Privacy Policy

Account Information:

• Full name or username
• Email address
• Password (handled and encrypted by Firebase Authentication; we do not store passwords on our servers)
• Date of birth (for age verification)
• Profile information you choose to add
• Account preferences and settings

Survey and Assessment Data:

• Responses to personality questionnaires
• Self-discovery survey answers
• Goal-setting information
• Life wheel assessment data
• Progress tracking information
• Preferences and interests

User Content:

• Reflections and journal entries
• AI coaching conversation history
• Notes and personal insights
• Goals and action plans
• Mindfulness practice logs
• Any other content you choose to submit

Communication Data:

• Customer support inquiries and correspondence
• Feedback and survey responses
• Communications preferences

Payment Information:

• Payment card details (collected and processed by Stripe, Inc.)
• Billing address
• Transaction history
• Promotional codes used

Device Information:

• Device type, model, and operating system
• Mobile device identifiers
• Device settings and preferences
• Browser type and version
• IP address
• Time zone settings

Usage Data:

• Features and content accessed
• Time spent on different sections of the App
• Interaction patterns and engagement metrics
• Session duration and frequency
• Navigation paths within the App
• App performance data
• Error logs and crash reports

Location Information:

• Approximate location based on IP address
• Precise geolocation (only if you grant permission, and it is required to provide services)
• Time zone information

Cookies and Similar Technologies:

• Session cookies
• Preference cookies
• Analytics cookies
• Advertising cookies (with consent)

For more information about our use of cookies, please see our Cookie Policy.

• Social Media: If you connect your social media accounts, we may receive profile information as permitted by your privacy settings
• Payment Processors: Transaction confirmations and payment status from Stripe
• Analytics Providers: Aggregated usage statistics and performance data
• Third-Party Services: Information from integrated services you authorize us to access

• Create and manage your account
• Deliver personalized AI-powered insights, recommendations, and coaching
• Generate personality analyses and compatibility assessments
• Provide daily insights and micro-tasks tailored to your profile
• Enable goal tracking and progress monitoring
• Deliver mindfulness practices and guided content
• Process and fulfill your subscription requests
• Provide customer support and respond to your inquiries
• Send service-related communications and notifications
• Improve and optimize the App's functionality and user experience
• Develop new features and services

• Train, test, and improve our artificial intelligence algorithms
• Develop and enhance machine learning models
• Create personalized user experiences based on AI-generated insights
• Generate anonymized and aggregated datasets for research and development
• Improve the accuracy and relevance of AI-generated content

• Process subscription payments and manage billing
• Prevent fraudulent transactions
• Handle refund requests
• Maintain transaction records for accounting purposes

• Send you important updates about the Services
• Notify you about changes to our policies or terms
• Respond to your comments, questions, and requests
• Send you promotional communications (with your consent)
• Conduct surveys and collect feedback

• Analyze usage patterns and trends
• Measure the effectiveness of features and content
• Conduct statistical analysis and research
• Generate anonymized, aggregated data for business intelligence

• Protect against, identify, and prevent fraud and other illegal activity
• Enforce our Terms of Use and other policies
• Comply with legal obligations and respond to legal requests
• Protect the rights, property, or safety of the Company, users, or others
• Monitor and ensure the security of our systems

• Display personalized advertisements and promotional content
• Measure advertising effectiveness
• Conduct marketing campaigns
• Send promotional emails and notifications (which you can opt out of)

• Processing necessary to provide the Services you requested
• Processing necessary to fulfill our contractual obligations to you

• Processing of special category data (e.g., personality assessments that may reveal sensitive information)
• Marketing communications and promotional content
• Optional features that require explicit consent
• Non-essential cookies and tracking technologies

• Improving and optimizing our Services
• Training and developing AI models to enhance user experience
• Conducting analytics and research
• Detecting and preventing fraud
• Ensuring network and information security
• Internal administrative purposes
• Understanding how users interact with our Services

We have balanced our legitimate interests against your rights and freedoms and have implemented appropriate safeguards.

• Compliance with applicable laws and regulations
• Responding to legal requests and court orders
• Tax and accounting obligations

We engage trusted third-party service providers who process personal data on our behalf, including:

Authentication Services:

• Firebase Authentication (Google): User authentication, account management, and password security. We do not store user passwords on our servers; all authentication is handled by Firebase.

Payment Processing:

• Stripe, Inc.: Payment processing, fraud prevention, and billing management. We do not store complete payment card information on our servers.

Cloud Hosting and Storage:

• Cloud infrastructure providers that host our databases and servers
• Data backup and disaster recovery services

Analytics and Performance:

• Analytics providers that help us understand App usage
• Performance monitoring and crash reporting services
• A/B testing and optimization platforms

AI and Machine Learning:

• AI Services — Google LLC (Google AI Studio — Gemini 2.5 Flash): Powers the Lumi AI coaching feature. Processes personal profile data and conversation history to generate personalised responses. Data processing is subject to Google's Terms of Service and Privacy Policy. Prompts and responses are temporarily retained by Google for up to 55 days for safety and quality purposes.
• Analytics and Monitoring — Langfuse GmbH, Gethsemanestr. 4, 10437 Berlin, Germany: AI interaction logging and quality monitoring. Receives conversation inputs and AI-generated outputs for performance oversight.

