Echoes
DRAFT. This page is a draft for review by a UK solicitor. It is not final and is not yet in force. Words in [square brackets] are still to be confirmed.

Echoes Privacy Policy

Date: 4 October 2026. Version: [privacy-v1-draft].

1. The short version

  • Your recordings and photos stay on your iPhone or iPad. They only leave it if you print, share or save a copy yourself.
  • Typing up your recordings happens on your iPhone or iPad. Your recordings are not sent anywhere for this.
  • When you talk with Ellie (the computer voice that asks the questions), or ask her for help, your words are sent to xAI (for her replies) and ElevenLabs (for her voice), two AI companies [xAI is in the United States; location of ElevenLabs' contracting company to verify]. This only happens if you say yes.
  • When you tap 'Send my details to Echoes', your contact details come to us.
  • We do not keep a copy of your stories. We have no adverts and no tracking.
  • You can ask us questions or complain at [email protected], or contact the ICO.

2. Who we are

Echoes App Ltd is responsible for your personal information in Echoes. In the law's words, we are the "controller": the organisation that decides why and how your information is used.

  • Company number: [company number]
  • Registered office: [registered office address]
  • Email: [email protected]
  • ICO registration number: [ICO registration number]

We have not appointed a Data Protection Officer, because the law does not require one for an organisation like ours [solicitor to confirm]. You can contact us about privacy at [email protected].

Personal information (the law says "personal data") means any information about a living person who can be identified from it.

3. What stays on your iPhone or iPad

These things are kept inside Echoes on your iPhone or iPad. We do not receive them:

  • your recordings;
  • the words typed up from your recordings, and words you type yourself;
  • your story titles;
  • your photos and videos (Ellie does not see them);
  • your chats with Ellie;
  • your profile (for example your name, and the name Ellie calls you);
  • your yes and no choices, with the date and the version of the words you saw.

Typing up uses Apple's speech recognition, set to work on the device only, and a program called Whisper, which also runs on the device.

Your stories only leave your iPhone or iPad:

  • if you print, share or save a copy yourself (for example through AirPrint, Messages, email or the Files app); then the copy goes where you choose;
  • in the cases listed in section 4.

iCloud: if your iPhone or iPad backs up to iCloud, Apple may keep a copy of Echoes, including your stories, as part of that backup. That is between you and Apple, under Apple's terms. Whether the backup is end-to-end encrypted depends on your Apple settings and on what Apple offers in the UK.

4. What leaves your iPhone or iPad, who gets it, and why

When What is sent Who gets it Why Our legal reason ("lawful basis")
You talk with Ellie, or ask her for help in the Help tab What you say or type; the last ten lines of your chat; the question you are answering; the name Ellie calls you; the titles and words of up to three of your stories xAI, which runs the Grok AI service (United States) So Ellie can write her reply Your consent. For health, beliefs and similar details, your explicit consent (see section 6)
You tap 'Auto proof read' The words of that one story xAI (Grok) To tidy spelling and punctuation Your consent and explicit consent (the same yes)
Ellie speaks Ellie's words, which can include your name or things you said ElevenLabs (voice "Jessica") To turn her words into speech Your consent and explicit consent (the same yes)
You tap 'Send my details to Echoes' in Settings Your name, email, birthday, address, mobile number, the name Ellie calls you, and the date you started Us, carried by a form service called FormSubmit [operator and country, to verify] to our email [email provider, to confirm] So we can contact you about your book. Your birthday is used [purpose, for example to print your date of birth in your book; see 'Your birthday' below] Steps you asked us to take before a contract
As above, if the form does not work The same details, in an email your own Mail app fills in. You choose whether to send it Us, through your own email provider As above As above
The first time Echoes types up a recording with Whisper Nothing of yours. Echoes downloads a 148 MB file. The download site sees your device's internet address, as any website does Hugging Face (huggingface.co), which hosts the file To get the typing-up program Our legitimate interests in making typing-up work (Hugging Face uses the address under its own policy)
Before Ellie talks A connection check with none of your information xAI and ElevenLabs To check Ellie can work Not personal information beyond your device's internet address
You order a printed book (when ordering opens) The stories, words and photos you choose for the book; your name; your delivery address; your email Us and [print partner name and country] To make and deliver your book Contract. Your explicit consent for health, beliefs and similar details in the book
You pay for a printed book (when ordering opens) Card or payment details, name, billing address, email Us (Echoes App Ltd takes the payment), through our payment provider [payment provider name and country]. We do not see or keep your full card number [verify with the chosen provider] To take payment and keep records Contract; legal obligation (tax records). The payment provider also uses some details for its own legal duties, such as preventing fraud, under its own privacy policy [verify]
You subscribe Payment and purchase details Apple, which runs the App Store To sell and manage your subscription Apple's own terms. Apple tells us that a purchase was made, but not your name or card details [verify]
You have chosen in your Apple settings to share analytics with app developers Crash reports from Apple Us, from Apple To fix problems Our legitimate interests in fixing faults [verify what Apple's reports contain]

