Privacy Policy

Telepon

Last updated: September 29, 2026

SAAC sp. z o.o. ("we", "us", or "our") operates Telepon, an AAC (augmentative and alternative communication) messenger. Telepon consists of two mobile applications:

Telepon for caregivers (Android and iOS) — used by parents, family members, therapists and other caregivers;
Telepon for wards (Android) — used by the people they support ("wards"), who communicate with pictograms. A ward's profile is always set up and managed by a caregiver.

This Privacy Policy explains what personal data we process when you use Telepon, why, and what rights you have. We are the controller of this data.

1. Information We Collect

1.1 Caregiver account

Phone number — used to create your account and to log in with a one-time code sent by SMS. We do not use passwords.
Name you choose to display to other members of your groups.
Profile photo — optional, taken with the camera or chosen from your photo library.
Language of the app.

1.2 Ward profile

A ward does not register or enter personal data. The ward's device is paired with the caregiver's account using a one-time code, and the caregiver gives the ward's profile a name. For a ward's profile we process:

the name given by the caregiver;
settings chosen by the caregiver, such as voice type and display settings;
a communication level, which our team may set to adapt the vocabulary of pictograms to the ward's needs.

1.3 Messages and content

Messages — pictogram messages and text messages (written by caregivers) exchanged between members of a group, together with the conversation history.
Pictogram boards — the ward's boards, folders and symbols, and statistics of how often symbols are used.
Photos for creating pictograms — when a caregiver photographs a paper board or objects to create new pictograms, the photos are stored so the import can be completed and reviewed.
Voice input — when a caregiver dictates a message, the recording is sent for transcription and translation into pictograms. The recording itself is not stored.

1.4 Device and technical information

device identifier, device model, operating system and app version;
push notification token, so we can notify you about new messages;
online status and last-seen time, shown to members of your groups;
diagnostic logs — app events, errors and response times, linked to your account and device. We do not put message content, names, phone numbers or login codes in these logs.

1.5 Analytics and session recordings

Both apps use PostHog to understand how Telepon is used and to find and fix problems. PostHog receives usage events and device information, linked to your account identifier.

Both apps also record sessions: a recording of what is displayed on the screen while the app is in use. Because Telepon is a communication app, a recording may include what was on the screen at that time — messages, pictograms, names and profile photos. Login codes and invitation codes are hidden in recordings. Recordings are used only by our team to diagnose problems and improve the app, and are automatically deleted after a limited retention period.

1.6 What we do not collect

We do not collect your precise location or your phone's contacts. We do not show ads and we do not use the advertising identifier. The camera, photo library and microphone are used only when you choose to use a feature that needs them (profile photo, creating pictograms from photos, voice input). The ward app may use the camera only to scan a pairing QR code.

2. How We Use Your Information and Legal Bases

We process personal data under the General Data Protection Regulation (GDPR) on the following legal bases:

Performance of a contract (Art. 6(1)(b)) — to create and maintain accounts, pair ward devices, deliver messages and notifications, translate text and speech into pictograms, and create pictograms from photos.
Legitimate interest (Art. 6(1)(f)) — to keep Telepon secure, prevent abuse, diagnose errors (logs), and improve the app (analytics and session recordings). You can object to this processing — see section 9.
Legal obligation (Art. 6(1)(c)) — to respond to lawful requests from authorities and to report child sexual abuse material, as described in our Child Safety Standards.
Consent (Art. 6(1)(a) and Art. 9(2)(a)) — where information may reveal a ward's health or disability (for example the communication level), we process it on the basis of consent given by the caregiver on the ward's behalf. Consent can be withdrawn at any time.

3. Artificial Intelligence

Telepon uses the Google Gemini API to:

translate text and speech written or dictated by caregivers into pictograms — to make the translation fit the conversation, the most recent messages of that conversation are included;
recognise symbols in photos of paper boards and draw new pictograms from photos.

We use the paid Gemini API service. Under its terms, Google does not use this data to train its models. The results of AI processing are suggestions of pictograms; no decisions with legal or similarly significant effects are made about anyone automatically.

4. Who Can See Your Data

4.1 Other Telepon users

Members of the groups you belong to can see your name, profile photo and online status, and the messages exchanged with them. There are no public profiles and no user search in Telepon.

4.2 Service providers

We use the following service providers, who process data on our behalf and under data processing agreements:

Hetzner Online — servers and data storage (Germany);
Google — Gemini API (artificial intelligence, see section 3) and Firebase Cloud Messaging (push notifications; on iOS delivered through Apple Push Notification service);
PostHog — analytics and session recordings (EU cloud); PostHog privacy policy;
SMSAPI — sending SMS login codes (Poland).

We do not sell your personal data and we do not share it with third parties for their marketing purposes.

4.3 Authorities

We disclose data to law enforcement and other public authorities when required by law, and we report child sexual abuse material as described in our Child Safety Standards.

5. International Transfers

Our servers are located in the European Union. Some service providers (in particular Google) may process data outside the European Economic Area. In such cases the transfer is protected by the standard contractual clauses approved by the European Commission or another safeguard required by the GDPR.

6. Data Security

Data in transit is encrypted using TLS.
Login codes are stored only in hashed form and expire after a few minutes.
Access to personal data is restricted to authorised personnel.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the President of the Personal Data Protection Office (UODO) within 72 hours in accordance with Article 33 of the GDPR, and will inform affected users without undue delay where required by Article 34 of the GDPR.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

7. Data Retention

Account, profile, messages, boards and photos — for as long as the account exists. After the account is deleted, this data is permanently erased within 30 days.
SMS login codes — deleted shortly after they expire.
Diagnostic logs — 30 days.
Backups — up to 30 days, after which they are overwritten.
Analytics and session recordings — for a limited retention period, after which they are deleted automatically. After account deletion, analytics data is no longer linked to your identity.

We may keep specific data for longer where the law requires it or where it is necessary to report child sexual abuse to, or cooperate with, law enforcement.

8. Children and Wards

The Telepon app for caregivers is intended for adults. The Telepon app for wards may be used by children and by adults with communication difficulties.

A ward's profile can only be created by a caregiver who is the ward's parent or legal guardian, or who acts with their authorisation. The caregiver provides the ward's data, gives consent on the ward's behalf where consent is required, and can exercise the ward's rights described in section 9.

If you believe that a child's data has been provided to us without the authorisation of their parent or legal guardian, please contact us at dev@saac.pro and we will delete it promptly. How we protect children from abuse is described in our Child Safety Standards.

9. Your Rights

Under the GDPR you have the right to:

Access — request a copy of the personal data we hold about you
Rectification — request correction of inaccurate data
Erasure — request deletion of your personal data
Restriction — request restriction of processing of your data
Data Portability — receive your data in a structured, machine-readable format
Object — object to processing based on our legitimate interest, including analytics and session recordings
Withdraw Consent — withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal

To exercise any of these rights, contact us at dev@saac.pro. We will respond within 30 days. If you believe your rights have been violated, you have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) in Poland.

10. Account Deletion

You can delete your account in the app (Settings > Delete account) or by emailing dev@saac.pro. A caregiver can request deletion of a ward's profile they manage in the same way.

The account is deactivated immediately and can no longer be used.
Personal data, messages, boards and photos are permanently erased within 30 days.
Analytics data is no longer linked to your identity.
This action is irreversible.

More information: Account Deletion.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us:

SAAC sp. z o.o.
ul. Leona Frankowskiego 26
20-736 Lublin, Poland

Email: dev@saac.pro