Privacy Policy
Effective date: 01 August 2026 Last updated: 01 August 2026
1. About this Policy
This Privacy Policy explains how Discursia Ltd ("Discursia", "we", "us", "our") collects, uses, and protects personal data when you use the Discursia mobile application (the "App") and the website at discursiaapp.com (the "Website"). Together, the App and the Website are referred to as the "Service".
Discursia Ltd is the data controller for the personal data described in this Policy.
Registered office: Discursia Ltd Unit A, 82 James Carter Road Mildenhall Bury St. Edmunds Suffolk IP28 7DE United Kingdom
ICO registration number: ZC144519
Data Protection Officer: Contactable at privacy@discursiaapp.com.
We are committed to protecting your privacy and handling your personal data transparently, lawfully, and in line with the UK General Data Protection Regulation ("UK GDPR"), the EU GDPR (where applicable), and the Data Protection Act 2018.
2. Summary, the Short Version
We have tried to keep this Policy as plain as we can. The essentials are:
- Discursia is strictly for users aged 18 and over. We use a secure third-party age verification partner to verify your age, and they do not store your image or document or use it to train their models.
- For your safety, the audio of every call is recorded and we capture periodic screenshots of the video. No human or AI ever listens to the audio. AI reviews all screenshots first; clean screenshots are deleted automatically within 24 hours of the call ending and are not seen by a human. If a report is filed or our automated moderation flags something, the file may be kept for up to 7 days if an investigation is required, then deleted unless an investigation is still active.
- We collect only what we need to run the Service and keep it safe.
- We collect your email and phone number partly to send you sign-in codes, and partly to stop banned users from returning to harm the community.
- Ads in the App are based on the topic you have just discussed. The advertising platform we use may also use data they already hold about you to personalise those ads further. You can switch off this personalisation through the iOS App Tracking Transparency prompt on first launch and through your device settings, as explained in Section 7. We never share your conversations, recordings, screenshots, name, email, or phone number with any advertiser.
- We do not sell your personal data, and we do not use your conversations, recordings, or screenshots to train AI models, and neither do our carefully selected third-parties to maintain your privacy.
- You can delete your account in the App at any time. Your personal identifying details (name, email, and phone number) are permanently scrambled and anonymized straight away, freeing up your credentials so you can register a new account in the future if you choose. We only retain the email and phone numbers of banned users on our secure blocklist to protect the community.
The full detail follows.
3. The Data We Collect
Examples
Source
Account data
Name, email address, phone number, profile picture
You, at sign-up
Verification data
An 18+ pass or fail result from our age verification partner, plus your estimated age. We do not receive or store your identity document or the biometric scan. Our partner acts as a separate data controller for those, and they do not use customer verification data to train their models and delete verification artefacts after the check is complete.
Age verification partner
Profile data
Gender, region, declared interests and topics
You, at sign-up
Call data
Topic selected, call duration, partner matched, periodic video screenshots, call audio. Audio and screenshots are deleted automatically within 24 hours of the call ending if nothing has been flagged or reported. No human or AI ever listens to your call audio. AI reviews all screenshots first; clean screenshots are not seen by a human.
Generated when you use the App
Microphone access for setup
We briefly access the microphone on your first call or when your settings are not optimal so we can suggest the best audio settings for clearer calls. No audio captured in this step is recorded, transmitted, or stored.
Generated when you use the App
Device and technical data
Device model, operating system version, app version, IP address, mobile advertising identifier (IDFA on iOS or Android Advertising ID on Android), push notification token, crash logs, performance and usage events
Automatically, via the App and our diagnostics provider
Communications data
The content of any email or in-app support message you send us, plus reports you file about other users (name, contact details, reason for the report)
You, when you contact us or report a user
We do not collect: payment data (the App is free and currently has no paid tier), precise GPS location, your contacts list, your photo library, or any biometric data. If you choose to sign in using Face ID, Touch ID, or fingerprint, the biometric match happens entirely on your device's secure chip. We only receive a yes-or-no authentication signal. Your biometric data never leaves your device and is never visible to us.
