Privacy Policy

Last Updated: September 11, 2026

1. Data Controller

The data controller responsible for your personal data is:

2. Data We Collect, Transmit, and Legal Basis

Under the General Data Protection Regulation (GDPR), we are required to inform you of the legal basis for processing your personal data. The table below summarises the data we collect, why we collect it, and the legal basis for each.

Photo Data

To generate summaries and narratives for your photo captions, photos you take or select are sent to external generative AI services. How data is handled after transmission is governed by each service's privacy policy.

• MimiSeka Scia: Generated summaries and narratives are embedded as metadata in the photo and saved to your device's photo library (in the "MimiSeka" album). This feature can be disabled in Settings.

Conversation, Diary, and Note Text (Scia)

The text you type or speak while talking about a photo, any note you attach to a photo, and the material used to write a diary entry are sent to third-party generative AI services in order to produce the writing. Once transmitted, that data is handled according to each service's own privacy policy. The conversation record itself is kept on your device (see 4. Data Stored on Your Device) and is never synced to iCloud.

Initial Survey

On first launch, the app asks for the following information:

• Vision status
• Age
• Narrative mode preference
• Auto-read-aloud setting

This information is used to optimise app settings and is also stored in anonymised form on our servers to improve the service. It is never used to identify any individual.

Device Identifier

To maintain stable service operation (daily request rate limiting), a device-specific identifier assigned by Apple (identifierForVendor) is sent to our server. This identifier changes when the app is reinstalled and is not used for cross-app tracking or advertising purposes.

Location Data (Optional)

Location data is only collected when you grant the app location access through your device's iOS system settings. When enabled, location data is used for:

• Adding location metadata to photos (when saving to album in Scia)
• Providing contextual information for narrative generation
• Showing where a photo was taken on a map inside the app
• Building an on-device register of the regions you have visited
• Retrieving place and venue names for the capture point via Apple Maps
• Retrieving the weather at the capture point and time via Apple WeatherKit

Precise location data (latitude and longitude) is sent to our servers only if you use the "leave a story at this place" feature described below, and only with your explicit consent. Otherwise, a coarse location name (city or municipality level) may be sent to generative AI services as contextual information for narrative generation. Place names, venue names, and weather are retrieved through Apple's services and do not pass through our servers.

Content You Publish as a "Listenable Photo" (Optional)

MimiSeka Scia lets you turn a story or diary entry into a link or QR code so that people without the app can listen to it. Only when you use this feature, the following is stored on our servers (AWS Tokyo region) and becomes accessible to anyone who has the link:

• Text — the story or diary entry, its title, capture date, and other display information
• Narration audio — the synthesized audio file
• Photo — stored only if you explicitly choose to publish with the photo

The legal basis is your explicit consent, given at the moment you publish. Publication is time-limited and you choose the period; expired content is deleted automatically. You may withdraw consent at any time via "Disable QR" in the app, after which the link no longer opens. Withdrawal does not affect the lawfulness of processing before withdrawal.

Our servers count how many times published content has been played or viewed and report that count back to you. We do not record who viewed it.

"Leave a Story at This Place" (Optional)

MimiSeka Scia lets you leave a story at the place where the photo was taken. If you use this feature, your story (text, narration audio, capture date, and precise capture coordinates) is stored on our servers and shown anonymously to other users who visit that place. The publication period is one year.

The legal basis is your explicit consent, which you give before the first time you use the feature. Your name and display name are never shown. You may withdraw at any time from within the app; withdrawal stops new deliveries, though the story may remain on devices that already received it.

Before publication, the text is sent once to an automated content check (OpenAI's Moderation API). Text judged inappropriate is neither stored nor published. The legal basis for this check is our legitimate interest in keeping the service safe for the people who receive these stories, and our obligation as a platform to prevent the distribution of illegal content.

Stories can be reported by other users. A reported story stops being delivered immediately; we then review it and decide whether to restore or delete it. The reason selected by the reporter, and any note they write, are stored for up to 400 days for audit purposes.

For this feature only, we store a pseudonymised identifier for the author and for the reporter, derived from the publishing identifier held on your device by a salted, irreversible hash. It is used solely to exclude an author's stories from delivery when a recipient blocks them, and to identify repeat offenders. It is never displayed and never passed to other users. Authors and reporters are hashed with separate domains, so the two cannot be matched against each other. Because a pseudonymised identifier is still personal data under the GDPR, your rights of access, erasure, and objection apply to it; contact us and we will act on the request.

Push Notifications (Optional)

If you use "letters from MimiSeka," we deliver notifications through Apple's Push Notification service (APNs). The legal basis is your consent, given through the iOS permission prompt, and you can revoke it at any time in iOS Settings.

iCloud (CloudKit) Storage and Sync

The story text and titles, capture notes, emotion tags, and narration audio collected on your shelf are stored and synced in your own iCloud. The photo images themselves are not sent — they stay in your device's photo library, and only an identifier for each photo is stored in iCloud. This happens entirely within Apple's services and does not pass through our servers. Data held in iCloud is governed by Apple's privacy policy, with Apple acting as the controller for that storage.

In-App Purchases

If you buy a subscription or a ticket pack, we verify the signed purchase receipt issued by Apple on our servers and record the resulting allowance against your device identifier. We never receive your payment details, such as credit card numbers.

Usage Data

To improve the app, the following usage data is recorded on your device:

• Number and completion rate of narrative generations
• Feature usage frequency
• Error occurrences
• Accessibility feature usage (VoiceOver, etc.)

This data is anonymised and stored on our servers solely for the purpose of service improvement. It is never used to identify any individual.

