Privacy Policy

Last updated: July 3, 2026

Frame is an iOS app that helps you read a dating conversation and choose your next message. You paste a conversation (as text or screenshots) and Frame returns a read of the situation and a suggested next move. Handling that kind of content carefully is the whole job, so this policy is written to be read, not skimmed past.

The short version: no account, no email, no real name. Frame identifies you only by a random ID. Conversations you submit are processed to generate your read, kept briefly so the app works, and deleted automatically. We never sell your data, never use it for advertising, and never allow it to be used to train AI models.

1. Who is responsible

The controller for data processing in connection with Frame is:

YANGOT Technologies UG (haftungsbeschränkt)
Fasanenstraße 67i
82008 Unterhaching, Germany
Managing director: Waldemar Panin
Email: frame@panin.de

2. What we collect and why

Anonymous account

When you first open Frame, the app creates an anonymous session with a randomly generated user ID. We do not ask for your name, email address, phone number, or any login. Everything below is linked only to that random ID.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Conversations you submit

The core feature. When you request a read, we process:

• the conversation text you paste, and/or
• screenshots you upload (up to 3 per read), from which we extract the message text.

Screenshots are processed to extract the conversation text and are not stored as images. Extracted transcripts and the reads generated from them are stored under your anonymous ID so the app can show you your results, and are deleted automatically after 30 days. You can delete them at any time before that (see section 6).

Conversations may include messages written by another person. We process this content solely on your request, solely to generate your read, with the short retention and no-training guarantees described here. Please only submit conversations you are personally part of.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR); for any third-party content, our legitimate interest in providing the service you requested (Art. 6(1)(f) GDPR), safeguarded by data minimisation, short retention, and no secondary use.

Onboarding answers and coaching memory

During onboarding you answer a few questions about your dating situation. Frame may also keep short coaching notes ("memory") so later reads have context. Both are stored under your anonymous ID and deleted when you delete your data.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Purchases

Subscriptions are bought through Apple and managed by RevenueCat, our subscription infrastructure provider. We receive your anonymous user ID, the product you bought, and the subscription status — never your payment details, which stay with Apple.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Usage analytics

We collect first-party product events (for example: onboarding step completed, read requested, error shown) to understand whether the app works and where it fails. These events are linked to your anonymous ID and never contain your conversation content, screenshots, or names. We do not use third-party advertising or tracking SDKs in the app, and we do not track you across other companies' apps or websites.

Legal basis: our legitimate interest in improving and securing the service (Art. 6(1)(f) GDPR).

Notifications

If you opt in to notifications, iOS handles the permission. You can turn them off any time in system settings.

Legal basis: your consent (Art. 6(1)(a) GDPR).

3. AI processing

Frame uses large language models to extract text from screenshots and to generate your read:

• Screenshot text extraction: Google Gemini API (Google LLC / Google Ireland Ltd.).
• Read generation: models accessed via OpenRouter, Inc., configured to deny data collection and require zero-data-retention routing — providers that would store or log your content are excluded.

Your conversations are sent to these providers only to generate your read, and are not used to train their models. We send only what is needed for the read; your anonymous ID is not shared as part of the model input.

4. Service providers

Where providers process data outside the EU/EEA, transfers rely on the EU–US Data Privacy Framework and/or the EU Standard Contractual Clauses (Art. 46 GDPR).

5. Retention

• Transcripts and reads: deleted automatically after 30 days.
• Screenshots: not stored; processed for text extraction only.
• Onboarding answers, coaching memory, analytics, purchase records: kept while your anonymous account exists, deleted when you delete your data.
• Records we are legally required to keep (e.g. for tax purposes) are retained for the statutory period.

6. Deleting your data

In the app, open Settings → Delete my Frame data. This permanently deletes your transcripts, reads, onboarding answers, coaching memory, analytics events, and credit records from our systems, and clears the app on your device. Because accounts are anonymous, there is nothing left that identifies you afterwards.

7. Your rights

Under the GDPR you have the right to access, rectify, and erase your personal data, to restrict or object to processing, and to data portability (Art. 15–21 GDPR). You can exercise most of these directly in the app; for anything else, email frame@panin.de. Note that because accounts are anonymous, we may be unable to link you to stored data unless the request comes from your app installation.

You also have the right to lodge a complaint with a supervisory authority, for example the Bavarian Data Protection Authority (BayLDA), Promenade 18, 91522 Ansbach, Germany.

8. Children

Frame is intended for adults and is not directed at anyone under 18. We do not knowingly process data of minors.

9. Changes

We will update this policy when our data practices change and post the new version here with an updated date. Material changes will be highlighted in the app.