Privacy Notice — Secretary42

The short version. Secretary42 transcribes your speech on your device. The app does not transmit your microphone audio, transcript text, prompt text, local transcription history, app settings, or activation key to insight 42. There is no user account, and diagnostics are off by default. Separate network flows do occur for purchase and payment (through Paddle), licence delivery, licence activation and periodic licence checks, model and software downloads, updates, optional diagnostics, support, and website/checkout operation, and the website uses Google Analytics only if you accept it on the consent banner. Those are described below.

1. Controller and contact

insight 42 UG (haftungsbeschränkt), Barellistraße 6, 85049 Ingolstadt, Germany. Privacy / data-protection requests: privacy@insight42.com. General contact and full company details: see the Impressum.

We have not appointed a Data Protection Officer, as we are not legally required to do so under Art. 37 GDPR / § 38 BDSG.

2. What stays on your device

The following are processed locally and are not transmitted to insight 42 by the app:

• Your microphone audio (processed by the bundled on-device whisper.cpp engine; temporary files are deleted after transcription).
• Your transcribed text and any prompt text.
• Your local transcription history (stored in a local database on your device; by default the most recent entries are kept; you can view, copy, and delete them).
• Your app settings, your activation key and the signed licence lease it is exchanged for. The lease payload carries no personal data — only a version, plan, issue/expiry timestamps and a random value — no email, name, Paddle IDs, device identifier, or IP. Your licence is bound to the installation, and the private key the app generates for that binding stays on your device and is never transmitted; only a signature and random identifiers are sent (see §3).
• A local diagnostics/telemetry log file the app writes on your device for troubleshooting; it is not uploaded unless you choose to share it with support.

There is no cloud transcription and no cloud-transcription fallback under the current release configuration, and no user account — so there is no insight 42 server-side profile of you tied to the dictation product.

3. Processing that does involve personal data

3a / 3b. Payment (Paddle) and licence delivery

Payment is processed by Paddle, which acts as merchant of record / authorised reseller and as an independent controller for the purchase, payment, tax, billing, invoicing and related buyer data, under its own privacy policy.

We receive your buyer email address from Paddle after purchase so that we can deliver your Secretary42 activation key and provide purchase-related support. We receive this data from Paddle, not from the desktop app.

To email you your licence, our backend licence-minter temporarily holds your Paddle customer identifier together with the activation key in an encrypted pending delivery record. On each delivery attempt it uses the customer.read permission to read your current buyer email from Paddle. The email exists in memory only: it is never written to our database or logs. The encrypted customer identifier and key are destroyed when the mail provider accepts the message, and in every case within seven days. The desktop app contains no Paddle API key.

Apart from that pending delivery record, the licence-minter datastore is designed not to retain direct identifiers: no buyer email address, no raw Paddle customer, subscription or transaction IDs, no raw webhook bodies, and no plaintext licence credential once delivery has been accepted. What it does retain is keyed digests of those identifiers together with limited operational metadata, on the retention periods set out in §5. We treat these records as pseudonymous operational data where GDPR applies — not as anonymous or non-personal data.

3c. Diagnostics (Sentry) — opt-in only

Diagnostics are off by default, and the diagnostics service is not initialised until you explicitly opt in (Settings → License). On a fresh or opted-out install there is zero diagnostics egress. If you opt in, we send sanitized crash and performance metadata — app version, release channel, build identifier, OS, CPU architecture, local engine/model, language, a duration bucket, latency, real-time factor, and outcome — identified only by a random local install ID generated on your device. We do not receive your name, email, account ID (none exists), audio, transcript text, prompts, API keys, or local file paths. You can opt out at any time, which clears the diagnostics state and rotates the install ID.

3d. Website analytics (Google Analytics) — opt-in only

The website at secretary42.de uses Google Analytics 4, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, only if you click Accept analytics on the consent banner. Until then, and if you click Reject, the site loads nothing from Google. Google processes this data on our behalf under its data-processing terms. We have switched Google signals, advertising features and ad personalisation off; we run no advertising. Google Analytics 4 does not log or store IP addresses; Google uses the address in transit only to derive an approximate location. We do not send Google your name, email, licence or activation key, or Paddle's transaction identifiers, and the desktop app never contains Google Analytics. You can withdraw your consent at any time under Cookie settings in the footer of every page (see §10).

3e. Whisper-model downloads

When you choose a Whisper model, the app downloads the model file from Hugging Face. The model host receives connection metadata (such as your IP address and user agent). Hugging Face, Inc. is US-based (with an EU establishment, Hugging Face SAS, France); public model repositories are stored in the US by default and US transfers rely on Standard Contractual Clauses.

