Privacy Policy

Version 1.3 · 26 September 2026 · Applies to the Nenapu app and nenapu.ai

What changed in 1.3. Nenapu now sends reminders about your Memory Library. Sections 2, 3, 4 and 6 say what they are, what we keep to send them, and how to stop them.

The short version

1. Who is responsible for your data

Nenapu ("we", "us") operates the Nenapu app and nenapu.ai, and is the data fiduciary (India), data controller (EU/UK) and "business" (California) for the personal data described here. Contact: [email protected].

2. What we collect

Things you give us

Things collected automatically

We do not collect precise location, contacts, browsing history, or advertising identifiers. The nenapu.ai website sets no analytics or advertising cookies.

3. How we use it, and on what legal basis

What we doWhy (legal basis)
Host, process and deliver your recordings and photos to the people you've authorisedPerforming our contract with you (GDPR Art. 6(1)(b)); the explicit consent of the people recorded (Art. 9(2)(a)); consent (India DPDP Act)
Create and manage accounts, invitations and access levelsPerforming our contract; consent
Send service emails — invitations, important account and policy noticesPerforming our contract; legitimate interest
Send reminders about a Memory Library, in the app, by push and by email, and keep reminder recordsLegitimate interest in helping families use the service they set up (Art. 6(1)(f)); performing our contract for the weekly email you switch on
Send one reminder email to someone invited by email who has not joined, and remember a request not to be remindedLegitimate interest of the person who invited them, and ours (Art. 6(1)(f)); for the request not to be reminded, honouring that person's objection
Scan content with automated tools (including AI) for illegal or prohibited materialLegitimate interest in a safe service (Art. 6(1)(f)); legal obligation where the law requires detection or reporting (e.g. child sexual abuse material)
Review a sample of recordings — including recordings nobody has reported — to check they meet our TermsLegitimate interest in a safe service and in enforcing our Terms (Art. 6(1)(f)); the explicit consent of the people recorded (Art. 9(2)(a)); consent (India DPDP Act)
Measure how each Memory Library is used: who has joined and in what role, how often and how recently each member recorded, asked or commented, invitations sent and accepted, export downloads, streaming totals, and when they last signed in. We use this to run, support and improve Nenapu.Legitimate interest in running and improving the service (Art. 6(1)(f))
Keep security logs, prevent abuse, debug problemsLegitimate interest in a secure, working service
Respond to lawful requests from courts or authoritiesLegal obligation (Art. 6(1)(c))

Life-story recordings are deeply personal — they can touch on health, faith, and family history, and they carry a person's face and voice. We treat all of it as sensitive data: it is processed only with the explicit consent of the people recorded, given when they agree to record for a Memory Library, and everyone who appears in a recording has the same rights over their data as the account holder (section 8).

We do not use your family's recordings to train AI models, to advertise, or for any purpose beyond operating the service, without asking you first.

Reminders

Nenapu sends a few short reminders when something in a Memory Library needs you. They name people and count things. They never include your family's recordings, photos, questions or comments.

What we send, and to whom.

How they reach you. Reminders to people in a Library appear in the app's inbox. Some also come as a push notification, if you allow notifications on your phone; we send those through Expo, which delivers them via Google FCM and Apple APNs. Only three kinds come by email, sent through Resend: the weekly email, the note about recording time, and the one reminder to someone invited by email. A reminder is either sent automatically or sent by a person at Nenapu who has looked over the list of reminders due. That list shows who a reminder is for, which Library it is about, and the names and counts in it.

Defaults and limits. Every kind of reminder is on until you switch it off, except the weekly email, which is off until you switch it on; we offer it to you once, in the app. We send you at most two reminders a week and one push notification a day, and nothing between 21:00 and 08:00 in your time zone. You can change those hours; for someone without an account we use India time. If two reminders of one kind in a row go unopened for a week, we stop sending you that kind.

Stopping them. "What we send you" in the app has a switch for each kind of reminder, including recording time reminders, and your quiet hours. Every reminder email has a link that stops that kind of email. It works without signing in, and so does your email app's own unsubscribe button. Messages about your account, safety, memories on hold and changes to who keeps a Library are not reminders, and they are always sent.

Pausing a Library. The Storykeeper, and a co-Storykeeper who can add co-Storykeepers, can switch on "Pause messages about this Library". Until it is switched off, we send no reminders about that Library to anyone, including the person it is about, and nothing held back in the meantime is sent later. We can pause a Library's reminders from our side too.

The person a Library is about. They get a weekly reminder, in their own language, only if their Storykeeper switches it on, and only when a question is waiting for them. "Not now, remind me later" pauses it for 14 days. They can ask us to stop it, and we tell their Storykeeper; it then stays off unless the Storykeeper switches it back on. If three reminders in a row go unopened, we stop them and tell the Storykeeper.

