Privacy Policy

Last Updated: 12 September 2026 · Effective Date: 12 September 2026

This policy applies to the AbilityMic application (Android, iOS, macOS, Windows, Linux) and the website https://abilitymic.com. It is aligned with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA), the Children's Online Privacy Protection Act (COPPA), and the Google Play Data Safety requirements.

1. Data Controller (GDPR Art. 13)

Controller: Kierepka.pl, Poland.
Privacy contact: privacy@abilitymic.com
Support: support@abilitymic.com
Website: https://abilitymic.com
Account deletion: /account-delete.php

Privacy requests are handled through privacy@abilitymic.com. AbilityMic has not appointed a Data Protection Officer; this contact is the controller's privacy contact.

2. About AbilityMic

AbilityMic is an Augmentative and Alternative Communication (AAC) application for non-speaking individuals or people with speech and communication difficulties. It is designed to be offline-first: by default, your communication boards, history, and preferences stay on your device.

Some features (AI sentence shaping, board sync, emergency alerts) require connecting to AbilityMic's backend or third-party services. Each of those features is optional and opt-in, and disabling them stops the corresponding data flow.

3. What Data We Process

3.1 Stored locally on your device (default)

The following data never leaves your device unless you explicitly enable an online feature:

• Communication boards (OBF/OBZ), speech / utterance history
• App settings, preferred name, language, TTS voice
• Custom symbol images
• Sensitive data (private user notes, home address, emergency contact phone numbers, AAC professional PIN, user profile) — always encrypted with AES-256-GCM, key derived per-device

Legal basis (GDPR): performance of contract / legitimate interest for normal app data; explicit consent (Art. 9) for special-category health data.

3.2 Data processed only when you use a specific feature

• Microphone / speech recognition: audio (transient — not stored). Device OS speech API or AbilityMic backend if you enabled cloud STT.
• Camera / Image-to-AAC: photos you select or capture. Processed on device; AI symbol generation sends prompts (not raw photos) to the backend if enabled.
• Cloud TTS: text to be spoken. Sent to the AbilityMic backend, cached locally; falls back to on-device TTS if unavailable.
• AI Support (paid subscription): short message context (current sentence draft) sent to the AbilityMic backend, which proxies to AI providers.
• Board sync: boards stored for your account. If you deliberately link an AAC professional and grant board permission, that AAC professional may remotely download, create, and update them.
• Remote AAC professional collaboration: user and AAC professional account identifiers, user display name, permissions, link/revocation timestamps, and a hashed one-time invite code. A AAC professional never receives your password. Board and statistics permissions are separate and revocable.
• Aggregate statistics: only when telemetry is enabled and statistics are separately shared: interaction count, active days, period, and aggregate intent categories. This feature does not upload raw utterances, voice recordings, images, board content, or private user notes.
• Emergency SOS (foreground only): approximate or precise location, selected emergency-contact phone numbers, and an optional TTS message sent to the SMS/email recipients you chose. The backend logs minimal metadata. We do not request background location.
• Smart Home (Apple HomeKit on iPhone / iPad): after you grant Apple’s system permission, the app reads your HomeKit homes and reachable power accessories and sends on/off/toggle actions through Apple’s HomeKit APIs. AbilityMic’s backend does not receive HomeKit home, accessory, or command data.
• Account & subscription: email, hashed password, device identifier, and subscription receipt held on the AbilityMic backend. Payments are processed by Google Play Billing or Apple App Store; we never see your card number.

Legal bases for online features: account, link, and sync operations are necessary to provide the selected service (GDPR Art. 6(1)(b)); minimal security logs rely on our legitimate interest in protecting the service (Art. 6(1)(f)). Optional statistics and content capable of revealing health information rely on consent (Art. 6(1)(a)) and, for health data, explicit consent (Art. 9(2)(a)). Consent may be withdrawn prospectively at any time.

3.3 Roles of the AAC professional, organisation, and AbilityMic

AbilityMic is the controller for consumer account and service-operation data. A professional or organisation that determines its own purposes and means of using user data will ordinarily be an independent controller. Where AbilityMic acts only on an organisation's documented instructions, it may act as a processor; organisations should determine roles and enter into an Art. 28 data-processing agreement where required before using client data. The portal is not a substitute for a clinical record system.

