Privacy Policy
Spominka records your family's life stories, so we take personal data seriously. This policy explains what data we collect, why, who we share it with, and what rights you have. We've tried to write it in plain, everyday language — if anything is unclear, write to us at info@spominka.si.
1. Who is the data controller
The controller of your personal data is:
MIRKO AI, storitve umetne inteligence d.o.o.Stari trg 15, 3210 Slovenske Konjice, Slovenia
Company registration number: 9861335000 · VAT ID: SI22316132
Email: info@spominka.si
For any questions about privacy, or to exercise your rights, contact us at the email address above at any time.
2. Who this applies to
The Spominka service involves two roles:
- Family user (subscriber) — the person who creates the account, sets up the profile and manages the service (typically a grandchild, child or other relative).
- Narrator (the data subject) — the person who shares their life stories in the conversations (typically an older family member).
Both roles are protected by this policy. Recording and processing the narrator's stories takes place solely on the basis of the narrator's consent (see sections 4 and 5).
3. What data we collect
Account data
- Email address, name and, if you sign in with Google, a unique account identifier and profile picture provided by Google.
- Technical login data (login tokens, time of last login).
Narrator profile
- Name, year and place of birth, language, the chosen name and voice of the conversational companion, and similar settings.
- Consent to recording (the fact of consent, its date and version).
Conversation content
- Conversation transcripts — the text of what was said, broken down by segment.
- Voice recordings — an audio recording of the narrator is stored only, if consent was given; it is limited in length and remains as a family heirloom (e.g. for later listening).
- Extracts and memories — stories, facts, quotes, and the people and places mentioned, which we summarise from the conversation to prepare the book.
- Photographsyou upload, and the text of the resulting book.
Special categories of personal data. Life stories can, by their nature, contain sensitive data — about health, religious or philosophical beliefs, political opinions, ethnicity or sex life. We process such data solely on the basis of your explicit consent (Article 9 GDPR), and only for the purpose of preparing your book. Topics you mark as private stay out of the conversation and out of the book.
4. Why we process data (purposes and legal basis)
| Purpose | Legal basis (GDPR) |
|---|---|
| Managing the account and providing the service (conversations, preparing the book) | Performance of a contract — Art. 6(1)(b) |
| Recording and processing the narrative, including sensitive data | Explicit consent — Art. 6(1)(a) and Art. 9(2)(a) |
| Sending login and essential system messages | Performance of a contract / essential cookies — Art. 6(1)(b) |
| Security, abuse prevention and maintaining an audit trail | Legitimate interest — Art. 6(1)(f) |
You can withdraw consent at any time (see section 8). Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
5. Who we share data with (processors)
We do not sell your data. To run the service, we use carefully selected providers who process data on our behalf and according to our instructions:
| Provider | Purpose | Which data |
|---|---|---|
| Anthropic (Claude) | Conducting the conversation, summarising, preparing the book | Conversation transcripts, extracts, part of the profile (name, people, places) |
| OpenAI | Semantic search (vector embeddings); for uploaded recordings, also speech transcription | Text of the narrative; for uploaded recordings, audio |
| Soniox | Speech-to-text and text-to-speech conversion | Narrator's audio (STT); response text (TTS) |
| ElevenLabs | Text-to-speech conversion | Text of the companion's responses |
| Brevo (EU) | Sending login emails | Email address, name |
| Login (OAuth) | Login data (email, name, identifier) |
6. Transfers of data to third countries
Some of the providers listed above (Anthropic, OpenAI, Soniox, ElevenLabs, Google) are based in the United States, so some data is processed outside the European Economic Area. For such transfers, we ensure appropriate safeguards in line with Chapter V GDPR (typically the European Commission's Standard Contractual Clauses). You can request a copy or details of the safeguards at info@spominka.si.
7. Where and how long we store data
Data is stored in a data centre within the European Union. Only authorised personnel access it, and only to the extent necessary to operate the service and provide support.
- Narrative content, memories and the book are kept until you delete them — the purpose of the service is, after all, to create a lasting family heirloom. We do not delete content automatically.
- Audit log (records of access, export and deletion) is kept for up to 365 days.
- Abandoned, empty sessions with no content are automatically cleared after about 48 hours.
When you delete your account or an individual session, we permanently remove the associated content, including audio recordings and photographs.
8. Your rights
Under the GDPR, you have the following rights regarding your personal data:
- Access — to a copy of the data we hold about you.
- Rectification — of inaccurate or incomplete data.
- Erasure (“the right to be forgotten”) — permanent deletion of your account and content.
- Portability — export of your data in a machine-readable format.
- Restriction and objection to processing.
- Withdrawal of consent — at any time, without affecting the lawfulness of past processing.
- Complaint to the supervisory authority.
You can exercise most of these rights directly in the app (Settings → Privacy: data export, deleting sessions or your account, withdrawing consent). You can also write to us at info@spominka.si and we will respond without undue delay, and at the latest within one month.
If you believe we are processing your data in breach of the regulations, you can lodge a complaint with:
Information Commissioner of the Republic of SloveniaDunajska cesta 22, 1000 Ljubljana
Email: gp.ip@ip-rs.si · Web: www.ip-rs.si
9. Cookies
We use only essential cookies, necessary for operation and login (secure cookies for sessions and login tokens). These are technically necessary, so we do not need separate consent for them. We currently do not use analytics or advertising cookies, or any tracking services. If we introduce these in future, we will update this policy and obtain your consent where required.
10. Children
The service is not intended for children. Accounts are intended for adult family users, and narrators are typically adults. If you believe we have inadvertently collected a child's data without an appropriate basis, please let us know and we will remove it.
11. Changes to this policy
We may update this policy from time to time. For significant changes, we will update the date at the top of this page and, where appropriate, notify you directly as well. We recommend reviewing this policy periodically.
12. Contact
For any questions about privacy and data processing, write to us at info@spominka.si.