UpwardSpiralData Protection Guideline
Effective Date: August 19, 2025
Version: 1.1 (Beta)
🚨 Please Read: You Are Using a Beta Version
Welcome to the creawie Happiness Journal! We are thrilled to have you here. As a beta tester, you are getting an early look at our app, and your feedback is vital.
However, "beta" means our app is still under development. We need to be completely transparent with you:
- Data Security is NOT Guaranteed: Our security measures are not yet fully implemented. Your data is stored in a database that is not encrypted at rest.
- Risk of Data Loss: It's possible that data might be accidentally deleted during this phase. Please do not use the app for information you cannot afford to lose.
- Purpose Limitation: We promise to use your data for one reason only: to improve and develop the app. We will never sell it or use it for marketing.
By using the beta version, you acknowledge and accept these conditions and risks.
The Short & Simple Version
We believe in transparency. Here’s the gist of our data practices in plain English:
- What we collect: Your WhatsApp name & phone number, your email, and the content of the voice messages you send us.
- How it works: When you send a voice message, our system automatically transcribes it to text and analyzes it to find "happy moments" and deeper insights.
- Why we collect it: To make the app work! We store your journal entries so you can review them. We also analyze them to improve our app's core features.
- Your Control: You are in complete control. You can ask us to delete all your data at any time by sending an email to info@creawie.com. We will delete it within 24 hours.
- After the Beta: At the end of the beta, we will contact you and ask if you want to keep your data for the official launch or if you want it permanently deleted. The choice is yours.
1. Who We Are
The creawie Happiness Journal app ("the service") is provided by:
Ralph Pighin, operating under the business name "creawie" (Sole Proprietor)
[Your Full Street Address]
[Your City, Postal Code]
Germany
Email: info@creawie.com
For the purpose of data protection laws like the EU General Data Protection Regulation (GDPR), we are the "Data Controller" of your personal information.
2. What Data We Process and Why
We only collect data that is essential for the app to function and to improve it during this beta phase.
| Data Type | Why We Need It |
|---|---|
| WhatsApp Phone Number / Identifier & WhatsApp Name | To identify you as a unique user and connect your journal entries to your account. |
| Email Address | To allow you to sign up and log in to our web app to view your journal entries. We will also use it to contact you regarding the beta program. |
| Voice Messages & Their Transcripts | This is your journal entry. We process the voice message to create a text transcript, which is then stored so you can review it. |
| Synthesized Insights and "Happy Moments" | This is a core feature. Our system analyzes your transcript to extract the core event (e.g., "met with spouse") and higher-level insights about what contributes to your happiness (e.g., "meaningful connections are important"). This is stored and shown to you, and helps us improve our analysis features. |
3. How Your Data is Processed: The Technical Journey
To understand the risks, it's important to know the path your data takes:
- You send a voice message to our designated number on WhatsApp.
- WhatsApp delivers this message to our automation platform, n8n.
- The workflow sends the audio file to OpenAI's ChatGPT API for transcription.
- The text transcript is then analyzed to generate insights.
- The transcript and the analysis results are stored in our Supabase database, linked to your WhatsApp identifier.
- When you log in to the web app, we retrieve this data from the database to show you your entries.
4. Legal Basis for Processing Your Data
Under GDPR, we must have a valid legal reason to process your data. For this beta service, our legal basis is your Consent.
By signing up for the beta and sending your first voice message, you explicitly consent to the processing of your data as described in this guideline, including the transfer of your voice data to the US for transcription and the inherent risks of a beta product. You can withdraw this consent at any time by requesting the deletion of your data.
5. Who We Share Your Data With (Third Parties)
We do not sell your data. However, we use essential third-party services (subprocessors) to provide our service. Here’s who they are and what they do:
Core Infrastructure (within the EU)
- Microsoft Azure: Our automation platform (n8n) is hosted on Azure in the "Germany West Central" region (Frankfurt, Germany).
- Supabase / Amazon Web Services (AWS): Our database is provided by Supabase and hosted on AWS servers in the "EU-Central-1" region (Frankfurt, Germany).
Transcription Service (in the US)
International Data Transfer Notice
To convert your voice messages into text, we use the API service provided by OpenAI, LLC, which is based in the United States.
- This means your voice data is transferred from our servers in Germany to OpenAI's servers in the US for the sole purpose of transcription.
- This transfer is conducted under a recognized legal mechanism. OpenAI is certified under the EU-U.S. Data Privacy Framework, which ensures an adequate level of protection for your personal data.
By using our service, you acknowledge and consent to this transfer of your voice data to the United States for processing by OpenAI.
6. Data Retention: How Long We Keep Your Data
We will store your data for the duration of the beta phase. At the end of the beta, we will contact you via email and ask for your explicit consent to either:
- Migrate your data to the official, secure version of the app.
- Permanently delete all of your data.
If we don't hear back from you within a reasonable timeframe, we will default to the most privacy-friendly option: permanent deletion. Remember, you can request deletion at any point.
7. Your Data Protection Rights
You have rights over your data. Because this is a beta with a small team, the easiest way to exercise these rights is to email us directly at info@creawie.com.
- The Right to Access: You can ask for a copy of the data we hold about you.
- The Right to Rectification: You can ask us to correct inaccurate data (e.g., update your email address). Note: Transcribed entries cannot be edited.
- The Right to Erasure (The "Right to be Forgotten"): You have the right to request the complete deletion of your data at any time. We promise to fulfill this request within 24 hours of receiving your email.
- The Right to Withdraw Consent: You can withdraw your consent at any time by requesting data deletion.
8. Compliance with WhatsApp Policies
We are committed to complying with Meta's WhatsApp Business Platform policies. By using our service, you are initiating a conversation with us and instructing us to process the messages you send. Our processing is a direct function of the journaling service you are signing up for, and we do not use your data for any other purpose.
9. Contact Us
If you have any questions, concerns, or requests regarding your data, please do not hesitate to contact us.
Data Protection Contact:
Ralph Pighin
info@creawie.com