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Privacy Policy

1) Scope:

This Privacy Policy describes how we collect, use, disclose, and protect personal information when you use ANEW’s websites, apps, voice/chat interfaces, and related services (“Services”). It applies wherever we operate, with regional rights noted below.


2) What We Collect

We collect information in these categories:

  • Account & Contact: name, email, username, password (hashed), country/region, preferences.
  • Wellness Inputs & Interactions: text/voice/chat transcripts, journaling entries, session metadata (e.g., timestamps, modality selections, milestones), self-reported states/symptoms, goals, and feedback.
  • Device & Usage: IP address, device/browser details, app version, crash logs, cookies/SDK signals, pages/screens viewed, feature usage, timestamps, referrers.
  • Integrations (if you connect them): limited health or activity data from Apple Health, Google Fit, wearables, or calendars; we only ingest fields you authorize.
  • Payments: handled by payment processors; we receive limited billing metadata (e.g., last 4 digits, card brand, status).
  • Support & Research: support requests, surveys, product research, and (if you opt in) de-identified data for research & product improvement.
     

We may create de-identified and/or aggregated data that cannot reasonably identify you.


3) How We Use Information (Purposes)

We use information to:

  1. Provide the Services (contract): account creation, authentication, core features, personalization, insight generation (trends, progress, patterns), troubleshooting, notifications.
  2. Safety & integrity (legitimate interests/legal obligations): detect misuse, fraud, security incidents, and policy violations.
  3. Improve the Services (legitimate interests/consent): analytics, A/B tests, quality, performance, and new features.
  4. De-identified/aggregated analytics (legitimate interests): measure usage, performance, and general trends without PII.
  5. Research & product improvement (consent): use de-identified data for research, including publishing aggregated findings that do not include PII.
  6. Marketing/communications (consent/legitimate interests): product updates, optional newsletters (separate opt-in).
  7. Legal compliance: tax, accounting, regulatory requests, and enforcing our Terms.
     

EU/UK Lawful Bases (summary)

  • Contract: to deliver the Services you request.
  • Consent (explicit for special category data): processing wellness/somatic inputs for personalization; research opt-in.
  • Legitimate Interests: service analytics, security, de-identified stats, product improvement (balanced against your rights).
  • Legal Obligation: where required (e.g., tax, court orders).
     

You can withdraw consent at any time in Settings → Privacy or by contacting us.


4) De-Identified & Aggregated Data

We de-identify or aggregate information so it cannot reasonably identify you. We may use and share such data (e.g., general trends across users) publicly or with partners. We do not include PII in these outputs.


5) Cookies, SDKs, and Similar Technologies

We use cookies/SDKs for authentication, session continuity, performance, and analytics. Manage preferences in Settings and your browser/OS controls. Some features may not work without certain cookies.


6) How We Share Information

We share information with:

  • Service providers / processors (e.g., cloud hosting, analytics, voice/telephony, security, email, customer support, payment processing) under contracts that limit their use to our instructions.
  • Integrations you enable (e.g., Apple Health, wearables) per your authorization.
  • Business transfers (e.g., merger, acquisition) where the successor is bound by this Policy.
  • Legal & safety: to comply with law/process, enforce terms, or protect rights, safety, and security.
    We do not sell personal information. We do not share personal information for cross-context behavioral advertising (as defined by the CPRA).
     

7) Retention

We retain personal information only as long as needed for the purposes in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. You can request deletion; see Your Rights below.


8) Security

We implement reasonable administrative, technical, and physical safeguards (e.g., encryption in transit/at rest, access controls, audit logs). No system is perfectly secure; you are responsible for protecting your credentials and devices.


9) International Transfers

We may process data in the U.S. and other countries. Where required, we use appropriate safeguards such as EU Standard Contractual Clauses (and UK Addendum) for cross-border transfers. You can contact us for copies subject to redactions.


10) Your Rights & Choices

Global

  • Access, correction, deletion, portability (export), and restriction/object (where applicable).
  • Withdraw consent (where processing is based on consent).
  • Opt out of marketing emails at any time.
     

California (CPRA)

California residents have rights to know, access, delete, correct, and opt-out of “sale”/“sharing” (we don’t sell/share personal information) and to limit use of sensitive personal information. We provide site-wide links: “Do Not Sell or Share My Personal Information” and “Limit Use of My Sensitive Personal Information.” We will not discriminate against you for exercising rights.


EEA/UK

You have rights of access, rectification, erasure, restriction, portability, and objection; and the right to withdraw consent where processing is based on consent. You may lodge a complaint with your local supervisory authority. 


Exercise your rights: in Settings → Privacy. We may verify your identity before responding.


11) Special Category / Wellness Data (EU/UK)

To process wellness/somatic inputs for personalization, we rely on your explicit consent (separate from acceptance of Terms). You may withdraw this consent in Settings → Privacy; we will cease such processing and may provide a reduced experience.


12) Children

The Services are intended for adults (18+). We do not knowingly collect personal data from children. If you believe a child provided data, contact us to delete it.


13) HIPAA Notice

We are not a HIPAA covered entity or business associate unless we sign a Business Associate Agreement. Do not upload PHI intended to be regulated by HIPAA unless a BAA is in place.


14) Research & Product Improvement (Optional)

With your optional consent, we may use de-identified data for research and product improvement, including publication of aggregated findings. This will never include PII. You can withdraw consent at any time in Settings → Privacy.


15) Changes to this Policy

We may update this Policy. We will post the effective date and, for material changes, provide reasonable notice. Continued use after the effective date constitutes acceptance.

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