Privacy Policy

Cotidie — AI Journaling App
Operator: Omar Alain Beltran Diaz, trading as Beltran Apps
Consent version: ai-companion-2
Effective date: April 26, 2026  •  Last updated: October 12, 2026
Privacy Contact: beltran-apps@outlook.com

1. Introduction

This Privacy Policy explains how Omar Alain Beltran Diaz, trading as Beltran Apps (operator of Cotidie) (“we”, “us”, “our”) collects, uses, and protects your personal data when you use the Cotidie mobile application (“the App”).

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and applicable EU/EEA data protection laws.

2. Data Controller & Infrastructure

Data Controller: Omar Alain Beltran Diaz, trading as Beltran Apps (operator of Cotidie)
Privacy Contact: beltran-apps@outlook.com
Website: https://reasoning-apps.cloud
Infrastructure & Endpoint: reasoning-apps.cloud, hosted on IONOS cloud servers in Spain (European Union / EEA jurisdiction).

3. Data We Collect

3.1 Account data

When you register, we collect your email address, a hashed password, timestamp and version of your consent, and your age confirmation (at least 16 years old).

3.2 Subscription data

We store a RevenueCat user identifier to associate your account with your subscription status. RevenueCat manages all billing and subscription data — see Section 6.

3.3 Journal content & AI companion

By default, your journal entries are written and stored encrypted locally on your device.

AI processing is strictly optional. If and only when the AI Companion is explicitly enabled by you, the App transmits the following data to our backend at reasoning-apps.cloud (hosted on IONOS cloud servers in Spain):

Purpose & Non-Clinical Nature: This data is processed solely for generating reflective follow-up questions and weekly summaries. The App and its AI companion do not provide medical, clinical, psychiatric, or therapeutic diagnosis or treatment.

Zero-Training Guarantee & Ephemeral Processing: Journal entries and contextual excerpts are processed ephemerally in real time and are NEVER used to train, retrain, or fine-tune AI foundation models. There is no persistent storage of journal text on our AI proxy servers; all transmitted journal text is discarded immediately after the AI response is generated.

We also record an audit ledger of when you enabled, re-consented, or withdrew AI consent, together with the consent version (currently ai-companion-2), as required for regulatory compliance.

3.4 Technical data

We may collect minimal technical data necessary to operate the service, such as server error logs. This data never includes journal content.

4. Legal Basis for Processing (GDPR Art. 6 & Art. 9)

AI processing is strictly optional and based entirely on your explicit opt-in consent.

DataLegal basis
Account dataContract performance (Art. 6(1)(b))
Consent records & audit ledgerLegal obligation (Art. 6(1)(c))
AI companion (journal text, recent excerpts, dates, mood labels, language code)Explicit opt-in consent (Art. 6(1)(a)) — strictly optional, withdrawable at any time
Special-category journal content processed by the AI companionExplicit opt-in consent (Art. 9(2)(a))
Technical/error logsLegitimate interest (Art. 6(1)(f))

5. How We Use Your Data

We use your data exclusively to provide and maintain your Cotidie account, process journal entries and reflection context through the AI companion feature (when enabled) to generate reflective follow-up questions and weekly summaries, manage your subscription status via RevenueCat, and comply with legal obligations.

The AI companion is designed strictly for personal reflection and emotional awareness; it does not provide medical, clinical, or therapeutic diagnoses.

We do not sell your data. We do not use your data for advertising. We never use your journal entries or excerpts to train AI foundation models.

6. Third-Party Services & Infrastructure

RevenueCat

We use RevenueCat to manage in-app subscriptions. RevenueCat receives your RevenueCat user ID and subscription transaction data from Apple App Store or Google Play. RevenueCat acts as a data processor on our behalf.

RevenueCat Privacy Policy  •  RevenueCat Terms

Apple App Store / Google Play

Purchases are processed by Apple or Google. Their privacy policies apply to payment data. We do not receive or store your payment information.

Self-hosted AI Model Service & Cloud Infrastructure (IONOS Spain)

AI companion requests and responses are routed through our dedicated endpoint at reasoning-apps.cloud, hosted on IONOS cloud servers in Spain (European Union / EEA jurisdiction). Our self-hosted language model service processes journal entries and excerpts solely for the seconds required to generate your reflective question or weekly summary. It retains zero persistent storage of journal text and operates under our Zero-Training Guarantee. Processing is conducted under explicit opt-in consent pursuant to GDPR Art. 6(1)(a) and Art. 9(2)(a).

7. Data Retention

Data typeRetention period
Account dataUntil account deletion + 30 days
Consent records3 years from consent date (legal obligation)
AI companion consent events (audit ledger)3 years from the event (audit record)
Journal content & excerpts (AI processing)Zero persistent storage — processed ephemerally in real time and discarded immediately once the AI response is returned
Local journal databaseStored encrypted locally on your device under your complete control
Subscription records (via RevenueCat)Per RevenueCat’s policy
Inactive accountsAnonymized after 2 years of inactivity

8. Your Rights Under GDPR

Right of access & Data portability (Art. 15 & Art. 20)

You can request a copy of all personal data we hold about you. You can also export your journal entries directly from the App at any time using the in-app PDF export feature, or request an export of your account data in JSON format.

Right to rectification (Art. 16)

You can correct inaccurate data via the Settings screen in the App.

Right to erasure (Art. 17) — “Right to be forgotten”

You can request complete account and data deletion directly within the App (Settings → Delete Account) or by contacting us at beltran-apps@outlook.com. We will complete the erasure within 30 days.

Right to withdraw consent (Art. 7)

AI processing is strictly optional. You can withdraw your AI companion consent at any time directly in the App via Settings > Privacy & AI > AI Companion (by toggling the AI Companion off). Withdrawal takes effect immediately: all data transmission to the AI backend immediately halts, and your journal data remains 100% on your device. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Right to object (Art. 21)

You have the right to object, on grounds relating to your particular situation, to processing based on our legitimate interests (Art. 6(1)(f)) — here, the processing of technical/error logs described in this policy. If you object, we will stop processing that data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary to establish, exercise or defend legal claims. This right does not apply to the AI Companion, which is based on your consent; to stop that processing, withdraw your consent as described above.

Right to lodge a complaint (Art. 77)

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU/EEA Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR (Art. 77). We would appreciate the chance to address your concern first — contact us at beltran-apps@outlook.com.

To exercise any of these rights, contact us at: beltran-apps@outlook.com. We will respond within 30 days.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encrypted local storage on your device by default, encrypted data transmission (HTTPS/TLS), encryption at rest of account identifiers such as email addresses, and strict access controls on our backend systems.

10. International Transfers

Our backend infrastructure (reasoning-apps.cloud) is hosted on IONOS cloud servers in Spain, strictly within the European Union / EEA jurisdiction. We do not transfer your personal data outside the EU/EEA except through RevenueCat, which maintains Standard Contractual Clauses (SCCs) for GDPR compliance.

11. Children’s Privacy

Cotidie is not directed at children under 16, in line with GDPR Art. 8. Registration requires you to confirm you are at least 16 years old (the confirmation is never pre-ticked), and that confirmation is recorded for audit purposes. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, contact us at beltran-apps@outlook.com and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via the App or email. The “Last updated” date at the top reflects the most recent revision. Continued use of the App after changes constitutes acceptance of the updated policy.

13. Contact

Omar Alain Beltran Diaz, trading as Beltran Apps
Privacy Contact: beltran-apps@outlook.com
Website: https://reasoning-apps.cloud/privacy