If you were invited by email and have not joined. Three days after the invitation, we send you one reminder email for that Library, naming who invited you. Its "Do not remind me again" link keeps a coded fingerprint of your address (a keyed hash, not the address itself), so that no Library sends you an invitation reminder again. It does not stop a family member sending you a new invitation.

4. Who we share it with

We share personal data only with the service providers Nenapu is built on, each acting under our instructions to run the service:

Beyond that, we disclose data only: with your direction (people you invite see what you share with them); if required by law — a subpoena, court order or lawful government request; to prevent serious harm; or, if Nenapu is ever acquired or merged, to a successor bound by this policy (we would notify you first). We never sell personal data, and we never share it for advertising. In the words of the CCPA: we do not "sell" or "share" personal information, and we haven't in the past 12 months.

5. Where your data lives

Our application servers are currently in India. Our media and delivery providers operate globally, so recordings and technical data may be processed in other countries, including the United States. Where GDPR or UK GDPR applies to a transfer, we rely on appropriate safeguards such as our providers' Standard Contractual Clauses. India's DPDP Act permits such transfers to countries not barred by the Indian government.

6. How long we keep it

7. Security

Data is encrypted in transit (TLS) everywhere, and recordings and photos are served through signed links that expire. Video and audio recordings are stored with a media provider that encrypts them at rest; other data — photos, questions, account details — lives on access-restricted servers in India. Access to production systems is restricted to those who operate the service. When our staff open a Memory Library's page in our operator console, that access is logged against them. Passwords are stored hashed, and backups are encrypted with a key held offline before they touch disk. No internet service can promise perfect security, but if a breach ever affects your data we will notify you and the relevant authorities as the law requires — including the 72-hour GDPR window and the Indian Data Protection Board and CERT-In requirements.

8. Your rights

These apply to everyone, everywhere — we don't make you prove your jurisdiction first. Make a request, or email [email protected]. We acknowledge every request within 24 hours and answer it within 30 days. If your request is a grievance under India's IT Rules, the shorter statutory clock in the India section below applies instead:

If you're in India (DPDP Act, 2023)

You have the rights above plus the right to nominate someone to exercise your rights if you die or are incapacitated — for a memory service, we consider that important, and the Storykeeper model in our Terms reflects it. Grievances go to our Grievance Officer, Karthik Kumar ([email protected]) — raise one here, or email with "Grievance" in the subject line. Under the IT Rules, 2021 we acknowledge your grievance within 24 hours and resolve it within 15 days. Where a complaint is about content that exposes you, impersonates you, or shows you in a sexual act or without clothing, we act on it within 24 hours. If it stays unresolved, you may approach the Grievance Appellate Committee or the Data Protection Board of India.

If you're in the EU, UK or EEA (GDPR / UK GDPR)

The rights above are your Articles 15–21 rights. You may also lodge a complaint with your local supervisory authority. Where we rely on legitimate interest, we've balanced it against your rights, and you can ask us about that assessment.

If you're in California (CCPA/CPRA) or another US state with a privacy law

You have the rights to know, delete, correct and port, described above. There is nothing to opt out of: we do not sell or share personal information, and we do not use sensitive personal information beyond providing the service you asked for. You can appoint an authorised agent to act for you.

9. Children

Nenapu accounts are for adults (18+). Families sometimes record children as part of a Memory Library — for example a grandchild asking a question. Where a child appears, we rely on the Storykeeper's confirmation that the child's parent or guardian has agreed, and a parent or guardian can ask us to remove a child's appearance at any time. We never profile children — or anyone — for advertising, and we show no ads. We don't knowingly collect data directly from children; if you believe a child has created an account, tell us and we'll remove it.

10. Automated decisions

Our automated content scanning (described in the Terms) can flag content for a person to review. A very high automated score, or a report from a public page, can put a recording on hold on its own — temporarily unplayable and unshared for everyone. A hold is not a decision: a person reviews the recording and decides what happens to it, and we aim to do that within three days. Removing a recording is always a person's decision. We also review a sample of recordings that nothing has flagged and nobody has reported; every review, whether prompted by a report or part of a routine sample, is logged against the person who carried it out. No decision with legal or similarly significant effect is made about you without a human able to review it — you can always contest a moderation action, or write to [email protected].

11. Changes to this policy

We'll update this policy as the service grows. Material changes will be announced in the app or by email before they take effect, with the version and date updated at the top of this page.

12. Contact

Privacy questions, rights requests, grievances: use our request form, which keeps a record and starts the clock, or email [email protected].