Supervisory Authority – ANPD

If You believe that the processing of Your personal data violates the LGPD, You have the right to lodge a complaint with the Brazilian National Data Protection Authority:

Autoridade Nacional de Proteção de Dados (ANPD)

Website: https://www.gov.br/anpd | E-mail: comunicacao@anpd.gov.br

To exercise any of Your LGPD rights, please contact Our DPO: John Lisek at dpo@appvestor.com or privacy@appvestor.com. We will respond within 15 days of receipt of Your request, as required under the LGPD.

18. PIPA – For users in South Korea

You have the right under this Privacy Policy, and by law, if You are within South Korea, to:

• Access Your Personal Data and update or delete the information We have on You.
• Correct the Personal Data We hold about You.
• Object to the processing of Your Personal Data.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Appvestor and Our Data Partners will not collect, process, share, or access any location data from South Korea. Location used for place tags is read and stored only on Your Device; the address lookup described in section 3 is performed by Your Device’s geocoding service.

You may exercise Your rights by contacting Appvestor at privacy@appvestor.com. 

19. Deletion of Your Data

All data that has fulfilled its purposes will be identified by Appvestor and deleted without delay in accordance with this privacy policy. Appvestor will take all commercially and technologically reasonable measures to ensure personal data will practically not be recoverable or reproducible. Digital documents containing personal data will be deleted via a technical method that will make it reasonably impossible to recover, retrieve, or become re-identifiable. Appvestor does not store personal data on non-digital documents or files.

Voice Recorder: Audio Memos does not use user accounts, and Appvestor does not store Your recordings or transcripts. You are in control of the data on Your Device:

• Delete individual recordings in the App; their transcripts, markers and place tags are deleted with them. Deleted recordings can be removed permanently from the Trash, and are otherwise removed automatically after 30 days.
• Delete a downloaded speech model under “Speech model” in the App’s settings.
• Remove everything the App stores by uninstalling it or by clearing its storage in Your Device’s system settings.
• Recordings copied to Music/Voice Memo and files You shared with other apps remain where they are until You delete them there. Android backup data in Your Google account can be managed and deleted through Your Google account settings.
• Reset or delete the Advertising ID of Your Device in its system settings.

To request deletion of any personal data Appvestor may hold about You (for example from correspondence with Us), contact privacy@appvestor.com.

20. Overseas Transfer of Data – South Korea (PIPA)

Appvestor may share personal data as described in this privacy policy with the following third-party service providers outside of Korea.

Users have the right to ask Appvestor not to continue overseas transfer of Personal Data by contacting Appvestor at privacy@appvestor.com or by changing Your choices under “Privacy options” in the App’s settings and the App’s permissions in Your Device’s system settings.

개인정보보호법과 정보통신망 이용촉진 및 정보보호 등에 관한 법률에 따른 국내대리인의 정보는 다음과 같습니다.

–       명칭 및 대표자: 제너럴에이전트 주식회사 (대표이사: 김은미)

–       주소: 서울특별시 종로구 새문안로5가길 28, 1216호(적선동)

–       전화번호: (02) 735-8706

–       전자우편 주소: appvestor@generalagent.co.kr