Privacy Policy

Last updated: 10 July 2026 · Effective date: 10 July 2026

Our privacy promise

Trace is a private voice journal for iPhone. You tap record, you speak, and Trace transcribes and saves your entry. That entry is yours, and it stays on your device.

Here is the whole policy in one sentence: Trace does not collect, transmit, sell, or share any of your personal data, because everything Trace creates stays on your iPhone and is never sent to us or to anyone else.

There is no account, no login, no sign-up, no cloud sync run by us, no analytics, and no server of any kind that we own. We, the people who make Trace, genuinely cannot see your recordings, your transcripts, or your insights. We built the app that way on purpose. The rest of this document explains the details, honestly and in plain language.

The Apple "Privacy Nutrition Label": Data Not Collected

On the App Store, every app shows a privacy summary that Apple calls the "App Privacy" label, sometimes nicknamed the privacy nutrition label. Trace's label says "Data Not Collected."

That is not marketing language. It is a formal declaration we make to Apple, backed by the app's privacy manifest file (PrivacyInfo.xcprivacy), which states that Trace does no tracking, contacts no tracking domains, and collects no data types. It declares a single, standard reason for one Apple API (reading and writing your own on-device preferences with UserDefaults).

"Data Not Collected" means exactly what it sounds like. Trace does not gather data from your device and send it to us or to a third party. All of the processing that makes Trace useful, including transcription and insights, happens locally on your iPhone using software bundled inside the app. Because nothing is collected, there is nothing for us to store, analyze, leak, or hand over.

What Trace creates, and where it lives

When you use Trace, the app creates a few kinds of data. Every one of them lives only on your device:

• Audio recordings. When you tap record and speak, Trace saves the audio as .m4a files inside the app's own private folder (its Documents directory) on your iPhone.
• Transcripts. Trace converts your speech to text on your device and stores the resulting transcripts in a local database (Apple's SwiftData) on your iPhone.
• Insights and AI digests. Trace summarises each entry into a compact "digest" and uses those digests to build insight cards: weekly narratives, recurring themes, mood signals, people you mentioned, questions you asked yourself, and similar summaries. All of it is computed on your device and stored locally.
• Preferences. Small settings (for example, whether you have finished onboarding) are stored using Apple's standard on-device preference storage (UserDefaults / @AppStorage). Nothing sensitive is kept there.

All of this sits inside the app's sandbox, the private storage area that iOS gives every app. We cannot reach into your device and read any of it. There is no copy on a server we control, because no such server exists.

Microphone

The microphone is the only permission Trace ever asks for. iOS will prompt you to allow microphone access the first time you try to record. Trace uses the microphone for one thing: capturing the audio you choose to record.

Your audio is processed entirely on your device. It is never uploaded to us or to any third party. You can revoke microphone access at any time in iOS Settings, under Privacy and Security, then Microphone. If you do, recording will stop working until you allow it again, but your existing entries remain on your device.

How AI and machine learning are used (and their limits)

Trace uses on-device artificial intelligence and machine learning models. We want to be clear and honest about what they do and what they do not do.

• Transcription is performed by WhisperKit, an on-device version of OpenAI's open-source Whisper speech-recognition model, compiled to run with Apple's CoreML. The model files are bundled inside the app. There are no network calls for transcription. Trace does not use Apple's Speech framework or any cloud transcription service.
• AI insights are generated using Apple's Foundation Models, the on-device large language model that ships with iOS as part of Apple Intelligence. Trace uses it to summarise your entries into digests and to write insight cards (for example, a narrative of your week). The model runs entirely on your iPhone. There is no cloud AI, no network inference, and your journal content is never sent to Apple, to us, or to anyone else. These AI cards are available on devices that support Apple Intelligence; on other devices Trace falls back to simpler on-device analysis.
• Statistical insights (such as word frequencies, recording patterns, and mentioned people) are computed on your device using Apple's Natural Language framework and ordinary code. Nothing is sent to a server.

Background processing. To keep insights fresh without slowing the app down, Trace registers a standard iOS background processing task that digests new entries and regenerates insights while your iPhone is charging, typically overnight. This background work is exactly the same on-device processing described above, just run at a convenient time. It requires power, it explicitly does not require or use a network connection, and no data leaves your device during it.

Please keep the following in mind. AI-generated transcripts and insights can be inaccurate, incomplete, or simply wrong. Speech recognition can mishear words, especially with accents, background noise, names, or specialized terms. Insights are pattern-spotting heuristics, not judgments about you. You should not rely on Trace's transcripts or insights as fact, and they are not medical, psychological, therapeutic, legal, financial, or any other kind of professional advice. Trace is a journaling tool. If you have a question about your health or wellbeing, please speak with a qualified professional.

We try not to overstate what this technology can do. It is helpful, on-device convenience, not a clinician and not an oracle.

iCloud Backup

This is the one place where a copy of your Trace data may leave your iPhone, and it happens only if you have turned it on, and it is run by Apple, not by us.

