Privacy Policy

Telepon

Last updated: October 6, 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.
Reports — when you report a message or a person, we store who reported whom, the group, the reason, any note you add, and the decision our team takes.
Blocked people — the list of people you have blocked. It is visible only to you; the person blocked is not told.

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.

A ward's conversations are visible to the administrators of their group. Caregivers are responsible for who the person they support is talking to, so an administrator of a ward's group can read that ward's conversations with other members of the group. They cannot write on the ward's behalf.

4.2 Our team, when content is reported

When someone reports a message or a person, our team reads the reported content in order to decide what to do. To judge a report we also open a limited window of the conversation around the reported message — the messages immediately before and after it — and nothing further. Every such access is recorded in our systems. We do not disclose who filed a report to the person reported.

4.3 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.

4.4 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, boards and photos — for as long as the account exists. Within 30 days of deletion this data is erased, and anything that cannot be erased because it belongs to someone else's conversation is irreversibly anonymised (see section 10).
Reports — kept for 12 months after a decision is taken, so that repeated behaviour can be recognised. Reports concerning a child's safety, and the accounts they concern, are kept for as long as required to cooperate with the authorities.
SMS login codes — deleted shortly after they expire.
Diagnostic logs — 30 days.
Early-access sign-ups — until you withdraw consent or the early-access programme ends, and no longer than 24 months (see section 11).
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 [email protected] 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 [email protected]. 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 [email protected]. 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.
Within 30 days your personal data — name, phone number, profile photo, devices and diagnostic logs — is erased.
Messages you have already sent remain in the conversations of the people who received them, because those conversations are also their data. They are no longer linked to your profile, and your name no longer appears next to them.
Boards and pictograms you created for a ward remain with that ward's profile, so that the person who relies on them to speak does not lose them.
Analytics data is no longer linked to your identity.
This action is irreversible.

More information: Account Deletion.

11. Early-Access Form

On telepon.app/wczesny-dostep you can sign up for early access to Telepon without creating an account. The controller of this data is SAAC sp. z o.o. (contact details in section 14).

What data — your email address; optionally your first name, your role (e.g. parent, therapist), the device the child uses and a comment. We also store the language of the page, the campaign you came from (utm_* parameters), and the date and version of the consent you gave.
Purpose — to contact you about early access and to choose the first testers. We do not send a newsletter or ads to this address, and we do not share this data with others for marketing.
Legal basis — consent (Art. 6(1)(a) GDPR). If you write about the child's health or disability in the comment, we process it on the basis of explicit consent (Art. 9(2)(a) GDPR).
Where — the form sends the data directly to our servers at Hetzner Online (Germany). As with any connection to our server, your IP address goes into technical logs, which we keep for 30 days to protect the service from abuse (see sections 2 and 7).
Choosing testers — we choose the first testers ourselves; no automated decision-making is involved.
How long — until you withdraw consent or the early-access programme ends, and no longer than 24 months after you sign up.
Withdrawing consent — at any time, by emailing [email protected]. We will then delete your sign-up. Withdrawal does not affect the lawfulness of processing before it.

Giving the data is voluntary, but without an email address we cannot contact you. You have the rights described in section 9, including the right to lodge a complaint with the President of the Personal Data Protection Office (UODO).

12. telepon.app Website Statistics

On telepon.app, including the early-access page, we measure traffic with PostHog (EU cloud). We want to know how many people visit the site, where they come from and whether the form works.

No cookies — the site stores nothing on your device: no cookies and no data in browser storage. Visits from one day are linked by a hash that PostHog computes on its side from the IP address and browser data; its random part changes every day.
What data — the pages visited, the page you came from, campaign parameters (utm_*), device and browser type, the IP address and the approximate location derived from it (country, city), clicks on the “Sign up” button, starting a video, and whether the early-access form was sent. We do not send the email address, first name or comment from the form to PostHog.
No recordings — we do not record visits to the site.
Legal basis — legitimate interest (Art. 6(1)(f) GDPR): checking that the site and our campaigns work. You can object (see section 9) or block the analytics script in your browser.
How long — the same as the apps' analytics data (see section 7).

13. 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.

14. 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: [email protected]