Dailer

    PRIVACY POLICY

    Effective date: 13/08/2026

    Last updated: 13/08/2026

    This Personal Data Privacy Policy (hereinafter referred to as the "Privacy Policy") applies to all information posted in the Application and which may be obtained about the User during their use of the Application. This Privacy Policy is intended to ensure a high level of protection of the User's personal data.

    The Privacy Policy of LLC "START OF INNOVATION" is designed to ensure the highest possible level of protection of the User's personal data.

    In this document, you can find a list of the User's data that is processed; the purpose of processing; methods and terms of processing personal data; the rights granted to the User, as well as other provisions regarding the processing of personal data. If you still have any questions after reading this document, you can always send a letter to obtain the necessary information by sending it to the following address: contact@dailer.com.

    1. DEFINITION OF TERMS

    1.1. Terms used in this Privacy Policy:

    1.1.1. "Application Administration" – LLC "START OF INNOVATION" (legal entity identification code: 45893739) represented by Director Vasylko Anna and persons duly authorized by her to manage the Application and provide services to Users.

    1.1.2. "Application "Dailer"" (hereinafter – "Application") – software installed on smartphones and/or other hardware devices that enable the use of the Application with the operating systems listed below, through which, and via the Internet, the User has the opportunity to access the relevant data and functionality of the Application provided by the Application Administration

    iOS link: https://apps.apple.com/app/id6747252886

    1.1.3. "Confidentiality of personal data" - the requirement not to allow the distribution of personal data (mandatory for compliance by the Administrator or another person who has access to personal data) without the consent of the subject of personal data or the presence of another legal basis. mandatory for compliance by the Administrator or another person who has gained access to personal data.

    1.1.4. "User" - a person who uses the Application and has agreed to comply with the Application Terms and conditions

    1.1.5. "Personal data" - any information relating directly or indirectly to an individual (subject of personal data).

    1.1.6. "Processing of personal data" - any action (operation) or set of actions (operations) carried out with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

    1.1.7. LLC "START OF INNOVATION" - Limited Liability Company "START OF INNOVATION", legal entity identification code: 45893739, registered office: Ukraine, 79493, Lviv region, Rudne village, I. Mazepy str., building 4/8, registered and operating under the laws of Ukraine, represented by Director Vasylko Anna, acting on the basis of the Articles of Association.

    1.1.8. "Terms of Use" – conditions for using the Application, which are an integral part of this Contract and are available at the link: https://dailer.com/terms-conditions

    1.1.9. "IP address" - is a unique network address of a node in a computer network built according to the IP protocol.

    2. GENERAL PROVISIONS

    2.1. The use of the Application by the User means the User's full and informed consent to this Privacy Policy and the terms of personal data processing.

    2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Application.

    2.3. This Privacy Policy applies only to the Application. The Application Administration does not control the possibility of transition and is not responsible for third-party web-sites to which the User can follow the links available on the Application.

    2.4. The Application Administration does not verify and is not responsible for the accuracy of personal data provided by the User.

    2.5. The User has the right to:

    • 2.5.1. to know about the sources of collection, the location of their data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give an appropriate mandate to obtain this information to persons authorized by him, except for cases established by law;
    • 2.5.2. to receive information about the conditions of providing access to personal data, in particular, information about third parties to whom his data is transferred;
    • 2.5.3. have access to your data;
    • 2.5.4. enter a reservation regarding the limitation of the right to process your data when giving consent;
    • 2.5.5. withdraw consent to the processing of personal data;
    • 2.5.6. file complaints about the processing of your data;
    • 2.5.7. present a reasoned demand to the owner of personal data with an objection to the processing of his/her data;
    • 2.5.8. to submit to the Application Administration a request for correction or destruction of personal data;
    • 2.5.9. to receive personal data provided by the User to the Application Administration and to transfer it freely to other personal data administrators;
    • 2.5.10. require the Application Administration to disclose the following information:
      • (a) categories of personal data that the Application Administration has collected about the User;
      • (b) categories of sources from which personal data is collected;
      • (c) business or commercial purpose of collecting personal data;
      • (d) categories of third parties to whom the Application Administration discloses personal information;
      • (e) specific parts of personal data that the Application Administration has collected about the User.
    • 2.5.11. Account Deletion and Data Retention. You have the right to delete your account and associated personal data at any time. You can initiate the deletion process directly within the App settings (under "Account" or "Profile" section).