4. How We Use Your Data and the Lawful Basis for Each Use
UK GDPR requires us to have a "lawful basis" for every use of your data. The breakdown is as follows.
Data involved
Lawful basis
Create and manage your account
Name, email, phone, profile picture
Contract (necessary to provide the Service)
Verify you are aged 18 or over
Age verification result
Legal obligation and legitimate interest (safeguarding minors)
Match you with another user on a topic
Profile data, interests, topic selected
Contract
Keep calls safe by recording audio and capturing screenshots
Call audio, video screenshots. Deleted within 24 hours unless flagged or reported. Never used to train AI models. Never sold or shared with any third party for commercial purposes.
Legitimate interest (protecting users from harm, illegal content, and abuse)
Investigate reports of abuse or policy violations
The reported user's call audio, screenshots, account data, plus the reporter's details
Legitimate interest (community safety), and legal obligation if law enforcement is involved
Prevent banned users from re-registering
Email, phone, device identifiers
Legitimate interest (community safety, see Section 8)
Send sign-in codes (one-time passwords)
Email and phone number
Contract
Send other service messages (password reset, ban notice, important policy updates)
Email
Contract
Send in-app and push notifications when a topic room you might want is open
Push notification token
Legitimate interest (delivering the core Service). You can switch all notifications off in your device settings, or via the "Allow notifications" toggle in the App's settings menu. If you do, you may miss invitations to topic rooms.
Send marketing or promotional messages
Email, push notification token
Consent. You can withdraw at any time using the unsubscribe link in every marketing email or by turning off notifications via your device settings.
Show contextual ads based on the call topic, and let our advertising partner personalise those ads using data they already hold about you
Topic label, mobile advertising identifier, IP address, device data (see Section 7)
Legitimate interest, with your right to opt out (see Sections 7 and 20)
Diagnose crashes and improve the App
Device data, crash logs, anonymised usage events
Legitimate interest (service stability)
Comply with legal requests
Any of the above
Legal obligation
You can object to any processing based on legitimate interest. See Section 13.
5. Audio Recording, Please Read This Carefully
The audio of every call you make on Discursia is recorded. You will be told this before your first call, and you must agree before you can use the Service. This is not reviewed by AI or humans unless there is an investigation.
- Why we do it. To protect you and other users from harassment, illegal conduct, and abuse.
- Who can listen. No human or AI listens to your call audio under any circumstances, unless a serious report has been filed and a member of our Trust and Safety team is investigating it.
- How long we keep it. Recordings are deleted automatically within 24 hours of the call ending if no report is filed.
- If a report is filed. The recording is retained for up to 7 days while our Trust and Safety team investigates, then deleted unless it forms part of an ongoing legal matter or law enforcement request.
- What we never do with it. We never use call audio for analytics, advertising, or training AI models. We never share it with advertisers or any commercial third party.
- Where it is stored. Encrypted, within our secure cloud infrastructure located in the European Economic Area.
- When we share it. Only when we are legally compelled to do so, for example a court order or a police request relating to a serious investigation.
This recording is authorised under your acceptance of our Terms and Conditions, and complies with the Regulation of Investigatory Powers Act 2000 (RIPA) and the UK GDPR.
6. Screenshot Moderation
To detect nudity, weapons, and other prohibited content during calls, we capture periodic still-image screenshots of the video feed. None of this is used outside of moderation purposes.
- Screenshots are analysed automatically by an image-moderation service running within our secure cloud infrastructure located in the European Economic Area. They do not store this information or use it for model training at all.
- Clean screenshots are deleted within 24 hours and no human or AI ever sees them again.
- Where the moderation service flags an image with high confidence of a serious violation, the offending account may be actioned (for example, suspended or banned) automatically without further human review.
