Privacy, explained clearly.

1. What Sonelo does

This Privacy Policy explains how Gaja Ventures Limited (“Gaja”, “we”, “us”, or “our”) collects, uses, discloses, retains, and protects personal data when you use Sonelo, including its iPhone or Mac application, custom keyboard, website, and related services.

Gaja Ventures Limited is the data user under Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) and, where applicable, the controller or personal information processor under other privacy laws.

2. Personal data we process

Account information

Before sign-in, Sonelo creates a random installation identifier to operate and enforce the one-time 10-recording trial. It is not your name, email address, Apple Account identifier, or advertising identifier. We retain it with limited trial-usage metadata so the same installation cannot repeatedly restart the trial.

When you use Sign in with Apple, we receive:

• a private identifier assigned to Sonelo by Apple;
• your name, if you choose to provide it; and
• your email address or Apple private relay address, if you choose to provide one.

We never receive your Apple Account password. If other login methods are added, we may receive an equivalent provider identifier and verified profile details.

Voice and text content

When you request dictation or translation, we process the audio recording you submit, the transcript generated from it, and the translated text when translation mode is selected. Recordings may incidentally contain personal or sensitive information, so do not dictate information you do not want processed by Sonelo and its service providers.

Usage and product information

We store limited metadata needed to operate Free and paid plans and show your statistics:

• an internal request identifier;
• recording duration and file size;
• whether dictation or translation mode was used;
• processed word count and request date and time;
• monthly and lifetime usage totals;
• referral participation and reward-credit balances; and
• subscription plan, status, dates, and transaction references.

Sonelo does not store your audio, transcript, or translation in its account database.

Technical and security information

Our hosting and network providers may process information normally generated by internet services, such as IP address, request time, response status, device or browser information, and diagnostic logs. Sonelo application logs use request identifiers and error categories and are designed not to contain recordings, transcripts, or translations.

Information we do not request

Sonelo does not require your contacts, photos, precise location, health data, advertising identifier, or unrelated keyboard input. We do not use advertising SDKs or cross-app tracking.

3. Why we process personal data

We process personal data to:

• provide dictation and translation requested by you;
• authenticate and secure your account;
• return text to the Sonelo app or keyboard;
• enforce the anonymous trial, recording, and monthly usage limits;
• calculate account statistics and referral rewards;
• verify and administer subscriptions;
• diagnose failures, prevent abuse, and protect Sonelo;
• respond to support, access, correction, and deletion requests; and
• comply with applicable legal obligations.

Where applicable, processing is based on performing our service agreement with you, your consent, our legitimate interests in operating and securing Sonelo, and compliance with law. You may withdraw consent for future voice processing from Sonelo Settings. Withdrawal does not affect processing already lawfully completed.

4. Keyboard Full Access and microphone access

iOS requires Full Access for the Sonelo keyboard to communicate with its containing app and online service. Sonelo uses this access for its voice-command status and result handoff. It does not use Full Access to collect unrelated text you type.

The iPhone companion app uses microphone permission only when you deliberately start a Sonelo recording or maintain the clearly indicated, time-limited hands-free session. Idle hands-free audio is discarded locally and is not uploaded.

You can disable microphone permission, Full Access, or the Sonelo keyboard in system settings.

5. Service providers and disclosures

We disclose data only as needed to operate Sonelo, process payments, protect the service, comply with law, or complete a corporate transaction subject to appropriate safeguards.

Current service providers include:

• Apple: Sign in with Apple, app distribution, and subscription processing.
• Vercel: API hosting, network delivery, and short-lived operational logs. Sonelo’s production function is configured to run in Singapore, although Vercel and its infrastructure subprocessors may process service data in other locations under their applicable terms.
• Neon: managed PostgreSQL account database with its primary region in Singapore, including limited restore history and backups.
• OpenAI: speech transcription and text translation. Audio and relevant text are sent to the OpenAI API solely to complete your request.

OpenAI states that API data is not used to train its models unless the API customer affirmatively opts in. Under OpenAI’s standard API controls, abuse-monitoring data may be retained for up to 30 days unless a different approved retention control or legal requirement applies.

We do not sell or rent personal data. We do not disclose Sonelo content for third-party advertising or permit third parties to track you across unrelated apps and websites.

