Privacy Policy

Who is responsible

Vits Consulting UG (haftungsbeschränkt), Germany is the data controller for the personal data described here, for the purposes of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the UAE Federal Decree-Law No. 45 of 2021 ("UAE PDPL").

• Registered address: Meisenstrasse 6, 40789 Monheim am Rhein, Germany
• Register: Amtsgericht Düsseldorf, HRB 90410
• Managing director: Thomas Vits
• VAT ID: DE333840324
• Privacy contact: privacy@murmur.mobi
• Contact form: https://murmur.mobi/contact

How this policy works

This is a notice, not a contract. We are telling you what happens to your data so you can decide what to do about it - we are not asking you to consent to it, and nothing here is conditional on your agreeing with it.

That distinction matters in practice. Most of what Murmur does with your data is done because you asked for the service, not because you ticked a box, so there is no consent for you to withdraw and no way for a withdrawal to leave the app half-working. Where we genuinely do need your consent, we ask for it separately and plainly, and you can take it back.

The separate agreement you do enter into is the Terms of Service, which you accept when you create an account.

What we collect

• Birth data - the date, time and place you enter, and the coordinates and timezone we derive from the place. This is the most identifying thing we hold, and it is the only thing the app cannot work without.
• Your account - an identifier from Apple or Google, or an email address if you use a sign-in link. We never receive or store a password. We never ask you for a name, a username, or a phone number. If Apple or Google sends us a first name with your sign-in, we keep it only to greet you by and use it for nothing else - Apple lets you withhold it, and a sign-in link carries no name at all.
• Your settings - voice tone, astrological tradition, language, reminder times, ambient sound.
• What you write - the messages you send to Murmur, anything you write in a reflection, and the mood you pick when you check in.
• Derived notes - short, one-sentence facts Murmur infers from your conversations so it can remember you between sessions, categorised internally as things like a recurring emotional pattern, a relationship, or a life event. These are inferences about you rather than quotes, and they are the most sensitive thing the app holds - which is why, since August 2026, they are stored only on your own phone. The model writes them; we do not keep a copy. Delete the app and they go with it.
• Usage counts - how many messages and requests you make per day and an approximate token count, which is what enforces your plan's allowance. It is a count, not content.
• Subscription status - whether you have Murmur Pro, and when it renews or lapses.
• Readings we generated for you, cached so that opening the same day twice does not regenerate it.

Analytics and crash reports

Murmur uses PostHog to understand, in aggregate, how the app is used and to learn when it crashes. It runs on PostHog's European Union infrastructure in Frankfurt. This exists so we can fix what breaks and improve what confuses; it is not advertising, and nothing it collects is sold or shared.

What it records: that the app was installed, opened or updated; the product moments we explicitly instrument, by name only - for example that onboarding was completed, never what you typed while completing it; your device model, operating system version and app version; a coarse location derived from your IP address (country and city, never GPS); and, when the app crashes, a technical report of where in the code it happened.

What it never receives: your birth data, your messages and reflections, your derived notes, your readings, your mood check-ins. The words you write do not go to PostHog.

These records are tied to the same account identifier as the rest of the service. That is deliberate: it means "Delete my account" erases your analytics history too, events included, rather than leaving an orphaned profile behind.

We rely on our legitimate interest in running a stable, comprehensible app (GDPR Art. 6(1)(f); KVKK Art. 5/2-f). PostHog acts as our processor under a data-processing agreement and may not use any of it for its own purposes.

When you write to us

The contact form on murmur.mobi sends us your message, the email address you give us, and a name if you enter one. Nothing else: the form sets no cookies, runs no analytics, and loads nothing from a third party, so there is nothing on that page to consent to.

We use it to answer you - our legitimate interest in responding to the people who contact us (Art. 6(1)(f) GDPR), or, where your message is about becoming or being a customer, to take steps in connection with that contract (Art. 6(1)(b) GDPR).

Your message arrives as an email in our own inbox and is kept while the matter is open, then deleted - unless German commercial or tax law requires us to keep that correspondence longer.

