Version 1.0 (draft for legal review) · Effective date: [[PLACEHOLDER: date of release]] · Last updated: 2026-10-08
Items in
[[PLACEHOLDER: ...]]must be filled by the owner before this policy is published. "WishBell" is the final product name.
1. Who we are
"WishBell" (the App) is provided by [[PLACEHOLDER: legal entity name]], [[PLACEHOLDER: registered company address]] ("we", "us"). We are the "Data Fiduciary" under India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the "controller" under the EU/UK GDPR.
- Contact for privacy questions: support@wishbell.app [[PLACEHOLDER: confirm mailbox is live]]
- Grievance Officer (India): [[PLACEHOLDER: name]], [[PLACEHOLDER: designation]], [[PLACEHOLDER: postal address]], email [[PLACEHOLDER: grievance email]], phone [[PLACEHOLDER: phone, optional]]. We acknowledge a grievance within [[PLACEHOLDER: 48 hours]] and resolve it within [[PLACEHOLDER: 15 days, and not later than the time the law allows]].
- EU/UK representative (only if required): [[PLACEHOLDER: name and address, or "not appointed"]]
2. The short version
- Your data stays on your phone. Events, people, dates, notes and settings live in a database on your device. We do not receive them unless you turn on a feature that needs the internet.
- Everything that leaves your phone is optional and has its own switch: cloud backup, AI features, analytics, crash reports. Each starts off and asks you first. You can withdraw any of them at any time in Settings.
- We never send phone numbers, your private notes or gift records to AI. Only the small set of fields listed in section 6 is sent, and only when you use an AI feature. A photo is sent only when you pick it yourself for Photo Magic; it is shrunk, its location and camera data are removed on your phone first, and the result is deleted from our servers within 24 hours.
- We do not sell your data, we do not use it for advertising and we have no advertising SDK in the App at launch. We do not track you across other apps or websites.
- You can export or delete everything from inside the App.
3. Data we handle and why
3.1 Data stored only on your device (we do not receive it)
| Data | Why |
|---|---|
| Events: title, date, time, repeat rule, tithi settings, category, card style, reminders, memories | To count down and remind you |
| People you add: name, nickname, relation, side of family, gender (optional), circles, birthday, anniversary, work anniversary, barsi / punyatithi, custom dates, likes, notes, photo, phone number (optional), wish log, gift log | To remind you and to help you wish them |
| Wish Studio: Wish Memory (for each wish you share: the first 8 words of the wish, the date, the format such as text, card or animated card, the card design, the language and tone, and the app you shared with), card designs you make, photos you add to cards, AI art and Photo Magic results you keep, and the card prepared for the "Card ready" morning reminder | So a wish is never repeated to the same person, to show "last year you sent…", and to re-open a card |
| Settings: language, theme, region (Purnimanta / Amanta), notification choices, consent choices | To run the App the way you set it |
| Imported contact birthdays and calendar events (when you choose to import) | Read on your device only, to let you pick what to add. The App does not upload your address book or calendar |
| Text extracted from an image you scan (when you use Scan to Add) | Read by on-device text recognition (Google ML Kit, runs on your phone) |
If you turn on App Lock, the on-device database is encrypted and the key is held in the Android Keystore or iOS Keychain.