Communication Services:

• Email service providers
• Push notification services
• Customer support platforms

Security Services:

• Fraud detection and prevention services
• Identity verification providers
• Cybersecurity monitoring services

All service providers are contractually obligated to protect your data, use it only for the purposes we specify, and comply with applicable data protection laws.

If we are involved in a merger, acquisition, sale of assets, bankruptcy, or similar business transaction, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice in the App of any such change in ownership or control of your personal information.

We may disclose your personal information if required to do so by law or in response to:

• Valid legal requests from government authorities, law enforcement, or courts
• Subpoenas, court orders, or other legal processes
• Circumstances where we believe disclosure is necessary to comply with applicable laws, protect the rights or safety of the Company or users, detect or prevent fraud, or enforce our Terms of Use

We may share aggregated, de-identified, or anonymized data that cannot reasonably be used to identify you with business partners, advertisers, research institutions, academic partners, and industry organizations. This data does not constitute personal information and is not subject to this Privacy Policy.

We may share your personal information with third parties when you have given us explicit consent to do so.

• Right of Access (Article 15 GDPR): You have the right to obtain confirmation of whether we process your personal data and request a copy in a structured, commonly used format.
• Right to Rectification (Article 16 GDPR): You have the right to correct inaccurate or incomplete personal data.
• Right to Erasure / "Right to be Forgotten" (Article 17 GDPR): You have the right to request deletion of your personal data in certain circumstances. This right is not absolute and may be subject to legal or legitimate business reasons for retention.
• Right to Restriction of Processing (Article 18 GDPR): You can request that we limit how we use your personal data in certain circumstances.
• Right to Data Portability (Article 20 GDPR): You can request a copy of your personal data in a machine-readable format and request that we transmit your data to another organization.
• Right to Object (Article 21 GDPR): You have the right to object to processing based on legitimate interests and the absolute right to object to processing for direct marketing purposes.
• Rights Related to Automated Decision-Making (Article 22 GDPR): You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.
• Right to Withdraw Consent: Where we process data based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: Cyprus: Commissioner for Personal Data Protection (www.dataprotection.gov.cy); UK: Information Commissioner's Office (www.ico.org.uk)

To exercise any of the above rights please contact us at [email protected].

• Right to Know: You can request information about the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to Delete: You can request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You can request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information. If we share data for cross-context behavioral advertising, you can opt out.
• Right to Limit Use of Sensitive Personal Information: You can limit our use of sensitive personal information to specific purposes.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise any of these rights, you may:

• Email us: [email protected]
• Use In-App Settings: Access privacy controls in your account settings
• Written Request: Send a letter to our registered address

To protect your privacy, we will verify your identity before processing your request. We will respond to verified requests within 30 days for EU/EEA/UK users (may be extended by 2 months for complex requests) and within 45 days for California users (may be extended by 45 days with notice). We do not charge a fee to process your requests unless they are excessive, repetitive, or manifestly unfounded.

You may opt out of receiving promotional communications by:

• Clicking the "unsubscribe" link in promotional emails
• Adjusting notification preferences in your account settings
• Contacting us at [email protected]

Even if you opt out of marketing communications, we will still send you transactional and service-related messages.

When you use the AI coaching feature, the following personal data is transmitted to Google Gemini with each message:

• Name, date of birth, place of birth, gender — Recipient: Google Gemini / Vertex AI
• Personality type, type description, wings, instinct — Recipient: Google Gemini / Vertex AI
• Gates and powers with descriptions — Recipient: Google Gemini / Vertex AI
• Mood score and mood comment — Recipient: Google Gemini / Vertex AI
• Ritual and lesson data — Recipient: Google Gemini / Vertex AI
• Conversation history (up to 50 most recent messages) — Recipient: Google Gemini / Vertex AI
• All of the above + AI-generated responses — Recipient: Langfuse (logging)

This data is transmitted solely to generate personalised coaching responses within the Lumi feature. The legal basis for this processing is your explicit consent (Article 6(1)(a) GDPR), obtained before your first use of the AI coaching feature.

You may withdraw consent at any time by sending us an email to [email protected], in which case we will disable the AI coaching feature. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Before your first interaction with the Lumi AI coach, you will be asked to review and consent to the data sharing described above. If you do not consent, the AI coaching feature will not be available, but all other App features remain fully accessible.

By default, data processed via Google Cloud Vertex AI is not used by Google to train its general AI models. Anonymised and aggregated data may be used internally by Playada Software Limited to improve the quality and relevance of AI-generated content within the App.

We process your data based on the legal grounds described in Section 5. You have the right to lodge a complaint with your local supervisory authority:

• Cyprus: Commissioner for Personal Data Protection (www.dataprotection.gov.cy)
• UK: Information Commissioner's Office (www.ico.org.uk)
• Other EU/EEA countries: Contact your national data protection authority

You may contact our Data Protection Officer at [email protected]. We use Standard Contractual Clauses and other appropriate safeguards for transfers outside the EEA/UK.

We do not sell your personal information as defined by the CCPA. California residents may request information about our disclosure of personal information to third parties for direct marketing purposes. We do not currently respond to "Do Not Track" signals.

We comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). You may lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).

If you are located in a jurisdiction with privacy laws not specifically addressed in this Policy, we will comply with applicable local requirements. Please contact us if you have questions about how local laws apply to our processing of your information.