Privacy Policy

Last updated: 30 October 2026

The German version is binding. This translation is for information only.

The essentials in brief

Your entries, pictures and tasks are stored encrypted on your devices. If you sync your iPhone and browser, our server only holds an end-to-end encrypted copy that we cannot read.
Mivelu only analyzes your texts if you switch on "Mivelu may listen" and your Mivelu Plus trial or subscription is running (the one exception is your first entry, see section 3.5). The text (and any voice recording or page photo) then passes briefly through our server to AI providers (including in the USA) for analysis. On this path it is protected by TLS, not end-to-end encrypted. Our server does not store it. The providers don’t use it for training and may keep it for up to 30 days to detect abuse.
We do not sell data, show ads or use tracking services. This website sets no cookies.

1. Controller

Provem Digital GmbH, Arnethgasse 40/6, A-1160 Vienna, Austria

Email: office@provem.at

You will find more details in the imprint.

For questions about data protection, contact us at office@provem.at.

2. This website (mivelu.com)

When you visit the website, our hosting provider Cloudflare processes technically necessary data such as your IP address, the time, the page requested and browser details, in order to deliver the page and protect it against attacks. The legal basis is our legitimate interest in a secure, working service (Art. 6(1)(f) GDPR).

The website sets no cookies, uses no analytics or advertising services and loads no fonts or scripts from third parties. The Nunito font is hosted on our own server.

3. The app and the web app

3.1 What stays on your devices

Mivelu stores your entries, feelings, memory pictures, tasks, threads and memory encrypted on your iPhone or in your browser. While "Mivelu may listen" is off, the iPhone turns dictation and photos of notebook pages into text directly on the device. While it is on, AI providers do this (section 3.5).

The web app uses your browser’s storage (localStorage and IndexedDB) only for what it needs to work: your encrypted entries and pictures, the encrypted key, your sign-in and settings such as the language. It does not use it for advertising or tracking.

We create an account so that the AI features, pairing and the subscription work. For this we process:

a random account ID and session tokens (stored on our side only as a checksum),
on the iPhone, a device attestation from Apple (App Attest) confirming that requests come from the genuine app,
if you sign in with an email code (in the app or in the browser), your email address. We send you the code through our email service provider Resend,
paired browsers with their name (for example "Safari on Mac"), pairing time and last use, so that you can see and unpair them on your iPhone.

The legal basis is the performance of the user agreement (Art. 6(1)(b) GDPR).

Our server also stores the days on which your account was active. We only record the date, separately for each platform (iOS or web). We delete this information after 13 months and together with your account. This shows us how many people use Mivelu and whether it runs reliably. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR).

3.3 Pairing iPhone and browser

When you pair by QR code, your iPhone and your browser exchange keys. Your sync key is encrypted on the iPhone and only passed through our server in this form. We cannot read it. A pairing request expires after two minutes and is deleted once it has been collected.

3.4 Sync between your devices

If you have paired a browser with your iPhone, Mivelu syncs entries, tasks, memory pictures and some settings (name, picture style, details from "About you", thread names) between them. Each record is first encrypted on the device with your sync key (AES-256-GCM). Our server only stores these encrypted records with a sequence number, the time of the change and the data type (entry, task, settings, picture), plus a fingerprint of your key. The fingerprint does not reveal the key. It only makes sure that an account never ends up with data under two different keys. The server cannot read the content. The legal basis is the user agreement (Art. 6(1)(b) GDPR).

3.5 "Mivelu may listen": the AI analysis

If you switch this on, Mivelu briefly sends content from your journal through our server to AI providers: usually the text of one entry, for patterns, memory and reviews also excerpts from several entries, as well as voice recordings and photos of notebook pages. It does this in order to

pick up which feelings are in it and find the matching passages in your words,
recognize a key sentence and recurring people, plans and themes (threads),
suggest tasks,
ask a follow-up question with "Think deeper",
write short notes for your memory and a summary for each month (monthly memory),
create a painted memory on request (also using your approximate age and gender from "About you", without names),
recognize patterns across your whole journal and write weekly, monthly and yearly reviews,
turn voice recordings (on the iPhone and in the web app) and photographed notebook pages into text.

Journal entries can contain very personal information, for example about your health or your emotional life. We only process them for these purposes with your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). You can withdraw your consent at any time in the settings. After that, no new texts are analyzed; you can still write. Mivelu and its AI features are available from the age of 16.

The AI analysis is part of Mivelu Plus. It only takes place while your trial or subscription is running. Once both have ended, Mivelu no longer sends any texts or recordings to AI providers, even if "Mivelu may listen" stays switched on. Your entries stay encrypted on your devices.

To get to know Mivelu, it analyzes your first entry once even without Plus (feelings, threads and a memory picture), if "Mivelu may listen" is switched on.

Our server only passes texts, recordings and photos on for the duration of the request and does not store them; the same applies to the finished memory picture on its way back. During the request they are held unencrypted in memory; they are transmitted via TLS. For each request we only store administrative data: request ID, time, model used, number of tokens processed, cost and result status, without content. This lets us keep quotas and costs under control.

AI providers we use:

OpenAI (OpenAI Ireland Ltd. / OpenAI, L.L.C., USA): feelings, supporting passages, tasks, Think deeper, memory, patterns, reviews, memory pictures and turning voice recordings into text.
Anthropic (Anthropic, PBC, USA): fallback provider for text features if OpenAI is not available.
xAI (X.AI LLC, USA): reading photographed notebook pages (xAI only), and fallback provider for voice recordings and text features.