3.2 Data that leaves your device, only when you switch the feature on
| Feature (optional) | Data | Who processes it | Purpose |
|---|---|---|---|
| Account and cloud backup | Sign-in identifiers (Google or Apple account name and email, or phone number if you sign in by OTP), a unique user ID, and your backed-up events, people, circles, settings and photos. Phone numbers of people you added are never included in the backup; they stay on your phone. | Google Firebase (Authentication, Cloud Firestore, Cloud Storage, Cloud Messaging, App Check) | Back up, restore and sync between your devices; check that requests come from the genuine App |
| AI features (Magic Add, Wish Studio wishes, gift ideas, ask) | The limited fields in section 6, plus your own typed or spoken text for Magic Add | Our AI gateway (Firebase Cloud Functions), which calls Google (Gemini) or Anthropic (Claude) to generate the answer | To turn your text into an event, write a wish or suggest ideas |
| AI art backgrounds (Wish Studio, optional) | Occasion, festival, the art style and colours you pick, and up to 5 one- or two-word motifs you choose (for example "cricket"). No names, no text, no photos | Our AI gateway, which calls a Google image model (Gemini image / Imagen). The finished picture is stored in Google Cloud Storage | To paint a card background; the App draws your text on top |
| Photo Magic (Wish Studio, Plus, optional) | The one photo you pick, shrunk to at most 1024 pixels with location, camera and other hidden data removed on your phone, plus the style you choose. You confirm that you own the photo or have the right to use it | Our AI gateway, which calls a Google image-editing model (Gemini image). The photo you upload is not stored; the result is stored in Google Cloud Storage | To turn your photo into a festive or artistic picture for a card |
| Purchases | Purchase and subscription status, an anonymous or account user ID, store receipt tokens. We never see your card or UPI details | RevenueCat, and Google Play or Apple App Store | Unlock Plus, restore purchases, fraud prevention |
| Analytics (opt-in) | Which screens and features are used (for example "event created"), device model, OS version, app version, language, a random installation ID. No names, notes, dates of people or phone numbers | Google Firebase Analytics | Improve the App |
| Crash reports (opt-in) | Crash stack traces, device model, OS version, app version, battery and alarm-permission state, a random installation ID. No personal content | Google Firebase Crashlytics | Fix crashes and reminder problems on specific phone brands |
| Reminder health ping | A device token for Firebase Cloud Messaging, when you have an account | Google Firebase Cloud Messaging | A silent daily message that lets the App re-check that today's reminders are scheduled |
3.3 Things we do not collect
Your location, your contacts or calendar (they are read on your device only), your call logs or SMS, a list of other apps installed on your phone, your advertising ID, your microphone audio (see 3.4), your payment card details, or health or biometric data (App Lock biometrics are checked by your phone's operating system; we only receive "success" or "failure").
3.4 Voice input
If you tap the microphone, speech to text is done by your phone's built-in speech service (Google on Android, Apple on iOS). The audio goes to that service under its own policy and may be processed on your device or on Google's or Apple's servers depending on the phone. The App receives only the text. We do not receive or store audio.
4. Legal bases and consent
- India (DPDP Act): we process your data on the basis of your consent, which is free, specific, informed and given by a clear action (switching on a feature or tapping Allow). We keep a record of your choices on your device and, if you have a backup, in your account. You can withdraw consent as easily as you gave it, in Me > Settings > Privacy. Withdrawing does not affect what was done before. We may also process data for legitimate uses allowed by the Act, for example to comply with law.
- EU/UK (GDPR): consent for backup, AI, analytics and crash reports; performance of our contract with you for running the App and purchases; legitimate interests for security and abuse prevention (rate limits, App Check). Analytics and crash reports are off by default for everyone, including EU users.
5. People whose data you add
WishBell holds data about other people (names, relations, birthdays, death anniversaries, notes). You decide what to add. Please:
- add information only about people you would normally keep in a personal phone book or diary, and in a way they would not find surprising;
- do not add sensitive details you do not need; the App needs only a name and a date;
- know that by default that information stays on your phone.
Our own use is limited to storing it for you. If you add people and then turn on cloud backup, their details (except phone numbers, see 3.2) are stored in your private backup, visible only to you. We do not contact these people, build profiles of them, or use their data for any other purpose. The App is for personal and household use. If you are a person whose details someone may have added and you want them deleted, contact the user directly; if you believe the data is in a cloud backup, write to us at support@wishbell.app and we will help to the extent we can identify it.
