Privacy Policy – Cookler
Effective Date: December 9, 2025
Cookler SAS (“Cookler”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use the Cookler mobile application (the “App”).This Privacy Policy applies solely to the Cookler App and should be read together with our Terms and Conditions.
1. Data Controller
Company: Cookler SAS
SIREN: 913 671 707
VAT: FR94913671707
Address: 4 Passage Germinal, 93200 Saint-Denis, France
Email: [email protected]
Cookler SAS is the data controller responsible for processing your personal data.
2. Information We Collect2.1 Information You Provide
We collect the following information when you create an account or use the App:
Required
- Email address
- Password (stored in encrypted/hashed form)
Optional
- Full name
- Phone number
- Address
- Profile picture
User-generated content
- Audio and video recordings
- Photos
- Notes and text
- AI-generated transcriptions
- Exported files (PDF, Excel, etc.)
2.2 Information Collected Automatically
When you use the App, we may collect limited technical data, including:
- Device type and operating system
- App version
- IP address (used only for security, fraud prevention, and abuse detection)
- Timestamps, feature usage, and error logs
- Subscription status (Free or Pro), managed via RevenueCat
This data is
not used for cross-app tracking, advertising, or data brokerage.
Usage and diagnostic data is processed in aggregated or pseudonymized form and is not used to identify users outside the Cookler App.
2.3 Payment Information
Cookler does not collect, store, or process payment card details.
Payments are handled exclusively by:
- Apple In-App Purchase (iOS)
- Google Play Billing (Android)
Cookler only receives subscription metadata such as:
- Plan type
- Subscription status
- Renewal and expiration dates
3. How We Use Your Data
We process personal data strictly to operate and improve the App.
3.1 Core App Functionality
- Create and manage user accounts
- Store, display, and organize notes
- Process recordings and files you upload
- Generate AI-assisted transcriptions and documents
- Enable search, export, and retrieval of your content
3.2 AI Processing
Your audio, video, image, or text content may be processed using Gemini AI solely to perform transcription and content structuring requested by you.
We do not:
- Use your content for advertising
- Share your content publicly
- Sell or license your content
- Train public or third-party AI models using your private data
3.3 App Security and Reliability
- Detect and prevent fraud or abuse
- Monitor performance and fix errors
- Enforce usage limits and subscription rules
3.4 Legal and Compliance
- Comply with applicable laws and regulations
- Respond to lawful requests from authorities
- Enforce our Terms and Conditions
4. Legal Basis for Processing (GDPR)We process your personal data based on:
- Contractual necessity – to provide the App
- User consent – for optional profile data
- Legitimate interest – security, stability, and service improvement
- Legal obligation – accounting and regulatory compliance
5. Data Storage and Security
5.1 Storage
Your data is securely stored using trusted infrastructure providers:
- Firebase (Google) – authentication and data storage
- Algolia – search indexing
- RevenueCat – subscription management
Data may be stored in the European Union or other regions with appropriate legal safeguards.
5.2 Security Measures
We apply industry-standard security measures, including:
- Encrypted data transmission (TLS/HTTPS)
- Secure authentication systems
- Restricted internal access
Despite our efforts, no system can guarantee absolute security.
6. Data Sharing and Third-Party Services
We share data only when strictly necessary to provide the App:
| Provider |
Purpose |
| Firebase (Google) |
Hosting, authentication, storage |
| Gemini AI (Google) |
AI transcription |
| Algolia |
Search indexing |
| RevenueCat |
Subscription management |
| Apple / Google |
In-app purchase processing |
We do
not sell personal data and do
not share data for advertising purposes.
Each third-party service processes data under its own privacy policy.
7. Data Retention
- Personal data is retained while your account is active
- When you delete your account:
- Your personal data is deleted within 30 days
- Certain data may be retained longer if legally required
Deleted data cannot be recovered.
8. Your RightsYou have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion of your data
- Restrict or object to processing
- Request data portability
- Withdraw consent at any time
Requests can be made at:
[email protected]
9. Children’s Privacy
The Cookler App is not intended for users under 16 years of age.If we discover that a minor’s data has been collected:
- The account will be terminated
- All associated data will be deleted
10. International Data Transfers
If you access the App from outside the European Union, your data may be transferred internationally.
We ensure appropriate safeguards are in place in accordance with GDPR requirements.
11. No Tracking & Advertising
Cookler does not use tracking technologies as defined by Apple, including:
- Cross-app tracking
- Third-party advertising identifiers
- Fingerprinting or data brokerage
No personal data is used for targeted advertising.
12. Account Deletion
You may delete your account at any time:
Account deletion is permanent and does not automatically cancel App Store or Play Store subscriptions.
13. Data Breach Notification
In the event of a personal data breach, Cookler will notify affected users and relevant authorities in accordance with applicable data protection laws.
14. Changes to This Policy
We may update this Privacy Policy from time to time.
When changes are made:
- The effective date will be updated
- Material changes will be communicated via email or in-app notice
Continued use of the App constitutes acceptance of the updated policy.
15. Contact
For privacy-related questions or requests:
Email: [email protected]
Company: Cookler SAS
Address: 4 Passage Germinal, 93200 Saint-Denis, France
