Beta Privacy Policy

Last updated: 2 June 2026

This Beta Privacy Policy explains how Kialo GmbH, of Joachimsthaler Straße 1-4, 10623 Berlin, Germany (“Kialo,” “we,” “us,” or “our”) handles personal information for the beta version of Dusted (the “Beta App”), distributed through Apple TestFlight and Google Play Internal Testing, and related beta testing activities, such as onboarding, surveys, interviews, support, and any optional continued use of the beta version of the app after the testing period. It does not apply to other products or services unless they link to this policy.

1. Adults only

The Beta App is only for adults aged 18 or older.

We do not knowingly allow anyone under 18 to participate in this beta. If we learn that someone under 18 is participating, we will remove them from the beta and delete their account in line with this policy.

2. Information we collect

We may collect the following information during the beta:

  1. Account and contact information
    This may include your name and email address.
  2. Beta participation information
    This may include onboarding responses, support messages, and whether you ask to hear about future testing.
  3. Household and app content
    This may include household participation information, tasks, observations, voice recordings, audio-derived transcripts, AI-generated task titles and structured outputs, and task completion history that you enter into or generate through the Beta App.
  4. Research and feedback information
    This may include survey responses, interview notes, support messages, email correspondence, and other feedback you choose to provide.
  5. Interview recording information
    With your separate permission and consent, we may also collect transcripts from beta interviews to accurately capture key insights and learnings. These transcripts will be accessible only to the core beta team for the purpose of improving the product and will be retained only for as long as necessary for reference. 
  6. TestFlight information
    If you use the Beta App through Apple TestFlight, Apple automatically collects certain beta install, usage, crash, and feedback information and shares some of that information with us. Apple’s TestFlight privacy notice says this can include items such as your invitation status, app version, installed build, device model, operating system version, language, sessions, crashes, crash logs, screenshots, and comments submitted through TestFlight. Apple also says this TestFlight collection cannot be turned off by the tester. (Apple)
  7. Google Play Console information
    If you access the Beta App through a Google Play Internal Testing, Google may collect and process information about your use of Google Play and the Beta App under Google’s own terms and privacy policy. Google says it provides developers access through Play Console to app-related data that is generally aggregated and anonymized to protect user privacy. Google’s examples of data made available to developers include device information, registered country and language preference, installs, updates, uninstalls, ratings and reviews, and app usage or developer-nominated events. (Google)

3. Information we do not currently collect through the Beta App

Based on the current beta build, we do not collect location data, contacts, photos, videos, or calendar data through the Beta App.

We also do not use third-party analytics tools or separate device crash reporting tools inside the Beta App. This does not include service providers used to operate app features, such as AI-assisted transcription and task processing.

If any of this changes during the beta, we will inform you in writing in advance.

4. How we use information

We may use personal information to:

  1. Operate and administer the beta.
  2. Onboard participants and provide support.
  3. Review usage, identify bugs, and improve the Beta App.
  4. Use AI-assisted processing to transcribe voice inputs and to interpret, structure, categorize, and generate tasks, observations, templates, and feedback entries submitted through the Beta App 
  5. Conduct surveys and interviews.
  6. Review content and usage during active testing.
  7. Investigate misuse, harassment, threats, or other harmful conduct connected to the beta.
  8. Protect the security and integrity of the Beta App.
  9. Comply with legal obligations and respond to lawful requests.
  10. Contact you about future testing, unless you separately ask us not to do so, and send you operational notices related to the beta, such as feature changes, required updates, discontinuation of beta access, or migration to a production version.

During active testing, the core beta team may manually review identifiable content and usage, including app entries, transcripts, AI-generated structured outputs, and feedback, in order to run the beta and improve the product.

Because this is an actively reviewed beta, any sensitive personal information you enter as tasks, observations, voice inputs transcripts, or feedback may be visible to the core beta team and may also be processed by our service providers, including AI processing providers, for the purposes described in this Beta Privacy Policy. If you are concerned about this for privacy reasons, please avoid entering such information.

