Privacy Policy

1. Introduction

Welcome to Chaptly, a mobile application developed and operated by Victory Interactive LLC, registered in the United States (30 N Gould St Ste N, Sheridan, WY 82801) ("we," "us," or "our").

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use the Chaptly app on iOS or Android platforms (the "App").

By using the App, you agree to this Privacy Policy. If you do not agree, please do not use our services.

2. Data Controller

Victory Interactive LLC is the data controller responsible for processing your personal data under the General Data Protection Regulation (GDPR).

If you are located in the European Economic Area (EEA) or the United Kingdom, you may contact us at privacy@chaptly.io regarding any data protection inquiries.

We currently do not have a designated EU representative.

3. Data We Collect

We collect the following categories of information:

Account Information

• Name or nickname
• Email address
• Profile photo or avatar
• Login credentials (hashed password, Google Sign-In, Apple Sign-In)

Usage & Device Information

• Device ID, IP address, OS version, timezone, interface language
• In-app behavior and analytics (via PostHog)
• Progress within emotional healing modules
• Push notification tokens

Content You Provide

• Responses to quizzes and exercises
• Selected goals, gender, and age range

Payment Information

• Purchase history via Apple In-App Purchases or Google Play Billing
• (We do not collect or store credit card details.)

AI-Generated Content

• Prompts and responses submitted to AI features (processed by OpenAI API).
• Such data is anonymized before transmission.

4. Purpose of Data Processing

We process your data for the following purposes:

• To create and manage user accounts
• To provide personalized self-help and wellness content
• To track user progress and performance
• To improve user experience and app functionality (analytics)
• To send notifications and reminders
• To manage subscriptions and in-app purchases
• To ensure secure authentication and prevent abuse
• To provide AI-powered recommendations and content generation
• To offer technical support and respond to user inquiries

5. Legal Basis for Processing (GDPR)

We process personal data based on the following legal grounds:

• Performance of a contract: To provide you with app functionality and user support
• Legitimate interests: To improve our services, prevent fraud, and ensure security
• Consent: For sending notifications and using AI personalization features
• Legal obligations: To comply with applicable financial and data protection laws

You may withdraw your consent at any time by adjusting your settings in the App or contacting us at privacy@chaptly.io.

6. Data Storage and Transfers

All personal data is stored securely on Amazon EC2 and Google Firebase servers.

Data may be transferred to the United States and other countries where our partners operate, including:

• Google / Firebase – authentication, cloud messaging
• PostHog (USA) – analytics
• OpenAI (USA) – AI content generation
• Apple / Google – purchase processing

When data is transferred outside the EU/EEA, we rely on Standard Contractual Clauses (SCCs) or equivalent legal safeguards to ensure an adequate level of data protection.

7. Data Retention

• Data related to active accounts is stored until the user deletes the account.
• Upon deletion, all personal information is permanently erased.
• Analytics data is retained according to PostHog's retention policy.

8. Data Security

We apply industry-standard security measures, including:

• SSL/TLS encryption for all network communications
• Bcrypt password hashing
• JWT-based authentication
• Firebase Authentication
• OAuth 2.0 for Google and Apple login
• Secure on-device storage for tokens

We do not currently implement two-factor authentication (2FA).

9. AI Features and Data Processing

Chaptly includes AI-assisted functionality powered by OpenAI API.

When using these features, anonymized user prompts may be transmitted to OpenAI servers for processing.

We do not share identifying information or personal identifiers.

AI responses are generated automatically and may not always be accurate or appropriate.

By using AI features, you acknowledge and agree to this data processing.

10. Children's Privacy

The App is intended for users aged 13 and older.

We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe your child has provided data to us, please contact privacy@chaptly.io to request deletion.

11. User Rights (GDPR / CCPA)

Depending on your location, you have the right to:

• Access your data
• Request correction or deletion
• Restrict or object to processing
• Data portability
• Withdraw consent
• File a complaint with a data protection authority

To exercise these rights, contact us at privacy@chaptly.io.

We will respond within 30 days as required by law.

12. Third-Party Services

The App integrates with several third-party services:

• Firebase (Google LLC) – authentication, push notifications
• PostHog (USA) – analytics
• OpenAI (USA) – AI processing
• Google Play Billing / Apple IAP – in-app payments

These providers have their own privacy policies. We encourage you to review them.

13. Data Deletion and Account Removal

Users may delete their accounts directly within the app.

Upon deletion, we immediately and permanently erase your personal data from our systems.

Guest accounts are automatically removed after inactivity or session expiry.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

If changes are material, we will notify users via email or in-app notification prior to the effective date.

15. Contact Information

If you have any questions or concerns regarding this Privacy Policy or your personal data, please contact us:

• privacy@chaptly.io (Data Protection inquiries)
• legal@chaptly.io (Legal department)
• support@chaptly.io (Customer support)