Privacy Policy

Last updated: May 28, 2026

She Affirms ("we", "our", "us") operates the She Affirms mobile application (the "App"), an AI-powered manifest pipeline that generates personalized manifest images and whispered audio stories from your wishes. This Privacy Policy explains how we collect, use, store, and protect your information when you use our App. We are committed to protecting your privacy and being transparent about our data practices.

1. Data Controller

The data controller responsible for your personal data is:

Jasper Slowik (operating She Affirms)
Arnold-Schlüter-Weg 3
33100 Paderborn, Germany
Email: contact@sheaffirms.app

2. Data We Collect

We are committed to minimal data collection. She Affirms does not require account creation, login, or email registration. We use anonymous authentication linked to a pseudonymous RevenueCat App User ID. Here is what we collect:

2.1 Pseudonymized Identifiers

  • RevenueCat App User ID: A random, pseudonymized identifier generated automatically by RevenueCat. This same ID is used as your anonymous Supabase user ID so that your generated manifest library can persist across sessions and devices. It is not linked to your name, email, or Apple ID.
  • PostHog Pseudonymized ID: A random identifier used for pseudonymized analytics. This ID is hashed and cannot be directly linked to your identity.

2.2 Onboarding Responses

During onboarding, we ask optional questions to personalize your experience. These may include:

  • Your first name
  • Your experience with manifestation
  • Personal goals and areas of focus (e.g., abundance, love, confidence, self-trust)
  • Current mood and intention
  • Preferred manifestation method and visual style

Onboarding responses are stored locally on your device in AsyncStorage. Selected preferences (such as the active manifest, chosen method, and style pack) may be sent with each generation request so the AI pipeline can tailor the output.

2.3 Manifest Generation Prompts

When you create a manifest, you type or speak a wish. The wish text is transmitted to our Supabase Edge Functions, which forward a structured prompt to Google Gemini for translation into a story arc, scene description, and affirmation line, then to Google's Nano Banana Pro image model and ElevenLabs Turbo v2.5 for audio generation. The resulting image and audio file are stored in Supabase Storage, and the wish text, generated affirmation, translation JSON, and a moderation flag are stored in Supabase Postgres so your library remains available across sessions. All of this server-side data is keyed to your anonymous user ID and is permanently deleted when you tap "Delete Account" in Settings.

Sensitive content notice — GDPR Art. 9 explicit consent. Wishes often touch on health, relationships, sexuality, religion, beliefs, or financial goals — categories that EU law treats as special-category data (GDPR Art. 9) and that US state laws treat as sensitive personal information. By tapping Generate you give explicit consent for us and the AI providers listed in §8 to process the wish you submit. You can withdraw consent at any time by deleting your account. We recommend not including specific medical diagnoses, full real names, or other highly identifying details in your wish text.

Personal context. If you choose to provide a name, location, "why," or notes about important people during onboarding or in your profile, that text is stored on your user row in Supabase Postgres so future generations can be tailored. You can edit or remove it at any time in Settings.

Moderation log. Wishes pass through a pre-flight keyword filter and Google Gemini's safety system. When a wish is blocked or abstracted (for example, a celebrity name removed), the category that triggered the filter is logged with the generation row for safety auditing for up to 90 days. The original wish text is never sent to advertisers or used to train third-party AI models.

2.4 Voice Input Transcription

If you use voice input for your wish, the audio recording is sent to OpenAI's Whisper API for transcription. Per OpenAI's API policy, audio submitted to the Whisper API is not retained or used to train models. Only the resulting transcript text is then passed into the standard generation pipeline. The voice file is deleted immediately after transcription — we apply zero retention to raw voice data.

2.5 App Usage Analytics

We collect pseudonymized analytics events via PostHog to understand how the App is used and to improve the experience. These events include:

  • Screens viewed and features used
  • Manifests generated, favorited, and shared
  • Streak milestones
  • Method and style pack selections
  • Paywall interactions

No personally identifiable information is included in analytics events. User identifiers are hashed. IP addresses are anonymized. Session replay and touch capture are disabled.

2.6 Subscription Data

If you subscribe (weekly $7.99 or yearly $45.99 with a 3-day free trial on Yearly only), Apple processes the payment entirely. We receive only the subscription status (active, expired, trial) through RevenueCat. We never receive or store your payment details, credit card information, or Apple ID credentials.

2.7 Device Information

Basic device information (device type, operating system version, app version) may be collected for debugging and compatibility purposes. IP addresses may be collected by our analytics and crash reporting services but are anonymized and not stored in identifiable form.