3.4 Data we do not collect

• We do not run advertising SDKs, analytics SDKs, or tracking pixels in the app.
• We do not sell your data (CCPA: no “sale” or “sharing” as defined by law).
• We do not profile users for behavioural advertising.
• We do not collect your contacts, calendar, or browsing history without explicit interaction.

3.5 Contacts permission (Android / iOS)

When you grant the Contacts permission, the app reads your contacts on demand only to let you pick an emergency contact or a “Call X” button. The contact data stays on your device. We never upload or sync your address book.

3.6 Location permission (Android / iOS)

Location is used only to attach your current location to an Emergency SOS dispatch, so a caregiver can find you. The SOS feature requires the app to be open and visible — we do not request background location, and the app cannot read your location while it is minimized or the screen is off.

3.7 AI features and automated decision-making

Every AI feature is optional and switched off until someone turns it on. Which feature runs on your device, which one sends content to our backend, and exactly what is sent, is set out in our AI transparency notice.

• No automated decisions about you. AbilityMic makes no decision producing legal or similarly significant effects within the meaning of GDPR Art. 22. AI proposes wording, a symbol or a draft board; a person accepts, edits or discards it.
• No evaluative profiling. We do not use AI to assess a person’s abilities, health, emotions or behaviour, and we do not perform emotion recognition or biometric categorisation.
• Legal basis. Online AI features rely on your consent (Art. 6(1)(a)); where the content you send can reveal health data, on explicit consent (Art. 9(2)(a)). Consent is given per feature and can be withdrawn at any time in the app’s privacy centre, without affecting the lawfulness of past processing.
• Training. We do not use your messages, boards, images or voice to train models of our own, and we do not sell them or pass them on to anyone for model training. Content you send through an online AI feature is processed by the provider listed in section 5 to produce your result, under that provider’s terms for API customers. We do not currently hold a separate contractual assurance from every one of those providers that submitted content is excluded from their own model training; if we establish that a provider trains on content submitted through AbilityMic, we will name it here and move the feature to another provider.
• Retention. Prompts and results are processed to produce the answer and are not kept as a user profile on our backend. Cloud speech output may be cached on your device so the same text does not have to be sent twice.
• Children. On a child profile, online AI features require the consent of a parent or guardian, who also decides which features are appropriate.

4. Pricing & Subscriptions

AbilityMic is a paid app:

• AbilityMic Core — one-time purchase of $59.99. Unlocks the core AAC experience: speech output, offline use, profile and board setup, and updates to the core app.
• AI Support — optional subscription of $10/month with a 14-day free trial. Adds AI sentence shaping, more natural phrasing, and faster message composition. Cancel anytime through your platform's subscription manager.

Purchases go through Google Play Billing (Android) or the Apple App Store (iOS). We never see your payment card. Subscription status is verified server-side; you can request deletion of your account and any associated subscription history at /account-delete.php.

5. Third-Party Providers (Sub-processors)

Online features rely on the providers below. Requests are routed through our backend, never directly from the app, and each AI function uses a chain: if the first provider is unavailable, the next one in the chain handles the request. Which providers are active depends on the server configuration at the time. They process data only as instructed by us, and we have data-processing agreements (DPAs) where required by law.

• AI sentence shaping, assistant tasks and board drafts: Groq, OpenAI, Google (Gemini), Cerebras, OpenRouter (US/EU)
• Image analysis (Image-to-AAC): Microsoft Azure AI Vision, with OpenAI or Google (Gemini) as fallback (EU/US)
• Speech recognition (cloud dictation): OpenAI Whisper or Groq Whisper (US)
• AI symbol and image generation: OpenAI or Stability AI (US)
• Cloud text-to-speech voices: ElevenLabs, Amazon Web Services (Polly) (US/EU)
• Payments and subscriptions: Google Play Billing / Apple App Store (US/EU)
• Emergency SOS SMS delivery: Twilio or the platform SMS API (US/EU)
• Backend hosting: CyberFolks (cyber-folks.pl), Poland — currently our only hosting provider (EU)

A feature you have not switched on sends nothing to any of these providers, and features that run on your device do not involve them at all. For the provider currently serving a specific feature, or an up-to-date sub-processor list, write to privacy@abilitymic.com.

