legal
Privacy Policy
Fenlo is an app where you write down what's on your mind. Because that can be very personal content, we explain here, as precisely as possible, what happens to that text.
1. Data Controller
Artur Abramskij
Alte Römerstraße 32
54329 Konz, Germany
Email: info@a-two.de
2. What stays on your device
Your entries, the topics derived from them, and your settings are stored locally on your device. Fenlo has no user account, and we do not keep a copy of your entries on our servers. If you delete the app, this data is gone – that's why there is an export function in the settings.
3. What is transmitted to generate a reply
For Fenlo to reply to you, the text you write is sent through our server to an AI service provider and processed there. This includes:
- the text of your current entry
- the most recent messages of the ongoing conversation
- short summaries of recurring topics that the app has previously generated from your entries
- your first name, if you provided one, and your tone preference
Important note on AI processing: As our AI service provider, we use OpenAI (OpenAI Ireland Ltd., Dublin, Ireland). Fenlo currently uses an OpenAI usage tier under which the submitted content may also be used by OpenAI to improve and train their AI models.
This means: the text you write in Fenlo leaves your device and is processed by OpenAI not only to generate a reply, but potentially also for training purposes. Please do not write anything in Fenlo that you don't want to reach an AI provider – in particular, avoid the names of third parties, addresses, health data, or other clearly identifying information.
We do not transmit your name or any contact details to OpenAI – only the content described above. OpenAI also processes data outside the EU (USA); this transfer relies on the European Commission's Standard Contractual Clauses.
4. Server and technical data
Requests run through a server function hosted by Supabase (Supabase Inc.), located in Frankfurt, Germany. We do not store the content of your entries there. We only store a randomly generated device identifier and a counter of how many requests came from that device within the current hour – this is needed to prevent abuse and excessive costs. These counters are deleted after at most two days. The device identifier cannot be traced back to you as a person.
5. Subscriptions
Purchases and subscriptions are processed by Apple. We only receive information from Apple, or our provider RevenueCat (RevenueCat Inc.), about whether a subscription is active. We never see payment details – these are processed exclusively by Apple.
6. Notifications
If you allow push notifications, they are scheduled entirely locally on your device. No data is transmitted to us for this purpose. You can disable them at any time in the app settings or in your system settings.
7. Analytics
We measure, in anonymized form, which features are used (e.g. how many users complete onboarding) in order to improve the app. This does not include the content of your entries – only event names and technical metrics.
8. Legal basis
- Art. 6(1)(b) GDPR – performance of the usage contract for the app's core functionality, including AI-generated replies.
- Art. 6(1)(f) GDPR – legitimate interest in stability, security, and abuse prevention.
- Art. 6(1)(a) GDPR – consent, where legally required, in particular for the use of content for training purposes as described in Section 3.
9. Retention period
Your entries remain on your device until you delete them or remove the app. We do not store content on our server; the technical counters described in Section 4 are deleted after at most two days. How long OpenAI retains transmitted content is governed by OpenAI's own policies.
10. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability, and objection. You can withdraw any consent you have given at any time, with effect for the future. Since we do not store your entries, you can delete them completely yourself at any time: via "delete everything" in the settings, or by uninstalling the app.
For requests: info@a-two.de
You also have the right to lodge a complaint with a data protection supervisory authority. The competent authority is the Landesbeauftragter für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz (the state data protection authority of Rhineland-Palatinate, Germany).
11. Children and minors
Fenlo is intended for people aged 17 and older. We do not knowingly collect data from children.
12. Not a substitute for counseling or treatment
Fenlo is a companion for sorting through thoughts and is not a medical device. The app does not provide diagnoses, does not give treatment recommendations, and does not replace professional counseling, psychotherapy, or medical treatment. In an acute crisis, please contact a crisis line in your country, or in Germany the Telefonseelsorge (0800 111 0 111 or 0800 111 0 222, free of charge, available around the clock), or in an emergency call 112.
13. Changes
We update this policy whenever the app or the services we use change. The current version is always shown at the top of this page.