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Manuel Mobile App – Privacy Policy
Last updated: 21 May 2025
Important notice – No Tracking
The Manuel mobile application does not use Apple’s Identifier for Advertisers (IDFA) and does not track you across apps or websites owned by other companies within the meaning of Apple’s App Tracking Transparency (ATT) Framework.
1. Who we are
2. Scope and where to find this Policy
This Policy applies when you:
- install or use the App (iOS / Android);
- interact with push notifications or in-app messages;
- contact us via the App’s support features.
You can read this Policy at any time under Settings › Privacy Policy in the App and on https://manuel.chat/privacy. It does not cover data processed on websites or services outside the App.
3. What data we collect
| Category | Examples | Collected by | Linked to you? |
|---|---|---|---|
| Account details | Name, email address, phone number, company, user role | Manuel backend | Yes |
| Identifiers | App-generated user ID, internal device ID, IP address (server logs). No IDFA collected. | Manuel backend | Yes |
| Usage data | Screens visited, buttons tapped, session length | Microsoft Clarity*, Manuel backend | No (aggregated unless required for support) |
| Knowledge items | Answers or documents you mark as “Keep” in the Knowledge Centre | Manuel backend | Yes (visible only to your company) |
| Communications | Support tickets, survey responses | HubSpot, Survicate | Yes |
| Diagnostics | Crash traces, performance metrics | Firebase Crashlytics | No |
| Push-notification token | OneSignal device token | OneSignal | Yes |
* Microsoft Clarity (“session-replay”) is disabled by default on iOS and only records a session after you enable “Help improve Manuel” under Settings › Privacy.
We do not collect precise or coarse device geolocation and the App never requests GPS permission.
4. Why we process your data and legal bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Create & maintain your user account | Contract (Art. 6 (1)(b)) |
| Provide core App functions incl. document search & knowledge items | Contract |
| Deliver push notifications | Legitimate interest (Art. 6 (1)(f)); you can disable in OS settings |
| Analytics & product improvement (pseudonymised/aggregated) | Legitimate interest |
| Marketing emails (opt-in) | Consent (Art. 6 (1)(a)) |
| Compliance & security | Legal obligation / Legitimate interest |
You may withdraw consent at any time; this does not affect processing carried out before withdrawal.
5. How you can manage your data (incl. in-app deletion)
Delete account in-app
- Open Settings › Account › Delete account.
- Confirm deletion; we immediately log you out and queue your account and associated personal data for permanent erasure within 30 days (unless retention is required by law – e.g. billing records).
Delete knowledge items
Inside the Knowledge Centre tap ⋯ › Delete.
Export your data
Open Settings › Account › Export data to download a JSON/CSV archive.
If you cannot access the App, email info@manuel.chat.
6. Third-party processors
We share data only with vendors acting on our behalf under a Data Processing Agreement (DPA) and offering GDPR-compliant safeguards and an Apple Privacy Manifest (“PrivacyInfo.xcprivacy”) for their SDK:
| Vendor | Purpose | Data shared | Location / Transfer mechanism |
|---|---|---|---|
| Google Cloud Platform (europe-west4 – Amsterdam) | Hosting & storage | All backend data | EU |
| OpenAI (Azure West EU) | Generative-AI answers | Prompt text & anonymised metadata | EU |
| Anthropic Claude (AWS eu-central-1) | Generative-AI answers | Prompt text & anonymised metadata | EU |
| Google AI Gemini (europe-west9) | Generative-AI answers | Prompt text & anonymised metadata | EU |
| HubSpot Inc. | CRM & in-app chat | Account & support data | EU (Frankfurt DC) |
| Microsoft Clarity | Session-replay analytics (opt-in) | Usage data (pseudonymised) | EU |
| Survicate Sp. z o.o. | In-app surveys | Survey responses | EU |
| OneSignal Inc. | Push notifications | Device token, basic identifiers | USA → SCCs |
We do not sell personal data and we do not allow third parties to use it for their own purposes.
7. Data retention
| Data set | Retention period |
|---|---|
| Account & content | While account is active + 12 months, then anonymised |
| Knowledge items | While subscription is active; deleted within 90 days after contract ends or on request |
| Push-notification tokens | 24 months after last app activity |
| Analytics & crash logs | 26 months (Google default), then aggregated |
| Marketing consents | Until withdrawn + 24 months (audit) |
| Support tickets | 6 years (statutory limitation) |
After expiry, data is securely erased or irreversibly anonymised.
8. International transfers
Where we transfer data outside the European Economic Area we rely on:
- Adequacy decisions (e.g. EU–US Data Privacy Framework), or
- European Commission Standard Contractual Clauses (SCCs) plus supplementary measures (encryption, access controls).
9. Security measures & incident reporting
- Encryption in transit (TLS 1.2+) and at rest (AES-256).
- Network isolation & firewalling in Google Cloud VPC.
- Role-based access control (RBAC) with multi-factor authentication.
- Regular penetration tests and automated vulnerability scans.
- Continuous monitoring & incident alerts.
If a personal-data breach occurs, we will notify the Dutch Data Protection Authority and affected users within 72 hours, in accordance with Articles 33-34 GDPR.
10. Your privacy rights
You have the right to:
- Access your data
- Rectify inaccurate data
- Erase data (“right to be forgotten”)
- Restrict processing
- Data portability (JSON/CSV)
- Object to processing (including direct marketing)
To exercise these rights use the in-app tools (see §5) or email info@manuel.chat. We respond within 30 days.
You may also lodge a complaint with the Dutch DPA: autoriteitpersoonsgegevens.nl.
11. Children
The App is not directed to children under 13 years (US COPPA) or 16 years (EU GDPR). We block registration below that age. If you believe a child has provided personal data, contact us so we can delete it immediately.
12. Changes to this Policy
We may update this Policy to reflect technical or legal changes. We will notify you in-app or by email and post the new version here at least seven (7) days before it takes effect. The revision date at the top indicates the latest change.
13. Contact
Email: info@manuel.chat
Post: Manuel B.V., Burgemeester Bosmastraat 3, 7101 GX Winterswijk, The Netherlands
By installing or using the App you acknowledge that you have read and understood this Policy.
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