Privacy Policy

Effective Date: February 17, 2026  · Version: 1.0  · Last Updated: February 17, 2026

1.Introduction

Welcome to Dairoo, the personal calendar app that lets you save notes, images, videos, audio recordings, and documents for every day of the year.

Protecting your personal data is our top priority. This Privacy Policy informs you about what data we collect, why we collect it, how we use it, and your rights under the General Data Protection Regulation (GDPR - EU Regulation 2016/679) and the Italian Privacy Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Our core privacy principles:

  • Privacy by Design: Analytics services are disabled by default
  • Explicit Consent: We always ask permission before collecting non-essential data
  • Data Minimization: We only collect data strictly necessary for the service
  • Transparency: We clearly explain what we do with your data
  • Guaranteed Rights: You can access, modify, export, or delete your data at any time

2.Data Controller

The Data Controller is:

dairoo

Email: team@dairoo.com

For any request regarding the processing of your personal data or to exercise your GDPR rights, you can contact us at the addresses above.

3.Personal Data Collected

Dairoo collects different categories of personal data, depending on the features you use and the consents you have provided.

3.1 Authentication Data (Always Collected)

Legal Basis: Art. 6(1)(b) GDPR - Contract performance

When you create a Dairoo account via Google Sign-in or Apple Sign-in, we collect:

  • Email: Required to identify your account
  • Full Name: First and last name provided by the authentication provider
  • Profile Picture: Profile image (optional)
  • Firebase UID: Unique identifier generated by Firebase Authentication
  • Login Method: Google or Apple
  • Registration Date: Account creation timestamp

Source: Provided directly by you through Google or Apple during registration.

Why we collect it: This data is essential to create and manage your account, allow you to access the app, and sync your notes across devices.

3.2 User Content (Always Collected)

Legal Basis: Art. 6(1)(b) GDPR - Contract performance

When you use Dairoo to create notes, we collect:

  • Text Notes: Text entered in daily notes
  • Images: Photos uploaded by the user
  • Videos: Videos uploaded by the user
  • Audio: Audio recordings created in the app
  • Documents: PDF, Word, Excel, and other document files
  • Metadata: Creation date/time, modification date/time, note title
  • Calendar Settings: Calendar name, notification settings, language

Where it's stored:

  • Firestore (Firebase): Primary database (server: europe-west1 - Belgium)
  • Google Drive: Automatic backup synced with your personal Google account

Why we collect it: This is the core of the application. Without collecting this data, we couldn't provide you with the calendar and notes service.

Important: Your notes are encrypted at rest on both Firestore and Google Drive. Only you can access the content of your notes through your Google/Apple account.

3.3 Analytics and App Usage (Consent Required)

Legal Basis: Art. 6(1)(a) GDPR - Explicit consent

If you accept the "App Analytics" consent in privacy settings, we collect anonymous data about app usage via PostHog:

  • App Events: Screen views, user actions
  • Anonymous Identifier: Randomly generated anonymous_id stored on your device, never linked to your account
  • Device Information: Device model, operating system, app version
  • Timestamps: Date and time of events

What we DON'T collect:

  • ❌ Email or username
  • ❌ Firebase UID or any account identifier
  • ❌ IP Address (disabled with disableGeoip: true)
  • ❌ Content of your notes
  • ❌ Precise geolocation data

Server: Europe (Frankfurt, Germany) - PostHog EU Cloud

Why we collect it: To understand how users utilize the app and improve user experience.

How to revoke: Go to Settings → Privacy → Disable "App Analytics". The effect is immediate.

Retention: 7 years (configurable, can be reduced upon request)

3.4 Error Monitoring (Consent Required)

Legal Basis: Art. 6(1)(a) GDPR - Explicit consent

If you accept the "Error Monitoring" consent, we collect technical information about crashes and bugs via Sentry:

  • Stack Traces: Source code and error lines (anonymized)
  • Device Information: Model, operating system, app version
  • Breadcrumbs: Sequence of user actions leading to the error
  • Timestamps: Date and time of the error

What we DON'T collect:

  • ❌ IP Address
  • ❌ Cookies or personal identifiers
  • ❌ Email or username
  • ❌ Content of your notes
  • ❌ Session Replay

Server: Germany (EU)

Why we collect it: To identify and fix technical bugs, improving app stability.

How to revoke: Settings → Privacy → Disable "Error Monitoring".

Retention: 90 days from the error

3.5 Email Marketing (Consent Required)

Legal Basis: Art. 6(1)(a) GDPR - Explicit consent

If you accept the "Marketing Emails" consent, we subscribe your email to our newsletter via Loops.so:

  • Email, Name (optional), Subscription Date, Subscription Status

Email Frequency: Maximum 2 emails per month

How to revoke: Click "Unsubscribe" at the bottom of any email, or Settings → Privacy → Disable "Marketing Emails".

