Facet · iPhone
Privacy
Draft. This text is still under legal review and may change.
Last updated: 3 October 2026
Facet (“we”, “our”, “the app”) is a personal journaling app for iPhone. This policy explains which data the app processes, how it is used, and your rights under the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
This policy covers the Facet app only. For this website, see the website privacy policy.
Data Controller
Data controller in the sense of Art. 4 (7) GDPR is:
Michael Hubert BeckerFeierabend Apps
Obere Dorfstr. 6B
90427 Nuremberg, Germany
Email: support@facetjournal.app
1. Data Storage on Your Device and in iCloud
Your journal entries, mood data, tags, AI-generated insights, streaks, achievements and time capsule letters are stored locally on your device using Apple’s SwiftData framework. If you have iCloud enabled, this data syncs to the private database of your personal iCloud account via Apple’s CloudKit.
A few settings are also synced via your iCloud key-value storage so that they survive a reinstall or a new iPhone: the first name and birthday (day and month) you can optionally enter for personal greetings, your reminder time, and whether Face ID lock and Apple Health are switched on.
We never have access to your iCloud data. Storage in iCloud is provided by Apple under your agreement with Apple.
2. Data Sent to External Services (AI Features)
Facet uses AI to detect mood and tags, and to provide weekly and monthly insights, personalized writing prompts, reminder texts and chat with your journal. For these features, data is sent over an encrypted connection (HTTPS/TLS) to our API proxy server, which forwards it to the AI service for processing. Specifically:
- Saving or editing an entry: the entry text, so that mood, tags and an emoji can be detected. This happens automatically for every saved entry. If the AI service cannot be reached, the app falls back to a simple built-in analysis.
- Weekly and monthly insights: the entries of the period with date, mood level and tags. If Apple Health is connected: aggregated daily sleep hours, step counts and workout minutes for that period.
- Writing prompts and reminder texts: some of your most recent entries with date, mood level and tags. The resulting reminder texts are shown as local notifications on your device.
- Chat with your journal: your question and your recent entries with date, mood level and tags as context. Chat conversations are not stored.
The following is not sent: time capsule letters, your name and birthday, and any account or device identifier. Facet has no user accounts.
Processor: Anthropic, PBC, 548 Market Street PMB 90375, San Francisco, CA 94104, USA (provider of the Claude API).
API proxy: Our proxy server runs on Cloudflare Workers, a service of Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. When the app connects, Cloudflare processes technical connection data (such as your IP address) and passes the request through to Anthropic.
Legal basis: Art. 6 (1)(b) GDPR (performance of contract — providing AI features you requested) and Art. 6 (1)(f) GDPR (legitimate interest in offering functional journaling features). Where health data from Apple Health is included, the legal basis is Art. 9 (2)(a) GDPR (your explicit consent, which you give by connecting Apple Health and granting access). You can withdraw this consent at any time by revoking Facet’s access in the Health settings of your iPhone.
Third-country transfer: Data is transferred to the United States. The transfer to Anthropic is based on the EU Standard Contractual Clauses (SCCs) concluded with Anthropic and the EU-U.S. Data Privacy Framework (Anthropic is a certified participant). The transfer to Cloudflare is based on the EU-U.S. Data Privacy Framework and the Standard Contractual Clauses included in Cloudflare’s data processing addendum.
Retention: Anthropic processes the data to generate the response and, under its commercial terms, keeps API inputs and outputs only for a limited period (longer only where needed for Trust & Safety review in case of abuse). Our proxy server does not log or retain your journal content.
3. Health Data
Connecting Apple Health is optional and off by default. If you choose to connect it, Facet:
- Reads sleep duration, step count and workouts to correlate them with your mood
- Writes a mindful session to Apple Health when you save a journal entry (tracking your journaling time as mindfulness)
- May include aggregated health metrics (sleep, steps, workout minutes) in AI insight requests as described in Section 2
- Never uses health data for advertising or marketing
- Never shares health data with third parties beyond the AI processing described above
You can change or revoke Facet’s access to Apple Health at any time in the Health settings of your iPhone.
4. Face ID and Touch ID
If you switch on the lock, Facet asks iOS to verify your face or fingerprint. The check is performed by iOS. Facet only receives the result (success or failure) and never has access to your biometric data.
5. Notifications
Daily reminders and time capsule notifications are scheduled locally on your device. We do not operate a push notification server.
6. Support Requests
If you contact us by email, for example via “Report a Bug” in the app, we process your email address, your message and the app version included in the email in order to answer your request (Art. 6 (1)(b) and (f) GDPR). We delete this correspondence once it is no longer needed, unless statutory retention periods apply.
7. Data We Do NOT Collect
- We do not require an account and do not collect your name, email address or other personal identifiers (except when you email us, see Section 6)
- We do not use analytics or tracking SDKs
- We do not show advertisements
- We do not sell your data or share it with third parties for their own purposes; the only recipients are the service providers named in Section 2
- We do not use cookies or cross-app tracking
8. Subscriptions
Facet Pro subscriptions are handled entirely by Apple’s App Store. We do not process or store any payment information. The app checks your subscription status with Apple on your device. Subscription management is available through your Apple ID settings.
9. Data Security
Your journal data is stored on your device and optionally in your personal iCloud account. Data transmitted to the AI service uses HTTPS/TLS encryption. We do not operate databases that store your personal information.
10. Children’s Privacy
Facet is not directed at children under 13. We do not knowingly collect personal information from children.
11. Your Rights under GDPR
Since your journal data lives on your device and in your personal iCloud account, you already have technical control. In addition, under the GDPR you have the following rights regarding any personal data we process (e.g. temporary processing via the AI service):
- Right of access (Art. 15 GDPR) — request information about any data processed about you.
- Right to rectification (Art. 16 GDPR) — have inaccurate data corrected.
- Right to erasure (Art. 17 GDPR) — request deletion. You can remove today’s entry directly in the app. Deleting the app removes the data stored on your device; the copy in your iCloud remains until you delete Facet’s data in your iCloud storage settings. For any other data, you can request deletion by email.
- Right to restriction of processing (Art. 18 GDPR).
- Right to data portability (Art. 20 GDPR) — you can export your entries in the app’s settings at any time, as text or as a full backup in JSON format.
- Right to object (Art. 21 GDPR) — object to processing based on legitimate interest at any time.
- Right to withdraw consent (Art. 7 (3) GDPR) — where processing is based on consent, you may withdraw consent at any time with effect for the future.
To exercise any of these rights, contact support@facetjournal.app. We respond without undue delay and in any event within one month, as required by Art. 12 (3) GDPR.
12. Right to Lodge a Complaint
Under Art. 77 GDPR you have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de
13. Changes to This Policy
We may update this policy from time to time, for example when the app’s features change. Changes will be posted on this page with an updated date.
14. Contact
If you have questions about this privacy policy, contact us at support@facetjournal.app.
For provider information required under German law (§ 5 DDG), see our legal notice.