- Where the moderation service flags an image with lower confidence, or where a user has filed a report, a member of our Trust and Safety team may review the image to decide whether action is warranted. The team's level of review reflects the severity of the potential violation.
- In-app Reporting and Blocking: You can instantly report any user or block them directly from within the app. Blocked users will not be able to match with you again.
- Flagged screenshots are kept for up to 7 days, then deleted unless an investigation is still active.
- Our automated safety moderation scans video screenshots strictly for safety violations (such as nudity, graphic content, or weapons) and does not extract, process, or store biometric templates, facial geometry, or unique facial identifiers.
7. Advertising and How It Works on Discursia
Discursia is funded by contextual advertising. The model is intended to be as private as a free, ad-funded service can be.
- After certain calls, you may see an advert related to the topic you just discussed. For example, after a "Tennis" call you might see an advert for tennis equipment.
- We use established advertising platforms to serve these ads.
- What is shared with the advertising platform from inside Discursia. The topic label of your call (for example "Tennis"), the data the advertising software collects automatically including your mobile advertising identifier, your IP address and device model, and your interaction with the ad itself.
- What is never shared with the advertising platform. Your name, email, phone number, profile picture, call audio, video screenshots, conversation content, your list of past topics, your gender, or any other profile field.
About ad personalisation and cross-app tracking. Because we currently use standard advertising SDKs, our advertising partners may use the data collected from inside Discursia (such as your IP address and mobile advertising ID) and combine it with data they already hold about you from other apps and websites. This allows them to build a richer profile of you and serve personalised ads. For example, if you have been searching for tennis rackets elsewhere and you join the Tennis topic in Discursia, you may see ads for tennis rackets. Discursia does not build that profile, does not see it, and does not provide our partners with any personal data like your name or email, but you should be aware that cross-app tracking takes place.
We are continuing to refine our advertising setup so that in the future, as little data as technically possible leaves the App, and so that no third party can use Discursia to passively observe what you are doing. Until then, standard tracking applies unless you opt out.
You can switch personalisation off at any time.
- The first time you open the App on iOS, you will see Apple's App Tracking Transparency prompt. Tapping "Ask App Not to Track" stops the ad personalisation described above.
- On iOS at the device level: Settings → Privacy and Security → Tracking → switch off "Allow Apps to Request to Track", and Settings → Privacy and Security → Apple Advertising → switch off "Personalised Ads".
- On Android at the device level: Settings → Google → Ads → "Delete advertising ID" or "Opt out of Ads Personalisation".
- California residents can also opt out by emailing privacy@discursiaapp.com (see Section 20).
We do not sell your personal data. We do not use any data from your conversations, recordings, screenshots, or moderation logs for advertising of any kind.
8. Ban Evasion and Safe Voluntary Account Deletion
To keep Discursia safe and compliant, we handle account closures based on why the account was closed:
- Ban Evasion (Involuntary Ban): If a user is removed from Discursia for violating our acceptable use rules, we retain their email address and phone number on our secure backend blocklist for 3 years. This is legally processed under our Legitimate Interest (community safety) to prevent them from creating new accounts and returning to harm other users.
- Voluntary Account Deletion (Innocent Users): If you voluntarily choose to delete your account, we completely and permanently anonymize your name, email, and phone number immediately. We do not retain your raw contact details. This ensures complete privacy compliance and frees up your original phone number so you can register a fresh account in the future if you choose.
- Lawful basis: Legitimate interest for ban enforcement; Consent and Contract for voluntary deletions.
- Retention: 3 years for banned users; Instant anonymization for voluntary deletions.
9. Who We Share Your Data With
We only share your data with the service providers below, each of whom is contractually obliged to protect it and use it only for the purposes we instruct.
What they do
Data Shared
Location
Amazon Web Services (AWS)
Hosts our backend, user database, audio recordings, screenshots, and runs our automated image-moderation service. AWS does not use these images to train its models.
