damlaYour words stay with you.
Last updated: 20 October 2026 · Applies to the Damla app for iPhone and iPad (version 1.0) and to damla.mobi.
The short version
- Damla has no account, no analytics, no advertising and no tracking.
- Your conversations, the clues Damla notes, your Relations and your saved notes are stored encrypted on your device. They are never sent to us.
- This version does not use AI. Replies come from written prompts and phrase matching that run on your device.
- Optional voice dictation uses Apple’s speech recognition, which may process audio on Apple’s servers.
- Damla+ subscriptions are handled entirely by Apple. We never see your payment details.
- You can delete everything in the app at any time: Settings → Delete all local data.
1. Who is responsible
The controller for the processing described here is:
Vits Consulting UG (haftungsbeschränkt)Meisenstrasse 6
40789 Monheim am Rhein
Germany
Managing director: Thomas Vits
Email: hello@damla.mobi
For anything about privacy, write to hello@damla.mobi. For readers in Türkiye, we act as data controller (veri sorumlusu) within the meaning of the Personal Data Protection Law No. 6698 (KVKK) to the extent it applies.
2. How this policy works
Damla is designed so that we, the developer, do not receive what you write. Most of this policy therefore describes data that exists only on your device and is controlled by you. Sections 6 to 9 describe the small amount of data that does reach us or another company: through Apple’s services, through this website, and when you email us.
3. What the app stores on your device
The app keeps its data in a single encrypted entry in the iOS Keychain. Only Damla on your device can read it. It contains:
| Data | Why |
|---|---|
| Date of birth | To confirm you are at least 16 and to apply extra protections under 18. If you enter an age under 16, it is not saved. |
| Your “Discover yourself” and “Ask Damla” conversations | So you can continue where you left off. |
| Clues: short quotes from your own messages, with the pattern they point to | To show you the evidence behind each tentative estimate. |
| Your chosen or estimated profile | To show your profile. |
| Relations: the first name or nickname you enter, the relationship type, a profile you choose, notes and conversations about that person | To help you reflect on your relationships. |
| Saved notes | To keep what you choose to remember. |
| Settings: language, dark mode, “Remember on this device”, number of Ask Damla exchanges today, safety pause status | To make the app work as you set it. |
If you turn off Settings → Remember on this device, conversations, clues, Relations and notes are not saved after you close the app. Your settings, date of birth and chosen profile are still kept.
None of this data leaves your device unless you share or export it yourself (section 5). The tentative profile estimates are calculated on your device; we cannot see them, and they have no legal or similar effect on you.
Backups and uninstalling
Keychain data can be included in your encrypted iCloud or computer backups, which are handled by Apple under its own terms. On iOS, Keychain data may also remain on the device after the app is deleted and reappear if you reinstall it. To remove everything for certain, use Settings → Delete all local data before you delete the app.
4. Information about other people
Relations and Ask Damla let you write about people in your life. That information stays on your device and is never sent to us. Please be thoughtful: use a first name or nickname, write only what helps you reflect, and do not use Damla to judge, rank or make decisions about anyone. Damla does not assess other people, and it refuses requests to diagnose, manipulate, hire or fire someone by type.
5. Sharing and exporting
- Profile cards. You can share an image of your profile card through the iOS share sheet. You choose the recipient; that service then handles the image under its own terms.
- Export. Settings → Export all my data creates a file (
damla-private-export.json) with your date of birth, conversations, clues, Relations and notes. The file is not encrypted. Only send it somewhere you trust. The app asks you to confirm first.
We do not receive anything you share or export, unless you send it to us yourself.
6. Voice dictation
Dictation is optional and starts only when you tap the microphone. The app asks for microphone and speech-recognition permission the first time. Your speech is converted into text by Apple’s speech recognition. Depending on your device and language, Apple may process the audio on its servers. Apple acts as an independent controller under the Apple Privacy Policy. Damla does not record or keep audio; it receives only the text, which you can review before sending. You can withdraw these permissions at any time in iOS Settings → Damla.
7. Damla+ subscriptions
Damla+ is sold through Apple’s App Store. Apple processes your purchase, payment and Apple Account details as an independent controller. The app checks your subscription status on your device using Apple’s StoreKit. We do not receive your name, email address or payment information.
Apple provides us with sales and financial reports, such as how many subscriptions were sold in which country. We use them for accounting and tax obligations. Deleting your local data does not cancel your subscription; manage or cancel it in your Apple Account settings.
