Soul Circle LLC ("Soul Circle," "we," "us," or "our") operates the mobile application Soul Circle AI (the "App") and the website soulcircle.live (the "Site," together, the "Services"). This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information, and the rights you have over that information.
By using the Services you confirm that you have read, understood, and agreed to this Policy. If you do not agree, do not use the Services.
Data Controller: Soul Circle LLC, a California limited liability company.
Address: 1405 Bluebird Ave, Los Angeles, CA 90069, USA.
Email (general): soulcircleai@gmail.com
Email (privacy requests): soulcircleai@gmail.com (Subject: "Privacy Request")
EU/UK Representative: Not yet appointed; EU/UK users may contact us directly using the address above pending appointment.
This Policy applies to information we collect through:
This Policy does not apply to third-party websites, products, or services we link to or that you reach through the Services. Their own privacy policies govern.
Soul Circle AI is a peer-support platform. Through your use of the Services—particularly questionnaires, daily check-ins, and group conversations—you may voluntarily share information that constitutes sensitive personal information under applicable laws, including:
We treat all such information with the highest level of care. We process it only as strictly necessary to deliver the Services, never for advertising, and never for targeted profiling outside the matching system. You may withdraw, edit, or delete this content at any time. Do not share information you do not want stored or seen by other group members.
We use your information for the following purposes:
| Purpose | Legal Basis |
|---|---|
| Providing the Services to you | Performance of a contract |
| Account creation, login, support | Performance of a contract |
| Subscription billing | Performance of a contract |
| Security, abuse prevention, debugging | Legitimate interests |
| Aggregated analytics, product improvement | Legitimate interests |
| Marketing emails (if any) | Consent |
| Optional features (location sharing, contacts scan) | Consent |
| Processing sensitive personal information shared in questionnaires/messages | Explicit consent and substantial public interest in mental wellness support |
| Responding to legal process, regulators, courts | Legal obligation |
| Protection of vital interests (e.g., suicide risk) | Vital interests |
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal.
We use artificial intelligence (currently powered by OpenAI's models) to:
Effect on you: AI determinations affect which groups and people are suggested to you, and whether content you submit is allowed to post. They do not produce legal effects, deny services to you, or evaluate creditworthiness, employment, insurance eligibility, or any similarly significant outcome.
Your rights regarding AI: You have the right to (a) request information about how an automated decision was made, (b) request human review of any moderation decision affecting you, (c) contest a decision, and (d) opt out of certain automated processing where required by law. Email us at the address above with subject "AI Review Request."
Limitations: AI is imperfect, may produce biased or inaccurate outputs, and should not be relied on as professional advice (medical, legal, mental health, financial, or otherwise).
The mobile App does not use browser cookies. We use:
We do not use advertising trackers, third-party marketing pixels, or cross-site behavioral tracking.
| Provider | Purpose | Region |
|---|---|---|
| OpenAI, L.L.C. | AI processing for matching, questionnaires, moderation | United States |
| Vonage | SMS verification codes (2FA) | United States / Global |
| SendGrid (Twilio) | Transactional email delivery | United States |
| Apple Inc. | App distribution, In-App Purchase, Sign In with Apple | United States / Global |
| Google LLC | App distribution (Play Store), Google Sign-In, Play Billing | United States / Global |
| RevenueCat, Inc. | Subscription management and analytics | United States |
| Stripe, Inc. | Web subscription processing (fallback) | United States |
| Expo / EAS | App build, OTA updates, infrastructure | United States |
| Neon / Replit (PostgreSQL) | Database hosting | United States |
| Sentry (if enabled) | Crash and error reporting | United States / EU |
We require all sub-processors to maintain appropriate technical and organizational measures to protect your data. We may add, replace, or remove sub-processors as our business evolves; material changes will be reflected in this Policy.
We do not sell your personal information. We may share your information in the following circumstances:
We will publish a transparency report disclosing aggregate numbers of government requests once we receive a meaningful volume of such requests.
We are based in the United States. Your information will be transferred to, stored in, and processed in the United States and other countries where our sub-processors operate. These countries may have data protection laws different from those of your country.
For transfers from the EEA, UK, or Switzerland, we rely on appropriate safeguards including:
You may request a copy of the safeguards we use for a specific transfer by contacting us.
| Category | Retention Period |
|---|---|
| Account data (email, username, profile) | Until account deletion + 30-day grace period |
| Questionnaire responses and personality profile | Until you delete them or your account |
| Group and direct messages | Up to 2 years after creation, then auto-deleted |
| Daily check-ins | Until account deletion |
| Verification codes (SMS / email) | 10 minutes or until used |
| Authentication sessions | 30 days inactive, then expired |
| Server logs (IP, request data) | 90 days |
| Crash reports | 90 days |
| Subscription records | 7 years (tax and audit obligations) |
| Moderation records and abuse reports | 2 years |
| Backups | Up to 35 days, then overwritten |
| Legal-hold data | Duration of hold + applicable statute |
If retention is required by law (tax records, regulator requests, litigation holds), we retain the relevant data for the legally required period, even after account deletion.
