Privacy Policy

This Privacy Policy describes how COMPMASTER LLC ("Company", "we", "us", or "our") collects, uses, processes, and discloses information in connection with your access to and use of the Solen application and related services (the "App").

This Privacy Policy is separate from the Terms of Service and governs data handling practices only. By using the App, you acknowledge that you have read and understood this Privacy Policy.

2.1 Personal Information

We may collect personal information ("Personal Information") that you voluntarily provide or that is generated through your use of the App, including but not limited to:

• Account identifiers (email address)
• Profile information and onboarding responses (e.g., first name, journaling goals)
• User-submitted journal entries, check-ins, moods, and reflections
• Authentication and security data
• Communications with support

2.1.1 Self-Reported Information & Accuracy

Certain information collected by the App is self-reported by users, including emotional states, personal reflections, intentions, and other subjective information provided during journaling or ongoing use.

We do not independently verify the accuracy, completeness, or truthfulness of user-provided information. App outputs, AI-generated reflections, summaries, and insights are produced based on the information submitted by users and are intended for personal, informational purposes only.

2.2 Non-Personal & Derived Information

We also collect non-personal information and derived data, including:

• Usage data, interaction logs, and feature engagement
• Device, browser, and technical metadata
• Aggregated analytics and performance metrics
• AI-generated summaries, emotion tags, sentiment scores, and reflections

AI-generated outputs may be derived from personal information provided by users and may be associated with an identifiable account. Such outputs are treated as personal data where applicable.

We do not store full payment card details. Payments, subscriptions, recurring billing, auto-renewals, and related transactions are processed by third-party payment processors. Billing information such as subscription status, plan type, and payment timestamps may be stored for account management, compliance, and support purposes. All billing terms, refunds, cancellations, and payment disputes are governed by the Terms of Service.

We use collected information to:

• Provide, operate, and maintain the App
• Generate AI-powered reflections, insights, mood analysis, and journaling summaries
• Authenticate users and prevent fraud or abuse
• Process subscriptions and manage account status
• Improve functionality, performance, and security
• Comply with legal obligations
• Perform automated analysis intended to provide emotional insights and patterns based on user-provided journal content

Automated analysis is performed solely to provide informational insights. The App does not make medical, psychological, legal, or eligibility decisions on behalf of users. Solen is not a substitute for professional mental health support.

We use trusted third-party service providers to support App functionality. These providers may process data on our behalf solely to perform services for us and subject to their own privacy and security obligations.

Our vendors may include, without limitation:

• Cloud infrastructure and database providers (e.g., Supabase)
• Authentication providers
• Artificial intelligence providers (e.g., Anthropic, OpenAI)
• Payment processors (e.g., Stripe)
• Hosting and deployment providers (e.g., Vercel)

We do not control third-party vendors' internal practices. You are responsible for reviewing their respective privacy policies.

We do not use personal data to train proprietary artificial intelligence models. Third-party AI providers process data only to generate requested outputs in accordance with their contractual and privacy obligations.

The App may contain links to third-party websites, services, or platforms. We are not responsible for the privacy practices, content, or security of third-party sites. Accessing third-party services is at your own risk.

We do not sell personal data. We may share information:

• With service providers for operational purposes
• To comply with legal obligations or lawful requests
• To protect rights, safety, or prevent fraud
• In connection with a corporate transaction or restructuring

We retain data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal requirements, resolve disputes, and enforce agreements. Certain data may be retained where required to comply with legal obligations, resolve disputes, enforce agreements, or maintain security and fraud prevention records. Users may request deletion of their account and associated personal data, subject to applicable legal and operational retention requirements.

9.1 GDPR (EEA / UK)

If you are located in the European Economic Area or United Kingdom, you may have rights to access, correct, delete, restrict, or object to processing of your personal data, as well as data portability rights.

9.2 CCPA / CPRA (California)

California residents may have the right to request disclosure, access, deletion, or correction of personal information collected about them. We do not sell or share personal information for cross-context behavioral advertising.

9.3 Exercising Rights

Requests may be submitted by contacting support. We may require identity verification before fulfilling requests.

We implement reasonable administrative, technical, and organizational safeguards to protect data. However, no system is completely secure, and we cannot guarantee absolute security.

The App is not intended for individuals under 18. We do not knowingly collect personal data from minors. If such data is discovered, it will be deleted promptly.

Data may be processed and stored in the United States or other jurisdictions where our service providers operate. By using the App, you consent to such transfers.

We may update this Privacy Policy from time to time. Continued use of the App after updates constitutes acceptance of the revised policy.

For questions or requests related to this Privacy Policy, please contact: support@solen.app