      Once you request account deletion, all your personal information (including name, email, and authentication identifiers from Google or Apple) will be permanently deleted or anonymized within 30 days, except where we are legally required to retain certain data.

      Please note that deleting the App from your device does not delete your account or personal data from our servers.

    2.6. The Application will not discriminate against you or take any action against you for exercising the rights set forth in Chapter 2 of this Policy.

    2.7. The legal grounds for the personal data processing are:

    • (a) Clause "a" of paragraph 1, Article 6 GDPR: Your consent of processing for Your personal data for the purposes stated in Clause 4.1 of this Policy;
    • (b) Clause "b" of paragraph 1, Article 6 GDPR: in case the processing of Your personal information is required for the performance of a contract to which You are the subject.

    2.8. The Application Administration does not sell or share the personal data it collects (within the meaning of the California Consumer Privacy Act), except for the transfer of limited advertising identifiers to Meta Platforms, Inc. and Adjust GmbH for the purpose of displaying and measuring the effectiveness of advertising — subject to the User's consent granted via App Tracking Transparency (ATT) (see the "Advertising and Tracking" section). California users have the right to opt out of such "sharing" under the CCPA/CPRA.

    2.9. The App Administration respects the User's tracking choice made through the App Tracking Transparency (ATT) system prompt on iOS devices. If the User declines to grant tracking permission, their data will not be used for personalized advertising across other companies' apps (see the "Advertising and Tracking" section).

    2.10. This Privacy Policy has been developed to confirm the compliance of the services provided by the Application with the provisions of the Law of Ukraine "On Personal Data Protection", the General Data Protection Regulation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ("GDPR"), the California Consumer Privacy Act of 2018 ("CCPA"), the California Online Privacy Protection Act ("CalOPPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Utah Consumer Privacy Act ("UCPA") and other laws governing the interaction with personal data of Internet users.

    3. SUBJECT OF THE PRIVACY POLICY

    3.1. This Privacy Policy defines the obligations of the Application Administration regarding non-disclosure and ensuring the regime of protection of the confidentiality of personal data which the User provides to the Application Administration for the proper use of the Application.

    3.2. Personal data permitted for processing under this Privacy Policy are provided by the User at their own discretion by filling out the appropriate forms in the Application or upon entering the Application.

    3.2.1. By filling out the registration form in the Application ("Welcome to Dailer" page), the User provides the following data:

    • User's e-mail.

    3.2.2. The User has the right to fill out the user profile ("Profile" page) and specify the following data:

    • User's Name and Surname.

    Entering such data occurs exclusively at the User's initiative.

    3.2.3. When using the AI assistant in the AI Chat section, the Voice Assistant, or other AI-powered features (scheduling suggestions, semantic search, automatic event categorization, and personal schedule summaries), the following data may be transferred to OpenAI OpCo, LLC: messages sent by the User to the AI assistant; voice recordings and their transcripts; fields from calendar events the User has explicitly connected (title, description, location, date/time, tags, attendee email addresses); and the full text of notes the User creates in Dailer. See Section 5.7 for the complete list of data, purposes, and User controls.

    3.2.3.1. Before any of the AI-powered features described in Clause 3.2.3 are activated, the User is shown a dedicated consent screen listing the specific data sent, the recipient (OpenAI OpCo, LLC), and the purposes of processing. AI features remain disabled until the User explicitly agrees. The User may review or withdraw this consent at any time in Settings → AI Data Sharing. The Application Administration provides internal monitoring (in the manner set out in this Policy); however, it is not responsible for the manner and methods by which OpenAI OpCo, LLC processes, stores, and deletes the data transmitted to it. Before activating any of the AI features, we strongly recommend reviewing the terms of use and privacy policy of OpenAI OpCo, LLC at the following link: https://openai.com/policies/

    3.2.4. During the first use of the Application, by displaying the relevant dialog boxes, the User is offered to grant the Application access to the device's geolocation and permission to send notifications. Granting or refusing such access and permission is carried out by the User at their own discretion. Access and permission may be revoked at any time through the settings of the User's device on which the Application is used. Failure to provide access and permission may limit the possibility of using the Application or suspend access to the Application as a whole.

    3.3. The Application collects statistics on the IP addresses of its Users. Such information is used for the purpose of identifying and resolving technical problems.

