Privacy Policy – Inner Gate

Effective Date: 2026-07-06

This Privacy Policy explains how [LEGAL_ENTITY_NAME] (“Inner Gate”, “we”, “us”) collects, uses, shares, and protects personal data when you use the Inner Gate mobile application and related services (the “App”).

1. Controller and Contact

Data controller: [LEGAL_ENTITY_NAME], [REGISTERED_ADDRESS]. Contact: [PRIVACY_EMAIL].

2. Personal Data We Collect

• Account data: email, password (stored as a hash), profile fields (name/nickname, bio), avatar URL, account status.
• User content: diary/journal entries, practice/progress records, and other content you submit in the App.
• Community data: chat messages and optional file attachments (URLs and metadata such as MIME type).
• Subscription data: subscription status/plan, the RevenueCat customer identifier, and purchase/invoice metadata returned by the payment provider.
• Support and communications: emails you send to support and our replies.
• Analytics and diagnostics: event telemetry (for example, feature usage) and error reports.
• Security and audit data: IP address and device / browser information (User‑Agent) recorded when you take sensitive or administrative actions, for security, abuse‑prevention, and audit purposes.

3. How We Use Personal Data

• Provide the App and its features (accounts, content storage, community, progress tracking).
• Generate and deliver your data export on request.
• Maintain security, prevent abuse, and enforce our Terms (including moderation and handling reports).
• Process subscriptions and verify access to paid features.
• Communicate with you about your account (verification, notices, support).
• Improve the App through aggregated analytics and diagnostics.

4. Legal Bases (GDPR – for EEA/UK users)

If you are in the EEA/UK, we process personal data under these legal bases:

• Contract: to provide the App, including content storage, community features, and account management.
• Legitimate interests: to secure the App, prevent abuse, and improve services (balanced against your rights).
• Consent: where we rely on your consent — including your separate, explicit consent to process special‑category data (see Section 4a) and any optional analytics or marketing features — which you can withdraw at any time in your Profile settings.
• Legal obligation: where we must comply with law.

4a. Special Category Data & Explicit Consent

Your private journal entries and your interactions with our AI features may reveal information about your health, wellbeing, or religious or philosophical beliefs. Under the GDPR this is “special‑category” data (Article 9). We process such content only where you give separate, explicit, feature‑specific consent — one for private‑journal storage and one for AI features — which you can withdraw at any time in your Profile settings. Withdrawing consent stops any further processing of that content but does not affect the lawfulness of processing already carried out before you withdrew.

5. Sharing and Third‑Party Processors

We do not sell your personal data. We share it with service providers acting as processors to operate the App, including:

• Cloud storage / object storage (S3‑compatible): storing avatars, community uploads, and data exports.
• Email delivery (Postmark): sending transactional emails (verification, exports, deletion notices).
• Analytics (Amplitude): event telemetry linked to your user ID and event properties.
• Error monitoring (Sentry): diagnostics; depending on configuration, this may include device/network metadata and IP address.
• Payments (RevenueCat): subscription and purchase metadata tied to an app‑user identifier (native in‑app purchases via the Apple App Store and Google Play).
• Push notifications (Google Firebase Cloud Messaging): device push tokens and notification content (title and body, which may include message previews) are sent to Google’s Firebase Cloud Messaging (FCM) to deliver push notifications to your device.
• AI providers (OpenAI via LangChain and Google Gemma) and vector storage (Pinecone): for AI‑powered features and Ukrainian‑language translations; inputs you submit may be sent to these providers to generate responses or power retrieval. Inputs sent to OpenAI’s API are not used to train its models and are subject to limited retention under OpenAI’s API data‑usage and enterprise terms; we set the provider’s no‑retention option (store: false) where the API supports it and minimize the content we send. AI‑generated and AI‑translated content is subject to the applicable providers’ terms, including Google’s Gemma Prohibited Use Policy.

We may also share data if required by law, to protect rights/safety, or in connection with a corporate transaction.

6. International Transfers

Some providers may process data outside your country (including outside the EEA). Where required, we use appropriate safeguards (such as Standard Contractual Clauses) or other lawful transfer mechanisms.

7. Retention

• Account deletion: when you delete your account, we anonymize key identifiers and soft‑delete the account; after 30 days it is scheduled for permanent deletion.
• Chat messages: retained for up to 1 year and then scheduled for deletion.
• Data exports: download links expire after 7 days; export files are intended to be deleted after expiry.
• Reports/abuse handling: retained as needed to investigate and enforce rules.
• Security/audit logs: records of sensitive and administrative actions (including IP address) are retained for approximately 2 years and then deleted.
• Backups: residual copies of deleted data may persist in encrypted backups for a limited period beyond the 30‑day deletion window before they are overwritten on the normal backup rotation.

8. Security

We use technical and organizational measures designed to protect personal data, including access controls and encryption in transit. No method of transmission or storage is 100% secure.

9. Your Rights

Depending on your location, you may have rights to access, correct, delete, or export your data; and to object to or restrict certain processing. If you are in the EEA/UK, you also have the right to lodge a complaint with a supervisory authority.

You can request a data export and delete your account within the App. You can also request account and data deletion from the web at https://inner-gate.com/account-deletion-request, without the app. For other requests, contact: [PRIVACY_EMAIL].

10. California and Other US State Privacy Rights

We do not sell your personal information, and we do not share it for cross‑context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (as amended by the CPRA) and similar US state privacy laws. We have not done so in the preceding twelve months.

Depending on your state of residence, you may have the right to know about and access the personal information we hold, to request its deletion or correction, to opt out of the sale or sharing of personal information, and not to be discriminated against for exercising these rights. You can request a data export and delete your account within the App; for any other request, or to exercise a right described here, contact [PRIVACY_EMAIL]. We will verify your request against your account before acting on it, and you may use an authorized agent where the law permits.

Consumer Health Data (Washington My Health My Data Act)

If you are a Washington State resident, the My Health My Data Act applies to us (the Act has no business‑size threshold). We treat your private journal entries and wellness reflections as “consumer health data”. We collect and process this data only with your consent, we do not sell or share it, and we honor your requests to delete it. To exercise these rights, contact [PRIVACY_EMAIL].

11. Children

The App is not intended for children under 16. If you believe a child has provided us personal data, contact us and we will take appropriate steps.

12. Changes

We may update this Privacy Policy from time to time. If changes are material, we will notify you in the App and/or by email. The “Effective Date” above indicates when the policy takes effect.

13. Contact

Privacy inquiries: [PRIVACY_EMAIL].