PRIVACY

Soulfi App - Microsoft Azure OpenAI (incl. the Whisper model)

Version date: 2026-06-04

Important note: This notice explains how the Soulfi App processes personal data for AI chat and optional voice input features. It is intended as a clear, user-friendly legal notice for international use.

1. Data controller

Soulfi GmbH

Email: privacy@soulfi.com

Phone: +49 40 22860138

Data Protection Officer: Maike Kruse

Email: privacy@soulfi.com

2. What this notice covers

This notice explains data processing for:

AI chat,

optional voice input (microphone),

storage and deletion of chat content.

Voice input is optional. You can always use chat by typing.

3. AI chat with Microsoft Azure OpenAI

3.1 What is this service?

Soulfi uses Microsoft Azure OpenAI Service to generate AI-based chat responses.

3.2 How an AI request works

You enter a message.

Example: "I feel anxious about tomorrow."

• Your message is transmitted in encrypted form (for example, TLS).
• The service processes your message and generates a response.
• The response is shown in the app.
• Example: "That is understandable. Here are three short breathing techniques that may help now."

3.3 Practical text-chat example

Typical flow:

You type: "I feel very nervous today."

• The message is securely transmitted.
• The service generates a suitable response.
• The response appears in your chat history.

3.4 AI model training

Under the contractual terms used by Soulfi with Microsoft Azure OpenAI, customer data are not used to train base models.

3.5 Processing location

AI processing (chat and speech-to-text) is performed on Microsoft Azure infrastructure in the EU region Sweden (Sweden Central), based on the configured setup.

Soulfi's app backend (for example account and chat data) is hosted on servers of Hetzner Online GmbH in Germany.

Processing in third countries outside the EU/EEA is not intended under the configured setup.

4. Voice input and speech-to-text (Whisper via Microsoft Azure OpenAI)

4.1 What happens during voice input?

You can optionally speak instead of typing. Your speech is converted into text and that text is processed in the chat.

4.2 Processing flow

Audio is recorded locally on your device.

Example: You say: "I am anxious about tomorrow's appointment."

• Transmission starts only after active user action (for example, tapping microphone/send).
• Audio is converted into text via OpenAI's Whisper model, operated through Microsoft Azure OpenAI.
• Example: Speech becomes text: "I am anxious about tomorrow's appointment."
• The transcribed text is processed in the chat context.

4.3 Practical voice-input example

You press the microphone button.

You speak your message.

• Audio is converted into text.
• The text is processed like a normal chat message.
• You receive the AI response in chat.

4.4 Text input vs. voice input

Text input (default):

You type a message.

• The text is processed.
• The response appears in chat.
• Voice input (optional):
• You speak a message.
• Audio is converted into text.
• The text is processed exactly like normal chat input.

Both paths lead to the same functional result. Voice input is an optional convenience feature.

4.5 Audio and text data

Audio data are processed for speech recognition.

The transcribed text is relevant for chat history.

Voice input can be disabled via operating system permissions.

5. Legal bases

Where the GDPR applies, processing is based in particular on:

• Art. 6(1)(b) GDPR (performance of contract) for core chat features,
• Art. 6(1)(a) GDPR (consent) for optional microphone use,
• Art. 9(2)(a) GDPR (explicit consent), where special category data are provided.

Outside the GDPR scope, equivalent legal bases under applicable local law may apply.

6. Retention and deletion

Chat content is stored according to product-side retention rules (currently up to 12 months), unless deleted earlier.

Users can delete chat content in the app.

Audio data from voice input are retained only as needed for technical processing and then deleted according to active system rules.

Practical examples:

Individual messages can be removed.

Full chat history can be deleted in app settings.

Microphone permissions can be withdrawn at any time in the operating system.

7. Recipients and processors

To provide the service, Soulfi uses technically required service providers, including Microsoft (Azure OpenAI, including the Whisper model for speech-to-text).

Relevant data-processing agreements are in place where legally required.

8. Security measures

Soulfi applies appropriate technical and organizational safeguards, including:

transport encryption,

access controls,

role-based permissions,

security and availability controls in cloud infrastructure.

9. Your rights

Subject to applicable law, you may have the right to:

• access,
• rectification,
• erasure,
• restriction of processing,
• data portability,
• objection,
• withdrawal of consent with future effect.

