Privacy Policy
Summary
- Phantom Machines is based in the Czech Republic. No investors, partners or advertisers get your data.
- We do not know who you are. We ask for no sign-up, email login or user profile. Purchases go through Apple; Apple does not give us your name, email or payment details.
- Where an app sends what you submit to our server and on to an AI provider to produce the result, we do not store that content. It is processed in memory and discarded. The provider does not use it to train its models and may keep it for up to 30 days for abuse monitoring.
- We keep only the small amount of technical and billing data an app needs. Each app's section in Part B lists that data and how long we keep it.
- No ads, no advertising or analytics SDKs, no tracking across apps or websites, no cookies on the website. We do not sell your personal data and never have.
- You can reach us at support@phantommachines.com for any question or request about your data.
Part A — General
1. Who is responsible for your data
The controller of the personal data described in this Policy is:
Daniil Badalov, an individual, trading as Phantom Machines
Siroka 240/2, 362 63 Dalovice, Czech Republic
Email: support@phantommachines.com
Website: phantommachines.com
We are established in the European Union, so no EU representative under Article 27 GDPR is required. We have not appointed a Data Protection Officer because the law does not require one for processing of this kind and scale; the contact above handles all privacy matters.
2. Scope and definitions
This Policy covers:
- the website phantommachines.com (Section 4);
- our support mailbox (Section 5);
- each app listed in Part B.
"Personal data" means any information relating to an identified or identifiable person (GDPR Article 4(1)). "Content" means the material you choose to submit to an app for processing (each app's section in Part B says what this includes). "Apple" means Apple Inc. and its affiliates, including Apple Distribution International Ltd. for the EU.
Apple's own collection of data through the App Store, in-app purchases, Apple ID and macOS/iOS system services is governed by Apple's privacy policy (apple.com/legal/privacy), not by this Policy.
3. Principles that apply to everything we do
- No accounts in the usual sense. We do not ask for your name, email address, phone number or any login. Where an app needs to recognise a paying customer, it uses random identifiers generated by the app and the transaction identifiers that Apple provides.
- Content is not stored on our servers. We transmit Content to produce the result you asked for, and we discard it. Server logs contain no Content.
- No advertising, no tracking, no analytics. Our apps and website contain no advertising or analytics SDKs, no tracking pixels and no third-party cookies. We do not track you across other companies' apps or websites and do not combine data from other sources with yours. Our apps therefore do not request App Tracking Transparency permission, because there is nothing to ask about.
- No sale of personal data. We do not sell, rent or trade personal data, and we do not share it for cross-context behavioural advertising. This has been true since Phantom Machines started and we do not plan to change it.
- Data minimisation. Where a random identifier or a hash can do the job of a direct identifier, we use the random identifier or the hash.
4. Website (phantommachines.com)
The website is a static site served by a cloud hosting and edge infrastructure provider.
- Cookies and trackers: none. The site sets no cookies and loads no analytics, advertising or social-media scripts.
- Hosting logs: like any web host, our hosting provider receives your IP address, browser type, requested pages and timestamps in order to deliver the site and protect it from attacks. The provider processes these connection logs under its own privacy policy and retention rules; we do not run analytics on them and do not use them to identify visitors.
- Legal basis: our legitimate interest in operating a working and secure website (GDPR Article 6(1)(f)).
5. Support correspondence
If you email support@phantommachines.com, we receive your email address, whatever you write, and any attachment you send. We use this only to answer you and to improve the apps, on the basis of our legitimate interest in providing support (Article 6(1)(f)) or, where the message concerns a purchase, the contract with you (Article 6(1)(b)). Support email is hosted by our email service provider as a processor. We keep support correspondence for up to 24 months after the last message in the thread, then delete it, unless a dispute requires us to keep it longer.
