Privacy Policy — SoulCue AI

Effective date: 29-11-25

This Privacy Policy describes how Individual Entrepreneur Dmitrii Kotelnikov (“we”, “us”) processes information when you use the SoulCue AI mobile application (“App”).

Controller: Individual Entrepreneur Dmitrii Kotelnikov
Address: Building 5, Ponichala 3 Settlement, Krtsanisi District, Tbilisi 0190, Georgia
Contact: insane.products.studio@gmail.com

1. What We Collect

• Chat content: your messages, prompts, conversation context, and saved insights needed to generate AI responses and provide the App’s features. Before any chat content is transmitted for AI processing, we filter and de-identify it to remove or mask personal data and personal references where possible, including names, email addresses, phone numbers, physical addresses, account identifiers, internal user IDs, and other information that may directly or indirectly identify you. We do not send your personal data to third-party AI providers. Only filtered and de-identified chat content that is needed to generate AI responses and support safety checks may be transmitted to OpenAI and Anthropic via our backend. We do not use chat data for targeted advertising or third-party advertising profiling.
• Device & usage data: device model, OS version, app version, language, time zone, approximate region, IP address (transient), timestamps, and in-app events necessary to operate, secure, and improve the App.
• Analytics & diagnostics: aggregated analytics events (Firebase Analytics) and crash logs (Crashlytics). These do not include your chat messages.
• Purchases: subscription status and receipts via Apple and Adapty. We never receive your full payment card details or Apple ID password.

2. Data We Do NOT Collect

We do not collect or access:

• contacts or address book
• photos, videos, or media files
• precise location (GPS)
• health or medical information
• financial data outside subscription status
• advertising identifiers for personalized ads

3. How We Use Data

We use data to:

• operate and improve the App,
• generate AI responses, reflections, insights, and training content,
• filter and de-identify chat content before AI processing,
• ensure security and prevent abuse,
• provide customer support,
• manage subscriptions and entitlements,
• comply with legal obligations,
• personalize your experience where applicable.

We do not use your data for targeted advertising.

4. Legal Bases (EEA/UK)

• Contract performance: providing the App and its features, including AI responses and subscription access.
• Legitimate interests: security, diagnostics, service improvement, abuse prevention, and basic analytics.
• Consent: where required by law, such as optional analytics choices or other optional features.

5. Sharing and Processors

We share data only with service providers and processors necessary for the App’s functionality. We do not send your personal data to third-party AI providers. Before chat content is sent for AI processing, we filter and de-identify it to remove or mask personal data and personal references where possible, including names, email addresses, phone numbers, physical addresses, account identifiers, internal user IDs, and other information that may directly or indirectly identify you. Third-party AI providers receive only filtered and de-identified content needed to generate AI responses and support safety checks.

• OpenAI — AI processing of filtered and de-identified chat content to generate responses and support safety checks.
• Anthropic — AI processing of filtered and de-identified chat content to generate responses and support safety checks.
• Google Firebase — analytics, aggregated usage data, crash diagnostics, and app performance monitoring.
• Adapty — subscription status, receipts, entitlements, and paywall management.
• Apple — App Store distribution, payment processing, and subscription management.

Our service providers are required to protect data using the same or equivalent level of protection described in this Privacy Policy and to process data only for the purposes described here. We may share de-identified or aggregated statistics. We do not sell personal data.

6. International Transfers

Data may be processed in countries outside your own, including the United States and other countries where our service providers operate. Where required, we use safeguards such as Standard Contractual Clauses or equivalent protections.

7. Storage & Retention

• Chat history: stored locally on your device. If cloud sync or server-side history becomes available and you enable it, chat data may be stored on our servers.
• AI processing: before your messages and conversation context are processed by OpenAI and Anthropic, we filter and de-identify chat content to remove or mask personal data and personal references where possible. We do not send your personal data to third-party AI providers. The AI providers receive only filtered and de-identified content needed to generate responses and support safety checks.
• Analytics & logs: retained for up to 24 months, then deleted or anonymized.
• Abuse prevention logs: retained only as long as necessary.
• Subscription records: retained as long as necessary to manage access, purchases, refunds, disputes, and legal obligations.

8. Your Rights

Depending on your location, you may have rights to access, correct, delete, restrict, or port your data, and object to certain processing.

To exercise rights, contact insane.products.studio@gmail.com. Some analytics can be disabled via device or App settings where available.

9. Children

The App is intended for users aged 16+. We do not knowingly collect personal data from children under this age.

10. Security

We use reasonable safeguards such as TLS encryption, limited access controls, and secure infrastructure. However, no method of storage or transmission is completely secure.

11. California / US State Privacy Notices

We do not sell personal information. California and other US state residents may request access or deletion by contacting us at the email above. We will not discriminate against users who exercise privacy rights.

12. Changes

We may update this Policy by posting a new version here. Material changes will be communicated in the App when feasible.

13. Contact

Individual Entrepreneur Dmitrii Kotelnikov
Building 5, Ponichala 3 Settlement, Krtsanisi District, Tbilisi 0190, Georgia
Email: insane.products.studio@gmail.com