Legal

Privacy Policy

Effective Date: June 14, 2026

This Privacy Policy explains how [Legal entity — to be finalized] (“Shadow,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects information when you use the Shadow mobile application, website, and related services.

Shadow is a wellness and journaling app. It is not therapy, medical care, mental health treatment, crisis support, or a clinical service.

By using Shadow, you agree to this Privacy Policy.

1. Information We Collect

We collect information you provide, information generated through your use of the Service, and information from third-party service providers.

A. Account Information

We may collect:

• user ID;
• email address;
• authentication provider ID;
• account creation date;
• subscription status;
• app settings;
• deletion requests;
• support requests.

B. Journal and Reflection Content

We collect the content you choose to submit, including:

• journal entries;
• written prompts;
• AI chat messages;
• AI-generated reflections;
• emotional reflections;
• self-reflection exercises;
• recurring themes or patterns;
• saved entries;
• notes or other text you enter.

This content may be sensitive. Please do not enter information you do not want processed by Shadow and its service providers.

C. Mood and Wellness Data

Depending on the features you use, we may collect:

• mood check-ins;
• emotional state labels;
• tags;
• self-reported patterns;
• self-reflection categories;
• usage history related to journaling or reflection.

Shadow does not provide diagnosis, treatment, therapy, medical advice, or clinical assessment.

D. AI Processing Data

When you use AI features, we may process:

• your prompts;
• relevant journal context you choose to provide or that the app uses to generate a response;
• AI-generated responses;
• safety classification signals;
• system instructions used to operate the AI feature.

We use AI providers such as OpenAI to process prompts and generate responses. According to OpenAI’s current API data controls, data sent to the OpenAI API is not used to train OpenAI models unless the API customer opts in.

E. Device and Technical Information

We may collect:

• device type;
• operating system;
• app version;
• device identifiers;
• push notification token;
• language;
• region;
• time zone;
• crash logs;
• diagnostic data;
• performance data.

F. Analytics Data

We may collect content-scrubbed analytics, such as:

• app opens;
• screen views;
• onboarding completion;
• subscription events;
• feature usage;
• retention events;
• crash and performance events.

We do not intentionally send journal entry text or AI conversation content to analytics tools.

G. Payment and Subscription Data

Purchases are processed by Apple. We do not receive your full payment card information.

We may receive subscription-related information, such as:

• subscription status;
• product ID;
• renewal status;
• trial status;
• transaction identifiers;
• expiration date;
• cancellation status.

H. Support Communications

If you contact us, we may collect:

• your name;
• email address;
• message content;
• screenshots or files you choose to send;
• support history.

2. How We Use Information

We use information to:

• provide and operate the Service;
• create and manage accounts;
• store journal entries;
• generate AI reflections;
• personalize app functionality;
• maintain safety features;
• detect crisis-related language and show resources;
• process subscriptions;
• provide customer support;
• debug crashes and improve performance;
• analyze content-scrubbed usage trends;
• prevent abuse, fraud, or misuse;
• enforce our Terms;
• comply with legal obligations.

3. AI, Safety, and Crisis Processing

Shadow may use automated systems to detect certain crisis-related phrases or patterns and display safety resources.

This detection is not perfect. Shadow does not guarantee that it will detect all crisis situations. Shadow does not monitor users in real time and does not provide emergency intervention.

Crisis-related processing is used to provide safety resources and operate the Service. It is not used to provide diagnosis, therapy, treatment, or emergency support.

Crisis-flagged journal content is structurally excluded from the AI memory pipeline. It is not used to personalize future AI reflections.

4. How We Disclose Information

We may disclose information to the following categories of recipients.

A. Service Providers

We use vendors to operate the Service, including:

• cloud hosting and database providers;
• authentication providers;
• AI inference providers;
• analytics providers;
• crash reporting providers;
• payment/subscription infrastructure;
• notification services;
• customer support tools.

These providers may process information only as needed to provide services to us.

Current providers may include:

• OpenAI — AI inference (chat completions, embeddings, safety classification);
• Mixpanel — content-scrubbed analytics;
• Sentry — crash reporting and diagnostics (content-scrubbed);
• Apple — subscriptions, in-app purchases, App Store distribution, Sign in with Apple authentication, Apple Push Notification service;
• Supabase — database, authentication, edge function infrastructure, file storage.

B. Legal and Safety Disclosures

We may disclose information if we believe it is reasonably necessary to:

• comply with law;
• respond to lawful requests;
• protect rights, safety, or property;
• investigate fraud, abuse, or security issues;
• enforce our Terms;
• protect users or the public.

C. Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, information may be disclosed or transferred as part of that transaction.

D. With Your Direction or Consent

We may disclose information when you ask us to or when you give consent.

5. Selling, Sharing, and Tracking

We do not sell your journal entries.

We do not intentionally disclose journal entries or AI conversation content for cross-context behavioral advertising.

We do not use journal entry content for third-party advertising.

If our practices change, we will update this Privacy Policy and provide legally required choices.