According to the providers, inputs sent through their interfaces are not used to train their models. They may, however, keep requests for a limited time to detect misuse, usually for up to 30 days.

3.6 Consents and quotas

We store whether and when you switched on "Mivelu may listen", your age group and your country, so that we can prove that consent was given and unlock the features correctly. The legal basis is our legal obligation to provide proof (Art. 6(1)(c) GDPR) and the user agreement.

3.7 Notifications, photos and microphone

The app schedules writing reminders on your iPhone. Mivelu only accesses photos, camera and microphone if you allow it and start the feature yourself.

3.8 Subscription

You can buy Mivelu Plus in the iPhone app through Apple or in the browser through Stripe. It starts with a free 7-day trial. A subscription applies to your account, so on all your devices.

Through Apple: the trial is an introductory offer from Apple. Apple processes the payment details. We receive the purchase confirmation from Apple (product, term, status including a running trial, a transaction number) to link your subscription to your account. Apple reports the change from the trial to the paid subscription, renewals and refunds directly to our server.
Through Stripe: payment takes place on a Stripe page. Stripe acts as the seller (merchant of record) and is a separate controller for payment, invoice and tax data; the Stripe privacy policy applies to this. Mivelu does not see card or bank details. Stripe receives your email address, billing address and payment details at the start of the trial and only charges you when it ends. We store your customer number and subscription number at Stripe, the product, term, status (for example trial or active), the end of the trial or of the current period and whether the subscription has been canceled. Stripe records whether you asked for an immediate start as proof at the time of purchase.
Cancellation: if you cancel through "Cancel contracts here", also during the trial, we process the email address you enter and the time of receipt and send you a confirmation by email.
After the end: if your trial or subscription ends, we do not delete any data because of that. No AI processing takes place after that (section 3.5). Encrypted sync (section 3.4) keeps running.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). We keep invoices and accounting records for as long as tax and company law require (in Austria usually seven years, § 132 BAO).

3.9 Emails about your reviews

If you want, we email you when your weekly, monthly or yearly review is ready. This stays off until you switch it on in the settings, and it needs a linked email address. The email contains nothing from your journal. We only tell that a review is ready from the number and timestamps of your synced entry records; their content stays encrypted. The emails are sent through Resend. So that no email arrives twice, we note for which period we wrote to you and delete this note after 400 days. You can unsubscribe at any time through the link in every email or in the settings. The legal basis is your consent (Art. 6(1)(a) GDPR).

3.10 Crash and error reports

If the iPhone app crashes or runs noticeably slowly, it sends us a technical report that Apple creates on the device (MetricKit). The web app reports technical errors in a similar way. The reports contain the device type, system version, app version and technical details of the error, never entries. We delete them after 90 days. The legal basis is our legitimate interest in a stable app (Art. 6(1)(f) GDPR).

4. Service providers and servers

Railway (Railway Corp., USA): runs our server and database in the Netherlands region (EU). Railway stores backups of the database in the USA. They contain your encrypted records as well as account and administrative data such as your email address.
Cloudflare (Cloudflare, Inc., USA): delivers the website and the web app and manages the domain.
Apple (Apple Distribution International Ltd., Ireland): App Store, subscriptions and App Attest.
Stripe (Stripe Payments Europe, Ltd., Ireland): sale, payments, subscriptions, invoices and VAT for purchases in the browser, as a separate controller (section 3.8).
Resend (Resend, Inc., USA): sends sign-in codes, confirmations (for example of a cancellation) and, if you switched them on, the emails about your reviews. For this, Resend receives your email address and the content of that message.
the AI providers listed in section 3.5.

We have concluded data processing agreements with these providers or use their data processing terms. Where data is transferred to the USA, we rely on the EU-US Data Privacy Framework if the provider is certified under it, and otherwise on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR).

5. How long we keep data

Journal content: never stored in plain text on our servers (for AI analysis only held in memory for the duration of the request, section 3.5). Synced records are only stored there in encrypted form until you delete them (an empty deletion marker then remains) or delete your account.
Account, consents and paired devices: as long as your account exists, also after the trial or subscription ends. If you delete your account in the app, we delete this data. A subscription through Stripe ends immediately at that point, and nothing more is charged. You cancel a subscription through Apple yourself in your iPhone settings; the app reminds you of this when you delete your account. If an iPhone switches to an email account or signs out, we immediately delete any account left behind without an email address, including its browsers and encrypted records.
Active days (date only, per platform iOS or web): 13 months; deleted together with the account if you delete it.
Sessions: web sessions end after 12 hours without renewal, app sessions after 7 days.
Sign-in codes: 10 minutes. Pairing requests: 2 minutes.
Administrative data on AI requests: as long as the account exists, at most as long as we need it for billing and proof.
Note of sent review emails: 400 days.
Crash and error reports: 90 days.
Technical logs of the website at Cloudflare: according to Cloudflare's retention periods, usually a few days.

6. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and objection (Art. 15 to 21 GDPR). You can withdraw consent at any time with effect for the future. You can export and delete your entries in the app at any time.

To do so, write to us at office@provem.at. You can also lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde): Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at.

7. Security

We transmit all data encrypted (TLS). Your stored and synced content is end-to-end encrypted; the AI analysis is not, because our server briefly handles the content for it (section 3.5). Content on your devices is encrypted with AES-256; the key only leaves the device in encrypted form during pairing. No automated system makes decisions about you that have legal effect.

Authorized Provem staff can see an account's metadata for support purposes, but never journal content. Every such access is logged.

8. Changes

As Mivelu develops, we update this policy. You will always find the current version here.