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§ Bryl

Privacy policy

Effective: 2026-05-06 · Last revised 2026-05-07

This is the privacy policy for Bryl, the iOS app for therapy session notes published by Roushan, Inc. Bryl is built on a privacy-by-architecture model: the app does not collect, transmit, or store your professional content on any server. Audio recordings, transcripts, and AI-generated notes never leave your device.

Plain-language summary

  • Audio you record never leaves your iPhone. No upload, no sync, no cloud backup of recordings.
  • Transcripts and notes never leave your device. They live in encrypted local storage on your device.
  • Bryl runs the AI on your iPhone. No prompts, no transcripts, and no notes are sent to OpenAI, Anthropic, or any other AI provider. Inference happens locally via Apple Foundation Models or a bundled on-device model.
  • No accounts. Bryl does not require sign-up, email, or password. There is no user record on any Bryl server because there is no Bryl server that handles your content.
  • No telemetry. Bryl ships with no analytics SDK, no crash reporter, no usage counters. We may add an opt-in (defaults-off) telemetry surface in a future build; if so, this page changes first and the in-app toggle ships in the same release.
  • The only network call Bryl makes is subscription receipt validation through Apple's StoreKit. It never carries your content.

What information Bryl handles

On-device only (never leaves your iPhone)

  • Audio recordings of sessions you capture in the app.
  • Audio files you import from Files, Voice Memos, or via the system Share Sheet.
  • Transcripts produced by on-device speech recognition (FluidAudio Parakeet + Apple Speech).
  • AI-generated notes produced by on-device language models (Apple Foundation Models on iPhone 15 Pro+ / iOS 26+; a bundled local model otherwise).
  • Your edits, notes, custom templates, and session metadata.
  • Encryption keys (stored in iOS Keychain).

These are stored under iOS Data Protection (encrypted at rest while the device is locked) plus an additional AES-256-GCM encryption layer on the local SQLite database. The encryption key lives in iOS Keychain and is never transmitted.

What leaves your iPhone

The complete list of outbound network calls Bryl can make:

  1. Apple StoreKit subscription receipt validation. Apple's framework validates your purchase with Apple's servers when you subscribe, restore, or renew. Bryl does not see, store, or transmit your Apple ID. The transaction information goes from your device to Apple, not to Bryl.
  2. (One-time, on first run, optional) Download of the Parakeet TDT v3 transcription model from a public bucket. You can skip this step and use Apple's built-in Speech framework instead — every clinical workflow continues to function offline once the chosen model is on disk.

That is the complete list. There is no telemetry SDK, no crash reporter, no analytics — Bryl is built without them. You can verify it yourself by enabling Airplane Mode after first launch — Bryl continues to function for recording, transcription, generation, editing, and export.

What Bryl does not do

  • Bryl does not have user accounts.
  • Bryl does not have a backend that handles your content.
  • Bryl does not sell, rent, or share your data with anyone.
  • Bryl does not use AI providers (OpenAI, Anthropic, Google, etc.) for content processing.
  • Bryl does not require, accept, or process Protected Health Information through cloud services. Because all processing is on-device, no Business Associate Agreement is required between you and Bryl.
  • Bryl does not include third-party advertising SDKs, attribution SDKs, or trackers.
  • Bryl does not access your contacts, photos library, or location unless you explicitly grant permission for a specific feature.

Data retention and deletion

Because Bryl stores all content on your iPhone, you control retention directly:

  • Delete a session → its audio, transcript, and note are removed from your device immediately.
  • Settings → Privacy & Security → “Erase all data” → wipes all sessions, transcripts, notes, encryption keys, and templates. Single tap, double-confirm, irreversible.
  • Uninstalling Bryl → removes everything (iOS standard behavior).

There is no Bryl server to request deletion from, because there is no Bryl server that stores your content. Subscription receipts are held by Apple, not Bryl; you can manage them via Settings → Apple ID → Subscriptions.