Server: USA (with Standard Contractual Clauses - SCC)

Retention: Until consent revocation or account deletion

3.6 Subscription Support (Consent Required)

Legal Basis: Art. 6(1)(a) GDPR - Explicit consent

If you accept the "Subscription Support" consent, we share data with RevenueCat to manage paid subscriptions:

  • Email, Name, Firebase UID, Login Method, Subscription Status, Expiration Date, Transaction ID

How to revoke: Settings → Privacy → Disable "Subscription Support".

Server: USA (with Standard Contractual Clauses - SCC)

Retention: Up to 12 months after account deletion

3.7 Onboarding Profile Data (Voluntarily Provided)

Legal Basis: Art. 6(1)(a) GDPR - Explicit consent; Art. 9(2)(a) GDPR for health-related data

During onboarding, we optionally ask you to share profile information. All fields are optional.

  • Age range, Gender, Occupation, Relationship status
  • Personal challenges: Selected from a list that may include references to emotional or psychological states

Important — Health Data (Art. 9 GDPR): The "personal challenges" category may include health-related data. This data is processed only on the basis of your explicit consent and is not shared with third parties.

Where it's stored: Firestore (europe-west1 - Belgium), in your private user document.

Retention: Until account deletion.

4.Purpose and Legal Basis

Pursuant to Art. 13 GDPR, below we summarize the processing purposes and related legal bases:

Data CollectedPurposeLegal BasisMandatory?
Email, Name, UIDAuthentication and account managementArt. 6(1)(b) - Contract✅ Yes
Note Content (text, media)Calendar service provisionArt. 6(1)(b) - Contract✅ Yes
Profile Data (age, gender, etc.)Internal app personalizationArt. 6(1)(a) - Consent❌ No
Personal Challenges (health data)Internal app personalizationArt. 9(2)(a) - Explicit consent❌ No
Analytics (PostHog)App improvement and UXArt. 6(1)(a) - Consent❌ No
Error Tracking (Sentry)App stability and bug fixingArt. 6(1)(a) - Consent❌ No
Email Marketing (Loops)Newsletter and promotional communicationsArt. 6(1)(a) - Consent❌ No
Support Email/Name (RevenueCat)Subscription assistanceArt. 6(1)(a) - Consent❌ No

5.Third-Party Services and Subprocessors

Dairoo uses the following third-party services ("subprocessors" under GDPR) to process your personal data:

5.1 Firebase / Google Cloud Platform

Services:
Firebase Authentication, Cloud Firestore, Cloud Functions, Firebase Storage
Location:
Europe (europe-west1 - Belgium)
Data Processed:
Email, name, UID, note content, metadata
Legal Basis:
Art. 6(1)(b) GDPR - Contract

5.2 Google Drive API

Service:
Automatic notes backup
Data Processed:
Note content (text, images, videos, audio, documents)
Important:
Notes are saved in YOUR personal Google Drive. We do not have access to your Google Drive.
Legal Basis:
Art. 6(1)(b) GDPR - Contract

5.3 PostHog (Analytics)

Location:
Europe (Frankfurt, Germany - EU Cloud)
Data Processed:
App events, anonymous_id, device info
Legal Basis:
Art. 6(1)(a) GDPR - Explicit consent
Consent Required:
Yes ("App Analytics")

5.4 Sentry (Error Tracking)

Location:
Germany (EU)
Data Processed:
Stack traces, device info, breadcrumbs
Legal Basis:
Art. 6(1)(a) GDPR - Explicit consent
Consent Required:
Yes ("Error Monitoring")

5.5 Loops.so (Email Marketing)

Location:
USA
Transfer Mechanism:
Standard Contractual Clauses (SCC)
Data Processed:
Email, name, subscription status
Consent Required:
Yes ("Marketing Emails")

5.6 RevenueCat (Subscription Management)

Location:
USA
Transfer Mechanism:
Standard Contractual Clauses (SCC)
Data Processed:
Email (if consent), name (if consent), Firebase UID, transaction data
Consent Required:
Yes ("Subscription Support") - only for email/name

6.International Data Transfers

Some of our subprocessors are located in the United States. We ensure all international data transfers comply with Chapter V of the GDPR (Art. 44-49).

Data Stored in EU

  • ✅ Firebase (europe-west1 - Belgium)
  • ✅ PostHog (Frankfurt, Germany)
  • ✅ Sentry (Germany)

Transfers to USA

  • Loops.so
  • RevenueCat
  • Legal Mechanism: Standard Contractual Clauses (SCC) — Decision 2021/914/EU

7.Data Retention

We retain your personal data only for as long as necessary, in accordance with Art. 5(1)(e) GDPR.