6. Data Retention

We retain information for as long as needed to provide the Service, comply with legal obligations, resolve disputes, enforce agreements, maintain security, and support legitimate business purposes.

General retention periods:

• account data: retained while your account is active;
• journal entries: retained until you delete them or delete your account, unless legal retention is required;
• AI interactions: retained as needed to provide the Service and maintain safety/security;
• analytics data: retained in aggregated or content-scrubbed form;
• crash logs: retained for debugging and security;
• subscription records: retained as needed for accounting, fraud prevention, and legal compliance;
• support emails: retained as needed to respond and maintain support history.

When you delete your account, we will delete or de-identify personal information unless retention is required or permitted by law. Soft-deleted records are hard-purged after 30 days.

7. Deletion

You may request deletion of your account and personal information by:

• using in-app deletion tools (Settings → reset what my guide remembers; or delete individual entries); or
• contacting us at agent@shado.co.

We may need to verify your request.

Some information may remain in backups for a limited period before deletion. We may also retain information where required for legal, security, fraud prevention, accounting, or dispute-resolution purposes.

8. Your Privacy Rights

Depending on where you live, you may have rights to:

• access personal information;
• correct personal information;
• delete personal information;
• export or receive a copy of personal information;
• object to or restrict certain processing;
• withdraw consent;
• opt out of certain disclosures;
• appeal a denied privacy request;
• limit certain uses of sensitive personal information.

To exercise rights, contact agent@shado.co.

We will respond as required by applicable law.

9. California Privacy Notice

This section applies to California residents to the extent California privacy law applies to us.

Categories of Personal Information We May Collect

• Identifiers: email address, user ID, device identifiers.
• Customer records: account and subscription information.
• Commercial information: subscription status, purchase history.
• Internet or electronic activity: app usage, logs, analytics events.
• Geolocation: approximate region from device or network settings, if collected. We do not collect precise location.
• Sensitive personal information: journal content, emotional reflections, mood check-ins, and other information you choose to submit that may reveal sensitive details.
• Inferences: themes, patterns, or reflection summaries generated from your use of the Service.

Sources

We collect information from:

• you;
• your device;
• Apple;
• service providers;
• app usage.

Purposes

We use information for the purposes described in Section 2.

Disclosure

We disclose information to service providers and other recipients described in Section 4.

Sale/Sharing

We do not sell journal entries or AI conversation content. We do not intentionally share journal entries or AI conversation content for cross-context behavioral advertising.

Rights

California residents may have rights to know, access, correct, delete, opt out of sale/share, limit certain sensitive personal information uses, and not be discriminated against for exercising privacy rights.

Contact agent@shado.co to exercise rights.

10. GDPR / EEA / UK Notice

If you are located in the European Economic Area, United Kingdom, or Switzerland, this section applies.

Controller

The controller of your personal data is:

Legal Bases

We process personal data based on:

• contract: to provide the Service;
• consent: where required, such as certain optional features;
• legitimate interests: to secure, maintain, analyze, and improve the Service;
• legal obligations: to comply with applicable law.

Rights

You may have rights to:

• access your data;
• correct your data;
• delete your data;
• restrict processing;
• object to processing;
• data portability;
• withdraw consent;
• lodge a complaint with a supervisory authority.

International Transfers

We may process information in the United States and other countries. Where required, we use appropriate safeguards for international transfers.

11. Consumer Health Data Notice

Shadow is a wellness and journaling app and may process information that some laws consider consumer health data, including mood, emotional reflection, and self-reported wellness information.

We use this information to provide journaling, reflection, AI guidance, safety prompts, account functionality, and related services.

We do not use consumer health data for diagnosis, treatment, therapy, or medical care.

We do not sell consumer health data.

We do not disclose consumer health data except as described in this Privacy Policy, including to service providers that help us operate the Service, when required by law, or with your consent.

12. Children’s Privacy

Shadow is not directed to children under 13.

We do not knowingly collect personal information from children under 13. If we learn that we collected personal information from a child under 13, we will take reasonable steps to delete it.

If you believe a child under 13 has provided personal information, contact us at agent@shado.co.

13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information.

Our architecture includes structural safeguards: content is never logged to analytics or crash reporting tools; sensitive AI call identifiers are not loggable; row-level security policies enforce per-user data isolation in our database; user content is processed through identity-stripping middleware before being sent to AI providers.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

You are responsible for keeping your account credentials secure.

14. Push Notifications

If you enable push notifications, we may collect and use a device token to send reminders, updates, or app-related notifications.

You can disable notifications through your device settings.

15. Third-Party Links and Resources

The Service may contain links or references to third-party resources, including crisis resources or educational resources (988 Suicide & Crisis Lifeline, Trans Lifeline, SAMHSA, findahelpline, and others).

We are not responsible for third-party websites, services, policies, or practices.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The updated version will be posted in the App or on our website with a new effective date. If changes are material, we may provide additional notice.

17. Contact

For privacy questions or requests, contact: