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Privacy Policy

Learn how we protect your privacy and handle your data in our AI-powered voice recording app.

Last updated and effective: October 4, 2026

This Privacy Policy explains what personal data the Primo Notes app for iPhone, iPad and Android and the website primonotes.com, including its free AI tools, process, why, who else receives it, how long it is kept and what rights you have. We wrote it to describe what the app and the website actually do. If something here is unclear, write to us and we will explain.

1. Who We Are

The controller of your personal data is Primo Technology Ltd. (“we”, “us”). You can reach us about anything in this policy at the address under Contact. We have not appointed a data protection officer, because the law does not require one for our processing; privacy questions come straight to us at the same address.

2. What This Policy Covers

This policy covers the Primo Notes app and primonotes.com. It does not cover the App Store or Google Play, which process your purchase and your store account under their own policies, or websites we link to.

In short: you can use the app without giving us your name. Your recordings stay on your device. The text of your notes and the files you add are processed by the AI providers named below to produce transcripts, summaries, flashcards and quizzes, and we do not sell your data or show ads.

3. What We Collect, Why, and Our Legal Basis

3.1 Your Account

  • What: the app creates an anonymous account the first time you use it. You can instead sign in, or later link the anonymous account, with Apple, Google, an email and password, or an email sign-in link. We store an account identifier, your email address if you sign in with one, how you signed in, your device platform, the app version you started with, whether you have premium, your monthly usage counters and when the account was created and last used. We do not ask for or store your name.
  • Why: to keep your notes in sync and tied to you, to apply the free plan and premium limits, and to let you sign in on another device.
  • Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).

3.2 Your Notes and the Material You Add

  • What: what you create or add in the app: recordings, uploaded audio and video, photos, PDFs, web links and YouTube links, and what the app makes from them: titles, transcripts with speaker labels, summaries, flashcards, quizzes, your AI chat messages, folders, language and duration.
  • Where: recordings you make stay on your device. A file that has to be processed is uploaded to our cloud storage only for the time the processing takes and is deleted as soon as it is done. The resulting note text is stored in our database under your account so that it syncs across your devices.
  • Why: to provide the features you ask for.
  • Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR).

Material you add may contain personal data about other people, such as a lecturer’s voice or names in a document. We process it only to produce the note you asked for, and you are responsible for having the right to record and upload it. Please do not add health data or other sensitive information about yourself or others unless you need it in your notes.

3.3 Subscriptions

  • What: Apple or Google processes your payment; we never see your card details. RevenueCat, our subscription provider, receives your account identifier, your email address if your account has one, your platform and sign-in method, identifiers of your app installation and device, and the store’s record of your purchases, so that it can confirm which subscription you hold.
  • Why: to unlock premium, restore purchases on a new device and keep the records accounting law requires.
  • Legal basis: performance of our contract with you, and compliance with our legal obligations for financial records (Art. 6(1)(b) and (c) GDPR).

3.4 Analytics, Install Attribution and Diagnostics

  • What: Google Analytics for Firebase records how the app is used (screens, features used, app version, device type, language, approximate region) together with your account identifier and an app installation identifier. On Android, Firebase Crashlytics sends crash reports with the device state at the time of the crash. AppsFlyer records which advertising campaign, if any, led to your install, using your device identifiers, IP address, our subscription identifier for you and your email address if your account has one. On iPhone and iPad, AppsFlyer uses the advertising identifier only if you allow tracking when the app asks; on Android you can reset or delete the advertising identifier in your device settings.
  • Why: to see which features work, fix crashes and learn which campaigns bring people to the app. We do not use this data to show you ads.
  • Legal basis: our legitimate interest in understanding and improving the app and our marketing (Art. 6(1)(f) GDPR), and your consent where the operating system asks for it, such as Apple’s tracking prompt (Art. 6(1)(a) GDPR). You can object to analytics at any time by writing to us.

3.5 Permissions and Notifications

The app asks for the microphone to record, the camera and photo library to add pictures, and, on iPhone and iPad, permission to track as described above. Reminders, such as the notice before a free trial ends, are scheduled on your device and do not pass through our servers. You can change any permission in your device settings; the related feature then stops working.

3.6 The Website and the Free AI Tools

  • Visits: Google Analytics 4 records the pages you view, how you arrived, your device and browser, an approximate location derived from your IP address (Google Analytics does not store the IP address itself) and actions such as tapping a download button. Legal basis: our legitimate interest in running and understanding the website (Art. 6(1)(f) GDPR).
  • Free tools: when you use a free tool, the text, PDF, image, audio or YouTube link you submit is sent to our server, processed by the providers listed in section 4 and the result is returned to you. We do not store what you submit or the result. If a request fails, our error log may contain part of it for up to 30 days. Legal basis: performance of the service you request (Art. 6(1)(b) GDPR).
  • Abuse protection: to keep the free tools free, a small cookie counts how many runs you have used today and expires after 24 hours, and Google reCAPTCHA Enterprise, through Firebase App Check, assesses your browser and IP address to tell people from automated abuse. The website also remembers in your browser’s storage whether you closed the app download prompt. Legal basis: our legitimate interest in security and in preventing abuse (Art. 6(1)(f) GDPR).