We implement administrative, technical, and physical safeguards designed to protect your data:
No system is perfectly secure. While we use industry-standard practices, we cannot guarantee absolute security. You are responsible for keeping your password and device secure and for promptly notifying us of any suspected unauthorized access.
If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
You have all rights in 15.1 plus the right to be free from solely automated decisions that produce legal or similarly significant effects, and the right to lodge a complaint with your local Data Protection Authority. EU residents may contact the Irish Data Protection Commission as a starting point.
Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Florida (FDBR), Tennessee (TIPA), Iowa (ICDPA), Indiana (INCDPA), Montana (MCDPA), Delaware (DPDPA), New Hampshire, New Jersey, Minnesota, Maryland (including the My Health My Data Act), and Washington State have similar rights to access, correct, delete, port, and opt out of profiling and targeted advertising. We honor these rights as provided by your state's law.
Residents of Brazil (LGPD), Canada (PIPEDA / Quebec Law 25), Australia (Privacy Act), India (DPDP Act), China (PIPL), Japan (APPI), and South Korea (PIPA) have substantially similar rights, which we honor in accordance with each law.
Email soulcircleai@gmail.com with subject "Privacy Request." We will verify your identity (typically by confirming you control the registered email/phone) and respond within 30 days (extendable to 90 in complex cases). Most rights can also be exercised in-app via Profile → Account → Delete Account / Export Data.
Soul Circle does not sell your personal information for monetary consideration and does not share your personal information for cross-context behavioral advertising. We do not honor or process Global Privacy Control (GPC) signals because we do not engage in any "sale" or "sharing" that GPC is designed to opt you out of. If our practices change, we will update this Policy and provide a clear opt-out mechanism.
The Services are intended for users 13 years of age and older. We require date-of-birth at sign-up to verify age and reject accounts under 13. If we learn we have collected personal information from a child under 13 without verifiable parental consent, we will delete it immediately. Parents who believe their child has provided us with personal information should email us so we can delete the account.
For users aged 13–17 in jurisdictions requiring parental consent (e.g., South Korea, China, certain US state laws), we encourage parental involvement and may require additional consent. Users in California aged 13–18 may request deletion of any content they posted publicly through our standard rights process.
Information you share in groups, direct messages, or on your profile is visible to other users you interact with. Other users may screenshot, copy, or redistribute content you share, in violation of our Terms. We are not responsible for the actions of other users. Treat group conversations as semi-public — do not share information you would not want disclosed.
The following features require your explicit permission and may be revoked at any time through your device settings:
We may disclose information without your consent where:
If you discover a security vulnerability, please report it confidentially to soulcircleai@gmail.com with subject "Security Disclosure." We commit not to pursue legal action against good-faith security researchers who follow responsible disclosure practices.
We may send you transactional emails (account, security, billing) which you cannot opt out of as long as you have an active account. Promotional or product-update emails are sent only with your consent and you may unsubscribe at any time using the link in those emails or by contacting us.
We may update this Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. Material changes (e.g., new categories of data, new sharing practices, expanded purposes) will be communicated via email and an in-app notice at least 14 days before they take effect, and where required by law, your fresh consent will be obtained. Continued use of the Services after changes take effect constitutes acceptance.
You may deactivate or delete your account at any time via Profile → Account → Delete Account. Upon deletion:
The Services may link to third-party websites, articles, podcasts, videos, or services we do not control. We are not responsible for their privacy practices and recommend you review their policies before sharing information.
We do not respond to Do Not Track browser signals because no industry standard for honoring them currently exists. We do not engage in cross-site tracking regardless.
Disputes about this Privacy Policy are subject to the dispute-resolution provisions of our Terms of Use, including binding arbitration and class-action waiver, where permitted by law.
If any provision of this Policy is held unenforceable, the remaining provisions remain in full force. This Policy, together with our Terms of Use and any in-app disclosures, constitutes the entire agreement between you and Soul Circle regarding our processing of your personal information.
Soul Circle LLC
1405 Bluebird Ave, Los Angeles, CA 90069, USA
Email: soulcircleai@gmail.com
Privacy requests: subject "Privacy Request"
Security disclosures: subject "Security Disclosure"
AI review requests: subject "AI Review Request"