Privacy Policy

In short: right now we only keep your e-mail and language to tell you when Cira launches; later, inside the app, you decide what you share, and it stays under your control.

1. Who is responsible for your data

The controller of your personal data is:

HT HOUSEBOATS sp. z o.o.
ul. Morska 54, 75-950 Koszalin, Poland
KRS 0000769170 · NIP PL4990676720
Contact: marcinbaranowski1979+cira@gmail.com

This is the company you can write to about anything in this policy, including exercising your rights (see section 6).

2. What we collect today — the waitlist

Cira is currently in a pre-launch stage. If you sign up to the waitlist, we collect:

• Your e-mail address, so we can contact you;
• Your chosen language, so we can write to you in a language you understand;
• Basic technical logs (such as IP address and browser type), generated automatically when you use our website, mainly for security and troubleshooting.

Purpose: to inform you about early access to Cira and related updates, and to keep our website secure and working properly.

Legal basis: for your e-mail address and chosen language, your consent (Article 6(1)(a) GDPR), given when you submit the waitlist form — you can withdraw this consent at any time, see section 6. For the basic technical logs, which are generated automatically for every visitor regardless of whether the waitlist form is submitted, our legitimate interest (Article 6(1)(f) GDPR) in keeping our website secure, preventing abuse, and troubleshooting technical issues.

3. What the future app will collect

Cira is being built as a wellness companion app. This section describes, transparently, what the app will process once it is available, so you know what to expect before you use it:

• Voice recordings, converted into text so the app can hold a conversation with you. We aim to process voice only for as long as needed to produce the text, and not to keep raw audio longer than necessary for that purpose;
• Conversation logs — the text of what was said, so the app can respond helpfully and, where you allow it, keep a history;
• Wellbeing information you choose to share — for example how someone is feeling, sleeping, or coping. This may include health-related data. Because health data is a special category of data, we only process it with your explicit consent under Article 9(2)(a) GDPR. Where Cira is used to support another person (the "cared-for person"), that person's own explicit consent is required before their wellbeing information is processed;
• Family-report contents — summaries generated for family members or carers who the user has chosen to keep informed, containing only what the user has agreed to share.

You will always be able to see, in the app itself, what is being recorded and what is shared with whom, and you will be asked for consent before any sensitive information is processed.

4. Who processes your data on our behalf

We use a small number of trusted providers to run Cira, acting strictly as our data processors under written agreements:

• Cloudflare, for website hosting and infrastructure, using EU data centers where available;
• AI speech and language processing providers, who convert voice to text and help generate conversational responses.

We do not sell your personal data to anyone, and we do not use it for advertising. Data is only shared with processors to the extent necessary to run the service described above.

International transfers: some of our processors, including our AI speech and language processing providers, may process data outside the European Economic Area (for example, in the United States). Where this happens, we rely on legally recognised safeguards, such as an adequacy decision by the European Commission or Standard Contractual Clauses, to ensure your data continues to receive a level of protection equivalent to that under the GDPR. You can ask us for more details about these safeguards using the contact address in section 1.

5. How long we keep your data

Waitlist data is kept until we have contacted you about launch, or until you withdraw your consent — whichever comes first.

App data (once the app is available) is kept according to the retention settings on your account. You will be able to delete your data, or your whole account, at any time from within the app or by contacting us.

6. Your rights under GDPR

You have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase your data ("right to be forgotten");
• Restrict how we process your data;
• Port your data to another provider, in a structured, commonly used format;
• Object to processing based on our legitimate interests;
• Withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal;
• Lodge a complaint with a supervisory authority. In Poland, this is the Personal Data Protection Office (Urząd Ochrony Danych Osobowych, UODO). If you live in another EU country, you may instead contact your local data protection authority.

To exercise any of these rights, write to us at marcinbaranowski1979+cira@gmail.com.

7. Cookies and similar technologies

We do not use marketing or advertising cookies. Our website only uses technically necessary storage — the minimum needed to make the site and the waitlist form work correctly.

8. Changes to this policy

We may update this Privacy Policy as Cira develops, especially as the app moves from waitlist to full release. We will post the updated version on this page with a new effective date. If changes are significant, we will make reasonable efforts to let you know directly.

Effective date: 2026-07-08.