Privacy Policy

1. Introduction

Soly ("we," "us," or "our") operates the Soly mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this policy carefully. By using the App, you consent to the practices described in this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. Personal Data

2.1 Information You Provide Directly

• Account Information: When you create an account, we collect your name, email address, and profile picture (if you sign in with Apple or Google).
• Mood Data: Emotion entries, contextual tags, and notes you create within the App.
• Journal Entries: Written thoughts, reflections, and personal writings you record. Journal entries may constitute health data relating to your mental wellbeing.
• Preferences: App settings such as theme, language, notification preferences, and privacy controls.

2.2 Information Collected Automatically

• Usage Data: If you enable Analytics in Settings → Privacy, we collect information about how you interact with the App, including features used, screens viewed, and session duration. This helps to inform and improve our direction and development.
• Device Information: Device type, operating system version, app version, and unique device identifiers.
• Crash Reports: Technical error reports and performance diagnostics to help us improve the App.

2.3 Information from Third Parties

• Authentication Providers: If you authenticate using Apple Sign-In or Google Sign-In, we receive your name and email address from those providers.
• Payment Processors: Subscription transactions are processed through the Apple App Store and managed by a subscription infrastructure provider. We do not collect, store, or have access to your payment card information.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the App's core features, including mood tracking, journaling, and statistics.
• Generate AI-powered weekly insight reports and personalized artwork based on your mood data (only when you explicitly request it).
• Manage your account, authenticate your identity, and process subscription transactions.
• Send local notifications for mood logging reminders (only when you enable reminders).
• Analyze aggregated, anonymized usage patterns to improve the App (only when you enable Analytics).
• Respond to your support requests and communicate important updates about the App.
• Detect, prevent, and address technical issues or abuse.

4. AI Data Processing

Soly offers AI-powered features, including weekly mood analysis reports and personalized artwork generation. AI processing only occurs when you explicitly request it. Before each generation, a confirmation dialog informs you what data will be processed.

4.1 Data Sent to AI Providers

When you generate a weekly insight report, the following data is sent to Google Gemini for mood analysis and report generation, and Together.ai for artwork generation:

• Primary and secondary emotions from your mood entries for the selected period.
• Contextual tags (names and categories) attached to your entries.
• Journal excerpts — limited to the first 400 characters per entry, for up to 12 entries.
• Aggregated statistics: mood distribution, day-of-week patterns, time-of-day patterns, and tag-mood correlations.

For artwork generation, the AI provider receives only a synthesized image prompt derived from your mood patterns (emotional arc, abstract themes, and color palette). No raw journal text, email address, name, or account identifiers are sent for artwork generation.

4.2 How AI Providers Handle Your Data

• AI providers process your data solely to generate your report and artwork. They do not retain, store, or use your data for any other purpose, including training AI models.
• Data is transmitted securely via encrypted HTTPS connections.
• AI-generated content (reports and artwork) is stored in your account and accessible only to you.

4.3 Your Control Over AI Processing

• AI processing only occurs when you explicitly request it by tapping "Generate Report."
• You can review and manage AI processing preferences in Profile → Privacy.

5. Sharing with Third Parties

5.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing or advertising purposes.

5.2 Service Providers

In order to provide you with our services, carry out our activities, and to comply with legal obligations, we share your personal data with certain third parties such as:

• Cloud storage and database providers, to help us securely store and back up your data. To provide these services, the providers receive your Account Information, Mood Data, and Journal Entries. The providers we currently use are located in the US.
• Analytics providers, who assist us in the improvement and optimization of the App. To provide these services, the providers receive Device Information and Usage Data (only if you enable Analytics). We currently use a provider located in the US.
• Subscription infrastructure providers, who facilitate the offering of in-app subscriptions. In doing so they receive your Account Information and subscription status. The provider we currently use is located in the US.
• AI service providers (Google Gemini and Together.ai), who generate insight reports and personalized artwork on your behalf. To provide these services, the providers receive the data described in Section 4.1 (only when you explicitly request report generation). The providers we currently use are located in the US.
• Authentication providers (Apple and Google), who facilitate secure sign-in to the App.
• Law enforcement authorities, government bodies, and the courts where they request it and disclosure is lawful (e.g., prevention and detection of crime).

These providers are contractually obligated to protect your data and may only use it to perform services on our behalf.

6. Data Security

We have implemented appropriate technical and organizational security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

• All data is transmitted using TLS 1.2+ encryption.
• Data at rest is encrypted and stored securely in cloud infrastructure.
• Access to your data is protected by Row-Level Security policies, ensuring only you can access your own data.
• Authentication is managed through secure tokens and industry-standard protocols.

While we implement commercially reasonable security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We are committed to the principle of storage limitation and will retain your personal data for no longer than is necessary to fulfil our processing purposes.

• Active Accounts: Your data is retained for as long as your account is active and you continue using the App.
• Account Deletion: Following account deletion or a written deletion request, all personal data (mood entries, journal entries, reports, artwork, and profile information) is permanently deleted within 30 days, save for certain instances where legal obligations require longer retention periods.
• Anonymized Data: We may anonymize some personal data so it will no longer be associated with you. In this event we are entitled to retain and use the information freely to improve the App.

8. Your Rights

You have several rights in relation to your personal data:

• Access: View all personal data we hold about you through the App.
• Deletion: Permanently delete your account and all associated data via Profile → Account → Delete Account.
• Correction: Update or correct your personal information in your profile settings.
• Opt-Out of Analytics: Disable analytics data collection in Profile → Privacy.
• Opt-Out of AI Processing: Disable AI features in Profile → Privacy at any time.
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, you may use the in-app controls or contact us at the email address below.

9. Tracking and Advertising

Soly does not track you across other companies' apps or websites. We do not collect the Apple Identifier for Advertisers (IDFA) or participate in ad networks. We do not display advertisements in the App.

10. International Data Transfers

To provide our services, we transfer your data to partners outside your country of residence, including the United States. We are committed to ensuring your personal data is protected when transferring to third countries. We ensure appropriate safeguards are in place in compliance with applicable data protection laws, including Standard Contractual Clauses where required.

11. Children's Privacy

The App is not intended for children under the age of 13 (in the United States) or under the age of 16 (in the European Union). We do not knowingly collect personal information from children under these ages. If we become aware that we have collected data from a child without parental consent, we will take steps to delete that information promptly.

12. California Privacy Rights (CCPA)

If you are a California resident, you have the right to:

• Request disclosure of the categories and specific pieces of personal information we have collected about you.
• Request deletion of your personal information.
• Opt out of the sale of your personal information (we do not sell personal information).
• Not be discriminated against for exercising your privacy rights.

13. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, you have additional rights under the General Data Protection Regulation, including the right to:

• Access, rectify, or erase your personal data.
• Restrict or object to certain data processing.
• Data portability (receive your data in a structured format).
• Withdraw consent at any time (where processing is based on consent).
• Lodge a complaint with your local data protection authority.

Our legal bases for processing personal data are: your consent, performance of a contract (providing the App's services), and our legitimate interests in improving the App.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any substantive or material change will be brought to your attention by posting the updated policy in the App, updating the "Effective Date" above, and where required, providing additional notice (such as via email or in-app notification). Your continued use of the App after any changes constitutes your acceptance of the updated policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: solyapp.team@gmail.com
• In-app: Profile → Send Feedback