3. Data Stored on Your Device

The following data is stored locally on your device using AsyncStorage and is never transmitted to our servers in identifiable form:

  • Your name and onboarding responses
  • Preferences (language, notification settings, default method and style pack)
  • Streak and daily progress data

Since the pivot to the AI manifest pipeline, your library of generated manifests (image files, audio files, and the associated affirmation line) is stored in Supabase Storage and Supabase Postgres, keyed by your anonymous RevenueCat App User ID — not on your device. This allows your library to persist if you reinstall the App. You can request deletion of this server-side data at any time (see Section 18).

Deleting the App from your device removes all locally stored data. To also delete server-side data, use the "Delete Account" option in Settings or contact us.

4. iOS Widgets

If you use the She Affirms widget on your Home Screen Screen, the current manifest affirmation line is shared between the App and the widget via a secure iOS App Group container on your device. This widget data does not leave your device.

5. How We Use Your Data

  • To provide, maintain, and improve the App
  • To generate your personalized manifest images and audio stories through our AI pipeline
  • To persist your generated library across sessions and devices, keyed by your anonymous user ID
  • To manage your subscription status
  • To understand App usage patterns through pseudonymized analytics
  • To send daily reminder notifications (only if you opt in)
  • To detect and fix bugs and improve performance

6. AI-Generated Content

All manifest images, audio stories, and affirmation lines in the App are generated by artificial intelligence (Google Gemini 3 Flash, Google Nano Banana Pro, ElevenLabs Turbo v2.5) in response to prompts derived from your wishes. AI-generated content can be imperfect, may contain inaccuracies, and reflects patterns in training data rather than verified facts.

The App is intended for inspiration, journaling, and personal reflection only. It is not a substitute for medical, psychological, financial, legal, or any other professional advice. You are solely responsible for your own well-being and for any decisions you make based on content generated by the App. If you are experiencing a mental health crisis, please contact a qualified professional or an emergency service.

7. Legal Basis for Processing

Under the GDPR, we process your data based on the following legal grounds:

  • Consent (Art. 6(1)(a)) and explicit consent (Art. 9(2)(a)): Analytics, crash reporting, and the processing of special-category data contained in your wishes are only collected after you explicitly grant consent. You can withdraw consent at any time in Settings.
  • Contract performance (Art. 6(1)(b)): Generating the manifest content you request, storing your library, and managing your subscription through RevenueCat are necessary to provide the service you purchased.
  • Legitimate interest (Art. 6(1)(f)): Crash reporting via Sentry is collected to maintain app stability and fix bugs. This processing is minimal, pseudonymized, and does not override your rights.

8. Third-Party Services

We use the following third-party services. Each receives only the minimum data needed for their function.

  • Supabase (Postgres + Storage + Edge Functions, EU region): stores your anonymous user ID, onboarding answers you choose to sync, generated manifest images and audio files, and processes generation prompts in transit. Privacy Policy
  • Google (Gemini API): processes the text of your wish to generate the image prompt and the 40-second whispered story script. Prompts are not retained beyond the generation call. API Terms
  • ElevenLabs: generates the whispered audio story from the script text. Privacy Policy
  • OpenAI (Whisper API): transcribes voice input to text when you use the voice input feature. Audio is not retained by OpenAI per their zero-retention API policy. Privacy Policy
  • RevenueCat: subscription management and payment status tracking. Receives your pseudonymized user ID and subscription status. Privacy Policy
  • PostHog: pseudonymized event analytics. Privacy Policy
  • Sentry: crash reporting and performance diagnostics. Receives pseudonymized crash logs and device metadata. No personally identifiable information is collected. Privacy Policy
  • Apple: payment processing via the App Store and push notification delivery. Privacy Policy

We have entered into data processing agreements with our third-party providers to ensure your data is handled in compliance with applicable data protection laws.

We do not sell, rent, or trade your personal data to any third party.

9. Device Permissions & Cookies / Tracking on Device

The App may request the following device permissions. All permissions are optional and you can change them at any time in your device settings:

  • Notifications: To send daily manifest reminders at your chosen time.
  • Microphone: Only requested when you use the voice input feature to dictate your wish. Audio is sent to OpenAI Whisper for transcription and is not retained.
  • Analytics Consent: After onboarding, we ask for your consent before collecting pseudonymized analytics.
  • Photo Library: Only requested when you use the share feature to save a generated manifest image to your gallery.

Germany — TTDSG §25. Where the App reads or writes information on your device for non-essential purposes (analytics, error reporting), we obtain your prior consent through the in-app Privacy Choices toggle (Settings → Privacy Choices). Essential SDKs (subscription management, crash safety) operate under the contract necessity / strictly-necessary exception.

10. Push Notifications

If you enable daily reminders, we schedule local notifications on your device at the time you choose. Notification content is generated locally. We do not use push notifications for marketing or promotional purposes.

11. Content Sharing

When you share a manifest, the App exports the generated high-resolution image (and optionally the paired audio story). No personal data is included in the shared file.