Data Retention

Content published as a "listenable photo" is retained until the period you chose when publishing (30 days by default), after which it is deleted automatically. A story left at a place is retained for one year. Report records are retained for up to 400 days, and block records until they are removed. In both cases, withdrawing publication in the app makes the content unreadable from then on. Usage data and device identifiers are retained for the duration of service operation and deleted when the service is discontinued. Initial survey data is retained as anonymised statistical information for the duration of service operation.

3. Third-Party Services (Data Processors)

We use the following third-party services to provide app functionality. These services act as data processors on our behalf or as independent controllers for data transmitted to them.

Generative AI Services

The following generative AI services are used for photo analysis and narrative generation. All communications are routed through our server over encrypted connections (HTTPS).

• OpenAI — Photo analysis, text generation
• Anthropic (Claude) — Text generation

How data is handled after transmission is governed by each service's privacy policy:

• OpenAI Privacy Policy
• Anthropic Privacy Policy

Text-to-Speech Services

The following services may be used to convert generated text to audio. Only text generated within the app is sent; no photos or user-identifying information is included.

• OpenAI — Speech synthesis for summaries and narratives
• Aivis Cloud — Speech synthesis for summaries and narratives (when using the natural Japanese voice)

• OpenAI Privacy Policy
• Aivis Cloud Privacy Policy

X (formerly Twitter)

Posting to X is optional. If you choose to use this feature, you connect your account via X's secure account authorisation. The app only requests posting (write) permission; it does not access your timeline, followers, or any other read permissions. Authentication credentials are securely stored in the device's secure credential storage (Keychain) and deleted upon logout.

4. Data Stored on Your Device

Scia

Generated summary and narrative text can be embedded as a description field stored inside the photo file (IPTC caption) and saved to the "MimiSeka" album in your device's photo library. This feature can be toggled on or off in Settings. Saved photos may include the following embedded data:

• Summary/narrative text (as ALT text)
• Emotion tags (if selected)
• Vision level and narrative mode
• Location data (if location services are enabled)

We also store, on your device, the record of your conversations about photos and the profile notes distilled from them. These are never synced to iCloud and never leave your device. You can review and delete them from the app's settings.

Voice Recordings Attached to Photos

In Scia you can record your own voice and attach it to a photo (before or after taking it, or later from the chapter screen). Recording your voice is the only feature that uses the microphone.

Recorded audio files are stored in the app's own storage on your device. They are never transmitted to our servers, and they are never transcribed or analyzed. Audio is not included when you publish a story as a QR code or link, when you share it with someone, or when you leave a story at a place.

Because these recordings are part of your device backup (such as an iCloud backup), they carry over when you move to a new device. You can remove the audio from an individual chapter inside the app, and "Erase all data" in Settings deletes all of them.

5. Data Security

• All external communications are encrypted via HTTPS
• Service credentials are managed on our server, not stored in the app
• Apple's App Attest framework is used to verify that requests come from genuine, unmodified copies of the app
• Authentication credentials and device identifiers are securely stored in the device's secure credential storage (Keychain)

6. Sharing with Third Parties

Except for the data processors and services described above, we do not sell, rent, or otherwise provide your data to third parties.

7. International Data Transfers

Your data may be processed by third-party generative AI and speech synthesis services in countries outside the EEA/UK that may not offer the same level of data protection. All transfers are conducted over encrypted connections (HTTPS) via our server. Where personal data is transferred outside the EEA/UK, we rely on the European Commission's adequacy decisions or standard contractual clauses as appropriate to ensure adequate protection of your data.

8. Children's Privacy

This app is not directed at children under the age of 16 in the EEA/UK, but it may be used by children with visual impairments. All survey responses and usage data are collected exclusively as anonymous, non-personally identifiable information for all users regardless of age. Device identifiers are sent to our server solely for request rate limiting and are not linked to any personal information. Core app features (photo analysis, narrative generation, and read-aloud) remain fully available regardless of age.

That said, publishing a "listenable photo" and leaving a story at a place are features where what you write can be seen by other people. If a child uses the app, a parent or guardian should review these features first. Any publication can be withdrawn.

If we become aware that we have inadvertently collected personal data from a child without appropriate consent, we will take steps to delete such data promptly. If you believe a child has provided us with personal data, please contact us at privacy@mimiseka.jp.

9. Your Rights Under the GDPR

If you are in the EEA, UK, or Switzerland, you have the following rights regarding your personal data:

• Right of Access — Request a copy of the personal data we hold about you
• Right to Rectification — Request correction of inaccurate or incomplete personal data
• Right to Erasure ("Right to be Forgotten") — Request deletion of your personal data
• Right to Restriction of Processing — Request that we limit how we use your data
• Right to Data Portability — Request your data in a structured, commonly used, machine-readable format
• Right to Object — Object to processing based on legitimate interest
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at privacy@mimiseka.jp. We will respond to your request within 30 days.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement. For the UK, you may contact the Information Commissioner's Office (ICO).

Additional Controls

• Disable location services, album saving, and other features at any time from the in-app Settings
• Disconnect X integration by logging out, which deletes your authentication credentials
• Withdraw a published "listenable photo" at any time via "Disable QR" in the app; once withdrawn, the link no longer opens
• Withdraw a story you left at a place at any time from within the app
• Delete all on-device data at any time via "Erase All Data" in Settings
• Delete all on-device data by uninstalling the app (excluding photos already saved to your photo library). Withdraw anything you have published as a "listenable photo" or left at a place before uninstalling, or contact us

10. Changes to This Policy

If we make changes to this policy, we will notify you through the app or our website. For significant changes, a notification will be displayed when the app launches.

11. Contact Us