Your birthday

  • Echoes asks for your birthday because your date of birth is a key fact in a life story.
  • We use it only [purpose, for example to print your date of birth in your book; confirm exactly where it is used].
  • It stays on your iPhone or iPad until you tap 'Send my details to Echoes'. Then it comes to us with your other details.
  • It is not sent to xAI or ElevenLabs.
  • Giving your birthday is [optional: confirm the app lets you leave it blank, and that nothing else stops working if you do]. If you leave it out, [what happens, for example your book is printed without it].
  • Our legal reason: steps you asked us to take before a contract (making your book) [solicitor to confirm; consent is the alternative if it is truly optional].
  • We keep it only as long as your other contact details (section 8).
  • [Design note for minimisation: consider sending the birthday only with a book order that needs it, not with every 'Send my details', and offering year only if the full date is not needed.]

What we do not do

  • We do not have adverts.
  • We do not track you across other apps or websites.
  • We do not use analytics tools in the app.
  • We do not sell your information.
  • We do not use your stories to train AI.

What xAI and ElevenLabs do with what they receive

  • They act as our suppliers ("processors": companies that handle information only on our instructions) [to verify that their API terms make them processors].
  • How long they keep it: [to verify from their API terms].
  • Whether they use it to improve or train their systems: [to verify from their API terms].
  • We will update this section with their verified terms before Echoes is released.

Notifications. Any reminders Echoes shows are created on your iPhone or iPad. They do not send your information anywhere.

5. Why we need your yes before Ellie can talk

Apple's rules, and the law, require us to tell you clearly before your words go to an AI company, and to ask for your permission. Echoes asks:

Send my words so Ellie can answer. Ellie needs the internet to answer you. When you talk with her, or ask her for help, what you say is sent to Grok, a service run by xAI, a company in the United States. With it go the last ten lines of your chat, the question you are answering, the name she calls you, and the titles and words of up to three of your earlier stories. Her reply is sent to ElevenLabs so it can be spoken out loud. 'Auto proof read' also sends the words of that story to Grok. Your stories may mention your health, your beliefs or other people. Only share what you are happy to send. Your recordings are not sent. Typing up happens on this iPhone or iPad. If you say no, you can still record, write, play and print. Only talking with Ellie and 'Auto proof read' are turned off. [Yes, I agree] [Not now]

You can change your mind at any time in [Settings, then Legal]. Turning it off stops future sending. It does not undo what was sent before.

6. Sensitive information ("special category data")

  • Life stories often include health, religion or beliefs, sexuality, ethnic origin, political views or trade union membership. The law calls these "special category data". They may also include crimes.
  • Your own sensitive details: we only send them to xAI and ElevenLabs with your explicit consent: the clear yes in section 5, which names them. For printed books, we ask again on the order screen.
  • Other people's details: your stories will mention other people, including family, friends, children, and people who have died. They have not chosen Echoes.
  • We keep what we receive to a minimum. We do not keep copies of your stories, and we do not share them for any other purpose.
  • Please think about other people before you share their private details, especially with Ellie or in a printed book.
  • If you are mentioned in someone's story and are worried, contact us at [email protected]. In most cases we do not hold the story, but we will explain what we can do.

7. Sending information outside the UK

xAI and ElevenLabs are in the United States [ElevenLabs contracting entity and location, to verify]. FormSubmit: [to verify]. When your information goes outside the UK, we make sure the law's safeguards apply:

  • for a US company certified under the UK Extension to the EU-US Data Privacy Framework (the "UK-US data bridge"), we rely on the UK's adequacy regulations [to verify which suppliers are certified];
  • otherwise, we use the UK's International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses, with a risk assessment.

You can ask us for details at [email protected].

