Privacy Policy
Last updated: February 24, 2025
1. Responsible Party
Responsible person (according to Art. 4 para. 7 GDPR) and provider of this app:
Name: Lea Rademacher
Address: Viererblock 18a, 39326 Wolmirstedt
E-Mail: lea@transvoiceapp.com
2. General Information on Data Protection
We are pleased about your interest in our Trans-Voice app (hereinafter "App"). The protection of your privacy and your personal data has the highest priority for us. In this privacy policy, we inform you about the type, scope and purposes of processing your personal data.
3. Types of Data Processed
When downloading, registering and using our app, we may collect and process the following data depending on the scope of functions:
- Master Data
- E-mail address (mandatory for registration)
- Username/profile name (if you create one)
- Contact Data
- E-mail address (for support, password reset, newsletter etc.)
- Usage Data and Device Information
- IP address
- Device and browser information (e.g. operating system, app version)
- Log files (time of access, duration of use, functions accessed)
- Cookies or similar technologies that contain, among other things, a session or user ID
- Payment Data (when using paid services)
- Processed via external payment service providers (e.g. PayPal, Stripe)
- Voice Data
- Recorded voice clips or live audio for voice training (MTF)
- Duration, time and frequency of voice recordings
- Optional evaluation/analysis of this voice data to improve AI models (only with additional consent, see below)
Since voice recordings can allow conclusions to be drawn about gender or health, such data potentially constitute special categories of personal data (Art. 9 GDPR). We therefore treat this data with special care and obtain your express consent for processing (see point 5).
4. Purposes and Legal Bases of Data Processing
- Registration and Account Management
- Purpose: Enabling app use, creating a user account, support.
- Legal basis: Art. 6 para. 1 lit. b GDPR (fulfillment of a contract or pre-contractual measures).
- Voice Training and Live Voice Processing
- Purpose: Conducting real-time voice processing (e.g. voice effects, voice adjustment) or storing and analyzing voice recordings.
- Legal basis:
- Art. 6 para. 1 lit. b GDPR (contract fulfillment) for the basic function of the app.
- Art. 9 para. 2 lit. a GDPR (express consent) for processing possible special categories of personal data (e.g. conclusions about health).
- Optional Analysis/Improvement of AI Models
- Purpose: Using your voice data to further develop and improve our AI algorithms and models.
- Your express consent (Art. 6 para. 1 lit. a and Art. 9 para. 2 lit. a GDPR), which you can revoke at any time with effect for the future.
- Provision of the App and Security
- Purpose: Ensuring smooth operation, error analysis, IT security, protection against misuse.
- Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in a secure, trouble-free app).
- Newsletter and Marketing
- Purpose: Delivery of advertising information, news about the app.
- Art. 6 para. 1 lit. a GDPR (consent when subscribing to newsletter)
- You can unsubscribe from the newsletter at any time (opt-out link in every email).
- Payment Processing
- Purpose: Processing paid transactions via PayPal or Stripe.
- Legal basis: Art. 6 para. 1 lit. b GDPR.
Note on "Special Consent Processes"
Since your voice data can potentially contain sensitive information (e.g. conclusions about gender, health), express consent according to Art. 9 GDPR is additionally required for their storage and/or evaluation. This means that we will ask you for confirmation, for example, when starting recording for the first time or when uploading audio files, that we may process this data. Without this consent, further storage of voice data may not be possible.
Note on "Medical/Therapeutic Reasons" or "Interest Balancing"
- Art. 9 para. 2 lit. h GDPR (medical/therapeutic processing) may be relevant if the app is used in a medical context and medical professionals are involved.
- As a rule, however, we rely on your express consent for any processing of sensitive voice data.
- Interest balancing (Art. 6 para. 1 lit. f GDPR) alone is usually not sufficient for sensitive data (Art. 9 GDPR).
5. Data Storage and Deletion
We store the collected voice data and other personal data basically without time limitation, unless legal retention periods oppose this or you request deletion.
- You can have your account and all associated data deleted at any time via the account settings or by contacting us.
6. Data Sharing and Contract Processing
- Server Hosting and Database
- Voice recordings (voice clips) are stored on servers of DigitalOcean in Germany.
- IP addresses and other user data we store with Supabase (hosting location please specify more precisely, possibly in the EU).
- Voice Processing Services
- We use external service providers such as Whisper and OpenRouter to provide certain AI-based voice processing functions. These may transmit data to third countries (e.g. USA).