6. What AI features receive
AI is used only when you tap an AI feature, and only after you have given AI consent (a sheet that names the provider). Before sending, the App builds each request through a fixed allow-list. Examples:
| Feature | Sent | Never sent |
|---|---|---|
| Wish Studio wishes | Task, language, tone, length, how you address them (nickname or first name, such as "Jiju"), relation (for example jija ji), respect level, gender if you set it, occasion type (birthday, anniversary, barsi), festival, the age or years if you chose to include them, and only for that wish the likes, shared memories (for example "Goa trip 2023") and inside joke you typed or tapped in "Make it personal" (at most 5 each, 60 characters; phone numbers and email addresses are masked). To avoid repeats it also sends the first 8 words of up to 20 wishes you sent this person before, a random style number and a style hint. For "Prepare AI wish" the same fields are sent at about 8:30 AM on the day | Phone number, full name, photo, notes, gift log, other people, likes you did not pick for that wish |
| AI art backgrounds | Occasion, festival, art style, colour palette and up to 5 short motifs you choose. Names are removed from motifs | Text of the wish, names, photos, phone numbers |
| Photo Magic | The photo you pick (shrunk, location and camera data removed), the style, and a record that you agreed and confirmed your right to use the photo | Your other photos, names, the wish text, phone numbers |
| Gift ideas | Relation, age band, likes, budget, occasion | Same as above |
| Magic Add / paste list | The text you typed, spoke or pasted, and your language. Please do not paste things you do not want processed, such as passwords | Contacts, photos, anything you did not paste |
| Scan to Add | Text extracted from the image on your phone | The image itself [[PLACEHOLDER: confirm with engineering that images are not uploaded]] |
How it flows: the App talks only to our AI gateway over HTTPS. The gateway checks Firebase App Check and Authentication, applies per-user limits, and then calls the AI provider with our own API key, which is never in the App. The AI answer is checked against a fixed format and shown to you to confirm. The AI never decides dates; our date engine does. Photos for Photo Magic go to the image provider under terms that do not allow training on them [[PLACEHOLDER: confirm the zero-retention / no-training tier for the Google image model]].
Images: AI art backgrounds and Photo Magic results are stored in your own folder in Google Cloud Storage and handed to the App through a short-lived private link. AI art is deleted after 30 days. The photo you send to Photo Magic is never stored; its result is deleted within 24 hours. The App keeps a copy on your phone only when you use it on a card or save it. The AI never writes text on images; the App draws your words. A small "AI art" label is shown on AI pictures by default. You can report any AI wish or picture from the App.
Providers: Google (Gemini) and Anthropic (Claude). We may route a request to either one and may change the model. We use them as service providers under their API terms. [[PLACEHOLDER: confirm paid API terms with each provider that API inputs and outputs are not used to train models, and state their retention period, for example "up to [X] days for abuse monitoring"]]. Prompts and answers are not written to our logs by default; we keep only counters (user ID, date, number of requests) to enforce fair-use limits. AI output may be wrong or inappropriate; always review it.
AI features are optional and each has its own switch in Me > Settings > Privacy > AI features (including AI art backgrounds and Photo Magic). Without them, the App works with its on-device rule-based parser, its offline wish engine, ready-made card designs and on-device photo frames.
7. Sharing and disclosure
- We do not sell or rent your personal data, and we do not share it for advertising.
- Service providers that act only on our instructions: Google (Firebase, Gemini), Anthropic, RevenueCat, and the app stores. They see only the data described in section 3.2.
- When you share: if you share a card image, a wish text, or open WhatsApp from the App, that is your action. The content goes to the app you choose, under its own policy. We do not see it.
- Legal: we may disclose data if required by law or a court order, or to protect rights and safety, to the minimum extent necessary.
- Business transfer: if the App is sold or merged, the new owner must honour this policy, and we will tell you.
- Ads: there is no advertising SDK in the App at launch. If we add ads in future, we will update this policy first and ask for your consent where the law requires it. We will not show personalised ads to minors.
- Links: gift links and other links open third-party sites, which have their own policies.
8. International transfers
Firebase and the AI providers may process data in the United States and other countries. Where required we rely on lawful transfer mechanisms such as standard contractual clauses and the providers' certifications. Your cloud backup (Firestore database) and our Cloud Functions are hosted in the Google Cloud region asia-south1 (Mumbai, India). Some Firebase services, such as sign-in, push messages and analytics, and the AI providers, may still process data outside India. Under the DPDP Act, transfers outside India are allowed except to countries the Government restricts.