6. Who receives data (categories of recipients)
We share personal data only with the categories of service providers below, only to the extent described, and only under contracts that limit what they may do with the data (data processing agreements or equivalent terms). We do not share personal data with advertisers, data brokers or anyone else.
| Category of recipient | Role | What they receive |
|---|---|---|
| Cloud hosting and edge infrastructure provider | Processor: runs our server (api.phantommachines.com) and database and serves the website | The server-side data listed in Part B; Content while it passes through our server; website connection logs |
| AI service provider, for apps that use one (see Part B) | Processor: processes Content via an API to produce the result. Does not use the data to train its models. May keep inputs and outputs for up to 30 days for abuse and misuse monitoring, then deletes them. | Content submitted for processing (never stored by us) |
| Apple | Independent controller: App Store, in-app purchases, App Store Server Notifications, system services | Apple sends us transaction identifiers and notification events; Apple collects its own data under its policy |
| Messaging service used for internal operational alerts | Service used by us to receive alerts about outages, cost anomalies and suspected abuse | Pseudonymous account or device identifiers and numbers; never Content or IP addresses |
| Email service provider | Processor: support mailbox | Support correspondence |
We may also disclose personal data if the law requires it (for example a binding order from a court or authority), to establish, exercise or defend legal claims, or, in the unlikely event that Phantom Machines or an app is transferred to another owner, to the acquirer under the same commitments, with notice to you.
7. International transfers
We are in the Czech Republic (EU). Some of our service providers process data in the United States and other countries outside the European Economic Area. When personal data leaves the EEA, we rely on safeguards recognised by Chapter V of the GDPR, as applicable to the recipient: an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework, for recipients certified under it) or the European Commission's Standard Contractual Clauses, together with supplementary measures where needed. For the United Kingdom and Switzerland, the equivalent mechanisms recognised there apply. Where no such mechanism applies to a specific transfer (for example internal operational alerts), we limit the data to pseudonymous identifiers and numbers that cannot be used to identify you without information held only by us.
8. Security
We take measures appropriate to the risk, including: encryption in transit (HTTPS/TLS) for all traffic between the apps, our server and our processors; storing only hashed values where a direct identifier is not needed (IP addresses, licence keys); random identifiers instead of personal details; access to the server and database limited to the developer and protected by multi-factor authentication; automatic deletion of logs; and monitoring for anomalies. No system is perfectly secure. If we learn of a personal data breach that is likely to put your rights at risk, we will notify the Czech supervisory authority within 72 hours and inform you as required by GDPR Articles 33 and 34.
9. Children
Our apps and website are intended for a general audience and are not directed at children. We do not knowingly collect personal data from children under 13 years of age, or under the age at which a child can consent to online services in their country (15 in the Czech Republic; up to 16 elsewhere in the EU). Because we do not collect names, emails or ages, we cannot verify a user's age; if you believe a child has provided us with personal data, email support@phantommachines.com and we will delete it.
10. Your rights
10.1 Rights under the GDPR (and the UK GDPR / Swiss FADP where they apply)
You have the right to:
- access the personal data we hold about you and receive a copy;
- rectification of inaccurate data;
- erasure ("right to be forgotten") where the data is no longer needed or you object and we have no overriding grounds;
- restriction of processing in the situations set out in Article 18;
- data portability of data you provided to us under a contract, in a machine-readable format;
- object to processing based on our legitimate interests; we will stop unless we have compelling legitimate grounds;
- withdraw consent at any time where processing is based on consent (this does not affect processing already carried out);
- not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. The only automated decisions we make are those described in Part B; they are necessary for the contract, and you may ask for human review at any time.
How to exercise these rights. Email support@phantommachines.com. Because we do not hold your name or email, to find your records we will need the account or device identifier shown in the app (or details of your Apple purchase, such as the order date and product). We may ask for enough information to be reasonably sure the request comes from the user of that account. We respond within one month; in complex cases we may extend by up to two further months and will tell you if so. Exercising your rights is free, unless requests are manifestly unfounded or excessive.
