Privacy Policy

1. Who is responsible for your data

The data controller is Semiconductor.no AS, Maristova 147, 6888 Borgund, Norway, org. no. 930103535, represented by CEO Adriana Marglewska. Contact for data matters: kontakt@sawada.love.

Sawada® is authored by Ada Margo Marglewska®, with Dominik Iwo Sawa as co-author of the concept; the company operates the service on their behalf.

2. What data we process

Account data: e-mail address, display name, account identifier and — when signing in with Google — data shared by Google.

Content you create yourselves: diary entries, photos, messages, time capsules, important dates, calendar tasks, favourites, secrets in the vault, music tracks and duo invitations.

Technical data: IP address, browser type and security logs, needed to detect abuse.

3. Why and on what basis (Article 6 GDPR)

Running the account and providing Sawada's features — performance of a contract, Article 6(1)(b).

Security, abuse prevention and accounting — legitimate interest and legal obligations, Article 6(1)(f) and (c).

Analytics and other non-essential cookies — solely on the basis of your consent, Article 6(1)(a). You can withdraw your consent at any time without affecting prior processing.

Intimate content in the vault and messages may constitute special category data (Article 9 GDPR) — we process it solely on the basis of your explicit consent, expressed by adding the content to your duo's private space.

4. Who has access

Only your duo can see your content. Access is restricted at the database level by security rules tied to your account.

Processors acting on our behalf: infrastructure and database provider (hosting in the EU or based on standard contractual clauses), the AI models provider used in the Secret Sawada AI feature, the music-generation provider, and the transactional e-mail provider. Each operates under a data processing agreement and only to the extent necessary to provide the service.

We do not sell your data and we do not use it for advertising profiling.

5. Transfers outside the EEA

If a provider processes data outside the European Economic Area, this takes place on the basis of an adequacy decision or the European Commission's standard contractual clauses, together with additional technical measures (encryption in transit and at rest).

6. How long we keep your data

Account data and content — until account deletion or a deletion request. Backups expire within 30 days.

Security logs — up to 12 months. Billing data — for the period required by tax law.

7. Your rights

You have the right to: access your data, rectification, erasure ("the right to be forgotten"), restriction of processing, data portability, objection to processing based on legitimate interest, and withdrawal of consent.

Sawada provides a PDF export of content in the Archive, the ritual calendar and Messages — this fulfils the right to data portability.

We fulfil requests within 30 days. You can also file a complaint with the President of the Personal Data Protection Office (UODO) or another competent authority in your country.

8. Children

Sawada is intended for adults. We do not create accounts for people under the age of 16.

9. Policy changes

We will inform you of material changes in the app and ask for renewed consent where required.

10. Automated decisions and AI

Sawada does not make decisions producing legal or similarly significant effects solely by automated means. AI features generate suggestions only; they do not replace professional, medical, psychological or legal advice.

When you intentionally use an AI feature, the content needed to answer may be sent to the model provider. Do not submit information you do not want processed for that purpose.

11. Security incidents

We assess personal-data incidents and notify the competent supervisory authority within 72 hours where GDPR requires it. If an incident is likely to create a high risk to you, we also inform affected people without undue delay.