6. International and cross-border processing

Gaja Ventures Limited is based in Hong Kong. Sonelo’s database and primary API runtime are in Singapore, and Apple, Vercel, Neon, OpenAI, and their subprocessors may process data in other countries or regions.

We use contractual and organisational measures intended to require service providers to protect personal data consistently with this Policy and applicable law. Protections and government-access rules may differ between jurisdictions.

Users in Mainland China

If you use Sonelo in Mainland China, your personal information may be provided to recipients outside Mainland China, including Gaja Ventures Limited in Hong Kong and service providers operating in Singapore and other locations. Before voice content is transferred, Sonelo will request the consent required for this processing and cross-border transfer. The categories, recipients, purposes, and methods are described in Sections 2, 3, and 5.

Where Mainland law requires an additional security assessment, certification, standard contract, personal-information protection impact assessment, filing, or local representative, Gaja will complete the applicable measure before the relevant public processing begins.

Users in the EEA, United Kingdom, or Switzerland

Where applicable, international transfers are supported by recognised transfer mechanisms such as adequacy decisions, standard contractual clauses, the UK International Data Transfer Addendum, or another lawful safeguard. You may request information about the safeguard relevant to your data.

7. Retention and deletion

• Audio submitted to Sonelo: held in a temporary server file only while the request is processed and deleted when processing finishes or fails.
• Audio on your device: the submitted temporary recording is deleted after successful processing; unsubmitted or failed recordings remain under your control until cleared, replaced, or removed with the app.
• Transcript and translation: returned to your device and not stored in the Sonelo account database. The most recent result remains in Sonelo’s private shared app container until replaced or cleared.
• OpenAI API processing: subject to OpenAI’s applicable API retention controls, normally up to 30 days for abuse-monitoring data under standard settings.
• Account, usage, referral, and entitlement records: kept while your account remains active and deleted from the active Sonelo database when you use in-app account deletion, except where limited records must be retained for legal, fraud-prevention, payment, dispute, or security purposes.
• Operational logs: content-free request and error logs are retained for no longer than 30 days and may be available for a shorter period under the current hosting plan.
• Backups and restore history: deleted records may remain temporarily in encrypted provider backups or point-in-time restore history until those copies expire under the applicable provider schedule.

We retain legally required transaction, tax, dispute, and fraud-prevention records only for the applicable statutory or limitation period and restrict their use to those purposes.

Deleting Sonelo does not automatically cancel an App Store subscription. You can manage or cancel subscriptions through your Apple Account settings.

8. Your rights and choices

Subject to applicable law, you may ask us to confirm whether we hold personal data about you, provide access, correct inaccurate data, delete your account, restrict or object to particular processing, provide portable data where required, withdraw consent, or explain our data practices.

You can delete your Sonelo account in Sonelo Settings → Delete Sonelo account. You can clear the latest local result or withdraw voice-processing consent in Settings. We may need to verify your identity before completing a request.

Hong Kong users may exercise data-access and correction rights under the Personal Data (Privacy) Ordinance. Mainland China users may exercise applicable rights of access, copy, correction, deletion, restriction, withdrawal of consent, and account cancellation. EEA and UK users may also complain to their local supervisory authority.

9. Security

We use measures appropriate to the nature of Sonelo’s data, including encrypted HTTPS transport, server-side credentials, signed authentication tokens, restricted production access, database access controls, and deletion of temporary audio. No system can guarantee absolute security.

If a personal-data incident creates a notification obligation, we will notify affected users and authorities as required by applicable law.

10. Automated decisions

Sonelo uses automated speech recognition and translation to create requested text. It does not make decisions producing legal or similarly significant effects about you. Generated text may be inaccurate; review it before sending or relying on it.

11. Children

Sonelo is a general-audience productivity service and is not directed to children under 16. We do not knowingly create accounts for children below the age at which they can independently consent under applicable law. A parent or guardian who believes a child provided personal data should contact us.

12. Changes to this Policy

We may update this Policy when Sonelo, our providers, or legal requirements change. We will update the effective date and provide additional notice or seek new consent where required for a material change.

13. Contact Gaja Ventures Limited

Privacy questions, data requests, and complaints can be sent to: