Privacy policy — ASTORRE X SMART by Amstercode

1. Who we are

ASTORRE X SMART (“SMART”) is part of Astorre X and is developed and provided by Amstercode, Koningsstraat 107, 1432 PL Aalsmeer, the Netherlands, registered with the Dutch Chamber of Commerce (KVK) under number 82506949 (“we”, “us”). Amstercode is the controller of the personal data described in this policy and the developer named on the app’s Google Play listing. SMART is used with an ASTORRE X SMART account.

For anything about your data, write to office@amstercode.com. Website: amstercode.com.

2. What SMART does

SMART records conversations on your Android phone, transcribes them, and keeps a structured memory of them: promises and commitments, decisions, limits (amounts, deadlines, approvals, prohibitions, conditions), what changed between conversations, a short summary of each conversation written by AI, and drafts of follow-ups that you may approve and send. Every item, including every point of a summary, links back to the words it came from.

Audio reaches SMART only in ways you control:

Record. SMART records from the moment you tap Record until you tap Stop. Recording continues with the screen locked.
SMART Listening (optional). It is off until you turn it on, and it turns on only after an in-app explanation and a tap on Agree and turn on. While it is on, the microphone stays on, also when SMART is closed or the phone is locked. The phone itself detects when people are talking; SMART then records that conversation, including speech from a TV, radio or video. Stretches without speech are not saved or sent. It stays on for the time you choose (1 hour, 4 hours, 12 hours, or until you turn it off), and you can turn it off at any time from its notification or in the app.
Audio you share into SMART from another app, for example a call recording that another app made.
Call recordings your phone makes, only if you turn on Bring in call recordings automatically and choose the folder your phone saves them in. SMART cannot record calls itself. It reads only the folder you choose, through your phone’s own folder picker and a read-only permission you can withdraw in your phone’s settings, and it never changes or deletes anything in it. From then on, each new recording in that folder (including its file name, which may contain the other person’s name or number) is uploaded to your account when you open SMART, and processed like any recording you import. Turning the setting off stops this and gives the folder permission back.

A notification shows whenever SMART is using the microphone, unless you have turned SMART’s notifications off. SMART Listening does not start unless notifications are allowed, so you can always see that it is on. SMART pauses during phone calls on the phone and carries on when the call ends. SMART never starts recording by itself: it does not start when the phone starts, and it cannot be started from outside the app.

A recording is kept on the phone until our server confirms it has received it, and uploads when there is a connection — also after you stop recording or turn Listening off.

3. What we collect

Category	What it is	Why
Voice and sound recordings	Audio you record with Record; conversations SMART Listening saves when it detects speech; audio you share into SMART; call recordings you chose to bring in. A recording contains the voices of everyone speaking nearby, and any TV, radio or video that was playing.	To transcribe it, and so you can go back to what was said
Transcripts	The text of each recording, with timings and speaker labels, and the names you give to voices.	The basis of everything SMART shows you
Your memory	Promises, decisions, the limits ledger, summaries, “what changed” records, notes, and follow-up drafts with the recipients you enter and what you approved and sent — each linked to the passage it came from.	The product itself
Your dictionary	Names and terms SMART should spell right: names you give to voices, terms from documents you import that you accept, and terms you add yourself.	So that names are written correctly in your transcripts (see section 8)
Deletion receipts	For each deletion: when it happened, what kind of thing was deleted and how many items of each kind, which checks were run, and a signature. Never a title, a name or anything that was said.	So you can see, and later show, that a deletion was complete
Search records	When SMART looks up items in your memory for you: which kinds of items it considered and which ones it chose, with the time — identifiers only, never the words you searched for or anything that was said.	So we can check why SMART showed what it showed
Account	The email address and name of your ASTORRE X SMART account; your SMART user and workspace identifiers; the devices and sessions signed in to it.	To give you access and keep you signed in
Name and role	From ASTORRE X SMART 1.0.2, the name you choose when you first open SMART (up to 60 characters) and, if you give one, your role or company (up to 80 characters), with the time you finished that first step. Shown in the app, in the greeting and with your account.	So SMART can address you and show whose account it is
Installation identifier	From ASTORRE X SMART 1.0.2, a random identifier created for each installation of the app — not a hardware or advertising identifier — kept in the phone’s secure storage and sent to amstercode.com when you sign in, with the label “ASTORRE X SMART · Android” and the app version.	To know which installation is signed in to your account
Subscription	Plan, subscription state, paid-through date and a Stripe customer reference; the record of your purchase — when you accepted the terms and asked for SMART to start immediately, and which terms version — and of any cancellation, withdrawal or refund. We never see or store your card number — Stripe does.	To know whether your subscription is active, and to show and settle what was agreed (cancellations, withdrawals, refunds)
Service records	Request identifiers, error types and timings in our server logs, written so that they do not contain your content.	Keeping the service running
Sign-in security logs	For each sign-in to your ASTORRE X SMART account on amstercode.com, and other security events of the account: when it happened, what it was, the IP address, and the browser or app that was used.	To protect your account and detect misuse
Emails we send you	The emails amstercode.com sends you about your account and your subscription — for example the contract confirmation after a purchase, a password reset or an invitation — with the address they were sent to.	To deliver them; the contract confirmation also as a record of what was agreed

While SMART Listening is on, the phone detects speech and saves the conversations it hears. That speech detection happens only on the phone.

Signing in. From ASTORRE X SMART 1.0.2, you sign in inside the app. Your email address and password are sent only to amstercode.com, over an encrypted connection; neither the app nor the SMART server ever stores your password. Signing in returns your account’s name, which the app keeps only in memory to suggest it when you first open SMART. Each sign-in creates a short-lived session on amstercode.com that is ended right after, and a security log of the sign-in is kept (section 9). Your name and role are stored on the SMART server (section 8: Hetzner, in the EU), and the phone keeps a note of them, and that you finished the first step, until you sign out.

We do not sell your data, we do not share it with anyone for their own use, and we do not use your recordings, transcripts or memory to train any model.

4. What we do not collect

The SMART app contains no advertising, analytics, crash-reporting or attribution software, and does not read your advertising ID or other device identifiers. It does not collect your location, contacts, photos or videos, calendar, messages, browsing history or health information. SMART subscriptions are sold and billed by Amstercode; the app itself sells nothing and handles no payment information.

5. Automated processing and its limits

SMART uses automated processing — transcription, the recognition of commitments, decisions and limits, and a summary of each conversation — to organise your conversations for you. SMART does not make decisions about you or anyone else, and it does not score people.

The summary. It is written automatically from the text of the transcript. Before a summary is shown, SMART checks every point against the exact words it cites: a point that cannot be traced to those words, or that sounds more certain than what was said (for example “approved” where someone said it still needs approval), is not shown. The summary is marked as written by AI, and every point opens at the words and the moment in the recording it comes from.

It can be wrong: transcripts and extracted items can contain errors, which is why each item shows the passage it rests on. Extraction currently reads English and Romanian only; conversations in other languages are kept and transcribed, but nothing is extracted from them yet.

6. Purposes and legal bases

Under the EU General Data Protection Regulation (GDPR), we rely on:

Performance of our contract with you (Art. 6(1)(b)) — giving you access to your account, recording, uploading, transcribing and organising your conversations, search, export and deletion, and managing your subscription.
Legal obligation (Art. 6(1)(c)) — keeping invoices and billing records for as long as tax law requires.
Legitimate interests (Art. 6(1)(f)) — keeping the service secure and reliable and preventing abuse, using session records and server logs that do not contain your content.

7. Recording other people

Record starts only when you tap it. Once you turn on SMART Listening, it records conversations by itself whenever it hears speech, including in the background, until the time you chose or until you turn it off. Either way, the recording contains the voices of the people around you.

Many jurisdictions require you to tell people — or obtain their consent — before recording them. That obligation is yours. The app reminds you of it before SMART Listening turns on.

8. Who processes your data for us

We work with different technical service providers, which can change over time. They process data on our behalf, on our instructions and only to provide SMART to you. They are service providers: we do not share your data with them for their own use.

Provider	What for
Hetzner Online GmbH	Hosting the SMART server, database, recordings and backups, in Nuremberg, Germany (EU).
Technical service providers	Processing recordings and transcripts on our behalf, only to provide SMART to you. They are bound by contract and may not use your data for their own purposes, including training their own systems.
Stripe	Payment processing and billing of SMART subscriptions.
Hostinger	Hosting the Astorre X websites and account portal, and transactional email from amstercode.com.
Google	Distribution of the app, if you install it through Google Play, under Google Play’s own terms.

Everything the app sends travels encrypted (TLS) to our own server at smart-api.astorrex.com. The app does not talk to any of these providers directly.

Your dictionary. So that names are written correctly, the terms in your dictionary (section 3) are used when a recording is transcribed, as a plain list of words — never text from your recordings. A first name on its own is kept in your dictionary but never used, because it can make a similar-sounding name be written as that name.

Some of these providers may process data outside the European Economic Area. Where that happens, the transfer is protected by appropriate safeguards, such as the EU Standard Contractual Clauses or an adequacy decision of the European Commission. You can ask us for more information about these safeguards at office@amstercode.com.

9. How long we keep it

On the phone: a recording stays on the phone until our server confirms it has received it, and is then removed from the phone. The note of your name and role stays on the phone until you sign out.
Name and role: on the SMART server until you use Delete everything or your account is closed.
Recordings, transcripts, memory, imports and follow-ups: until you delete them, or until your account is closed (see section 10). Nothing is deleted automatically unless you turn on automatic deletion (below).
Automatic deletion (optional, off unless you choose it): under You → Your data → Automatic deletion (the screen names on this page are those of ASTORRE X SMART 1.0.2) you can have SMART delete conversations automatically 30 days, 90 days or 1 year after they are processed — either only the recording (the transcript, memory and summary stay) or the whole conversation. It applies from the moment you set it. A conversation you mark “Keep this one” is never deleted automatically.
After you delete something: it is removed from the live system immediately, together with everything derived from it (memory, limits, summaries, quoted passages, dictionary terms learned only from it). SMART then checks that nothing of it is left and gives you a deletion receipt (section 10). We make a backup every day and keep only the last 7 copies, so it can still exist in a backup for about 7 days, until those copies are replaced. If we ever have to restore a backup, our restore procedure first applies again every deletion recorded after that backup was made, so deleted material does not come back.
Search records: until you use Delete everything or your account is closed.
Deletion receipts: for as long as your ASTORRE X SMART account exists. They hold no content. The signed receipt issued when your account closes can still be read in the app for 12 months after the closing date; then the last identifier that reads it is deleted.
When your subscription ends: nothing is deleted. You keep read access, export and deletion; new recordings are held and are not transcribed until you subscribe again.
Account data (email address, name, identifiers, devices, app sessions and push-notification tokens): for as long as your ASTORRE X SMART account exists. On the day your account closes (section 10), SMART deletes everything it holds for you, and amstercode.com deletes the personal data held for your account, including its app sessions and push-notification tokens, except the billing records, sign-in security logs and email records below, which are kept only for the periods given there.
Sign-in security logs: 12 months after the sign-in or event they record, then deleted. This also applies after your account closes: each log is kept until its 12 months have passed, then deleted.
Emails we send you: the links in password-reset and invitation emails are never kept. Our copy of the text of an email is erased within 7 days of sending (within 30 days if it could not be sent), and the address it was sent to and the record that it was sent within 12 months. The contract confirmation is the exception: it is kept with the billing records below.
Server logs (the service records in section 3): 14 days, then deleted as the logs rotate.
Billing records (invoices, payment records, the record of your purchase, cancellation, withdrawal and refunds, and the contract confirmation we emailed you): seven years, as Dutch tax law requires businesses to keep their records.

10. Your rights and controls

In the app, without asking us, you can:

Export what SMART holds about you in writing — transcripts, memory, promises, the limits ledger, your name and role, and where each came from — in one file you save where you choose. Audio is not in the export; to keep a recording, open its conversation and save it (a long recording is saved a few minutes per file), or ask us for a copy of your recordings.
Delete a single conversation, or everything, under You → Your data. What SMART derived from it goes with it. Delete everything deletes all your SMART data immediately, while your account stays open. Afterwards you get a deletion receipt: what was removed, how many of each, the result of a check of the database for anything of it left, and until when a backup copy can still exist. Each receipt is signed, so it cannot be altered without that showing.
See and change your dictionary under You → Dictionary: remove any term, or accept or ignore a suggestion.
Turn automatic deletion on or off, and choose what it deletes (section 9).
Sign out of SMART on your phone. From ASTORRE X SMART 1.0.2, you can also sign out every other phone signed in to your SMART account, under You → Security → Sign out of other phones; the phone you use stays signed in. To end every session, including browsers, you can also write to us at office@amstercode.com from your account’s email address.
Turn off SMART Listening at any time, from its notification or in the app.

Closing your account. From ASTORRE X SMART 1.0.2, you can close your ASTORRE X SMART account in the app, under You → Your data → Close account; you can also close it by writing to office@amstercode.com from your account’s email address. The account closes at the end of the period you have already paid for (for an annual plan that has already renewed, as the cancellation rule in the terms provides); if a payment is outstanding, the open invoice is voided — nothing more is charged — and the account closes at once. Before you confirm, the app shows the exact closing date and whether the unused part is refunded. On that date SMART deletes all your SMART data automatically and issues a signed deletion receipt, which you can read in the app for 12 months after the closing date; on the same date amstercode.com deletes the personal data held for your account, except billing records, sign-in security logs and email records, which are kept as section 9 says. An account shared with other people (a shared workspace) cannot be closed in the app: to close it, write to office@amstercode.com. The steps are also on Delete your account and data.

Your rights under the GDPR

You have the right to:

access the personal data we hold about you;
have inaccurate data rectified;
have your data erased;
restrict how we process it;
receive it in a portable format (data portability);
object to processing based on our legitimate interests.

To use any of these rights, write to office@amstercode.com, preferably from your account’s email address so we can confirm the request is yours. We respond within one month of receiving your request. Where a request is complex, the law allows that period to be extended by up to two further months; if so, we tell you within the first month and explain why.

You also have the right to lodge a complaint with a data protection supervisory authority. In the Netherlands that is the Autoriteit Persoonsgegevens; you can also complain to the authority in the EU country where you live or work. We would appreciate the chance to solve the problem with you first.

11. Security

Everything between the app, the website and our servers is encrypted in transit (HTTPS/TLS). Your workspace is kept separate from every other customer’s: every request is limited to your own workspace, and this is tested. Access to the production server is restricted to named keys. Payment card data never reaches our servers.

12. Children

SMART is a business recording tool for adults. It is not designed for children and is not intended for anyone under 18.

13. Changes

We will tell you in the app and by email before a material change to this policy takes effect. The date at the top of this page shows when it was last changed.

14. Contact

Amstercode, Koningsstraat 107, 1432 PL Aalsmeer, the Netherlands · KVK 82506949 · office@amstercode.com · amstercode.com.