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Controller

Controller within the meaning of Art. 4(7) GDPR is the operator named in the Imprint. The contact details for all matters concerning this notice are given there.

A data protection officer has not been appointed; the statutory conditions requiring one are not met.

Scope

This notice applies to the Sheeps iOS application and to this website. It does not apply to third-party services reached from either.

Categories of data processed

Use of the application does not require a name, an email address or a telephone number. No account registration takes place.

  1. Account data: a randomly generated device identifier, a hash of a secret held on the device, time zone and the bedtime selected by the user.
  2. Preference data: selected themes, terms on the avoid list, selected voice, weirdness level, story length and story language.
  3. Content data: the stories generated for the user, together with their text, audio files and cover images.
  4. Usage data: start, last interaction and end of a playback session, and an estimate derived from these.
  5. Contract data: subscription status, credit balance and a record of each credit movement.
  6. Diagnostic data: events describing use of the application, crash and error reports, and processing times. The text of stories, the prompts used to generate them and the terms on the avoid list are not transmitted as part of this category.

Payment data is not processed. Payments are settled exclusively by Apple; card details, billing addresses and Apple Account data are not disclosed to the controller.

Terms entered on the avoid list may, depending on the entry, permit inferences about health within the meaning of Art. 9(1) GDPR. They are processed solely in order to exclude the corresponding content from generated stories, are not used for profiling and may be deleted by the user at any time in the application.

Purposes and legal bases

  1. Provision of the application, generation and delivery of stories, and administration of the credit balance — Art. 6(1)(b) GDPR (performance of a contract).
  2. Operational security, prevention of misuse, and diagnostic data for maintaining and improving the application — Art. 6(1)(f) GDPR (legitimate interests).
  3. Processing of avoid-list entries that permit inferences about health — Art. 9(2)(a) GDPR (explicit consent), given by the user through entry of the term and withdrawn by deleting it.
  4. Retention of records relating to purchases — Art. 6(1)(c) GDPR (legal obligation).

Data are not processed for advertising purposes, are not sold, and are not used to train machine-learning models, neither by the controller nor by the processors it engages. There is no cross-application or cross-website tracking and no advertising identifier is used.

Recipients

Data are disclosed to processors engaged under Art. 28 GDPR, bound by written agreement, acting solely on documented instructions and providing an equivalent level of protection. The categories are:

  • Hosting and database providers
  • Storage and content delivery providers
  • Providers of language-model, speech-synthesis and image-generation services
  • Providers of product analytics and error reporting
  • Providers of subscription management
  • Apple Inc. and Apple Distribution International Ltd., for distribution and payment processing

A current list of the processors engaged is provided on request. Requests to generate a story transmit preference data and the story generated so far; they do not transmit the device identifier. Beyond the above, data are disclosed only where the controller is legally obliged to do so.

Transfers to third countries

Some processors are established outside the European Economic Area, including in the United States and, for parts of speech synthesis and language-model generation, in other third countries. Transfers are made on the basis of the standard contractual clauses adopted by the European Commission pursuant to Art. 46(2)(c) GDPR, supplemented, for certified recipients in the United States, by the EU–US Data Privacy Framework in accordance with Art. 45 GDPR.

Storage period

  1. Account, preference and content data are stored until deleted by the user or until the account is deleted.
  2. Usage data and diagnostic data are erased after twelve months.
  3. Records relating to purchases are retained for the periods prescribed by tax and commercial law and are erased upon their expiry.

On deletion of the account, all data associated with it are erased, including the audio files and cover images held in storage. Records that must be retained under clause 7.3 are stripped of any reference to the account. Deleting the application from the device does not itself effect erasure.

Rights of the data subject

The data subject has the right of access (Art. 15 GDPR), to rectification (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18), to data portability (Art. 20) and to withdraw consent at any time with effect for the future (Art. 7(3)), without affecting the lawfulness of processing carried out before withdrawal.

These rights are exercised using the contact details given in the Imprint. Since no name and no email address are held, the account identifier displayed in the application must be provided; without it the controller is unable to identify the data subject (Art. 11(2) GDPR).

There is furthermore a right to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in the Member State of residence, place of work or place of the alleged infringement.

Right to object

Where processing is based on Art. 6(1)(f) GDPR, the data subject has the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them (Art. 21(1) GDPR). Following an objection, the data concerned will no longer be processed unless compelling legitimate grounds for the processing are demonstrated which override the interests, rights and freedoms of the data subject.

Provision of data and automated decision-making

Provision of the data described in clause 3 is neither required by law nor by contract, but is necessary in order to use the application. Without them no story can be generated or delivered.

Automated decision-making, including profiling, within the meaning of Art. 22 GDPR does not take place.

This website

This website sets no cookies, employs no analytics and loads no resources from third-party domains. The hosting provider processes server log data — IP address, time of request, requested resource and user agent — for the purpose of delivering the site and ensuring its security, on the basis of Art. 6(1)(f) GDPR. These logs are retained for a short period and are not combined with data from the application.

Minors

The application is not directed at children. Personal data of persons under the age of sixteen are not knowingly processed.

Amendments

This notice will be amended where changes to the application or to the applicable law so require. The version in force is the one published here.