PRIVACY POLICY

Last updated: July 19, 2026

This Privacy Policy ("Policy") applies to SoulTalk®, an AI powered journaling and self-reflection application, as well as related content, tools, features and functionality (collectively, the "Services") provided by SoulTalk Inc. ("SoulTalk," or "SoulTalk Inc.," "we," "our," or "us"). This Policy is hereby formulated by us in accordance with applicable laws to protect the personal information of users ("you" or "your"). This Privacy Policy describes how we collect, use, disclose, store, and protect information when you access or use the SoulTalk mobile application, and related Services. Please read this Policy carefully. By accessing or using SoulTalk and/or our Service, you agree and acknowledge that you understand, agree, and consent to this Policy. Scope & Consent This Policy establishes why, how, and what personal information we collect, use, store, process, share, transfer and publicly disclose about you, the information security protection measure we take, and the rights we honor for your access, update, deletion, and control of your personal information. Please read this Policy in combination with SoulTalk Terms of Service. If you do not agree with this Policy, you shall stop using SoulTalk and our Services, because using the Services constitutes your agreement to this Policy. We reserve the right to amend this Policy at any time and will update this policy periodically with updates when changes are made. By accessing and/or using our Service, you confirm that you are an adult at 18 years of age or over.

1. Artificial Intelligence and Automated Processing

1.1 SoulTalk uses artificial intelligence and automated systems to analyze user-submitted content and generate insights. 1.1.1 AI outputs are probabilistic and interpretive 1.1.2 Outputs do not constitute facts, diagnoses, or professional advice 1.1.3 No automated processing produces legal, medical, or therapeutic decisions 1.1.4 The SoulTalk team does not read your journal entries. Safety detection is automated, and any limited human review is restricted to system metadata and security signals, not the content of your entries. We will access or disclose the content of your entries only where we are legally required to do so, such as in response to a valid court order or legal process.

2. Information We Collect

2.1 Information You provide. We collect the information You provide when You use the App, such as Your account details and the content You create within the App. The journal entries You write are Your "Entries," and the content the App generates from them is Your "Insights." Including: 2.1.1 Your account information You provide 2.1.2 Your email address 2.1.3 Your account identifiers 2.1.4 Your preferences and settings 2.1.5 Optional profile information voluntarily provided by You 2.1.6 Your content and journal data which You write in the App 2.1.7 Consent record, meaning the date and the version of the Terms and this Policy You accepted 2.1.8 Your username 2.1.9 Confirmation You are 18 or older 2.2 Information collected automatically. We collect limited technical information necessary to operate and secure the App, such as basic device and app information and error logs. The App does not contain third-party advertising software and does not track You across other companies’ apps or websites. We use Adapty solely to manage and analyze subscriptions; this processing is limited to subscription functionality and is not used for advertising. 2.2.1 Device type, operating system, app version 2.2.2 Interaction logs, timestamps, and error reports 2.3 Payments. Subscriptions are processed by Apple through in-app purchase. We do not receive or store Your payment-card details. Apple provides Us only the information necessary to confirm and manage Your subscription. We collect only the information reasonably necessary to provide, maintain, and improve the Services. 2.4 Subscription data. To manage Your subscription, We and Our subscription provider Adapty collect Your purchase history and app and device identifiers. See Section 4.6.

3. How we use your information

3.1 Purposes. We use Your information as necessary to: 3.1.1 provide and maintain the App and its features including the generation of AI-assisted insights and summaries; 3.1.2 create, authenticate, and secure Your Account; 3.1.3 support the App’s safety features; 3.1.4 communicate with You about the Service, including service messages such as a sign-in code, a deletion confirmation, a data-export link, or notice that a trial or subscription is ending; 3.1.5 maintain the security and integrity of the App; 3.1.6 monitor performance, prevent abuse, and improve reliability; 3.1.7 comply with Our legal obligations; 3.1.8 detect content that may indicate a safety concern, so the App can surface support resources; SoulTalk does not use personal data for advertising, profiling, or marketing. 3.2 Legal basis. We process Your Personal Data based on Your consent and as necessary to provide the App You have requested. You may withdraw consent by deleting Your Account. 3.3 What we do not do. We do not use Your Entries or Insights for advertising, and We do not use them to train artificial-intelligence models.

