Table of Contents
1. Data Controller
The Data Controller for the processing of personal data is:
Via Cialdini 55A — 20821 Meda (MB), Italy
Email: app@anyvois.com
Website: www.anyvois.com
2. Definitions
- App: the Anyvois mobile application, available for Android (package:
com.voicelink.voicelink_app) and iOS. - Service: the set of features provided through the App and related backend servers.
- User: any natural person who installs the App and creates an account.
- Personal data: any information that identifies or makes identifiable a natural person, as defined in Article 4 of the GDPR.
- Processing: any operation performed on personal data (collection, recording, storage, communication, etc.).
- STT: Speech-To-Text — conversion of speech to text.
- TTS: Text-To-Speech — conversion of text to synthesized speech.
- PTT: Push-To-Talk — press-and-hold-to-record mode.
- Live Translate / LiveSense: real-time translation via audio streaming.
3. Data Collected
Depending on the features used, we collect the following categories of data:
3.1 Data provided directly by the user
- Username and display name: chosen during registration.
- Email address: used for authentication, password recovery, and service communications.
- Password: stored as an irreversible bcrypt hash (never in plain text).
- Preferred language: used to personalize translations and the interface.
- Profile picture (avatar): optional, uploaded by the user.
3.2 Data collected automatically
- Device ID: a unique device identifier generated on first launch (anonymized alphanumeric string). Used for single-session management and abuse detection.
- App version: reported to the backend on each WebSocket connection for update management.
- FCM Token: Firebase Cloud Messaging token for sending push notifications. Updated on each app launch.
- Activity timestamps: date and time of account creation, last access, and message sending.
- Anti-spam logs: message counters per minute and per hour, stored in volatile server memory (not in a persistent database).
3.3 Communication data
- Voice messages (PTT): recorded on-device via STT, converted to text before transmission. Raw audio is never sent to Anyvois servers for standard PTT messages.
- Text messages: original message text and translated text (stored in the database).
- Transcribed and translated text: the result of the STT → translation pipeline for voice messages.
- Message metadata: destination channel or chat, source language, timestamp.
3.4 Live Translate (LiveSense) data
- Streaming audio: during a LiveSense/Gladia session, PCM audio fragments from the microphone are streamed to the Gladia service (see Sections 5 and 8).
- Usage quotas: LiveSense minutes used, stored in the database for the gradual quota system.
- Session logs: session duration, number of audio chunks, and transcriptions and translations generated (if the "save sessions" feature is enabled).
3.5 Channel and chat data
- Public and private channels: name, type, invite code, member count, messages.
- Private chats (1:1): messages, translations, timestamps.
- Presence status: online/offline indication in active channels (non-persistent).
- Ghost mode: when active, the user appears invisible to others; this status is stored in the database.
3.6 Invite system data
- Invite links: code, optional custom slug, visits, claims, expiration.
- In-app invites: sender, recipient, channel, status (pending/accepted/declined).
4. Purposes and Legal Bases of Processing
| Purpose | Data involved | Legal basis (Art. 6 GDPR) |
|---|---|---|
| Registration and account management | Email, username, password hash, language, avatar | Performance of a contract (Art. 6(1)(b)) |
| Authentication and session security | JWT token, device ID, FCM token | Performance of a contract (Art. 6(1)(b)) |
| Transmission and translation of voice/text messages | Transcribed text, language, channel/chat ID | Performance of a contract (Art. 6(1)(b)) |
| Live Translate streaming (LiveSense) | Streaming PCM audio, transcriptions | Explicit consent of the user (Art. 6(1)(a)) |
| Push notifications | FCM token, notification content | Performance of a contract + implied consent upon installation (Art. 6(1)(b)) |
| Transactional emails (verification, password recovery, invite notifications) | Email address, username | Performance of a contract (Art. 6(1)(b)) |
| Abuse prevention and service security | Device ID, anti-spam counters, event logs | Legitimate interest of the Controller (Art. 6(1)(f)) |
| Invite management and referral system | Invite codes, visits, claims | Performance of a contract (Art. 6(1)(b)) |
| App version monitoring and updates | App version, device ID | Legitimate interest (Art. 6(1)(f)) |
| Compliance with legal obligations | All relevant data | Legal obligation (Art. 6(1)(c)) |
5. Audio and Voice Data — Detailed Processing
5.1 PTT (Push-To-Talk) Messages — Chat and Channels
When a user records a voice message using the PTT feature:
- Speech recognition (Speech-To-Text) takes place entirely on the user's device, using the native operating system APIs (Android SpeechRecognizer). Raw audio is never transmitted to Anyvois servers.