Data TypeRetention Period
Account and authenticationUntil account deletion
Note content (text, media)Until account deletion
Analytics (PostHog)7 years (reducible upon request)
Error logs (Sentry)90 days from the error
Email marketing (Loops)Until consent revocation or account deletion
Transaction data (RevenueCat)12 months after account deletion
Google Drive backupUntil manual deletion by you

Automatic Deletion on Account Deletion (within 48h):

  • ✅ Firebase Auth account deleted
  • ✅ All Firestore data deleted
  • ✅ Google Drive files automatically deleted
  • ✅ Loops contact deleted
  • ✅ RevenueCat customer deleted or anonymized
  • ✅ PostHog data: no deletion required (completely anonymous)
  • ✅ Sentry data: no deletion required (anonymous stack traces)

8.Your GDPR Rights

In accordance with Articles 15-22 of the GDPR, you have the following rights:

8.1 Right of Access (Art. 15)

You have the right to obtain a copy of all personal data we hold about you. Go to Settings → Export Data to generate a ZIP file containing all your notes, media, and account metadata.

8.2 Right to Data Portability (Art. 20)

You have the right to receive your data in a structured, machine-readable format. Use the same export procedure as the Right of Access (JSON export).

8.3 Right to Erasure — Right to be Forgotten (Art. 17)

Go to Settings → Delete Account and confirm with your email. All data is permanently deleted within 48 hours.

8.4 Right to Object (Art. 21)

Go to Settings → Privacy to disable individual consents: App Analytics, Error Monitoring, Marketing Emails, Subscription Support. Effect is immediate.

8.5 Right to Rectification (Art. 16)

For name/email: edit directly from your Google/Apple account settings. For note content: edit notes directly in the app. For other data: contact us.

8.6 Right to Restriction (Art. 18)

You have the right to request restriction of processing in certain circumstances. Contact us at team@dairoo.com explaining the request.

8.7 Right to Lodge a Complaint

If you believe the processing of your data violates the GDPR, you can lodge a complaint with:

Italian Data Protection Authority (Garante)

Piazza Venezia, 11 - 00187 Rome, Italy

Tel: +39 06.696771 · Email: garante@gpdp.it

Web: www.garanteprivacy.it

9.Data Security

We adopt appropriate technical and organizational measures to ensure a level of security appropriate to the risk, in accordance with Art. 32 GDPR.

Technical Measures

  • ✅ TLS 1.3 for all communications
  • ✅ Encryption at rest on Firestore (AES-256)
  • ✅ Encryption at rest on Google Drive
  • ✅ JWT tokens for Firebase authentication
  • ✅ Multi-factor authentication (Google/Apple MFA)
  • ✅ OAuth 2.0 for Google Drive
  • ✅ Firestore Security Rules
  • ✅ Firebase App Check

Organizational Measures

  • ✅ Data access limited to authorized personnel
  • ✅ Privacy training for all team members
  • ✅ DPA signed with all subprocessors
  • ✅ Daily automatic backups (7-day retention)
  • ✅ Incident Response Plan

Data Breach Notification

In case of a personal data breach, we commit to: notify the Authority within 72 hours (Art. 33 GDPR), notify affected users without undue delay if high risk (Art. 34 GDPR), and document all breaches.

10.Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect regulatory changes, new features, or improvements in data protection.

  • For substantial changes (e.g., new subprocessors, new purposes): email and in-app notification with 30 days' notice
  • For minor changes (e.g., editorial corrections): only the "Last Updated" date will be updated

All previous versions will be archived and available upon request.

11.Contact Information

For any question, request, or complaint regarding the processing of your personal data:

We commit to respond within 30 days of receiving the request (Art. 12.3 GDPR).

Appendix: Glossary

GDPR:
General Data Protection Regulation (EU Regulation 2016/679)
Data Controller:
Natural or legal person who determines purposes and means of processing (Dairoo)
Data Processor:
Entity that processes data on behalf of the Controller (e.g., Firebase, PostHog)
DPA (Data Processing Agreement):
Agreement between Controller and Processor
SCC (Standard Contractual Clauses):
EU standard contractual clauses for extra-EU transfers
Encryption at rest:
Encryption of data when stored (not in transit)
Encryption in transit:
Encryption of data during transmission (e.g., TLS)
anonymous_id:
Randomly generated local identifier (not personal data)
Firebase UID:
Unique Firebase identifier (pseudonymous, is personal data)

© 2026 Dairoo. All rights reserved.

Version 1.0 · Published February 17, 2026