HIPAA, DPDP, GDPR, and similar regulations

Bryl is built on privacy by architecture: because no Personal Health Information leaves your iPhone, Bryl is not a Business Associate, Data Fiduciary, Data Controller, or Data Processor for your professional content. You — the licensed professional using Bryl — remain solely responsible for your patients' data, the same way you are when writing notes by hand on paper. Bryl is the on-device tool that helps you draft notes; it does not see, transmit, or hold the content.

See the architectural attestation for a written overview suitable for your compliance file.

Children's privacy

Bryl is intended for use by licensed mental-health professionals (psychotherapists, psychologists, counselors, social workers) and their adult clients. Bryl is not directed at children under 13. Bryl does not knowingly collect data from anyone, including children, because Bryl does not collect data from anyone at all.

Subscription, billing, and refunds

Subscriptions and one-time lifetime purchases are processed by Apple via the App Store. Apple shares with Bryl only the information necessary to verify your entitlement (the subscription / one-time-purchase status, validated by signed receipt). Bryl does not see your payment method, billing address, or Apple ID. Refunds are governed by Apple's policy and are requested via Apple at reportaproblem.apple.com.

Waitlist

If you submit your email address on bryl.app to join the closed-beta waitlist, that email is stored in a Cloudflare KV store associated with this site, alongside the timestamp, an approximate country code from Cloudflare's edge, and the originating page. We use it for one purpose: to email you when your invite is ready. We do not share the list, sell it, or send marketing to it. You can request removal at any time by emailing privacy@bryl.app.

Outbound email (your “you're on the list” confirmation, plus an internal notification to our ops inbox) is sent via Cloudflare's Email Sending service from the same Cloudflare account that hosts this site.

Analytics on bryl.app (this marketing site only)

The Bryl iOS app ships with no analytics SDKs of any kind. The bryl.app marketing website is a separate surface where, with your explicit consent only, we use two analytics tools:

  • PostHog — for aggregated product-style metrics (which sections of the page people read, where the waitlist conversion happens). Cookieless by default; we keep autocapture and session-recording disabled.
  • Google Analytics 4 — for traffic shape and acquisition-channel reporting. We run it under Consent Mode v2 with all advertising signals denied; only aggregated/modeled traffic data flows to Google.

Both vendors are blocked by default. They only fire after you click “Allow analytics” in the consent banner. You can revoke consent any time via the “Manage analytics” link in the footer, which clears the local consent state and stops both vendors from receiving further events. We do not have an analytics tool that “phones home” before you opt in.

We do not use any advertising, attribution, or session-replay vendor on this site. Cloudflare's built-in edge logs (Worker traces) record raw request metadata for debugging and abuse prevention, like any web host's — they do not contain analytics data and are retained for a short period in line with Cloudflare's standard practice.

Consent record

When you click Allow analytics or Decline, we record a small consent receipt in our Cloudflare KV namespace so we can demonstrate, under GDPR Art. 7(1) and similar regimes, that consent was captured. The receipt contains: the decision (granted or denied), the privacy-policy version you decided against, the local timestamp of the decision, the server-side timestamp the receipt was written, your country code from Cloudflare's edge, your User-Agent string (truncated to 200 characters), and your IP truncated to a /24 prefix (e.g., 203.0.113.0) so the receipt cannot be used to re-identify you on its own. The receipt is keyed by a random UUID, never by your email or any other stable identifier we hold. We retain it for 24 months and then delete it. You can request its deletion sooner by emailing privacy@bryl.app — though without a stable identifier we will need additional information from you to locate the specific record.

Your rights (GDPR, UK GDPR, CCPA / CPRA, and other regimes)

Because the Bryl iOS app does not collect, transmit, or store any personal data on a Bryl-controlled server, most data-subject rights resolve trivially: there is no Bryl-side record to access, correct, port, or delete. Your audio, transcripts, and notes live on your iPhone — uninstalling the app or wiping the device removes them. This section nonetheless states each right explicitly so you can verify your jurisdiction's requirements.