- Only the transcribed text is sent to the servers for translation and distribution to other participants.
- The translated text is synthesized into speech (TTS) on the recipient's device, locally.
5.2 Live Translate / LiveSense (Gladia)
The LiveSense feature uses a third-party service (Gladia) for real-time translation with latency under 300ms. In this scenario:
- The user explicitly activates the LiveSense session via a dedicated button.
- PCM audio fragments from the microphone are streamed directly to Gladia via secure WebSocket (
wss://api.gladia.io/v2/live). - A client-side VAD (Voice Activity Detection) system filters silence, reducing audio data transmitted by 40–60%.
- Gladia returns the transcription and translation. These results may be stored in the Anyvois database as a "session archive" if the feature is enabled.
For Gladia's privacy policies regarding audio processing, please refer to: gladia.io/privacy.
5.3 Vivavois (High-quality text translation)
The Vivavois feature processes text (not audio) through neural machine translation engines (Marian NMT) hosted on Anyvois's VPS2 server in Germany. No audio data is involved in this feature.
6. Messages and Translations
6.1 Messages in public channels
Messages sent in a public channel are visible to all channel members at the time of posting. Messages in public channels are subject to a configurable TTL (Time To Live) set by the system administrator (default: 5 minutes from creation). Once the TTL expires, the message is automatically deleted from the database. Any user present in the channel at the time of delivery may have already received and cached the text on their device.
6.2 Private chats (1:1)
Private chat messages are stored in the database as original text and translated text. End-to-end encryption is not provided: messages may be accessed by system administrators for security purposes and abuse prevention.
6.3 Translations
Original text and generated translations (in the languages of participants) are stored in the message_translations table. Translations may be produced by the following engines:
- Argos Translate — open-source engine running locally on VPS2.
- Marian NMT — neural engine running locally on VPS2.
- Amazon Translate — AWS cloud service (see Sections 8 and 9).
7. Social Authentication Data
Anyvois supports sign-in via third-party providers. In these cases:
7.1 Google Sign-In
The user authorizes Google to share an ID Token with Anyvois. The backend verifies the token's validity via Google APIs. The following data are stored in the Anyvois database: Google user identifier (as an internal reference), display name, and email address provided by Google. The account is flagged as a social login account (no password hash stored).
7.2 Apple Sign-In
Similar to Google. Apple may provide an anonymized email address (relay address); this address is stored as the account identifier.
7.3 Discord OAuth2
The user authorizes Discord to share their basic profile information. The following data are stored: Discord User ID, username, and email (if granted by the user during authorization).
No social authentication provider has access to the user's messages, channels, or other communication data on Anyvois.
8. Third-Party Services (Sub-processors)
| Provider | Service | Data transmitted | Location / Regulation |
|---|---|---|---|
| Google LLC (Firebase) | Push notifications (FCM), Google authentication | FCM token, Google ID token, display name, email | USA / SCCs + Data Privacy Framework |
| Apple Inc. | Apple Sign-In | ID token, email (optional) | USA / SCCs |
| Discord Inc. | OAuth2 login | User ID, username, email (optional) | USA / SCCs |
| Gladia | Live Translate audio streaming (LiveSense) | Streaming PCM audio fragments (only during an active session) | France (EU) — GDPR |
| Amazon Web Services (AWS) | Amazon Translate — text translation | Text to be translated (anonymous, no user identifiers) | Germany, eu-central-1 region (EU) — GDPR |
| Zoho Corporation | Transactional email delivery (SMTP) | Recipient email address, username, email content | EU (EU data center) — GDPR |
| OVHcloud | VPS1 hosting (main backend) | All data processed by the backend | France (EU) — GDPR |
| Hetzner / VPS2 provider | VPS2 hosting (translation engines) | Text submitted for translation (channels/chats) | Germany (EU) — GDPR |
Data processing agreements pursuant to Article 28 of the GDPR have been or will be entered into with providers acting as data processors.