8. Analytics and crash reports from Apple
Damla contains no analytics or tracking code of its own. If you have allowed it in iOS Settings → Privacy & Security → Analytics & Improvements → “Share with App Developers”, Apple may give us aggregated usage statistics and crash reports through App Store Connect. They do not identify you to us. You can turn this off at any time in iOS Settings.
9. This website
damla.mobi is a static website hosted by Cloudflare, Inc. (USA) on Cloudflare Pages. It has no forms, no analytics, no advertising, no embedded third-party content and no scripts. We do not set cookies.
When you visit, Cloudflare processes your IP address, the time of the request, the page requested, your browser’s user agent and the referring page. This is technically necessary to deliver the site and to protect it from abuse. In exceptional cases Cloudflare may set a strictly necessary security cookie to detect malicious traffic. Cloudflare acts as our processor under a data processing agreement and keeps such logs only for a short time. The legal basis is our legitimate interest in a secure, working website (Art. 6(1)(f) GDPR; § 25(2) TDDDG for any security cookie).
10. When you write to us
If you email hello@damla.mobi, we receive your email address, your message and anything you attach. We use this only to reply to you. Our email is hosted by an email service provider acting as our processor. Please do not send your exported file or personal reflections unless they are needed to help you.
We delete correspondence when it is no longer needed. That is usually within three years of our last contact, unless we have to keep it longer by law, for example for business letters relating to a purchase.
11. What we do not do
- No user accounts or sign-in.
- No advertising, ad identifiers or tracking across apps and websites.
- No analytics or crash-reporting SDKs in the app.
- No selling or renting of personal data.
- No sending of your conversations, clues, Relations or notes to us or to any AI service.
12. Sensitive information
You may choose to write about your health, beliefs, relationships or other sensitive topics. This stays on your device and is not processed by us. Damla is not a medical device, a diagnostic tool or a crisis service. If you are in danger, contact local emergency services or see our safety resources.
13. Legal bases
Where the GDPR or UK GDPR applies, we rely on:
- Art. 6(1)(b): performing our contract with you, for example answering support questions about the app or Damla+.
- Art. 6(1)(c): legal obligations, such as keeping accounting and tax records.
- Art. 6(1)(f): legitimate interests, such as running a secure website and replying to general messages.
Where the KVKK applies, the corresponding grounds are Art. 5(2)(c) (performance of a contract), Art. 5(2)(ç) (legal obligation) and Art. 5(2)(f) (legitimate interest). Data that stays only on your device is under your control and is not processed by us.
14. International transfers
Apple and Cloudflare may process data in the United States and other countries. For the United States, transfers rely on the EU–U.S. Data Privacy Framework where the recipient is certified, and otherwise on the European Commission’s Standard Contractual Clauses (with the UK Addendum for the UK). For transfers from Türkiye, we rely on the standard contracts and other safeguards under Art. 9 KVKK, as applicable.
15. Security and retention
On your device, data is protected by the iOS Keychain and your device passcode. We keep the data that reaches us (emails, Apple reports) only as long as needed for the purposes above or as required by law. German commercial and tax law can require us to keep accounting records for up to ten years.
16. Deleting your data
- In the app: Settings → Delete all local data. This permanently removes everything Damla stored on this device. It does not cancel Damla+.
- Single items: you can delete individual notes and people in Relations.
- Emails: ask us at hello@damla.mobi and we will delete our correspondence with you, unless the law requires us to keep it.
Because we hold no copy of your app data, we cannot restore it, move it to a new phone or delete it for you. There is no sync between devices.
17. Your rights
Under the GDPR and UK GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). Where we rely on consent, you can withdraw it at any time.
You can also complain to a supervisory authority, for example the one where you live or the one responsible for us: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), www.ldi.nrw.de. In the UK, this is the Information Commissioner’s Office (ico.org.uk).
Under Art. 11 KVKK you have the right to learn whether your personal data is processed; to request information about it; to learn the purpose of processing and whether it is used accordingly; to know the third parties in Türkiye or abroad to whom it is transferred; to request correction or deletion and notification of this to third parties; to object to a result against you that arises exclusively from automated analysis; and to claim compensation for damage caused by unlawful processing. You may also complain to the Personal Data Protection Board (www.kvkk.gov.tr).
To use any of these rights, email hello@damla.mobi. We will reply within one month (30 days under the KVKK).
18. Age
Damla is for people aged 16 and over. The app asks for your date of birth and does not continue for anyone under 16. We do not knowingly collect data from children.
19. Changes to this policy
If a future version adds an online feature, such as AI-assisted replies, we will update this policy and explain it in the app, and ask for your consent before any of your text leaves your device. The date at the top always shows the latest version.