8. How long information is kept

Information Where How long
Your stories, recordings, photos, profile and choices Your iPhone or iPad Until you delete them, use [Delete everything], or delete Echoes
Words sent to xAI and ElevenLabs Their systems [To verify from their API terms]
Details sent with 'Send my details to Echoes' Our email Up to [24] months after we last hear from you, unless you order a book
Book content sent for printing (when ordering opens) Us and [print partner] Deleted within [30] days after your book is delivered, unless you ask for a reprint
Order and payment records Us and [payment provider] [6] years, for tax and legal claims
Complaints and requests about your rights Us [3] years after we close them

9. Your rights

You have the right to:

  • ask for a copy of the personal information we hold about you;
  • ask us to correct information that is wrong;
  • ask us to delete your information;
  • ask us to limit how we use it, or object to how we use it;
  • get your information in a form you can take elsewhere (most of your stories are already on your iPhone or iPad, and you can export them with [export button, exact label]. If your subscription has ended, the Terms of Service section 7 explains which stories can be exported. [Solicitor note: if Echoes is a controller of on-device data, rights requests must be free of charge (Art 12(5)). Locking export behind a subscription is then a risk. The safer variant in the Terms avoids it.]);
  • withdraw your consent at any time, as easily as you gave it, in [Settings, then Legal].

Things to know

  • We do not hold most of your information. It is on your iPhone or iPad.
  • To delete it all, use [Delete everything] or delete Echoes.
  • Deleting Echoes does not delete copies you printed, shared or saved yourself, and it does not cancel an Apple subscription.
  • For words already sent to xAI or ElevenLabs, and details you sent us, email [email protected]. We will delete what we hold, and ask xAI and ElevenLabs to delete theirs as far as their terms allow [to verify].
  • We will reply within one month. If a request is complex, we may take up to two months more and will tell you why. We may need to check who you are.

10. Complaints

  • If you are unhappy with how we use your information, please tell us first at [email protected] or [postal address].
  • We will acknowledge your complaint within [5 working days] (the law allows up to 30 days), look into it without undue delay, and tell you the outcome.
  • You can also complain to the Information Commissioner's Office (ICO), the UK regulator: ico.org.uk, 0303 123 1113.

11. If you die

  • The law on personal information protects living people. After you die, your stories are still on your iPhone or iPad. We do not keep a copy and cannot open your device.
  • If we hold your details (for example for a book order), we will deal with your executor or personal representative when they give us proof. We will still protect information about living people in your stories.
  • Our After-Death and Voice Keepsake Policy has more detail [link when live].

12. Children

  • Echoes is for adults aged 18 and over. We do not knowingly collect information from children.
  • Stories and photos may include children. Please take extra care before you share or print them.
  • If you think a child has used Echoes and sent us information, contact us and we will delete it.

13. Cookies and tracking

  • Echoes does not use cookies, advertising identifiers or tracking tools.
  • It stores on your iPhone or iPad only what it needs to work: your stories, settings and choices.
  • The printed and Interactive book pages use fonts built into the app, so opening them does not contact anyone else.

14. Keeping your information secure

  • Information sent from Echoes uses encrypted connections [verify HTTPS for every request, including FormSubmit].
  • Your stories on your iPhone or iPad are protected by your device's passcode and Apple's security.
  • Our email account is protected with two-step sign-in [confirm].
  • If something goes wrong that puts your information at risk, we will tell the ICO within 72 hours where the law requires it, and tell you if the risk to you is high.

15. Changes and new features

Changes to this policy. We may update this policy, for example:

  • if the law changes;
  • if we change a supplier who does the same job;
  • if we improve security;
  • if we add a feature.

The date at the top will change. For important changes, we will show a note in Echoes before the change starts.

New features that need your yes. We will not use this policy, or a change to it, to start using your information in a new way without asking you. Before any of these happen, we will explain the change in Echoes and ask for your yes:

  • keeping copies of your recordings, typed-up words or photos on our computers ("in the cloud");
  • sharing your stories with other people through Echoes;
  • short stories shared with friends (a possible future feature);
  • making a copy of anyone's voice;
  • a new company receiving your stories for a different job;
  • using your stories to train or improve AI;
  • any new use of sensitive details;
  • letting people under 18 use Echoes.

You can say [Yes, I agree] or [Not now]. If you say no, only that new feature is turned off. Everything else keeps working.

What we only need to tell you about. We may make some changes with a notice only, because they do not change what happens to your stories. For example:

  • replacing a supplier with another that does the same job, under the same protections;
  • improving security;
  • correcting this policy.

"Tell me when new features need your yes." In [Settings, then Legal] you can choose to see a short note in Echoes when a new feature needs your yes. This is only a reminder setting. It does not agree to any new feature, and nothing is sent. If you also choose to hear from us by email, we will only email you about new Echoes features if you have said yes to that, and you can stop at any time.

16. Contact

  • Echoes App Ltd, [registered office address].
  • Email: [email protected].
  • Full policy online: [privacy policy web address, only once live].

End of draft Privacy Policy. Version [privacy-v1-draft], 4 October 2026.