Please send requests to: Datenschutz@soulfi.de

10. Complaints

You may lodge a complaint with your local data protection authority, where applicable.

For users in the EU/EEA, this is typically your local supervisory authority.

11. Sources and further information

Microsoft Privacy: https://aka.ms/privacy

Microsoft Trust Center: https://azure.microsoft.com/support/trust-center/

Azure OpenAI: https://learn.microsoft.com/azure/ai-services/openai/

Azure OpenAI – Whisper (speech-to-text): https://learn.microsoft.com/azure/ai-services/openai/whisper-quickstart

12. Signing in to the app

Using the app requires a user account. You can sign in with your email address and a password. On Apple devices you can additionally use "Sign in with Apple"; in that case Apple shares your name and email address or, at your choice, an anonymized Apple relay email address. Sign-in via other third parties (such as Google) is not offered.

13. Location-based feature (weather)

The app can optionally use your approximate location ("While Using the App") to show your local weather and a matching daily greeting on the home screen. For this, your approximate coordinates are sent to the weather service Open-Meteo (open-meteo.com), which returns the current weather data. If location access is not granted, your approximate location may instead be derived from your IP address (service: ipwho.is). The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw the location permission at any time in your operating system settings.

14. Changes to this notice

Soulfi may update this notice due to legal, technical, or product-related changes. The latest published version in the app or related information pages is authoritative.

15. Advertising Measurement (Meta)

15.1 What is this?

Soulfi is advertised on Facebook and Instagram. To know whether that advertising works, we use Meta's software development kit (SDK) inside the app. It measures whether someone who saw an ad goes on to install the app and take certain steps. This helps us spend our advertising budget sensibly and reach only people who may actually benefit from Soulfi.

15.2 Which events are measured?

Exactly five events are transmitted:

• the app was opened
• an account was created (with an indication of whether via email, Google or Apple)
• a free trial was started
• a subscription was taken out
• a payment was confirmed

For subscription and payment, we also transmit the amount, the currency and whether it is a monthly or annual plan. The events for trial, subscription and payment are sent by our server only after Apple or Google have confirmed the purchase – never on the mere tap of a button.

15.3 What is explicitly not transmitted?

Soulfi is a mental health app. For that reason, no content goes to Meta: no mood entries, no journal texts, no chat conversations, no chosen goals or topics. Your email address, name or phone number are not transmitted to Meta either – we deliberately do not use the so-called Advanced Matching that Meta offers.

15.4 Which data is used for this?

So that Meta can attribute an event to an ad, technical identifiers are transmitted:

• an anonymous device identifier generated by the Meta SDK
• your device's advertising ID (IDFA on iOS, Google Advertising ID on Android) – only if you have consented (see 15.6)
• technical device details: device model, operating system version, language setting, screen size, time zone, app version

We additionally store these identifiers on our server and associate them with your Soulfi account so that our server can report the subscription and payment events.

15.5 A concrete example

You see a Soulfi ad on Instagram, tap it and install the app. On first launch, iOS asks whether Soulfi may track your activity across other apps. You agree. Meta then learns: "A device that saw the ad has installed and opened the app." If you later register and start the free trial, Meta learns: "This device created an account and started a trial." What you write in the app or how you are feeling is never disclosed to Meta.

15.6 Your consent and how to withdraw it

Transmission to Meta takes place only with your consent. On iOS, the system asks you on first launch ("Allow Soulfi to track your activity?"). If you decline, no advertising ID is collected and the SDK operates in a restricted mode in which Meta may use the data for measurement only, not for building audiences.

You can change your decision at any time:

• iOS: Settings → Privacy & Security → Tracking → Soulfi
• Android: Settings → Google → Ads → Delete or reset advertising ID

You can also contact us at any time (see Section 1); we will then delete the identifiers stored on our side.

15.7 Recipient, international transfer and retention

The recipient is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Meta may transfer the data to Meta Platforms, Inc. in the United States. Meta is certified under the EU-US Data Privacy Framework; the transfer relies on the corresponding adequacy decision of the European Commission. How Meta processes the data is described in Meta's Privacy Policy: https://www.facebook.com/privacy/policy

15.8 Legal basis

Art. 6(1)(a) GDPR (consent) in conjunction with Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG) for access to your device identifiers. Consent is voluntary; the app works fully without it.