4. Service providers

4.1 AI providers who process your entries. We rely on third-party AI Providers to deliver the App’s AI features. They process Your Entries only on Our behalf. 4.2 Who they are. To generate Your Insights, the App sends the text of Your Entries to Our AI Providers, who process them on Our behalf. Anthropic generates Your written Insights and tags, and Voyage AI converts Your Entries into the representations that power features such as SoulSignals. For more information, see Anthropic’s privacy policy and Voyage’s privacy policy. 4.3 Data minimization. We send each AI Provider only the Entry content necessary to generate Your Insights, and each AI Provider processes it only as necessary to return a result. 4.4 No training; limited retention. Neither AI Provider uses Your Entries to train its models. We have opted Voyage out of data retention, so Voyage does not store Your Entries and processes them only to return a result. Anthropic processes Your Entries under its commercial API terms, does not train on them, and retains them only for the limited period necessary for security and abuse detection before deleting them, except where longer retention is required by law or where content is flagged under Anthropic’s usage policies. 4.5 Processing location. Your information, including the content You create, is processed in the United States. 4.6 Subscription management. We use Adapty, a subscription-management service, to operate in-app subscriptions, including displaying subscription options, validating purchases, and maintaining Your subscription status. Adapty processes purchase information and app and device identifiers on Our behalf for these purposes. Adapty acts as Our service provider and does not use this information for its own purposes. See Adapty’s privacy policy for details.

5. Safety and crisis detection

5.1 SoulTalk is a journaling and self-reflection tool for personal use. It is not a therapy service, medical service, crisis service, or medical device, and it does not provide professional, medical, psychological, or legal advice and it should not be treated as a substitute for professional mental health care or other health care. Do not rely on the Services for any decision that requires a qualified professional. 5.2 If the App’s automated systems detect content that may suggest You are in distress, the App may show You mental-health and crisis support resources. This detection is automated, and Our team does not read Your Entries to determine what is and what is not a crisis. 5.3 If You are in immediate danger, contact Your local emergency number or qualified professional. In the United States, call or text 988. For support outside of the United States, you can find resources via sites like https://findahelpline.com/i/iasp

6. How we share your information

6.1 Recipients. We share Your information only as necessary as follows: 6.1.1 With Our AI Providers, as described in Section 4, acting as Our Service Providers. 6.1.2 With Apple, which processes and manages Your subscription. 6.1.3 With other Service Providers, such as hosting and email-delivery providers, under contracts that limit their use of the data to providing those services. 6.1.4 For legal and safety reasons, where required by law, to respond to lawful requests, or to protect the rights, property, or safety of Our users or the public. 6.1.5 In a business transfer, such as a merger, acquisition, or sale of assets, in which case We will provide notice before Your Personal Data becomes subject to a different privacy policy, and the recipient will be bound by protections at least as protective as this Policy. 6.1.6 With our contracted team to resolve account issues 6.2 What we do not do. We do not sell or rent Your Personal Data. We do not share it for advertising. We do not share it with affiliates or business partners for their own marketing, and the App has no public areas where other users can see Your Entries or Insights.

7. Retention, transfer, and deletion

7.1 Retention. We retain Your Personal Data for as long as necessary for the purposes described in this Policy to provide the App, comply with Our legal obligations, resolve disputes, and enforce Our agreements. 7.2 Transfer. SoulTalk is operated from the United States, and Your information, including Your Entries, is processed in the United States by Us and by Our AI Providers. If You use the App from outside the United States, Your information is transferred to and processed in the United States, where data-protection laws may differ from those in Your jurisdiction. 7.3 Deletion. You may delete Your Account at any time from within the App. When You do, We delete Your associated Personal Data, except for limited information We are required or permitted by law to retain. 7.3.1 Deletion of your account is irreversible 7.3.2 You may go to settings and then click "Delete Account" to delete your account

8. Your rights

8.1 California residents. We do not sell or share Personal Data for advertising. As a matter of practice, We honor the rights to know, access, delete, and correct Your Personal Data and the right not to receive discriminatory treatment for exercising Your rights. 8.2 Canadian residents. You have rights of access and correction under PIPEDA. Your information is processed in the United States and may be accessible to United States authorities under United States law. 8.3 Quebec residents. You have additional rights under Quebec law. Our Privacy Officer, reachable at privacy@soultalkapp.com, is responsible for the protection of Your Personal Data. 8.4 Exercising Your rights. To exercise any right regarding your data and privacy, contact privacy@soultalkapp.com.

9. Security

9.1 We use commercially reasonable administrative, technical, and physical measures to protect Your information. No method of transmission or storage is perfectly secure, and We cannot guarantee absolute security.

10. Children’s privacy

10.1 The App is intended only for adults 18 and older. We do not knowingly collect Personal Data from anyone under 18, and the App blocks signups from anyone who indicates they are under 18. 10.2 If We learn that We have collected Personal Data from a person under 18, We will delete it. If You believe a child has provided Us Personal Data, please contact Us at privacy@soultalkapp.com.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated Policy, update the "Last updated" date above, and, for material changes, notify You in the App or by email.

12. Contact us

SoulTalk Inc. privacy@soultalkapp.com 5900 Balcones Drive #31937, Austin, TX 78731