Complaints. You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state where you live or work. Our lead authority is the Czech Office for Personal Data Protection:
Úřad pro ochranu osobních údajů (ÚOOÚ)
Pplk. Sochora 27, 170 00 Praha 7, Czech Republic
www.uoou.cz
If you are in the United Kingdom you may complain to the Information Commissioner's Office (ico.org.uk); in Switzerland, to the Federal Data Protection and Information Commissioner (edoeb.admin.ch). We would appreciate the chance to resolve your concern first, but you do not have to contact us before complaining.
10.2 California residents (CCPA / CPRA)
Phantom Machines may fall below the thresholds at which the California Consumer Privacy Act applies. Regardless, we extend the following to California residents:
- Categories of personal information collected in the last 12 months: set out in each app's section of Part B.
- Sources: you (through the app) and Apple (transaction identifiers).
- Purposes: providing the service, billing and entitlements, fair use, security and abuse prevention, support, legal compliance.
- Disclosures for a business purpose: to the categories of service providers listed in Section 6.
- We do not sell personal information and we do not share it for cross-context behavioural advertising, and we have not done so in the preceding 12 months. We have no actual knowledge that we sell or share the personal information of consumers under 16. Because we do not sell or share, there is no opt-out to offer; Global Privacy Control signals are honoured in the sense that there is nothing to opt out of.
- Your rights: to know (access) what personal information we have collected about you, including the categories and specific pieces, sources, purposes and recipients; to delete it; to correct inaccurate information; to opt out of sale or sharing (not applicable, see above); to limit use of sensitive personal information (not applicable, see above); and not to be discriminated against for exercising your rights. We will not deny service, charge a different price or provide a different level of quality because you exercised a right.
- How to exercise: email support@phantommachines.com with "California privacy request" in the subject line. We verify requests by matching the account or device identifier from the app and, where relevant, Apple purchase details. You may use an authorised agent; we will ask the agent for proof of your written permission and may ask you to confirm directly. We respond within 45 days (extendable once by 45 days with notice).
- Retention for each category is set out in Part B.
- "Shine the Light" (Cal. Civ. Code §1798.83): we do not disclose personal information to third parties for their direct marketing purposes.
10.3 Residents of other US states and other countries
Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana and other states with comprehensive privacy laws have similar rights of access, correction, deletion, portability and opt-out of sale, targeted advertising and profiling. We do not sell personal data, do not engage in targeted advertising and do not profile you for decisions with legal or similarly significant effects. To exercise any right, email support@phantommachines.com; if we decline a request, we will say why and you may appeal by replying to our decision; we will answer the appeal within the period your state's law provides.
Wherever you live, you may contact us and we will honour the rights your local law gives you.
11. Do Not Track and Global Privacy Control
Our website and apps do not track you, so there is nothing for a "Do Not Track" or Global Privacy Control signal to switch off. We treat every visitor as if the signal were on.
12. Changes to this Policy
We may update this Policy when our apps, service providers or the law change. The effective date at the top shows the current version. For material changes, we will show a notice in the app or on the website at least 14 days before the change takes effect where reasonably possible. Previous versions are available on request.
13. Contact
Daniil Badalov — Phantom Machines
Siroka 240/2, 362 63 Dalovice, Czech Republic
support@phantommachines.com
Part B — App-specific rules
Each app we publish has its own section here. If an app is not listed, this Policy does not yet cover it; the App Store privacy details for that app apply.
B1. Briz (macOS)
Briz is a voice translation and dictation app for the Mac that also translates documents (PDF, Word, Excel, PowerPoint), web pages and live chat messages ("Live-chat"). This section explains what happens to data when you use it. In this section, "Content" means the audio, text, documents, web pages and chat messages you dictate, translate or otherwise submit to Briz.
B1.1 What happens to your Content
When you dictate, translate text, translate a document, translate a web page or use Live-chat:
- The app sends the relevant Content (an audio recording, the text you selected or typed, the document file, or the address and text of the web page) over an encrypted connection (HTTPS) to our server at api.phantommachines.com, which runs on our cloud hosting and edge infrastructure provider.