4. Recipients and their roles

We do not sell personal data or use it for advertising. Where a service provider processes personal data on our behalf, we use the data-processing terms required by Art. 28 GDPR. Paddle acts as an independent controller for checkout and payment and is not our subprocessor for that purpose.

Support channel

Support is private email only — support@insight42.com. We do not operate a public support forum. When you email support, please send only what is needed; avoid sharing audio, full transcripts, activation keys, payment details, or secrets unless we specifically ask. If you ever reach us through any public channel, do not post personal data there.

5. Retention

6. Legal bases

The legal bases per flow are set out in the table in §3. In summary: purchase and licence delivery rely primarily on contract (Art. 6(1)(b)); webhook verification/idempotency, security logging, updates and model-download logging rely on legitimate interests (Art. 6(1)(f)) with documented assessments; opt-in diagnostics and opt-in website analytics rely on consent (Art. 6(1)(a)), and storing or reading the analytics cookies on your device additionally on your consent under § 25(1) TDDDG.

7. Whether providing data is required

Providing your email at checkout is necessary to buy a subscription and receive a licence; without it we cannot deliver the licence. Diagnostics are optional and refusing them does not affect your use of the app. Website analytics are optional too: rejecting them does not affect the website, downloads or checkout. Support content is optional, but we need it to answer your request.

8. Your rights

Subject to the GDPR, you have the rights of access, rectification, erasure, restriction, portability, and objection (including the right to object to processing based on legitimate interests), and the right to withdraw consent for diagnostics (in the app) or website analytics (Cookie settings in the website footer) at any time without affecting prior processing. There is no user account, so there is no login or profile to export. Your dictation content never reaches us at all. Because a licence is bound to an installation, we do hold a pseudonymous licence record, and we can act on it: give us your activation key and we will locate, export, or delete that record. (Deleting it during an active subscription ends the licensed service — we will explain the consequence before acting.) If you no longer have the activation key, we can verify your purchase through Paddle instead. For payment data, contact Paddle (the controller for that data), and for diagnostics, contact us.

To exercise your rights, email privacy@insight42.com. You also have the right to lodge a complaint with a supervisory authority. The competent authority for insight 42 is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany.

9. International transfers

Some recipients may process personal data outside the EU/EEA, or their corporate group / subprocessors may have access from third countries. Where a recipient processes data outside the EU/EEA, appropriate safeguards apply, such as an EU adequacy decision, the EU-U.S. Data Privacy Framework for certified US organisations, or the EU Standard Contractual Clauses with supplementary measures where required. Sentry, GitHub/Microsoft and Google (for website analytics) are DPF-certified; Hugging Face's US transfers rely on SCCs; Brevo hosts in the EU with SCC/DPF fallback; Hetzner is EU/DE; Paddle (UK) benefits from the UK adequacy decision and uses SCCs for other transfers.

10. Cookies, the website, and the checkout (TDDDG)

Unless you accept analytics on the consent banner, a pageview on secretary42.de loads no analytics, advertising trackers, third-party scripts, third-party images, or non-essential cookies. Web-server access logging is disabled. The server must process the technical data needed to deliver each request, but does not retain it in an access log.

Google Analytics, only with your consent. If you click Accept analytics, the site loads Google Analytics 4 from Google, which sets the _ga and _ga_… cookies and receives the data described in §3. If you click Reject, none of it loads. Your choice is remembered in your browser's local storage (s42-consent-v1), which is strictly necessary for that purpose (§ 25(2) no. 2 TDDDG). You can change or withdraw your choice at any time under Cookie settings in the footer of every page: withdrawing stops Google Analytics on the page you are on and deletes its cookies, and no later page loads it. How Google uses data from sites that use its services: policies.google.com/technologies/partner-sites.

If you actively start checkout, the site loads Paddle's checkout resources and Paddle may set storage needed to run secure checkout under its own notices. We do not receive your card details.

11. Automated decision-making

insight 42 does not use automated decision-making producing legal or similarly significant effects within the meaning of Art. 22 GDPR. Any fraud/payment risk decisions at checkout are carried out by Paddle as part of its own controller processing.

12. Children

Secretary42 is not directed to children; you must be 18+ to purchase (see the Terms).

13. Changes

We may update this Notice; the "Last updated" date reflects the current version.

14. Contact

insight 42 UG (haftungsbeschränkt), Barellistraße 6, 85049 Ingolstadt, Germany — privacy@insight42.com.