9. Retention and deletion
| Data | Kept |
|---|---|
| On-device data | Until you delete it or uninstall the App |
| Cloud backup, account, photos | Until you delete them or delete your account. Delete account in Me > Settings > Privacy removes Firestore data, Storage files and the sign-in account within seconds. Copies in provider disaster-recovery backups are purged within [[PLACEHOLDER: 30]] days |
| AI request counters | [[PLACEHOLDER: 30]] days |
| AI art backgrounds (server copy) | 30 days, then deleted automatically. The copy on your phone stays until you delete it |
| Photo Magic | The photo you upload is not stored. The result is deleted from our servers within 24 hours. The copy on your phone stays until you delete it |
| Wish Memory and card drafts | On your phone until you delete the person, the wish log or the App. Included in your cloud backup only if backup is on |
| Analytics and crash reports | [[PLACEHOLDER: 14 months for analytics, 90 days for crash reports, or as configured]] |
| Purchase records | As long as needed for accounting and tax law (India: [[PLACEHOLDER: 8]] years, confirm with the accountant) |
| Support emails | [[PLACEHOLDER: 24 months]] |
| Deletion log | We keep only the fact that a deletion happened, for compliance |
Your consent and your account can be deleted at any time. If you are inactive for [[PLACEHOLDER: 36 months]] and have a cloud account, we will warn you by email and then delete it [[PLACEHOLDER: confirm or remove]].
10. Your rights
Everywhere, in the App: Export all your data as JSON or CSV; Delete all local data; Delete account (cloud); change or withdraw each consent; edit or delete any person or event.
India, under the DPDP Act, you have the right to:
- get a summary of your personal data we process and the processing we do, and the identities of those we share it with;
- correct, complete, update and erase your personal data;
- have your grievance addressed. Contact our Grievance Officer in section 1 first. If you are not satisfied within the time the law allows, you may complain to the Data Protection Board of India;
- nominate another person to exercise your rights if you die or become incapacitated.
EU/UK, under the GDPR you also have the right to: access, rectification, erasure, restriction, objection, data portability, withdrawal of consent, not to be subject to solely automated decisions with legal effect (we make none), and to complain to your national supervisory authority.
Other regions: where local law gives you more rights (for example California), contact us and we will apply them. We do not sell or "share" personal information as defined by California law.
To use any right that cannot be done in the App, email support@wishbell.app from the address linked to your account. We may ask you to verify yourself and will reply within [[PLACEHOLDER: 30]] days (or sooner if the law says so).
11. Children
The App is not directed to children under 13 and we do not knowingly collect their data. In India, a person under 18 may use the App only with the consent and supervision of a parent or guardian, and we do not track, profile or advertise to minors. If you believe a child gave us data without consent, write to us and we will delete it. [[PLACEHOLDER: legal review of DPDP verifiable-parental-consent obligations for under-18 users]]
12. Security
- Data is encrypted in transit (HTTPS only, no cleartext traffic).
- Optional App Lock with an encrypted local database; keys in the Android Keystore or iOS Keychain.
- No AI provider keys in the App; limits and validation on our servers; per-user access rules on cloud data (you can only read your own).
- Backup of the App by the operating system's auto-backup is switched off on Android, so your database is not copied to other places by the OS.
- Permissions are asked only when needed, with an explanation first: notifications, exact alarms (timed reminders only), contacts (import screen only), camera (Scan to Add only), microphone (voice input only), calendar (import only).
No system is perfectly secure. If a personal data breach affects you, we will notify you and the authorities as the law requires.
13. Cookies and similar technologies
The App does not use cookies. Our website https://wishbell.app does not set cookies either. It uses Cloudflare Web Analytics, which is cookieless and does not track you across sites.
14. Changes
If we make a material change, we will show a notice in the App and, where consent is needed, ask again. The date at the top is updated every time.
15. Contact
support@wishbell.app [[PLACEHOLDER]] · [[PLACEHOLDER: legal entity name and address]] · Grievance Officer as in section 1.
This is a draft prepared to match the App's architecture. It is not legal advice; have it reviewed by a qualified lawyer in India (and the EU if you target EU users) before publishing.