If you have iCloud Backup enabled in your iOS settings (many iPhones have it on by default), iOS backs up Trace's files to your iCloud account on the same schedule it backs up your other apps, such as Notes and Voice Memos. Trace itself never initiates a backup or an upload. This is iOS doing for Trace exactly what it does for every app on your phone.

These backups go to your Apple account, governed by Apple's privacy policy, not ours. We never see them. Apple encrypts iCloud backups in transit and at rest. If you have Apple's Advanced Data Protection turned on, your backups are end-to-end encrypted so that not even Apple can read them.

If you would rather Trace not be included in iCloud Backup, you can exclude it. On your iPhone, go to Settings, tap your name at the top, then iCloud, then Manage Account Storage (or Manage Storage), then Backups, choose your device, and turn Trace off.

Subscriptions and payments

Trace offers an optional subscription called Trace Plus, which unlocks unlimited entries and some features, including several of the AI insight cards. Two options are available: a monthly plan (com.thomaspeel.trace.plus.monthly) and a yearly plan (com.thomaspeel.trace.plus.yearly). Your subscription status is checked on your device through Apple's StoreKit; there is no account with us.

All payments are processed by Apple through StoreKit and your Apple ID. We never receive, see, or store your payment card details or billing information. Apple handles the entire transaction. Per Apple's standard terms, Apple shares limited, mostly aggregate sales and subscription information with us (for example, how many subscriptions are active or how much was earned in a period). That reporting does not identify you and never includes your journal content.

Apple's handling of your purchase is covered by Apple's privacy policy, available at apple.com/legal/privacy.

Third parties and SDKs

There are none that collect your data. Trace does not include any third-party advertising, analytics, tracking, or crash-reporting SDKs. The only outside parties involved are Apple's own on-device frameworks (which run locally and send us nothing) and Apple's App Store and StoreKit (which handle distribution and payments, as described above). We do not sell, rent, or share your personal information with anyone, because we never have it in the first place.

Children's privacy

Trace is not directed at children under 13 (or the equivalent minimum age in your country), and we do not knowingly collect personal information from children. In fact, Trace collects no personal information from anyone, of any age. There is no account, no sign-up, and no data collection in the app. If you believe a child has used the app and you have concerns, the same controls apply to their device: entries can be deleted in the app, and all data is removed if the app is deleted.

Your rights and choices

Privacy laws such as the EU GDPR, the UK GDPR, and the California Consumer Privacy Act as amended by the CPRA give people rights over personal data that a company collects about them, including the right to access, correct, delete, or port that data, and the right not to be discriminated against for exercising those rights.

Here is the honest situation for Trace: because we do not collect, receive, or store any of your personal data, most of these rights have nothing to act on at our end. We have no profile of you to show you, correct, or delete, because we hold nothing about you.

What we can tell you is that you already have complete control over your data, directly in the app:

• Export. You can export your transcripts from within the app to keep your own copy.
• Delete an entry. You can delete any individual recording and its transcript at any time. Deleting an entry also deletes the AI data derived from it: its digest is removed, and its contribution to your insights is dropped when insights next regenerate.
• Delete everything. You can delete all of your Trace data from within the app, or remove everything at once by deleting the app from your iPhone. Because there are no server copies, deleting the app deletes all of your data.

For California residents: we do not "sell" or "share" your personal information as those terms are defined under the CCPA/CPRA, and we never have. There is no data to sell or share.

If you have a question about any of this, contact us using the details at the end of this policy.

Data retention and deletion

We do not retain your data, because we never receive it. On your device, your recordings, transcripts, digests, insights, and preferences persist for as long as you keep them. They remain until you delete individual entries (which also deletes each entry's AI digest and removes its contribution to insights), use the in-app option to delete all data, or delete the Trace app (which removes the app's data from your iPhone, and since we hold no server copies, that removes everything). If you have iCloud Backup enabled, removing data may also require managing or deleting backups in your Apple account, as described in the iCloud Backup section above.

Security

Your Trace data is protected by the security built into your iPhone. Because everything stays on the device inside the app's sandbox, the most important protections are the ones you control: use a device passcode or Face ID / Touch ID, keep iOS up to date, and manage your iCloud backups according to your comfort level. No method of storage is perfectly secure, but keeping your data on your own device, and off any server of ours, removes an entire category of risk.

International users and data transfers

There are no international data transfers to worry about with Trace, because your data never leaves your device to reach us. Wherever you are in the world, Trace processes everything locally on your iPhone. (If you use iCloud Backup, any cross-border storage of those backups is handled by Apple under Apple's own terms and privacy policy, not by us.)

Changes to this policy

If we make a material change to this policy, we will update the "Last updated" date above and, where reasonable, note the change in the app's release notes. Because the app's core promise is "no data collection," any change that would alter that promise would be made clearly and conspicuously.

Contact

If you have any questions about this Privacy Policy or your privacy when using Trace, please email us at hello@yourtraceapp.com.

Trace is published by Thomas Peel (app bundle identifier com.thomaspeel.trace).