All call data and all account data
eu-north-1 (Stockholm, Sweden)
Yoti
Verifies your age at sign-up. Yoti does not use your verification data to train its models and deletes verification artefacts after the check.
Identity document and biometric scan (handled by Yoti as a separate controller). We only receive a pass or fail and your date of birth.
United Kingdom
Google
Serves contextual ads (and personalised ads, until you opt out). Also provides services we use for crash reporting, performance monitoring, and push notifications.
For advertising: topic label, mobile advertising ID, IP address, device data, see Section 7. For diagnostics and notifications: crash logs, device data, push token, anonymised usage events.
Global Google infrastructure
Law enforcement
When legally compelled, for example by a court order or police request
Whatever is specifically required by the request
UK
We do not sell your personal data. We do not share it with data brokers, marketing partners, or analytics providers beyond those listed above.
10. International Data Transfers
Most of your data is stored within the European Economic Area in our secure cloud infrastructure.
Some of our service providers may transfer data outside the UK and EEA, including to the United States. Where this happens, we rely on the following safeguards:
- The UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses (SCCs).
- The relevant EU Standard Contractual Clauses (2021/914) for EU users.
- Additional technical and organisational measures where appropriate, such as encryption in transit and at rest.
You can request a copy of these safeguards by contacting privacy@discursiaapp.com.
11. How Long We Keep Your Data
Retention period
Call audio (no report)
Deleted within 24 hours
Call audio (reported)
Up to 7 days, then deleted unless an investigation is active
Video screenshots (no flag)
Deleted within 24 hours
Video screenshots (flagged or reported)
Up to 7 days, then deleted unless an investigation is active
Report records (reporter's name, contact, reason, status such as completed)
3 years, to safeguard our platform and track any patterns so we can act better
Account data (active users)
For as long as your account is active
Account data (after self-serve deletion)
Wiped and completely anonymized immediately. Scrambled email and phone placeholders are preserved purely for database schema structure with zero personal identifying details.
Email and phone of banned users
3 years, for ban evasion prevention only
Crash logs and anonymised usage data
Up to 12 months
Marketing email records
Until you unsubscribe, plus 30 days
12. Where Your Data Is Stored
Your data is held within our cloud infrastructure in the European Economic Area, encrypted in transit using Transport Layer Security (TLS) and at rest using enterprise-grade Advanced Encryption Standard (AES-256) cryptographic keys. Data shared with Google may be processed on Google's global infrastructure, subject to the safeguards in Section 10.
13. Your Rights
Under UK GDPR and EU GDPR you have the rights listed below. They are free to exercise, and we will respond within one calendar month.
- Access. Request a copy of the personal data we hold about you.
- Rectification. Ask us to correct inaccurate data.
- Erasure (the right to be forgotten). Ask us to delete your data. We may keep limited records where the law requires us to.
- Restriction. Ask us to pause processing while a dispute is resolved.
- Portability. Receive your data in a structured, machine-readable format, or have it sent to another provider.
- Objection. Object to processing based on legitimate interest (Sections 4 and 8), or to direct marketing.
- Withdraw consent. Where we rely on consent (for example, marketing), you can withdraw at any time.
- Lodge a complaint. See Section 18.
How to exercise these rights.
- For most rights, email privacy@discursiaapp.com.
- For account deletion, you can do this yourself in the App: Menu → Delete Account → Delete Account → Enter Password → Confirm. If you no longer have the app installed, you can also request account deletion by emailing privacy@discursiaapp.com from your registered email address. Your data is removed straight away, with the limited legal exceptions listed in Section 11.
- For data export, email privacy@discursiaapp.com and we will provide your data within one calendar month.
We may ask you to verify your identity before fulfilling a request.
14. Children and Minors
Discursia is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18.
We use a secure third-party age verification partner to verify your age at sign-up. To complete this check, our partner may process a brief video selfie or facial image solely to estimate your age or match against a government ID. Discursia never receives, views, or stores your facial scans or document images. All biometric processing is executed securely by our partner as an independent data controller, and they delete all biometric artifacts immediately after the check is complete. We may also re-verify a user's age at any time if we receive a report or notice anything that suggests a user may not meet the minimum age.