6. Retention

• Local app data (boards, history, settings) — until you delete it in app or uninstall.
• Local sensitive data (medical, emergency) — until you delete it; encryption key destroyed on uninstall.
• Account data on backend — active for the life of your account; deleted within 30 days of an account-deletion request.
• Invite codes — valid for 15 minutes; only a hash is stored and removed no later than 24 hours after use or expiry.
• AAC professional–user link — while active; a minimal revocation record is retained for up to 30 days.
• Therapist-visible aggregate statistics — rolling maximum of 90 days; account deletion removes them sooner. Withdrawing consent stops future collection.
• Subscription receipts (legal/tax obligation) — up to 7 years (anonymized after account deletion).
• Backend access logs — 30 days, then deleted; no PII included.
• Failed sign-in attempts (brute-force protection) — a hash of the address and the IP it came from, deleted after 24 hours.
• Password reset links — only a hash of the link is stored; it expires after one hour and is spent on first use.
• Voice recordings (cloud STT) — not stored; processed in memory and discarded.

7. Your Rights (EU – GDPR / UK GDPR)

You have the right to: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), and objection (Art. 21). You may also withdraw consent for sensitive data at any time without affecting the lawfulness of past processing.

To exercise these rights:

• Most data is on your device — use Settings → Privacy in the app.
• For backend-stored data, write to privacy@abilitymic.com or use /account-delete.php.

You may lodge a complaint with a supervisory authority (e.g. in Poland: Prezes Urzędu Ochrony Danych Osobowych (UODO); in your country: your local data protection authority).

8. Your Rights (USA – CCPA/CPRA and Other States)

If you are a California or other US resident, you have the right to: know, delete, correct, opt-out of sale/sharing (we do not sell or share for cross-context advertising), and non-discrimination for exercising your rights. Submit requests to privacy@abilitymic.com.

9. Account Deletion

You can delete your AbilityMic account and associated server-side data at https://abilitymic.com/account-delete.php. You do not need the app. After confirmation, we delete the account, devices, private sync data, invites, AAC professional links, and aggregate statistics within 30 days. Boards previously marked public may remain, but their author is anonymised as “deleted user”. You may also revoke an AAC professional link without deleting the account.

10. Security

• Sensitive on-device data: AES-256-GCM, key derived via PBKDF2 from a per-device salt stored in the platform secure enclave (Android Keystore / Apple Keychain / Windows DPAPI).
• Backend traffic: TLS 1.2+ only.
• Backend passwords: bcrypt hashing.
• Authentication tokens: short-lived JWTs.
• AAC professional invitations: random 15-minute codes stored only as hashes, with separate board and statistics permissions.
• Principle of least privilege for backend administrative access.

No method of transmission or storage is 100% secure; we follow industry-standard practices (GDPR Art. 32) and continuously improve.

11. Children (COPPA / GDPR-K)

AbilityMic is designed primarily for adults and adolescents (13+) and the parents, caregivers, and AAC professionals of children with communication needs. Children under 13 may use the app under the supervision of a parent, guardian, or licensed AAC professional, who is responsible for managing settings, consent, and any data the child provides.

We do not knowingly collect personal information from children under 13 outside of features explicitly enabled by their adult caregiver. If you are a parent or guardian and believe we have collected information from your child without consent, contact privacy@abilitymic.com and we will delete it.

Linking a child's profile to an AAC professional, or sharing its boards and statistics, is done from the profile's own account, and the app asks a parent or authorised guardian to confirm consent before the invite code is issued.

12. International Data Transfers

If you are in the EU/EEA and use online features, some data may be transferred to providers in the United States. We rely on Standard Contractual Clauses (SCCs) under the GDPR for those transfers, plus the EU–US Data Privacy Framework where applicable. You can request a copy of relevant SCCs by writing to privacy@abilitymic.com.

13. Product Status and Purpose

AbilityMic is a consumer AAC communication tool, not a medical device, clinical record system, or HIPAA service. It does not diagnose, treat, monitor health conditions, recommend therapy, or make clinical decisions. Usage statistics are descriptive only. Professionals remain responsible for their own interpretation and for any separate records or decisions they make.

14. Changes to This Policy

We may update this Privacy Policy. Material changes will be communicated in-app (with a one-time notice on next launch) and on this page. The “Last Updated” date at the top reflects the most recent revision.

15. Contact & Complaints

Privacy / data protection: privacy@abilitymic.com
Support: support@abilitymic.com
Website: https://abilitymic.com
Account deletion: /account-delete.php

If you believe our processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority (e.g. in Poland: Prezes Urzędu Ochrony Danych Osobowych (UODO); in your country: your local data protection authority).