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Privacy Policy

Last updated: July 12, 2026 · Version 1.0

This policy explains what personal data we process when you use the UNMUTE mobile app (the "App"), and your rights under the GDPR (EU/UK) and the California Consumer Privacy Act (CCPA/CPRA).

1. Who we are (data controller)

UNMUTE ("UNMUTE", "we") is published by [LEGAL ENTITY NAME], registered at [REGISTERED ADDRESS], [COUNTRY].

2. Scope & data collected

We apply the principle of data minimization: we only collect what is necessary to operate the App.

CategoryExamplesSource
Account / identityEmail address, chosen username, pronouns/bio (optional)You, at sign-up
AuthenticationSession tokens. Passwords are hashed and stored by our authentication provider (Supabase); we never see or store your password in plain text.You
Progress & wellbeingXP, levels, streaks, mood check-ins, completed challenges, journal reflectionsYou, in the app
AI conversation contentThe text you send to the coach and to "Practice" roleplays, and the AI's responsesYou
Subscription / statusWhether you hold a Plus subscription, plan type, renewal status. Card data is processed by Apple — we never receive it.Apple / RevenueCat
Technical & telemetryDevice model, OS version, app version, crash diagnostics, coarse usage eventsAutomatically

What we don't collect

3. Why we process your data (purposes & GDPR legal bases)

PurposeLegal basis (GDPR Art. 6)
Create and operate your accountPerformance of a contract (Art. 6(1)(b))
Generate challenges, roleplays, and AI coach responsesPerformance of a contract
Save your progress, journal, and preferencesPerformance of a contract
Manage subscriptions and entitlementsPerformance of a contract
Crash diagnostics, security, fraud/abuse preventionLegitimate interest (Art. 6(1)(f))
Optional product-improvement analyticsConsent (Art. 6(1)(a)) — you can opt out

We collect your explicit in-app consent to this policy and our Terms before the App initializes (consent screen on first launch).

4. AI processing & data flow

When you interact with the coach or a Practice roleplay, the text of your message is sent over an encrypted connection to our gateway (a Supabase Edge Function), which forwards it to our AI subprocessor Mistral AI to generate a response, which is then returned to your device.

5. Subprocessors

We only share data with selected vendors, acting on our instructions under data processing agreements:

SubprocessorPurposeRegionPolicy
SupabaseDatabase, authentication, backend functionsEU region (GDPR)supabase.com/privacy
Mistral AIGenerative AI responses (text)EU (France)mistral.ai/terms
RevenueCatSubscription/entitlement managementUnited Statesrevenuecat.com/privacy
AppleApp distribution & in-app purchasesGlobalapple.com/legal/privacy
Expo / EASApp builds, crash diagnosticsUnited Statesexpo.dev/privacy

6. International data transfers

Your primary storage is hosted in the EU. Where a subprocessor processes data outside the EEA/UK (e.g., RevenueCat, Apple, Expo in the United States), these transfers are governed by Standard Contractual Clauses and equivalent safeguards.

7. Retention periods

We retain personal data only as long as necessary for the purposes above, or as required by law. Account and progress data is kept while your account is active, and deleted within [30] days after account deletion (backups purged within [90] days). [Confirm the retention periods used by AI subprocessors and state them here.]

8. Your rights

Under the GDPR (EEA/UK)

You have the rights of access, rectification, erasure ("right to be forgotten"), restriction or objection to processing, and portability, as well as the right to withdraw consent at any time. You may lodge a complaint with your supervisory authority (e.g. the CNIL in France).

Under the CCPA/CPRA (California)

You have the right to know/access, delete, and correct your personal information, and to opt out of its "sale"/"sharing". We do not sell or share your personal information, and we do not discriminate against you for exercising your rights.

How to exercise your rights

9. Children & minors (ages 13–18)

UNMUTE is intended for people 13 and older. We do not knowingly collect data from children under 13. Depending on your country, the age of digital consent ranges from 13 to 16; below that age, a parent or guardian must consent on your behalf. [Implement age verification and, where applicable, verifiable parental consent, and confirm Apple's age rating. Obtain specialized legal advice (COPPA / GDPR-children) before launch.]

10. Security

We use encryption in transit (TLS), encrypted on-device credential storage (Keychain/Keystore via secure storage), row-level security on the database, and the principle of least privilege. No system is perfectly secure, and we cannot guarantee absolute security.

11. Changes to this policy

Any changes will be posted here with an updated "Last updated" date. Material changes will be notified in the app and may require renewed consent.

12. Contact

[LEGAL ENTITY NAME][privacy@yourdomain.com][ADDRESS]