    3.4. Any other personal information, with the exception of that listed above (browsers, operating systems, etc.), is subject to secure storage and non-dissemination, except for cases provided for in clauses 5.2 - 5.3 of this Privacy Policy.

    4. PURPOSE OF COLLECTION OF PERSONAL USER INFORMATION

    4.1. The Application Administration may use the User's personal data in order to:

    • 4.1.1. Identification of the Application User to respond to a request, application of the User;
    • 4.1.2. Providing the User with access to personalised resources of the Application.
    • 4.1.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Application, providing potential services.
    • 4.1.4. Determining the location of the User to ensure security and prevent fraud.
    • 4.1.5. Confirmation of the accuracy and completeness of personal data provided by the User.
    • 4.1.6. Providing the User with effective customer and technical support in case of problems related to the use of the Application.
    • 4.1.7. Providing the User with product updates, special offers, pricing information, newsletters and other information on behalf of the Application with his/her consent.
    • 4.1.8. Carrying out advertising activities with the consent of the User.
    • 4.1.9. Providing the User with access to the Application or services of partners of LLC "START OF INNOVATION" in order to obtain products, updates and services.
    • 4.1.10. Providing AI-powered features (chat assistant, voice assistant, scheduling suggestions, semantic search, automatic event categorization, and personal schedule summaries) through our third-party AI processor, with the User's explicit consent.

    5. METHODS AND TERMS OF PERSONAL DATA PROCESSING

    5.1. The processing of the User's data is carried out without a time limit to achieve the purposes for which they were collected, following the specified Policy. Processing is carried out with the use of automation tools or without the use of such tools in any legal way.

    5.2. The User agrees that the Application Administration, in order to provide the service to the User, is authorised to transfer personal data to third parties, including, but not limited to, telecommunication operators, foreign subjects of relations related to the processing of personal data. We are also authorised to store and use the User's information to comply with our legal obligations and prevent abuse.

    5.3. The User's data may be transferred to the authorized bodies of the state authorities of Ukraine only on the grounds, conditions, and in the order established by the current legislation.

    5.4. In case of loss or disclosure of personal data, the Application Administration shall inform the User about the loss or disclosure of personal data.

    5.5. The Application Administration shall take all available and necessary organisational, technical and legal measures to protect the User's personal information from unauthorised or accidental access, destruction, blocking, copying, modification, distribution, dissemination, as well as from other illegal actions of third parties.

    5.6. The Application Administration together with the User shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

    5.7. Third-Party Services and Data Transfers. We use a set of trusted third-party services to ensure the app functions correctly, to analyze performance, and to improve user experience. These services may collect and process certain data:

    Authentication (Identity Providers)

    Google OAuth & Apple Sign-In: When you use these services to log in, we collect your name and email address to create and maintain your account.

    Data collected:

    • Name, email
    • language preference, and unique user identifier.
    • list of the calendars
    • calendar events and related event metadata;
    • timezone and calendar settings.

    We only access data that you explicitly authorize through the Google consent screen.

    Purpose: Account creation and security.

    How We Use Google User Data

    Google User Data is used solely for:

    • user authentication;
    • calendar synchronization;
    • creating, editing, and displaying calendar events;
    • AI-powered planning functionality;
    • improving user experience within Dailer.

    We do not use Google User Data for:

    • advertising purposes;
    • selling data to third parties;
    • building advertising profiles;
    • training generalized AI or machine learning models.

    Data Sharing and Disclosure

    We do not sell Google User Data to third parties.

    We may share limited data with trusted service providers strictly necessary to operate Dailer (such as cloud hosting, analytics, and infrastructure providers), and only to the extent required for service functionality.

    All such providers are required to maintain appropriate data protection and security standards.

    Data Protection and Security

    We implement industry-standard security measures to protect user data, including:

    • encryption in transit (TLS/HTTPS);
    • restricted access controls;
    • secure cloud infrastructure;
    • authentication and authorization safeguards.

    Data Retention and Deletion

    Google User Data is retained only for as long as necessary to provide the service functionality.

    Users may:

    • revoke Google account access through Google Security Settings;
    • request deletion of their data;
    • delete their Dailer account.

    Compliance with Google Policies

    Dailer's use and transfer of information received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.

    Analytics & User Engagement

    Amplitude: We use this to understand how users interact with our app (e.g., which features are used most often).

    Data collected: In-app events, clicks, and session duration.

    Purpose: Product optimization and analytics.

