Privacy Policy

In accordance with Art. 13, 14 GDPR · Status: October 2026 · Version 1.3

1. Controller

Fabian Paulik
Nikolaus-Lenau-Str. 14
85757 Karlsfeld, Germany

Email: hello@perrenixapp.com
Website: perrenixapp.com

2. Which data we process and why

2.1 Registration and account

An account is required to use Perrenix. We process the following data:

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

2.2 Two-factor authentication (2FA)

Perrenix optionally offers SMS-based two-factor authentication to secure your account. When activated, we process:

The phone number is processed via Firebase Authentication (Google LLC) and forwarded to the respective SMS provider for SMS delivery.

When an SMS is sent, Google reCAPTCHA (Google LLC) runs an invisible check in the background to make sure the request comes from a person and not from an automated attack. Google processes technical data about your device and browser for this, such as your IP address. Legal basis for this check: Art. 6(1)(f) GDPR (protection against misuse).

Two-factor authentication is required for the “Everyone” level (see 2.7), so that every persona in “Discover” is backed by a real phone number.

Legal basis: Art. 6 para. 1 lit. a GDPR (consent through activation)

2.3 Reflection content and entries

The core purpose of Perrenix is personal self-reflection. For this we process:

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

2.4 Points system

Perrenix uses a points system for motivation. Points are awarded automatically for activities such as answering questions, daily login, or adding photos. We store the points balance and a log of the last 100 point awards.

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

2.5 Health data (special categories pursuant to Art. 9 GDPR)

Sensitive data: Perrenix offers a separate Health tab with questions about allergies, illnesses, medications, and family medical history. This data qualifies as health data within the meaning of Art. 9 GDPR.

Processing takes place exclusively on the basis of your explicit consent (Art. 9 para. 2 lit. a GDPR). This is obtained separately when you first open the Health tab via an active checkbox.

Until your legacy is released, only you can see your health answers. They are never used for your AI persona and never sent to Google Gemini. Only if you explicitly choose this can they be read after the release – exclusively by the people you have marked as family in your circle of trust (see 2.7). This disclosure is also based on your explicit consent (Art. 9(2)(a) GDPR). You can withdraw your consent at any time.

2.6 Ancestry research

In the Ancestry tab you can write free-text entries about your family history and add documents (e.g. images or PDFs). We store:

Ancestry data is always private — not visible to others, not even after your legacy is released. The only exception are places that you release to your shared family tree yourself (see 2.10).

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

2.7 Legacy and release

As long as you use Perrenix, nobody but you sees your answers and your persona. In the “Legacy” area you decide who may see what after a release. Without your setting, nothing is released.

Life story and persona – three levels:

Health is set separately: “Nobody” or “Family only”. With “Family only”, after the release only the people you have marked as family in your circle of trust can read your health answers – never through the persona (see 2.5).

When a release happens – in two ways:

If a release happened by mistake while you are still alive, you can take it back in the app (“Undo the release”).

What becomes visible after the release – depending on your settings:

Data we process for this – including data of other people:

To prevent misuse, wrong code entries (at most 10 per day and profile) and requests (at most 5 per profile and 3 per email address within 24 hours) are limited. In the profile we create at the release, we store the email addresses of authorised people only as a hash, not in plain text. Finished requests (stopped or released), including the requester’s name and email address, are deleted 90 days after the request date.

Legal basis: Art. 6(1)(a) GDPR (your consent through your settings) and, for health answers, Art. 9(2)(a) GDPR. For the data of your trusted contacts and of requesting persons: Art. 6(1)(f) GDPR (legitimate interest in carrying out your wishes and checking requests securely).

2.8 AI features (Google Gemini)

Perrenix offers an AI companion, an AI persona and a persona search under “Discover”. The following applies:

Legal basis: Art. 6(1)(a) GDPR (your explicit consent in the app; you can withdraw it at any time and keep using Perrenix without AI)

2.9 Shared family tree

You can maintain a family tree together with relatives. Anyone who joins such a group can see the people and family relationships in the shared tree, as well as the names of the other members.

Legal basis: Art. 6(1)(a) GDPR (consent by creating or joining a group)

2.10 Places and place search

You can assign a place to a memory and release that place individually to your shared family tree.

Legal basis: Art. 6(1)(a) GDPR (consent by actively triggering the search or by releasing a place)

2.11 Voice and appearance (voice, photo and video recordings)

You can voluntarily save recordings of your voice as well as photos and videos of yourself. They serve exclusively as material so that an AI can later recreate your voice and appearance.

Legal basis: Art. 6(1)(a) GDPR and, insofar as biometric data is concerned, Art. 9(2)(a) GDPR (explicit consent, separate from the consent to the AI Persona)

2.12 Website

Our website perrenixapp.com is hosted by Netlify, Inc. (USA). When you visit it, Netlify processes technically necessary data in server logs – such as your IP address, date and time, the page requested and browser information – to deliver the website and keep it secure. These logs are kept only for a short time.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure, working website)

3. Data transfer and storage location

ServiceProviderPurposeLocation
Firebase FirestoreGoogle LLCData storageEU
Firebase AuthGoogle LLCAuthentication, 2FAEU
Firebase Cloud FunctionsGoogle LLCBackend logicEU (europe-west1)
Cloud Storage for FirebaseGoogle LLCVoice and image recordingsEU (europe-west1)
Google Gemini APIGoogle LLCAI features (companion, persona, search)USA¹
Google reCAPTCHAGoogle LLCProtection against misuse when sending SMS (2FA)USA¹
Zoho MailZoho Corporation B.V. (Netherlands)Sending emails (reminders, requests, releases, legacy letter)EU
NetlifyNetlify, Inc.Website hostingUSA¹
NominatimOpenStreetMap FoundationPlace search (only on your input)United Kingdom²

¹ For transfers to the USA we rely on the EU Standard Contractual Clauses (SCC) and the EU-US Data Privacy Framework.

² The United Kingdom is covered by an adequacy decision of the EU Commission, so no separate safeguard is required. Only the search term you enter and your IP address are transmitted — never the content of your entries.

No analytics: Perrenix currently does not use Firebase Analytics and does not set any analytics cookies. Should this change in the future, your consent will be obtained in advance.

4. Storage duration

5. Your rights

Contact: hello@perrenixapp.com

Competent supervisory authority: Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 27, 91522 Ansbach, Germany, www.lda.bayern.de

6. Data processing agreements

Google LLC (Firebase and Gemini API) — DPA via the Firebase Data Processing Terms.

Zoho Corporation B.V. (Zoho Mail) — data processing agreement in accordance with Art. 28 GDPR.

No selling of your data, no ads; data is only transferred to the services listed in section 3 and to the people you choose yourself.

7. Data security

8. Death of the user and digital legacy

Note: Perrenix is not a legally valid will and does not replace a notarised last will and testament.

The release of your legacy (after inactivity or after a request with your unlock code) is carried out to the best of our technical ability, but without guarantee. Heirs may request account access by providing a death certificate and certificate of inheritance. Relatives may request complete deletion.

9. Children and minors

Perrenix is intended exclusively for persons aged 18 and over.

10. Automated decision-making

Perrenix does not make any automated decisions with legal effect (no profiling within the meaning of Art. 22 GDPR). The AI companion serves exclusively as a conversational partner.

11. Changes

Material changes will be communicated by email or via in-app notification.