12. Children's Privacy

The App is intended for users aged 17 and over (App Store rating 17+). We do not knowingly collect personal data from children under 13 (COPPA), under 16 (GDPR jurisdictions where 16 is the floor — Germany, Ireland, Netherlands, Hungary, Italy), under 14 (Spain, South Korea), under 16 (Australia under the 2024 Privacy Act amendments), or under 18 for sensitive data in Brazil (LGPD Art. 14) and India (DPDP Act 2023). If we learn that we have inadvertently processed data of a child below the local threshold, we will delete it without undue delay. Parents or guardians who believe their child has used the App may contact contact@sheaffirms.app. The App is not directed at children.

13. Your Rights

Depending on your location, you have the rights below. Section 18 describes how to exercise them.

13.1 European Economic Area, Switzerland — GDPR / FADP

  • Access (Art. 15)
  • Rectification (Art. 16)
  • Erasure / "right to be forgotten" (Art. 17)
  • Restriction of processing (Art. 18)
  • Data portability (Art. 20)
  • Objection (Art. 21), including objection to processing based on legitimate interest
  • Automated decision-making (Art. 22): We do not engage in solely automated decision-making producing legal or similarly significant effects concerning you.
  • Withdraw consent at any time (Art. 7(3)) without affecting the lawfulness of prior processing
  • Lodge a complaint with a supervisory authority

United Kingdom. The App is not currently distributed in the United Kingdom App Store and is not directed at UK residents. We do not knowingly process the personal data of UK residents. If you believe you are a UK resident and have used the App through a non-UK Apple ID, please contact contact@sheaffirms.app and we will delete your data.

13.2 United States — CCPA/CPRA and other state laws

If you are a US resident, the following rights apply under your state's consumer-privacy law: California (CCPA/CPRA), Colorado (CPA), Connecticut (CTDPA), Delaware (DPDPA), Florida (FDBR), Indiana (INCDPA), Iowa (ICDPA), Kentucky (KCDPA), Maryland (MODPA), Minnesota (MCDPA), Montana (MCDPA), New Hampshire (NHPA), New Jersey (NJDPA), Oregon (OCPA), Tennessee (TIPA), Texas (TDPSA), Utah (UCPA), and Virginia (VCDPA).

  • Right to know / access what personal information we have collected.
  • Right to delete — use "Delete Account" in Settings.
  • Right to correct inaccurate personal information.
  • Right to portability.
  • Right to opt out of sale or sharing. We do not sell or share personal information for cross-context behavioral advertising. We have not sold or shared personal information in the preceding 12 months.
  • Right to limit use of sensitive personal information. Wishes may include religious beliefs, sexual orientation, or health data, which are sensitive personal information under California, Texas, Maryland and other state laws. We only process this content to generate your manifest; we do not infer characteristics about you, profile you, or share this content for any other purpose.
  • Right to non-discrimination.

CCPA Notice of Financial Incentive. The free generation offered after onboarding is not a financial incentive in exchange for personal information under Cal. Civ. Code §1798.125; it is a courtesy preview and does not require additional data.

California residents under the Shine the Light law (Cal. Civ. Code § 1798.83) may request a list of personal information disclosed to third parties for direct marketing — we do not engage in such disclosures.

13.3 Brazil — LGPD

Encarregado pelo Tratamento de Dados Pessoais (DPO): Jasper Slowik — contact@sheaffirms.app. Legal bases under LGPD Art. 7: consent, execution of contract, and legitimate interest. You may file a complaint with the Brazilian data protection authority (ANPD) at https://www.gov.br/anpd. The Consumer Defense Code (CDC) may overlap with consumer-related claims. Processing of children's data under LGPD Art. 14 follows the best-interest standard and requires specific parental consent for sensitive data.

13.4 Canada — PIPEDA & Quebec Law 25

Privacy Officer: Jasper Slowik — contact@sheaffirms.app. We will notify affected individuals and the Privacy Commissioner of any breach posing a "real risk of significant harm." Per Quebec Law 25 §12.1, we confirm we make no automated decisions producing legal or similarly significant effects. Complaints: OPC (https://www.priv.gc.ca) and CAI Québec (https://www.cai.gouv.qc.ca).

13.5 Australia — Privacy Act 1988 & APPs

We provide this APP 5 collection notice acknowledgement: we collect the data described in §2 for the purposes in §5, and disclose it to the sub-processors in §17. We make cross-border transfers to the United States and the European Union and take reasonable steps under APP 8 to ensure recipients handle your data consistent with the APPs. We do not disclose personal information overseas for direct marketing. Complaints: OAIC (https://www.oaic.gov.au).

13.6 India — DPDP Act 2023

Grievance Officer: Jasper Slowik — contact@sheaffirms.app. You may complain to the Data Protection Board of India. We require verifiable parental consent before processing data of users under 18; if a minor reaches the App, processing is paused pending consent.