Writing to hello@murmur.mobi or privacy@murmur.mobi reaches the same inbox and is treated the same way.

What we do not collect

Murmur contains no advertising SDK and no cross-app or cross-site tracking. We do not read your advertising identifier, we do not profile you for advertising, and we do not sell or share your data with data brokers - so there is no tracking permission to ask you for. The analytics described above is the whole of our telemetry; there is nothing else.

The one unavoidable exception: like any internet service, our hosting provider sees the IP address a request arrives from, and uses it transiently for security and rate limiting. We do not build profiles from it.

We send no marketing email and operate no mailing list. The only messages you get from us are the reminders you schedule yourself, which are scheduled on your device - we hold no push token and cannot send you anything you did not ask for.

We do not ask for and do not want health data. Murmur is not a medical or mental-health service and does not diagnose, treat or advise on any condition. If you write something about your health it is processed as ordinary message content - but please do not use Murmur as a place to record a clinical history.

Sensitive and special-category data

Some of what you share may reveal, or be used to infer, information treated as a special category of personal data under the GDPR and UK GDPR, or as "special-quality" personal data under the KVKK - for example, that you engage with astrology at all may say something about your philosophical or religious beliefs, and reflective writing can touch on emotional wellbeing.

We process this content solely to provide the reflective and astrological features you asked for, we do not use it for any other purpose, and we do not share it with anyone except the processors named below. Where the law requires your explicit consent for this, we ask for it separately rather than burying it here, and you can withdraw it without deleting your account.

Your sign-in credentials are treated as sensitive and protected accordingly.

Where your conversations go

This is the part most easily missed, so it is stated plainly: the words you write to Murmur leave your device.

Every message, reading and interpretation is sent through our own server to Infercom, the AI provider that generates the reply. Along with your message we send the parts of your chart the model needs to answer, today's sky, and any derived notes your phone has stored. The app never talks to the AI provider directly and never holds a key to it. Infercom processes this to produce a reply, acts as our processor under contract, and is not permitted to use it for its own purposes or to train models on it.

We do not keep your conversation on our servers. Your transcripts are stored in a database on your own phone; if you delete the app, they go with it. What survives on our side is the usage counts. The derived notes described above are stored on your phone too, alongside the transcripts.

You can also talk to Murmur during onboarding, before you create an account. To do that the app signs you in anonymously so the same protections and limits apply; that anonymous record carries no name or email, and it is replaced when you sign in properly.

Why we are allowed to

• To give you the service you asked for - your birth data, settings, conversations, readings and derived notes are processed to perform our contract with you (GDPR Art. 6(1)(b); KVKK Art. 5/2-c). Without them there is no chart and no conversation.
• To keep the service working and affordable - usage counts, security and abuse prevention rest on our legitimate interest in running a service that a handful of users cannot exhaust, where that does not override your rights (GDPR Art. 6(1)(f); KVKK Art. 5/2-f).
• To meet our obligations - billing and tax records are kept because the law requires it (GDPR Art. 6(1)(c); KVKK Art. 5/2-ç).
• Explicit consent - only where a special category of data genuinely requires it (GDPR Art. 9(2)(a); KVKK Art. 6). Asked for separately, and withdrawable at any time.

Who else touches it

The complete list of processors:

• Supabase - hosts our database, authentication and server functions in the European Union.
• Infercom - generates every AI reply, as described above.
• RevenueCat, with Apple and Google - handle subscriptions. Your payment details go to Apple or Google and never reach us; we only learn whether you are subscribed.
• PostHog - collects the analytics events and crash reports described above, on European Union infrastructure.
• Mailgun - delivers the sign-in link when you choose to sign in with an email address. It receives your email address and that one message, on European Union infrastructure, and nothing else.

Each acts on our instructions under a data-processing agreement, and none may use your data for their own purposes. We do not use content-moderation or email-marketing vendors, because we do not use those services at all - the only email we ever send you is the one that signs you in.

We may also disclose personal data to public authorities where we are legally required to, and to a counterparty in a merger, acquisition or insolvency - in which case we will tell you before your data moves.

