Last updated: May 2, 2026

Introduction

Reflect is a private journaling app. This policy explains what leaves your device, what stays on it, and how to delete it all. It's written in plain English so you can verify it against what the app actually does. If anything is unclear, email [email protected] and we'll explain.

What We Collect

How We Use Your Information

Storage & Security

Data Sharing

We don't sell your data. We don't trade it. We don't show ads, so there's nobody to share it with for advertising purposes.

The third parties we use to run the app, and what each sees:

Your Rights & Choices

Data Controller & Legal Basis (GDPR / UK GDPR)

For users in the European Economic Area, the United Kingdom, and Switzerland, the data controller for Reflect is Reflect, operated from Tunisia, contactable at [email protected].

We process your personal data on the following legal bases:

Your rights under GDPR / UK GDPR: access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, objection, and the right to lodge a complaint with your local supervisory authority. To exercise any of these rights, contact us at [email protected]. We respond within 30 days.

California Residents (CCPA / CPRA)

If you are a California resident, you have the right to know what personal information we collect, the right to delete it, the right to correct it, and the right to opt out of "sale" or "sharing" of personal information.

International Data Transfers

Reflect uses cloud services operated by Google LLC, primarily hosted in the United States. If you back up your data, use AI features, sync across devices, or use Together / Shared Journal, your data is transferred to and processed in the United States. For users in the EEA, UK, and Switzerland, these transfers rely on Google's Standard Contractual Clauses, the UK International Data Transfer Addendum, and Google's participation in the EU–US Data Privacy Framework.

If you'd rather your data not leave your device, you can use Reflect entirely offline: skip cloud backup, don't enable sync on a second device, disable AI features, don't connect a buddy, and don't enable the Shared Journal. The core journaling experience works fully offline.

Data Retention

Your right to deletion is absolute. You can:

AI Model Training

Your moments are never used to train AI models. Our integration with Google Gemini uses the paid API, which per Google's terms does not retain prompts after responding and does not use prompts to improve Google's foundation models. We do not run our own AI training pipeline. We do not share moments with any third party for model training, fine-tuning, or evaluation.

Data Breach Notification

If we become aware of a data breach affecting your personal information, we will notify affected users without undue delay and, where feasible, within 72 hours of discovery, as required by GDPR Art. 33–34. Because we use anonymous accounts (no email on file by default), notification is delivered via in-app message and push notification.

Children's Privacy

Reflect is for users aged 13 and above. Onboarding shows a date-of-birth picker on first launch. If your date of birth makes you younger than 13, the app routes you to a restriction screen with no Continue button — there's no way to enter the rest of the app. We don't store the date of birth; it's used only for the gate. If you believe a child under 13 has somehow created an account and added data, email [email protected] and we'll remove it.

In-App Purchases & Subscriptions

Reflect offers optional premium features through auto-renewable subscriptions (monthly, yearly) and a one-time Lifetime purchase, managed entirely via the Apple App Store or Google Play Store. There is a free trial for new users.

Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be notified within the app. Continued use of the app after changes means you accept the updated policy.

Contact Us

If you have any questions or concerns about this Privacy Policy or your data, please contact us at [email protected].