13.7 South Korea — PIPA

Chief Privacy Officer: Jasper Slowik — contact@sheaffirms.app. Refusing consent to non-essential processing may limit certain optional features but does not affect core functionality. Under-14 users require parental consent. Complaints: PIPC (https://www.pipc.go.kr).

13.8 Japan — APPI

Cross-border transfer notice: recipient countries include the United States (covered by EU adequacy as well as the EU-US Data Privacy Framework and SCCs for transfers from the EU; provider- specific safeguards in place) and the European Union (subject of an adequacy decision). Complaints: Personal Information Protection Commission (https://www.ppc.go.jp).

13.9 Mexico — LFPDPPP

You may exercise ARCO rights (Acceso, Rectificación, Cancelación, Oposición). This Privacy Policy serves as our Aviso de Privacidad simplificado. Contact contact@sheaffirms.app; complaints to INAI (https://home.inai.org.mx).

14. Data Retention

  • Local data: Stored on your device until you delete the App or clear app data.
  • Generated manifest library (images, audio, affirmation): Stored in Supabase Storage and Postgres for as long as your anonymous user ID is active, or until you request deletion.
  • Wish text: Stored in your manifest library in Supabase Postgres for as long as your anonymous user ID is active. Permanently deleted on "Delete Account."
  • Voice files: Zero retention — deleted immediately after transcription by OpenAI Whisper.
  • Personal context (name, location, "why," notes): Stored on your user row in Supabase Postgres until you edit it or delete your account.
  • Moderation logs: Category flag retained for up to 90 days for safety auditing, then aggregated.
  • Sentry crash diagnostics: Retained by Sentry for up to 90 days. PII is stripped before transmission.
  • Analytics data: Pseudonymized PostHog events retained for up to 12 months.
  • Subscription receipts: Retained by RevenueCat and Apple for as long as required by App Store / RevenueCat compliance and tax/finance regulations.

15. Data Security

All network communication uses TLS/SSL encryption. Supabase data is protected by row-level security policies keyed to your anonymous user ID. Local data is stored in your device's sandboxed app storage.

16. International Data Transfers

Supabase data is hosted in an EU region. Several third-party providers may process limited data in the United States. We rely on:

  • EU-US Data Privacy Framework (DPF): Google Cloud (Gemini, Nano Banana Pro) and OpenAI (Whisper) are DPF-certified.
  • Standard Contractual Clauses (Commission Decision 2021/914): ElevenLabs and Sentry transfers operate under SCCs plus provider-specific safeguards.
  • Supabase EU-region hosting keeps your manifest library, wish text, and personal context within the EU.
  • RevenueCat (US): subscription metadata transferred under SCCs.
  • Apple: per Apple's published DPA and global infrastructure terms.

A Transfer Impact Assessment is maintained internally per EDPB Recommendation 01/2020. You can request a summary by emailing contact@sheaffirms.app.

17. Sub-processors

A current list of sub-processors and their roles is maintained at https://sheaffirms.app/subprocessors.html. We will provide reasonable notice of new sub-processors via an updated "Last updated" date on that page; continued use after such notice constitutes consent.

18. Exercising Your Rights (DSAR)

Exercising your rights. Submit requests via https://sheaffirms.app/dsar.html or by emailing contact@sheaffirms.app from any address with the words "DSAR — She Affirms" in the subject. Because we do not require accounts, we verify identity by asking you to provide your anonymous user ID (Settings → About → User ID) and the approximate date of first use. We acknowledge requests within 5 business days and substantively respond within 30 days (one 30-day extension permitted under GDPR Art. 12(3) / CCPA §1798.130). We do not charge for the first request per 12-month period.

19. Breach Notification

Where a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours (GDPR Art. 33). Where there is a high risk, we will notify affected users without undue delay (Art. 34). Additional jurisdiction-specific timelines: Quebec Law 25 — without delay if "real risk of significant harm"; Australia NDB scheme — as soon as practicable; LGPD — reasonable time as defined by ANPD; CCPA — per applicable state breach-notification statutes.

20. No Training on Your Data

No training on your data. We do not use your wish text, voice recordings, personal context, or generated outputs to train our own or third-party AI models. Our provider contracts include zero-retention or no-training terms where available: Google Cloud Paid Tier (no training on Vertex / Gemini API content), ElevenLabs Zero Retention Mode, OpenAI Zero Data Retention for enrolled organizations.

21. Accessibility

Our accessibility statement (European Accessibility Act compliance, WCAG 2.1 AA target) is available at https://sheaffirms.app/accessibility.html.

22. Contact & Supervisory Authorities

For privacy questions or requests: contact@sheaffirms.app. For DSA Art. 16 illegal-content notices: contact@sheaffirms.app.

Our lead EU supervisory authority is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (https://www.ldi.nrw.de). Per-region authorities are listed in §13.

23. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy with a new "Last updated" date.