5. Legal bases for processing

We process personal information under the following legal bases:

We process account information, beta participation information, household and app content, support information, and operational information where this is necessary to provide, operate, administer, and support the Beta App and related beta activities.

We process research, feedback, product-improvement, safety, security, misuse-prevention, and beta evaluation information based on our legitimate interests in running, evaluating, securing, and improving the Beta App.

Where we ask for separate consent, such as for beta interview recordings or transcripts, we process that information based on your consent. You can withdraw your consent at any time, but this will not affect processing that took place before withdrawal.

We may process information where necessary to comply with legal obligations or to establish, exercise, or defend legal claims.

6. How information is shared

Your personal information will be shared in the following ways:

  1. With other participating household members
    Excluding any observations you enter, shared household content (such as the tasks in the Journal) will be visible to the other participating members of your household.
  2. Within our beta team
    Identifiable data you enter in the app or generate during testing may be accessed by the limited group of team members involved in running the beta, user research, support, and product improvement.
  3. With Apple through TestFlight
    Apple operates TestFlight under its own privacy terms. Apple says it collects TestFlight-related crash logs, usage information, and feedback, and shares some of that information with the application provider. Apple also tells testers to review the application provider’s privacy policy for how the provider handles the data it receives. (Apple)
  4. With Google through Google Play Console
    If you access the Beta App through a Google Play Internal Testing, Google operates Google Play under its own terms and privacy policy. Google says it collects information when users use Google Play and explains that collection in Google’s Privacy Policy. Google also says it makes certain app-related data available to developers through Play Console, and that this data is generally aggregated and anonymized to protect user privacy. Google’s examples include device information, registered country and language preference, installs, updates, uninstalls, ratings and reviews, app usage, and app technical performance data such as crashes and ANRs. (Google)
  5. Service providers
    We may use service providers that process personal information on our behalf, such as hosting, database, email, survey, scheduling, support, and payment providers. When we use them, we require them to process personal information for us and for the purposes described in this Beta Privacy Policy.We currently use the following external providers for beta operations:
    a. Typeform, for surveys and forms
    b. Calendly, for interview scheduling
    c. Gemini, for interview transcript generation
    d. OpenAI, for AI-assisted processing of Beta App inputs, including transcription and converting voice or text entries into structured tasks, observations, templates, or related app outputs
    e. Google Mail, for email communications

    We may use additional service providers where necessary for beta operations. If we do, we will update this Beta Privacy Policy before or when those changes take effect, where required.

    We do not permit our AI processing providers to use Beta App content to train their general-purpose AI models, unless we tell you and obtain any required consent or agreement.
  6. For legal or safety reasons
    We may disclose information if required by law, or if we have a good faith belief that disclosure is necessary to prevent serious physical harm, protect rights or safety, investigate misuse, or respond to lawful requests.
  7. International processing
    Some of our service providers may process personal information outside Germany or the European Economic Area, including through providers headquartered in the United States. Where this happens, we rely on appropriate safeguards where required, such as adequacy decisions, standard contractual clauses, equivalent data protection terms, or other appropriate transfer mechanisms as required under the GDPR.
  8. Automated processing
    The Beta App uses AI-assisted processing to transcribe, interpret, structure, categorize, and generate app entries, including tasks, observations, templates, feedback, transcripts, task titles, and related structured outputs.

    We do not use this processing to make legal or similarly significant decisions about you.

We do not share Beta App data with third party advertising or analytics companies.

7. Household information

The Beta App is designed for use within a single household. It is not designed to connect you with people outside your household.

Shared household content, such as the tasks in the Journal, will remain visible to participating household members.

If you leave the beta or delete your account, shared household content may remain available to the household, but we will remove or replace your direct identifiers in shared records where reasonably possible.