If you believe a minor is using Discursia, please email privacy@discursiaapp.com. We will:
- Suspend the suspected account immediately.
- Require the user to re-verify their age with a government-issued identity document.
- Delete the account and all associated data permanently if the user fails verification.
If you are a parent or guardian and believe that your child under the age of 18 has bypassed our verification and provided personal data to us, please contact us immediately at privacy@discursiaapp.com, and we will take immediate steps to delete such information from our systems.
15. Security
We protect your data using industry-standard measures, including:
- Encryption in transit (TLS) and at rest.
- Access controls. Only authorised Trust and Safety team members can review flagged content.
- Storage in our secure cloud infrastructure with enterprise-grade security controls.
- Automated deletion schedules, so clean call data is destroyed within 24 hours.
- Logging and audit trails for any access to user data.
No system is perfectly secure. If we ever discover a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours, and inform you without undue delay where the law requires it.
16. Cookies and the Website
The Website at discursiaapp.com uses a limited number of cookies. See our separate Cookie Policy for the detail.
The App does not use cookies. It uses your device's standard application storage to remember your sign-in and your preferences.
17. Changes to This Policy
We may update this Policy from time to time. If we make a material change (for example, adding a new category of data we collect, a new third party we share data with, or a significant change to your rights), we will notify you by email to the address linked to your account at least 14 days before the change takes effect.
Non-material changes (clarifications and typo fixes) will be reflected in the "Last updated" date at the top of this page without a separate notification.
18. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at privacy@discursiaapp.com so that we can try to resolve the issue.
You also have the right to lodge a complaint with the UK's data protection regulator:
Information Commissioner's Office (ICO) Wycliffe House, Water Lane Wilmslow, Cheshire SK9 5AF United Kingdom Helpline: 0303 123 1113 Web: ico.org.uk
EU users may also lodge a complaint with their local data protection authority.
19. California Residents, Your CCPA and CPRA Rights
If you are a resident of California, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
Your rights.
- The right to know what personal information we collect, use, disclose, and share, and to receive a copy of it.
- The right to delete the personal information we hold about you, subject to legal exceptions.
- The right to correct inaccurate personal information.
- The right to opt out of the "sale" or "sharing" of your personal information (see below).
- The right to limit the use of sensitive personal information. We do not use sensitive personal information for any purpose beyond what is strictly necessary to provide the Service and keep it safe.
- The right to non-discrimination for exercising any of these rights.
What we share. Discursia does not sell your personal information for money. However, when you use the App with ad personalisation switched on, our advertising partner may combine the data it sees inside Discursia with data it holds about you elsewhere in order to personalise the ads you see. Under California law, that combination is treated as "sharing" your personal information for cross-context behavioural advertising, even though no money changes hands.
How to opt out. You can stop this at any time by tapping "Ask App Not to Track" on the App Tracking Transparency prompt that appears on first launch on iOS, by switching off Personalised Ads in your device settings (see Section 7), or by emailing privacy@discursiaapp.com with the subject line "California Privacy Request". We treat the Global Privacy Control browser signal as a valid opt-out on the Website. We will respond to email requests within 45 days.
We do not knowingly sell or share the personal information of California residents under 16.
We do not sell your personal information. However, our use of standard advertising networks (Google AdMob) may constitute 'sharing' of your mobile advertising ID and IP address for behavioral advertising under California law. You can opt out of this sharing at any time through your device tracking settings or by tapping "Ask App Not to Track" on first launch on iOS.
20. Contact Us
For any privacy question or request:
Email: privacy@discursiaapp.com Post: Data Protection Officer, Discursia Ltd, Unit A, 82 James Carter Road, Mildenhall, Bury St. Edmunds, Suffolk IP28 7DE, United Kingdom