For waitlist email addresses, marketing-site analytics that you have explicitly consented to, and direct correspondence (e.g., emailing privacy@bryl.app), Roushan, Inc. is the data controller and you have the following rights:

  • Right of access (GDPR Art. 15 / UK GDPR / CCPA § 1798.110). You can request a copy of the personal data we hold about you. For most users this is one record: your waitlist email and the timestamp at which it was captured.
  • Right of rectification (GDPR Art. 16 / UK GDPR). You can ask us to correct inaccurate data. (You can also just email us the new value.)
  • Right of erasure / “right to be forgotten” (GDPR Art. 17 / UK GDPR / CCPA § 1798.105). You can ask us to delete the personal data we hold about you. We will action waitlist deletions within one business day; the email and any associated record is removed from Cloudflare KV.
  • Right to data portability (GDPR Art. 20 / UK GDPR / CPRA). You can request your data in a portable, machine-readable format. We will return JSON.
  • Right to restriction of processing (GDPR Art. 18) and right to object (GDPR Art. 21). You can ask us to stop processing your data, including for direct marketing (which we do not do, but the right exists nonetheless).
  • Right to opt-out of sale or sharing (CCPA § 1798.120 / CPRA). Roushan, Inc. does not sell or share your personal information for cross-context behavioral advertising or any other purpose. There is nothing to opt out of, but the right is reserved to you.
  • Right of non-discrimination (CCPA § 1798.125). Exercising any of these rights does not change the price, level, or quality of the Bryl product available to you.
  • Right to know about automated decision-making (GDPR Art. 22). Bryl performs no automated decision-making about you. Note generation runs on your device against transcripts you supply; the output is a draft for you to review and edit, not a decision Bryl makes about you.

To exercise any of the above, email privacy@bryl.app from the address you used. We will respond within 30 days (and typically within one business day). Verification: for waitlist requests, we verify by sending a confirmation to the email address on file.

Lawful basis (GDPR Art. 6). The lawful basis for storing your waitlist email is either (a) your explicit consent (Art. 6(1)(a)), provided when you submit the form, or (b) our legitimate interest in contacting you when the closed beta opens (Art. 6(1)(f)). The lawful basis for marketing-site analytics, when enabled, is your explicit consent (Art. 6(1)(a)).

International transfers. Bryl is operated by Roushan, Inc. (a Delaware, USA corporation). Data we hold (the waitlist email, marketing-site analytics if you have consented) is processed in the United States. Cloudflare may route processing through edge locations near you. For EU/UK/Swiss users, we rely on the EU–US Data Privacy Framework (where applicable) and the European Commission's Standard Contractual Clauses (SCCs) for any onward transfer.

Right to lodge a complaint. If you are in the EU, UK, or Switzerland, you have the right to lodge a complaint with your local data-protection authority. Examples: in the UK, the Information Commissioner's Office (ico.org.uk); in Ireland, the Data Protection Commission (dataprotection.ie); a directory for other EU member states is at edpb.europa.eu. We would prefer you raise concerns with us first, but the right is yours regardless.

Children. Bryl is a tool for licensed mental health professionals and is not directed to anyone under 18. Roushan, Inc. does not knowingly collect personal information from children; if you believe we have, email privacy@bryl.app and we will delete it.

Changes to this policy

If Bryl ever changes how it handles privacy (for example, if a feature is added that involves any new outbound data flow), we will update this document with a new effective date and show you an in-app notice describing what changed.

Contact

Privacy questions: privacy@bryl.app
General support: support@bryl.app

Roushan, Inc.
1111B S Governors Ave STE 55131
Dover, DE 19904
United States

Verifying the privacy claims

  1. Turn on Airplane Mode on your iPhone.
  2. Open Bryl.
  3. Record a session, transcribe it, generate a note, and export it.
  4. Everything works.

If anything required network access for content, it would fail in Airplane Mode. It does not. That is the proof.