- Our server forwards the Content to our AI speech-recognition and translation provider to transcribe and/or translate it.
- The result is returned to your Mac.
What we do not do with Content:
- We do not store Content on our server. It is held in memory only for as long as it takes to process the request and is then discarded.
- We do not write Content to server logs.
- We do not read Content, use it to build profiles, train models or improve the service, and we do not share it with anyone other than the processor that produces the result.
The AI provider's handling of Content: the provider processes Content on our behalf as a processor under a data processing agreement. It does not use API inputs or outputs to train or improve its models. It may retain inputs and outputs for up to 30 days to detect abuse and misuse, after which they are deleted, unless it is legally required to keep them longer.
Content belonging to other people. Content you submit may contain information about other people (for example, a message you received and want translated, or a document mentioning third parties). You decide what to submit. We process it only to produce the result for you and treat it exactly as described above.
Special categories of data. We do not ask for, and have no interest in, health, religious, political, biometric or similar sensitive data. If the Content you choose to submit happens to contain such information, it is processed solely to deliver the result you requested, under the same "not stored, not read" rules, on the basis of the contract with you and your deliberate choice to submit it.
Personal vocabulary. Your custom vocabulary (words and names you want recognised correctly) is stored on your Mac. Relevant entries may be included with a request so that the speech recogniser spells them correctly; when that happens they are handled like any other Content and are not stored on our server.
B1.2 Data our server stores about your use of Briz
To know whether a copy of Briz is entitled to use the paid service, to apply fair-use limits, to protect the service from abuse, and to keep it running, our server stores the following:
| Data | Details | Why |
|---|---|---|
| Account identifier | A random identifier created for your copy of Briz. It is not your Apple ID, name or email. | To tie your purchases and usage together. |
| Purchase records | Apple's original transaction identifier and product identifier, plan, App Store environment (production/sandbox), purchase and expiry dates, status, and the price paid. If you used a licence key (direct-download edition, where offered), a hash of the key, not the key itself. | To know what you bought and for how long, to calculate fair-use limits, and to handle refunds, renewals and revocations that Apple reports to us. |
| Apple App Store Server Notifications | Notification identifier, notification type (for example renewal, refund, revocation) and the related transaction identifier. | To keep entitlements accurate when Apple reports a change. |
| Device record | A random device identifier generated by the app; optionally a device model label (for example "MacBook Pro"); app version; distribution channel (App Store or direct download); first-seen and last-seen timestamps. | To recognise your devices, detect account sharing, and support you if something goes wrong on a specific version. |
| Usage counters | Seconds of audio and characters processed per billing period; a balance ledger (top-ups and deductions). | To apply plan limits and to deduct from your balance. |
| Request log | For each request: time, kind (translate / document / page / transcribe), units processed, cost, model used, token counts, latency, status, language pair, app version, and a truncated, salted SHA-256 hash of the IP address (the IP address itself is not stored). No Content. | To keep the service reliable, to investigate errors you report, and to detect abuse. Auto-deleted after 90 days. |
| Abuse and cost-protection records | Anomaly flags and a per-account cost ledger. | To detect scripted or shared use and to pause an account temporarily if its usage cost far exceeds what was paid (see B1.5). Anomaly records are auto-deleted after 90 days. |
What we do not have: your name, email, Apple ID, payment card, billing address, precise location, or the contents of anything you translated.
B1.3 Data that stays on your Mac
Briz keeps the following on your Mac only. It is not uploaded to us unless you choose to send it:
- your settings and preferences;
- your personal vocabulary (see B1.1 for how entries may travel with a request);
- recent dictation history and translated documents (so you can find them again);
- per-app language memory (which language you use in which app);
- a diagnostic log, which may contain technical information about the app, your Mac and recent errors. It does not contain the text of your dictations or translations. The log stays on your Mac unless you send it to us.
You can delete these at any time from the app or by removing the app and its data. If you ask us for help, you can send the diagnostic log voluntarily using "Save log for support" (About Briz); please review it before sending. We use it only to help you and delete it once your case is closed.