    OneSignal: We use this service for in-app messaging, user surveys, and content delivery (e.g., furniture-related updates).

    Data collected: Device identifiers (IDFV), engagement data (clicks on buttons via addClickName), and survey responses.

    Purpose: User communication and personalization.

    OpenAI OpCo, LLC:

    Dailer uses artificial intelligence to power its chat assistant, voice assistant, scheduling suggestions, semantic search, automatic event categorization, and personal schedule summaries. These features are powered by our third-party AI provider OpenAI OpCo, LLC (api.openai.com)

    We do not use any other third-party AI service.

    Data we send to OpenAI OpCo, LLC:

    • Messages you type in the AI chat
    • Voice recordings you make in the voice assistant, and their transcripts
    • Fields from calendar events you've explicitly connected (Google Calendar, Outlook, iCloud): title, description, location, date/time, tags, and attendee email addresses
    • The full text of notes you create in Dailer

    Purposes:

    • Powering the conversational AI chat and generating scheduling suggestions
    • Speech-to-text (transcribing your voice) and text-to-speech (spoken replies)
    • Generating text embeddings for semantic search over your own events and notes
    • Automatically categorizing calendar events
    • Generating your daily and monthly personal schedule summaries

    Data we do not send to OpenAI OpCo, LLC or any other third party: passwords, OAuth/login tokens, payment or subscription information, device identifiers, or contacts from your device's address book.

    Your control: AI features are off until you explicitly consent to them. You can review this disclosure and revoke consent at any time in Settings → AI Data Sharing. Disabling it turns off AI chat, the voice assistant, semantic search, auto-categorization, and summaries — core calendar features continue to work without it.

    Sub-processor safeguards: Data sent to OpenAI OpCo, LLC — including chat messages, voice recordings and transcripts, connected-calendar event fields, and notes — is used solely to provide the AI features described above. OpenAI OpCo, LLC retains this data for up to 30 days for abuse-monitoring purposes and does not use it to train OpenAI OpCo, LLC's models. OpenAI OpCo, LLC is contractually required to maintain data protection equivalent to the standards described in this Privacy Policy

    Internal observability: We use Langfuse, self-hosted on our own infrastructure, to monitor and debug AI feature performance. Your prompts and AI responses are not shared with any external observability or analytics vendor.

    Monitoring & Quality Assurance

    Sentry: To identify and fix software bugs and crashes in real-time.

    Data collected: Technical device information (OS version, device model) and crash logs.

    Purpose: Stability and performance monitoring.

    Langfuse: We use this self-hosted tool, running on our own infrastructure, for monitoring and evaluating the performance of our AI-driven features.

    Data collected: Inputs/outputs of AI interactions and performance metrics, stored only on our own infrastructure — not shared with any external vendor.

    Purpose: Improving AI accuracy and quality control.

    Advertising and Tracking

    Facebook SDK: The App uses the Meta Audience Network SDK (Facebook SDK) to display advertising and measure its effectiveness.

    For these purposes, the SDK may collect and process the following data:

    • Advertising Identifier (IDFA)
    • App usage data (Usage Data)
    • Advertising activity data (Advertising Data)

    This data is transferred to Meta Platforms, Inc. ("Meta" / Facebook) and may be used to personalize advertising, measure its effectiveness, and attribute app installs.

    The first time you launch the App on an iOS device, the system will ask for your permission to track (App Tracking Transparency). You can:

    • Grant or deny this permission directly in the prompt;
    • Change your decision later in your device settings: Settings → Privacy & Security → Tracking.

    If you decline tracking, your data will not be used for personalized advertising across other companies' apps.

    For more information on how Meta processes data, please see the Meta Data Policy.

    Adjust SDK: The App uses Adjust SDK (Adjust GmbH, Berlin, Germany — an AppLovin company) for app install attribution, measuring advertising effectiveness, and marketing campaign analytics.

    For these purposes, the SDK may collect and process the following data:

    • Advertising device identifier (IDFA) and vendor identifier (IDFV)
    • App usage data (app launches, session duration, feature interactions)
    • Device technical data (OS version, SDK version)
    • In-app purchase data (if this feature is enabled)

    This data is transferred to Adjust GmbH and may be used for install attribution, measuring the effectiveness of advertising campaigns, and aggregated analytics.