- We ensure that data processing agreements (Data Processing Agreements) and possibly standard contractual clauses are concluded with these service providers to ensure an adequate level of data protection according to GDPR.
- Payment Processing
- Exclusively via external service providers: PayPal and Stripe.
- In this context, payment data (e.g. credit card number, account information) can be transmitted directly to the payment service providers. The respective privacy policy of the payment service provider applies.
- No Sharing with Third Parties for Advertising Purposes
- We do not transmit your personal data to third parties for advertising purposes, unless you have expressly consented.
7. Newsletter and Advertising Emails
- If you subscribe to our newsletter, we use your email address to send you regular news.
- You can unsubscribe from the newsletter at any time via the unsubscribe link in the email or by sending us a message (see contact).
8. Cookies and Tracking (e.g. Umami)
- Type of Cookies: We use cookies and similar technologies (e.g. Local Storage) to recognize you as a user, save settings and ensure the functionality of the app.
- Analysis Tool Umami: We use Umami to evaluate user behavior (e.g. page views, clicks) anonymously.
- Legal basis: Art. 6 para. 1 lit. a GDPR, if you have consented to the use (cookie banner/tracking consent).
- You can restrict or prevent the setting of cookies at any time in your device settings or browser options. However, note that not all functions of the app may be fully usable.
9. International Data Transfer
- We operate our servers and databases basically in the EU/Germany.
- Certain external service providers (e.g. OpenRouter) may be located outside the EU (e.g. in the USA).
- When transferring to third countries, we use standard contractual clauses and other appropriate guarantees to ensure a level of data protection corresponding to the GDPR.
10. Data Security
We take appropriate technical and organizational measures (TOM) to protect your data from loss, manipulation and unauthorized access. These include encrypted connections (HTTPS), access and authorization concepts as well as regular security audits.
11. Your Rights as a Data Subject
You have the following rights according to GDPR (especially Art. 15-21):
- Information about your personal data processed by us.
- Correction of incorrect data.
- Deletion of your data, unless legal retention periods or overriding reasons oppose this.
- Restriction of processing if the accuracy of the data is disputed or the processing is unlawful.
- Data portability, i.e. provision of your data in a structured, common and machine-readable format.
- Objection to the processing of your data for reasons arising from your particular situation (Art. 21 GDPR).
- You can object to direct marketing at any time.
If you want to exercise any of these rights, please contact us using the contact details given below. Please note that we are entitled to verify your identity before providing information or making changes.
12. Contact for Data Protection / Data Protection Officer
Responsible Contact Person:
- Name: Lea Rademacher
- E-Mail: lea@transvoiceapp.com
(We are currently not obliged to appoint an official data protection officer, but we are happy to provide you with this contact person for questions about data protection.)
13. Right to Complain to a Supervisory Authority
You have the right to complain to a data protection supervisory authority of your choice, especially in the member state of your residence, workplace or the place of the alleged violation, if you believe that the processing of your personal data violates the GDPR.
14. Currency and Changes to this Privacy Policy
We reserve the right to adapt this privacy policy to update it for changed legal situations or when app functions are changed. You can always find the current version in our app or on our website.
Explanations on the Points "Consent Processes" and "Interest Balancing"
Consent Processes for Voice Data
- Why Consent?
Since voice data potentially constitutes data that allows conclusions about gender, health or other sensitive areas, we must obtain express consent (Art. 9 para. 2 lit. a GDPR). - How does this happen?
- When first opening the voice function or before uploading an audio file, you may receive a notice (pop-up) that explains why we need the audio data and how we process it.
- There you can actively agree ("Opt-in") that your voice data may be processed.
- Withdrawal
- You can revoke your consent at any time, e.g. by email to our contact address or in the app settings. However, this may result in the voice training functions only working to a limited extent.
Interest Balancing vs. Medical/Therapeutic Purposes
- Interest Balancing (Art. 6 para. 1 lit. f GDPR): When processing normal (non-sensitive) data, you can often claim a "legitimate interest". But with sensitive data (Art. 9 GDPR), this is usually not sufficient.
- Medical/Therapeutic Purposes (Art. 9 para. 2 lit. h GDPR) require processing by professionals or in a medically secured context. If your app operates more in the self-help/training area, this legal basis is rarely clearly applicable.
- Daher empfehlen wir die Therefore, we recommend express consent (Art. 9 para. 2 lit. a GDPR) for lawful processing of voice data when performing gender transition/voice training.