B1.4 macOS permissions
Briz asks macOS for:
- Microphone — to record your voice while you dictate. Recording happens only when you start it.
- Accessibility — to paste the translation where your cursor is in another app. Briz uses this to insert text; it does not read or collect the contents of other apps for any other purpose.
- Speech recognition / translation (optional) — Briz may fall back to Apple's on-device speech and translation frameworks in some situations. Processing then happens on your Mac under Apple's rules.
You can withdraw these permissions at any time in System Settings. Some features will stop working without them.
B1.5 Automated fair-use decisions
Our server automatically compares the cost of your usage with what has been paid for the current period. If usage far exceeds the plan's fair-use allowance, the server can pause the paid service for that account until the next paid period starts. This is a contractual usage limit, not a judgement about you, and it is reversible: if you believe a pause was wrong, email support@phantommachines.com and a human (the developer) will review it. Permanent bans are never automatic; they are decided by a human and only for serious abuse (see the Terms of Use).
B1.6 Internal alerts
When the server detects an outage, a cost anomaly or suspected abuse, it sends a short alert to the developer through a messaging service. Alerts contain pseudonymous identifiers (account or device identifier) and numbers (counts, costs); they never contain Content, IP addresses or anything that identifies you by name. Our basis is our legitimate interest in keeping the service running and protecting it from abuse (Article 6(1)(f)).
B1.7 Legal bases for Briz (GDPR Article 6)
| Processing | Legal basis |
|---|---|
| Transmitting and processing Content to deliver the result | Performance of a contract with you (Article 6(1)(b)). |
| Account, purchase and usage records; applying plan limits and balance | Performance of a contract (Article 6(1)(b)); and, for records we must keep, legal obligations under Czech accounting and tax law (Article 6(1)(c)). |
| Request log, device records, abuse and cost-protection records, internal alerts | Our legitimate interests in keeping the service reliable and secure and in preventing abuse and fraud (Article 6(1)(f)). We have assessed that these interests are not overridden by yours, given that the data is pseudonymous, contains no Content and is short-lived. |
| Diagnostic log you send to support | Your consent, given by sending it (Article 6(1)(a)); you may withdraw consent by asking us to delete it. |
| Responding to your rights requests | Legal obligation (Article 6(1)(c)). |
B1.8 How long we keep Briz data
| Data | Retention |
|---|---|
| Content (audio, text, documents, pages, chats, translations) | Not stored by us. Held in memory while the request is processed. AI provider: up to 30 days for abuse monitoring, then deleted. |
| Request log and anomaly records | 90 days, then deleted automatically. |
| Account, purchase, device and usage records | For as long as the account has an active or renewable purchase or balance, and for up to 36 months after the last activity, so that we can honour entitlements, handle refunds, disputes and chargebacks reported by Apple, and prove fair use. Records that Czech accounting or tax law requires us to keep are kept for the statutory period (generally up to 10 years) and then deleted. |
| Apple App Store Server Notifications | Same as purchase records. |
| Diagnostic logs you send to support | Until your case is closed, then deleted; at most 12 months. |
When data is no longer needed we delete it or anonymise it so that it can no longer be linked to you.
B1.9 App Store privacy details (summary)
Briz declares the following on its App Store product page: Purchase History, User ID, Device ID, Audio Data, Other User Content, Product Interaction and Performance Data — all linked to a random account identifier, none used for tracking, all collected only for app functionality. Audio and other Content is transmitted for processing and is not retained by us.
B1.10 California: categories of personal information (last 12 months)
identifiers (random account and device identifiers; a truncated hashed IP address); commercial information (purchase records and balance); internet or other electronic network activity (request log: kind of request, units, latency, status, language pair, app version); audio, electronic or similar information (Content, processed in real time and not retained by us). We do not collect sensitive personal information for the purpose of inferring characteristics about you, and we do not use or disclose it beyond what is necessary to provide the service you request.