    When the App is first launched on iOS devices, the system will ask for your permission to track (App Tracking Transparency). You can:

    • Grant or deny this permission directly in the prompt;
    • Change your decision later in your device settings: Settings → Privacy & Security → Tracking.

    If you decline tracking, Adjust does not receive the IDFA and instead uses only probabilistic attribution methods, without identifying your device.

    For more information on how Adjust processes data, you can find it in Adjust's Privacy Policy.

    6. OBLIGATIONS OF THE PARTIES

    6.1. The User is obliged to:

    • 6.1.1. Provide information containing personal data necessary to use the Application.
    • 6.1.2. Update, supplement the provided information containing personal data in case of changes in this information.

    6.2. The Application Administration is obliged to:

    • 6.2.1. Use the information received solely for the purposes specified in Section 4 of this Privacy Policy.
    • 6.2.2. Ensure that confidential information is kept confidential, not disclosed without the prior written consent of the User, and not to sell, exchange, publish, or disclose in any other way the transmitted personal data of the User, except for clause 5.3 of this Privacy Policy.
    • 6.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure generally used to protect this type of information in the existing business environment.
    • 6.2.4. To block personal data relating to the relevant User from the moment of application or request of the User or his legal representative or authorised body for the protection of the rights of personal data subjects for the period of verification, in case of detection of inaccurate personal data or illegal actions.

    7. RESPONSIBILITY OF THE PARTIES

    7.1. The Application Administration, which has not fulfilled its obligations, shall be liable for losses incurred by the User in connection with the misuse of personal data in accordance with the legislation of Ukraine, except as provided for in clauses 5.2, 5.3 and 7.2 of this Privacy Policy.

    7.2. In case of loss or disclosure of Confidential Information, the Application Administration shall not be liable if this information is confidential:

    • 7.2.1. Became public domain before its loss or disclosure.
    • 7.2.2. Was received from a third party before it was received by the Application Administration.
    • 7.2.3. Was disclosed with the consent of the User.
    • 7.2.4. Was disclosed through the fault of the User.

    8. DISPUTE RESOLUTION

    8.1. Prior to filing a lawsuit in court in disputes arising from the relationship between the User and the Application Administration, a claim (a written proposal for the voluntary settlement of the dispute) shall be submitted.

    8.2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the consideration of the claim.

    8.3. In case of failure to reach an agreement, the dispute will be referred to a judicial authority in accordance with the current legislation of Ukraine.

    8.4. The current legislation of Ukraine applies to this Privacy Policy and the relationship between the User and the Application Administration.

    9. ADDITIONAL TERMS

    9.1. The Application Administration is authorized to update (change) the Privacy Policy without the prior consent of the User.

    9.2. The new version of the Privacy Policy enters into force from the moment it is posted in the Application, unless otherwise provided by the new version of the Privacy Policy.

    9.3. The User confirms that they are familiar with and aware of the provisions of this Policy and accept the terms.

    9.4. All suggestions, comments, complaints, or questions regarding this Privacy Policy, as well as requests, including those regarding the exercise of rights provided by Section 2 of this Policy, should be communicated by sending a letter to the email address: contact@dailer.com.

    9.5. The current Privacy Policy is posted in the “Privacy and Terms” section on the User's personal account page of the Application, as well as at the address: https://dailer.com/privacy-policy

    9.6. In fulfillment of the requirements of the legislation of Ukraine regarding personal data protection, we inform you that the controller is a legal entity registered in the territory of Ukraine: Limited Liability Company "START OF INNOVATION", legal entity identification code: 45893739, registered location: Ukraine, 79493, Lviv region, Rudne village, I. Mazepy str., building 4/8, which is registered and operates under the laws of Ukraine, represented by Director Vasylko Anna, acting on the basis of the Articles of Association.

    9.7. For users from the European Union - we comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation ("GDPR"). For users in the United Kingdom, we comply with the GDPR as enshrined in the Data Protection Act 2018. We have not appointed a Data Protection Officer (DPO) as we do not fall into the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

    9.8. The Application Administration does not collect, store, process, or otherwise use cookies during the operation of the Application. The functioning of the Application does not require the use of cookies, and therefore information about the User's actions is not recorded using such tools.

    We may from time to time make changes to this Privacy Policy to comply with legal requirements and to reflect any changes in our data collection process. We recommend that you check this Privacy Policy from time to time to ensure that you are aware of any changes. If necessary, we may notify you by email about changes to this Privacy Policy.