Privacy Policy

1. Data Controller

The data controller is EightyFourNow, a sole proprietorship run by Cristiano Saggin, based in Llançà (Girona), Spain. For any privacy-related request, please write to support@eightyfournow.com.

2. Scope

This policy governs the processing of personal data collected through the website eightyfournow.com and through the mobile application Hearo — Life Memos ("the App").

3. Data collected on the website

The eightyfournow.com website does not use profiling cookies or third-party tracking tools. We only process data that users voluntarily choose to share via email (e.g. consulting requests), along with the minimal technical logs automatically generated by the hosting infrastructure (Firebase Hosting / Google Cloud) for security and service operation purposes.

4. Data processed by the Hearo App

Hearo is designed following the privacy by design principle. Voice memos can be processed in two distinct modes, chosen by the user:

• • Local processing (on-device): the free transcription engine processes audio directly on the user's device. Voice data is never transmitted to any external server.
• • Cloud processing (optional): for longer or more complex memos, users can choose to use cloud processing via Google Cloud Vertex AI (Gemini models). Content sent to the cloud is transmitted securely (encryption in transit), is never used to train artificial intelligence models, and is retained only for as long as necessary to provide the service.

5. Third-party services

The App relies on the following data sub-processors:

6. Legal basis for processing

Data processing is based, depending on the case, on user consent, performance of the service agreement (Terms of Service), and the controller's legitimate interest in ensuring the security and proper operation of the website and the App.

7. Data retention

Personal data is retained only for as long as strictly necessary to provide the requested service or to comply with legal obligations. Voice memos processed in the cloud are deleted from servers after processing is complete, unless the user has chosen a different configuration within the App.

8. Your rights (GDPR)

As a data subject, you have the right to:

• • Access your personal data
• • Rectify inaccurate data
• • Erasure ("right to be forgotten")
• • Data portability
• • Object to processing
• • Withdraw consent at any time

To exercise these rights, including deleting your account and associated data directly from the App (Settings → Delete Account) or by writing to support@eightyfournow.com.

9. International data transfers

Some providers (Google Cloud / Firebase) may process data on servers located outside the European Economic Area. In such cases, the transfer is governed by Standard Contractual Clauses approved by the European Commission or other appropriate safeguards provided for under the GDPR.

10. Children

Our services are not directed at children under 16, and we do not knowingly collect personal data from minors without the consent of a parent or guardian.

11. Complaints

You have the right to lodge a complaint with the competent supervisory authority, in particular the Agencia Española de Protección de Datos (AEPD), if you believe the processing of your data violates applicable regulations.

12. Changes to this policy

This policy may be updated periodically. Material changes will be communicated via notice on the website or within the App.