Please avoid entering real names or highly sensitive details about non-participants if you do not want that information to be accessible to the core beta team or processed by our service providers, including AI processing providers, for the purposes described in this Beta Privacy Policy.

8. Retention and deletion

During active testing, we keep direct identifiers in restricted systems that are only accessible to the core beta team.

For broader internal discussion, we will replace direct identifiers with anonymous IDs.

After the beta testing period ends, unless you continue using the beta version of the app, we plan to delete the separate key linking those IDs to your name and email and keep a scrubbed or deidentified dataset for internal product research and product improvement. The scrubbed or deidentified dataset will be kept indefinitely in our records. 

If you continue using the beta version of the app after the testing period, we may keep identifiable data while your account remains active on the beta and for up to 30 days after your beta access ends or your account is deleted.

If you withdraw from the beta before the end of the testing period:

  1. We will deactivate your beta access promptly.
  2. We will delete your direct identifiers, such as your name and email address, within 30 days, unless we need limited information for legal, security, fraud, or dispute reasons.
  3. We may keep deidentified or aggregated usage data that does not reasonably identify you for internal research, product improvement, fraud prevention, security, dispute handling, and compliance purposes.
  4. Encrypted backups may retain copies for up to 30 days before they are overwritten or expire.
  5. Copies processed by our service providers may also remain in their systems for limited periods in line with their contractual, security, and legal obligations, after which they are deleted or deidentified according to their applicable retention terms.

Unless you separately ask not to hear about future testing, we may keep your name and email for that purpose until you opt out or ask us to delete it.

You can delete your account from within the app. Upon deleting your account, we will transfer ownership of any households with other members to one of them, and will de-identify all your contributions. Deleting the app from your device does not delete your account.

9. Your choices

You can contact us to:

  1. Withdraw from the beta.
  2. Ask a privacy question.
  3. Stop future beta recruitment emails.
  4. Request access to personal information we hold about you.
  5. Ask us to correct inaccurate personal information.
  6. Ask us to delete personal information.
  7. Ask us to restrict or object to certain processing.
  8. Ask for a copy of personal information you provided to us in a portable format, where applicable.
  9. Withdraw consent, where we rely on consent.

Some rights may be limited depending on the nature of the information, the legal basis for processing, and whether we need to keep information for legal, security, fraud, dispute, operational, or compliance reasons.

Where we process personal information based on legitimate interests, you may object to that processing on grounds relating to your particular situation. If you object, we will no longer process the relevant information unless we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is needed to establish, exercise, or defend legal claims.

Our contact details are in Section 12 below.

For information about data handled by Apple through TestFlight, Apple says testers can view and manage Apple-held data through Apple’s Data and Privacy page, and that requests to access or delete TestFlight data should be made to the application provider. (Apple)

For information about data handled by Google through Google Play, Google explains that users can review and manage certain Google held data through their Google Account and related tools, including Google Dashboard and Download your data. Google also provides developers with certain app-related data through Play Console, which Google says is generally aggregated and anonymized to protect user privacy. For information that we receive or handle in connection with the Beta App, including any data you provide directly to us, you can contact us at legal@dusted-app.com. (Google)

10. Security

We use reasonable safeguards designed to protect personal information. We use service providers that are intended to process personal information on our behalf and under appropriate confidentiality, security, and data protection terms.

We limit access to identifiable data to the core team members who run the beta and related research.

We also keep the identification key separate from the scrubbed research dataset used for broader internal discussion.

11. Changes to this policy

We may update this Beta Privacy Policy from time to time.

If we make changes, we will post the updated version at this page and change the “Last updated” date above.

12. Contact us

For privacy questions, support, or withdrawal, contact us at:

Privacy contact: legal@dusted-app.com 
Support contact: support@dusted-app.com

13. Waitlist and product updates

If you register interest in Dusted by joining our waitlist, we collect the information you submit, such as your email address. We use this to manage the waitlist, contact you with launch information, and send product updates about Dusted. You can unsubscribe or ask us to delete your information at any time.