9. Data Transfers Outside the EU
Some providers (Google, Apple, Discord) are based in the United States. Transfers are carried out in compliance with the safeguards provided by the GDPR, in particular through:
- Standard Contractual Clauses (SCCs) adopted by the European Commission;
- Equivalent mechanisms approved by the European Commission (e.g., the EU-US Data Privacy Framework).
The backend infrastructure (VPS1, VPS2) and Amazon Translate (eu-central-1 region) are located entirely within the European Union (France and Germany), ensuring that core data processing takes place within the EU.
10. Data Retention
| Data category | Retention period | Notes |
|---|---|---|
| Account data (email, username, language, avatar) | Until account deletion or erasure request | Immediately deleted upon request |
| Messages in public channels | Configurable TTL (default: 5 minutes) | Automatically deleted from the database |
| Messages in private chats | Until one of the participants deletes their account | — |
| Message translations | Same as the original message | — |
| LiveSense session logs | Until account deletion or specific request | Only if the "save sessions" feature is enabled |
| Anti-spam logs | Volatile (in-memory), reset on server restart | Not persisted in the database |
| Email logs | 90 days (configurable) | For delivery monitoring |
| FCM Token | Updated on each login; deleted upon account deletion | — |
| Deep-link invites | Until expiration or explicit revocation | — |
| Translation logs | 90 days (for anonymous statistical purposes) | — |
Upon account deletion, all personal data associated with the user is permanently and irreversibly removed from the database. Anonymized copies may persist for aggregate statistical purposes.
11. Data Security
Anyvois adopts appropriate technical and organizational measures to protect personal data, including:
- Encryption in transit: all communications between the App and servers take place over HTTPS/TLS (SSL certificates on all anyvois.com subdomains) and secure WebSocket (WSS).
- JWT authentication: short-lived tokens accompanied by refresh tokens; revoked upon logout or device change.
- Irreversible password hashing: bcrypt with salt; passwords are never stored in plain text.
- Single-device session: a new login from a different device invalidates the previous session (force_logout).
- Anti-spam: rate limits on messages per minute and per hour, with automatic temporary bans.
- Restricted administrative access: the admin dashboard is accessible only via Basic authentication over HTTPS.
- System separation: translation engines are hosted on a separate server from the main backend.
12. Data Subject Rights
As a data subject, you have the right to:
- Access (Art. 15 GDPR): obtain confirmation of the processing of your data and receive a copy thereof.
- Rectification (Art. 16): correct inaccurate data or supplement incomplete data.
- Erasure ("right to be forgotten", Art. 17): request the deletion of your data, subject to any legal retention obligations.
- Restriction (Art. 18): obtain restriction of processing in certain circumstances.
- Portability (Art. 20): receive the data you provided in a structured, commonly used, and machine-readable format.
- Objection (Art. 21): object to processing based on legitimate interest.
- Withdrawal of consent: for processing based on consent (e.g., LiveSense), withdraw consent at any time without affecting the lawfulness of prior processing.
- Complaint: lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority — Garante per la Protezione dei Dati Personali, garanteprivacy.it).
To exercise your rights, write to: app@anyvois.com with the subject line "GDPR Request" and specify the right you wish to exercise. We will respond within 30 days of receipt.
13. Children
The Service is intended for individuals aged at least 16 years (or the minimum age for digital consent under applicable national law). Anyvois does not knowingly collect data from minors. If we become aware that a user is below the required minimum age, we will promptly delete the account and all associated data.
Parents or guardians who believe that a minor has created an account on Anyvois are invited to contact us at app@anyvois.com.
14. Changes to This Policy
Anyvois reserves the right to update this Privacy Policy to reflect regulatory, technical, or operational changes. In the event of material changes, users will be notified via an in-app notification or email at least 14 days in advance. Continued use of the Service after notification constitutes acceptance of the updated Policy.
The latest version will always be available at: www.anyvois.com/privacy_policy.html.
15. Contact
For any questions regarding this Privacy Policy or the processing of your personal data:
Via Cialdini 55A — 20821 Meda (MB), Italy
Email: app@anyvois.com
Supervisory Authority:
Garante per la Protezione dei Dati Personali
www.garanteprivacy.it