International transfers

Our database and server functions run in the European Union, and analytics and crash data stay there too, on PostHog's Frankfurt infrastructure - as do sign-in emails, which Mailgun sends from its European Union region. The AI provider that generates replies processes data outside the European Economic Area, which means your messages cross a border.

For transfers from the EEA and the UK we rely on the European Commission's Standard Contractual Clauses and the UK's International Data Transfer Agreement respectively.

For transfers of data of users in Türkiye we rely on a standard contract under Article 9 of the KVKK, notified to the Personal Data Protection Authority as that article requires. Since 1 September 2024, explicit consent is no longer available as a standing basis for routine international transfers under Turkish law, which is why we do not ask you for it.

Security, storage and how long we keep it

We use technical and organisational measures designed to protect your data against loss, alteration and unauthorised access. No service can promise perfect security, and we do not.

Your account, chart and settings are kept for as long as your account exists, and are deleted with it. Your derived notes are not kept by us at all: they sit on your phone, and deleting your account clears them from it. Cached readings are kept while they are useful and cleared with your account. Usage counts are kept for a rolling period sufficient to enforce daily and monthly allowances, then aggregated or deleted. Analytics events and crash reports are kept while they remain useful for spotting trends and regressions, and are erased with your account. Records we must keep for tax or accounting reasons are kept for the statutory period after account deletion, and for nothing else.

Deleting your account, and taking your data with you

Both are buttons in the app, not requests you have to make of us.

Open Profile → Privacy & data. "Export my data" sends you a copy of everything we hold. "Delete my account" removes your account and everything attached to it; you confirm once, and it cannot be undone.

Deleting your account does not cancel a subscription. Apple or Google keep billing you until you cancel it in the App Store or Google Play.

If you cannot reach the app, email privacy@murmur.mobi with the subject "Delete my account" from the address linked to your account.

Your rights under the KVKK (Türkiye)

Under Article 11 of the KVKK you may:

• Learn whether your personal data is being processed;
• Request information about the processing if it has been;
• Learn the purpose of the processing and whether it is used in accordance with that purpose;
• Know the third parties, in Türkiye or abroad, to whom your data is transferred;
• Request correction of incomplete or inaccurate data;
• Request erasure or destruction within the conditions of Article 7;
• Request that any correction, erasure or destruction be notified to third parties the data was transferred to;
• Object to a result reached against you by exclusively automated analysis of your data; and
• Claim compensation for damage arising from unlawful processing.

Apply in writing to our representative in Türkiye at the address above, or by the other secure methods recognised under the KVKK and the Communiqué on the Procedures and Principles of Application to the Data Controller. We will conclude your request as soon as possible and within thirty (30) days at the latest. If you are not satisfied, you may complain to the Kişisel Verileri Koruma Kurumu.

Your rights under the GDPR and UK GDPR

If you are in the EEA, the UK or Switzerland you may access your data, correct it, have it erased, restrict or object to how it is used, receive a portable copy, and withdraw any consent you have given.

Write to privacy@murmur.mobi saying which right you want to exercise; we may need to verify your identity first. You can also complain to your local supervisory authority - in Germany, the Bayerisches Landesamt für Datenschutzaufsicht; in the UK, the Information Commissioner's Office - though we would rather you gave us the chance to fix it first.

Your rights under the UAE PDPL

If you are in the United Arab Emirates you may, subject to the conditions in the law, request information about the categories and purposes of processing, access and a copy of your data, correction of inaccurate data, deletion, restriction or cessation of processing, portability where technically feasible, and object to automated decision-making that significantly affects you.

Write to privacy@murmur.mobi. If you are not satisfied with our response you may complain to the UAE Data Office.

Age

Murmur is for people aged 16 and over, and is not directed to children. We ask for a birth date on the first screen and stop there if it is under 16 - nothing entered is saved. If you believe a child has an account anyway, write to us and we will remove it.

Changes

If we change how we handle your data in a way that matters, we will tell you in the app before the change takes effect rather than quietly updating this page. The date at the top always reflects the version you are reading.

Questions: privacy@murmur.mobi.