Engram Terms of Use

Privacy Policy

Effective date: 15 October 2026

In short

  • You don't need an account to use Engram.
  • Your saves, photos, notes and the text recognised in them are stored only on your phone, encrypted. HKSolutions cannot access them and they are not sent to our servers.
  • Text recognition, place names from photo location, image recognition and search run on your phone.
  • Two Google components we use (ML Kit and Google Play Billing) may send technical diagnostics without content to Google (see 3.4).
  • Our server only serves the image model download and checks purchases; it runs in Finland (EU) and keeps no access logs.
  • This version sends no crash reports. We show no ads, run no usage analytics and don't sell your data.

1. Controller

This policy applies to the Engram mobile app and the sunizeka.org web pages, developed by HKSolutions (“we”). HKSolutions is the data controller under the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where applicable, the EU General Data Protection Regulation (“GDPR”).

Address: [legal form and address of HKSolutions]
Email: [support / privacy email address]

2. Our core principle

Engram is local-first. Your content is kept in an encrypted vault on your phone. Its core functions (saving, recognising, searching, exporting and deleting) work without an internet connection and send no content to HKSolutions.

3. What data is processed, where and why

3.1 Your saves (on your phone only)

Photos, screenshots, links, PDFs and notes you share or add; your save reasons; collections and reminders; text recognised in photos; the date a photo was taken and the city/district derived from its location. These are stored in an encrypted database (SQLCipher) and individually encrypted files on your phone. The encryption key is protected by your phone's secure key store (Android Keystore). HKSolutions cannot access this data.

3.2 Permissions

PermissionWhy
Photo location (ACCESS_MEDIA_LOCATION)To read the location of photos you share and convert it to a city/district name on your phone. Optional; without it, place search doesn't work but everything else does.
Notifications, exact alarms and running after a restartTo show your reminders on time. Notifications never show the content of your save.
Biometrics / screen lockTo unlock the vault. Android performs the fingerprint check; your fingerprint never reaches us or the app.
Google Play billingEngram Plus purchases.
Internet and network stateLink previews (if you turn them on), the optional image model download and purchases.

3.3 On-device AI and optional model download

Text recognition (Google ML Kit and a separate on-device engine for Cyrillic that ships with the app), place names from location, and image recognition run on your phone; no content is sent to any server for them. The image model that recognises photos without text is downloaded once, only with your consent and over Wi-Fi, from our server (sunizeka.org, see 3.8). As with any internet request, your IP address reaches our server; only the model file is downloaded and no data about you is sent. The file is checked before use and can be removed in Settings.

3.4 Technical diagnostics from Google components

Engram uses Google ML Kit for text recognition and Google Play Billing for purchases. These libraries may send technical diagnostics to Google (firebaselogging.googleapis.com) when your phone is online, so that Google can operate and improve its services. Based on our review, this may include: the app's name and version, the device manufacturer and model, Android version, network type, language, country, time zone, a random identifier for this installation, which function ran, how long it took, image dimensions and error codes. Your saves, recognised text, photos and searches are not included. Google describes the ML Kit part at https://developers.google.com/ml-kit/android-data-disclosure and its processing is governed by Google's privacy policy: https://policies.google.com/privacy. The app has no setting to turn this off.

3.5 Crash reports

This version sends no crash reports and has no crash-report switch in Settings. In versions for which we run our own crash-report server, the switch is off by default. If you turn it on and the app crashes, a report is stored on your phone and sent at the next start to our own, self-hosted server (no third-party crash service). A report contains only the type of error and where in the app's code it happened, the app version, the operating system, a coarse device class (phone or tablet, processor type, memory range), the hour it happened and a random report ID. It never contains the error text, your saves, notes, searches, file names, links, or any account or device identifier. The retention period will be stated in this policy when the feature is offered.

3.6 Engram Plus purchases

Purchases are made through Google Play. Your payment details are processed by Google and never reach us. When you buy or restore Plus, and from time to time while you have it, the purchase token from Google Play is sent to our server and checked there with Google Play. The token, product ID and subscription status are kept with a random account number created for this, which is not linked to your name, email address or phone number and has no link to the content of your saves. If our server cannot be reached, your purchase keeps working.

3.7 Exports and backups

Export files are created only when you ask, encrypted with a passphrase you choose, and saved where you choose. With Engram Plus, automatic backups are encrypted on your phone with a recovery key only you hold and written to a folder you choose (for example Google Drive), which keeps the newest 3. The folder's provider stores them under its own terms and cannot read them; we do not receive them.

3.8 Our server and this website

Our server is run by HKSolutions on a machine rented from Hetzner Online GmbH (Germany) in its data centre in Helsinki, Finland (European Union); Hetzner processes data only on our behalf. In this version the server does two things: it serves the image model download and it checks purchases. It sees your IP address as part of each connection but keeps no access logs. sunizeka.org uses no cookies, analytics or tracking tools and loads no external fonts or scripts.

4. Legal bases

Because your saves are processed only on your phone, HKSolutions does not process them. For the limited data HKSolutions does process: performance of a contract for purchase verification (KVKK Art. 5/2-c; GDPR Art. 6(1)(b)); legitimate interest for serving the model file and web pages you request and for server security (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)); your explicit consent for crash reports, if they are offered later (KVKK Art. 5/1; GDPR Art. 6(1)(a)).

5. Recipients and international transfers

For users in Turkey this is a transfer abroad. Transfers are made in line with KVKK Art. 9 and the relevant GDPR provisions.

6. Retention and deletion

7. Security

The database and files are encrypted on your phone; the key is kept in a hardware-backed key store. The vault lock (it locks again after the app has been in the background for more than 30 seconds), hidden previews in the recent-apps screen and blocked in-app screenshots add further protection. No system can guarantee perfect security; we recommend using your phone's screen lock and exporting regularly.

8. Your rights

Under KVKK Art. 11 and the GDPR you have the right to know whether your data is processed, to request information, rectification and erasure, to object, to know third parties to whom data is transferred, and to seek compensation for damage. Since your saves are only on your phone, you can view, export and delete them directly in the app. For data processed by HKSolutions, contact [support / privacy email address]. You also have the right to complain to the Turkish Personal Data Protection Authority or the data protection authority in your country.

9. Information about others

Screenshots and photos you save may contain information about other people. This content is stored only on your phone. You are responsible for respecting the rights of others when saving and sharing their information.

10. Children

Engram is not directed at children under 16 and we do not knowingly collect data from children.

11. Future online features

This version of Engram has no feature that sends the content of your saves to a server. Later versions may offer the following; each is off until you turn it on and is explained before you agree, and the AI provider is named here before it is offered:

12. Changes

We may update this policy. We will announce significant changes in the app and on this page before they apply. The effective date is shown at the top.

13. Contact

HKSolutions · [legal form and address of HKSolutions] · [support / privacy email address]