Privacy
What happens to your data.
As of: September 3, 2026
Who is responsible
The controller for the processing of your data is clicksgefühle GmbH & Co KG. Full details are in the legal notice.
- Postal address
- clicksgefühle GmbH & Co KG, Hauptplatz 46, 7100 Neusiedl am See
- Privacy enquiries
- office@clicksgefuehle.at
- Data protection officer
- Not yet appointed. Whether Heartwood must appoint one is currently being assessed; contact details will appear here once decided.
What data Heartwood processes
Your account
Email address, a display name of your choosing, your language, your plan and the times of creation and last sign-in. There is no password – you sign in via a link sent to your email address.
Your answers and recordings
The text of your answers, your voice recordings, your own rating of meaning and feeling – and, if you enable it, the location of a recording, rounded to about 100 metres. Every earlier version is kept: re-recording an answer does not overwrite the old one. You can delete individual versions yourself at any time.
These answers regularly contain special categories of personal data. The question catalogue explicitly asks about faith and belief, about illness, care and mental state, about grief and dying, about shame and guilt. Such details enjoy special protection under Art. 9 GDPR. Heartwood processes them only because you have expressly consented – see below.
Technical data
When you request a sign-in link, your IP address is not stored; only a non-reversible check value derived from it. It serves solely to prevent mass sending of sign-in links and is deleted after 24 hours. Browser identifiers are not stored. There is no analytics, no advertising identifiers and no embedded third-party content – even the fonts are served from our own server.
Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Running your account, sign-in, providing the archive | Contract, Art. 6(1)(b) GDPR |
| Content touching special categories – faith, health, sex life, origin, political opinion | Explicit consent, Art. 9(2)(a) GDPR |
| Transcribing your recordings | Contract, Art. 6(1)(b) – transcription carries search, review and profile. It is on by default and therefore expressly not a consent; you may object at any time in the menu. Where special categories are involved, your consent under Art. 9(2)(a) additionally applies. |
| Passing your legacy to the people you named | Contract and your release, Art. 6(1)(b) |
| Preventing abuse of sign-in link sending | Legitimate interest in a working sign-in path, Art. 6(1)(f) |
You can withdraw your consents at any time. Withdrawal takes effect for the future; the lawfulness of processing up to that point is unaffected.
Who else receives your data
Heartwood does not sell data and does not pass it on for advertising. Running the service does require providers. This table names every one of them:
| Recipient | For what | Which data | Location |
|---|---|---|---|
| OpenAI * | Transcribing voice recordings; on your explicit request also the life profile and questions about your own archive; also reading out the catalogue questions | the complete original voice recording; for profile and archive questions additionally the text of your previous answers. For reading out, only the catalogue question text is sent – no answer, no name. If a recipient asks a question about a released legacy, the answers released for them and the owner's display name are sent along | USA |
| Brevo (Sendinblue GmbH) | Sending emails | your email address, the message content including the sign-in link; for legacy emails the archive owner's display name | EU |
| Cloudflare * | Storing voice recordings, delivering the website and nightly backups | the voice recordings themselves, all traffic between your device and Heartwood, and the backup copies of database and recordings | Stored in the EU (Eastern Europe region); provider based in the USA |
| Hostinger | Running the server | everything held in the database: account, answer texts, locations, contacts, releases | Frankfurt am Main, Germany |
| OpenStreetMap Foundation (Nominatim) | Turning a recording location into a place name – only if you enabled location capture | the coordinates, rounded to about 100 metres; no account, no content | EU / United Kingdom |
| Spracherkennung deines Browsers * | live transcript while recording and voice commands in drive mode – only when transcription is enabled | the microphone signal. In Chrome, Edge and other Chromium browsers it is sent to a Google service for this; Safari and Firefox process it on the device depending on version | depends on browser; USA for Chromium |
* Transfer to a country outside the EU. What is still missing for this is set out below under “What is still open”.
Location entries in your archive and export include a map link to Google Maps – with the exact, unrounded coordinates. Heartwood never calls Google on its own; only clicking that link sends the coordinates there. This also applies to people you pass an export to or for whom you released memories.
How long things are kept
| Answers, recordings, earlier versions | until you delete them individually or delete your account. There is no automatic deletion – a life archive is meant to last. |
|---|---|
| Account | until you delete it |
| Sign-in links | valid for 15 minutes, entry deleted after 24 hours |
| Sessions | 30 days, then deleted; immediately on sign-out |
| Backups | 30 days |
| Blocked email addresses | If the delivery provider reports that an address was unreachable, we keep that for 30 days and then delete it – for that period it also blocks sign-in. If someone objected instead, meaning “stop writing to me”, that entry stays: deleting it after a period would mean writing to that person again. They can contact us at any time, with or without an account. |
Your legacy
You can release individual answers to named people. That release only takes effect after 90 days without a sign-in from you, followed by 30 days during which Heartwood asks after you, followed by a further 30-day period. If two of your trusted contacts confirm that you have died, only the first 90 days are skipped – the enquiry period and the notice period run unchanged, and a single person cannot trigger anything at all. Any sign-in stops the process immediately, at any stage. Recipients see only what you designated for them. Everything else stays private – then too.
Your rights
You have the following rights in relation to us:
- Access to what data we process about you (Art. 15)
- Rectification of inaccurate data (Art. 16)
- Erasure (Art. 17) – you can also trigger this yourself under “Delete account and all content”
- Restriction of processing (Art. 18)
- Data portability (Art. 20) – the export in your archive provides texts, metadata and recordings
- Objection to processing based on legitimate interests (Art. 21)
- Withdrawal of consent, at any time and without giving reasons (Art. 7(3))
Write to office@clicksgefuehle.at. You may also lodge a complaint with a supervisory authority; in Austria this is the Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Wien.
No automated decision-making with legal effect takes place. The life profile is a summary of your own answers for yourself – it does not score you and is shown to nobody else.
Cookies and browser storage
Heartwood sets exactly one cookie: fragen_session keeps you signed in, expires after 30 days and is not readable by scripts. It is required to operate the service, which is why there is no consent banner – there is nothing here we would need your permission for.
Your browser's local storage additionally holds unsent drafts, so they survive navigating away, and the device setting for location capture. Drafts are deleted when you sign out. Neither leaves your device.
What is still open
Heartwood claims only what verifiably holds. These points do not hold yet and are named here rather than concealed:
- No documented safeguard under Art. 46 GDPR is yet in place for the transfer to OpenAI in the USA. The same applies to Cloudflare: your recordings and the backups verifiably reside in the EU, but the company is based in the USA and the traffic between your device and the server runs through its global network. Those contracts will be concluded before the public launch and named here.
- Whether OpenAI excludes the transmitted content from training its own models is currently not contractually secured. For the life profile and archive questions the request is technically marked as not to be stored; no such setting exists for transcription.
- A data protection impact assessment under Art. 35 GDPR is mandatory for a life archive and has not yet been carried out.
If that goes too far for you, that is a fair call. You can switch transcription off in the menu – then no recording goes to the transcription service, and your browser's speech recognition is not started. The recording itself is still stored, in the audio store named above; if you would rather it were not, you can answer in writing. And you can delete your account and all its content yourself at any time.