4. AI Processing

Transcripts, summaries, flashcards, quizzes, chat answers and the results of the free tools are generated by AI. To produce them, we send the following to these providers, who act as our processors:

  • AssemblyAI: your audio and video, through a temporary link, for transcription and speaker labels.
  • OpenAI: the text of your notes and transcripts, your chat messages and the text you submit to a free tool, to generate summaries, flashcards, quizzes, answers and other study material.
  • Google (Gemini): your photos and PDFs, to read their text, and essays or documents you submit to a free tool.
  • Jina AI (Jina Reader): a web address you add, to read the text of that public page.
  • RapidAPI and the YouTube Data API: a YouTube link you add, to fetch the video’s public transcript and details.

Under the API terms we use, these providers do not use your content to train their models. They may keep it for a limited period to detect abuse and then delete it. On iPhone and iPad the app asks for your permission before your content is sent to them for the first time, and you can withdraw it in the app’s settings. AI makes no decision about you that has legal or similarly significant effects.

5. Who Receives Your Data

We do not sell your personal data and we do not share it for advertising. Besides the AI providers in section 4, these service providers process data on our behalf, each only for the purpose described:

We may also disclose data where the law requires it, for example to a court or authority with a valid request.

6. International Transfers

Several of these providers are based in the United States or process data there. Where a recipient is certified under the EU-US Data Privacy Framework, we rely on the European Commission’s adequacy decision for it; otherwise we rely on the European Commission’s Standard Contractual Clauses in our agreement with the provider. You can ask us for more detail on the safeguard that applies to a provider.

7. How Long We Keep Data

  • Your account and notes: until you delete a note or your account. Deleting the account erases them at once.
  • Files sent for processing: deleted from our cloud storage as soon as processing is finished.
  • What you submit to a free tool: not stored; error logs that may contain part of it are kept for up to 30 days.
  • Server logs: up to 30 days.
  • Analytics: Google Analytics keeps event data for no longer than 14 months; Crashlytics keeps crash reports for 90 days.
  • Subscription records: as long as you have a subscription and afterwards for as long as accounting and tax law requires.
  • AI providers: only for the limited abuse-monitoring period of their API terms.
  • Install attribution: under AppsFlyer’s retention rules, and deleted on request.

8. Delete Your Account and Data

In the app: open Settings, choose Delete account and confirm. This permanently deletes your account, all your notes, transcripts and generated material, your usage records and any files still in our cloud storage, and signs you out on every device. Recordings saved on your device are removed from the app’s storage.

Without the app: email us at the address under Contact with the subject “Delete my account” from the address you signed in with, or tell us how you signed in. We will confirm and complete the deletion within 30 days.

What is kept: purchase records we must keep under accounting and tax law, and data the providers above hold under their own retention periods, as described in section 7. On request we also ask RevenueCat and AppsFlyer to delete what they hold about you.

Subscriptions: deleting your account does not cancel a subscription. Cancel it in your App Store or Google Play account settings.

9. Children

Primo Notes is intended for people aged 16 and over. Users aged 13 to 15 may use it only with the permission of a parent or guardian. It is not directed at children under 13 and we do not knowingly collect their data. If you believe a child has used Primo Notes without the required permission, write to us and we will delete the data.

10. Security

Data travels encrypted between your device, our servers and our providers. Our database and storage rules let each account reach only its own data, our server endpoints are protected against automated abuse, and access to production systems is limited to the people who run the service. No system is perfectly secure, so if we learn of a breach that affects you, we will notify you and the supervisory authority as the law requires.

11. Your Rights

Under the GDPR you have the right to:

  • access the personal data we hold about you and get a copy;
  • have inaccurate data corrected;
  • have your data deleted, as described in section 8;
  • restrict our processing;
  • receive the data you gave us in a portable format;
  • object to processing based on our legitimate interests, including analytics;
  • withdraw a consent you gave at any time, without affecting processing that happened before.

To use a right, write to us at the address under Contact. We answer within one month and may ask you to confirm that the account is yours. Giving us your data is not a legal requirement, but without an account the app cannot sync your notes. If you live outside the EU, for example in the United States, you can make the same requests and we will honour them.

12. Changes to This Policy

When we change how we process data, we update this policy and the date at the top. If a change materially affects you, we also tell you in the app or by email before it applies.

13. Contact

Primo Technology Ltd. Email: info@techprimo.ai.