Privacy & Health Information Notice

Soul AI (“Soul AI”, “Platform”, “We”, “Our”, “Us”) is committed to protecting the privacy, confidentiality, and security of individuals who use our platform.

Mental wellness information is particularly sensitive. We recognise that users place significant trust in us when sharing personal thoughts, emotions, and experiences.

This Privacy & Health Information Notice explains how Soul AI collects, uses, stores, protects, shares, and deletes information when you use mobile applications, websites, the AI Counsellor, the Human Therapist Marketplace, SOS features, mood tracking, journaling, voice conversations, educational content, and future Soul AI services.

This Notice should be read together with the Soul AI Platform Terms of Service.

Soul AI has been designed around the following principles:

• Privacy by Design: Privacy considerations are incorporated throughout product design and development.
• Human-Centred AI: Artificial intelligence assists users but does not replace qualified professionals.
• Data Minimisation: We seek to collect only information reasonably necessary to provide and improve our services.
• Transparency: We aim to explain clearly how information is collected and used.
• User Control: Where feasible, users are provided meaningful choices regarding their information.
• Security by Design: Appropriate technical and organisational safeguards are implemented to protect information.

For purposes of this Notice:

Depending on how you use the Platform, we may collect the following categories of information:

A. Account Information
When creating an account, we may collect: Full name, email address, mobile number, date of birth, country, language preferences, profile photograph (optional), and login credentials.

B. Identity Verification
Where required, we may collect additional information to verify identity, prevent fraud, or comply with legal obligations. This may include government-issued identification (where necessary), one-time passwords, and device verification. Identity verification information is collected only where reasonably necessary.

C. Profile Information
Users may choose to provide preferred language, wellness goals, interests, emergency contacts, accessibility preferences, and communication preferences. Providing optional profile information is voluntary.

Soul AI is designed to support emotional wellbeing. Users may voluntarily provide information relating to:

• Mood, stress, anxiety, depression
• Relationships and family concerns
• Work-related challenges, burnout, and sleep
• Grief, trauma, emotional wellbeing, and personal goals

This information may be considered sensitive under applicable law. Soul AI processes such information only for purposes described in this Notice.

When interacting with the AI Counsellor, we may collect: messages, prompts, AI responses, conversation timestamps, conversation length, conversation categories, language used, user feedback, and safety flags generated by automated systems.

Conversation history helps provide continuity across sessions where users choose to enable that functionality.

Where users interact with therapists through the Platform, we may process: appointment information, booking history, session duration, therapist selected, payment status, communications necessary to facilitate services, feedback, and ratings.

If enabled by the user, Soul AI may process daily mood entries, mood scores, wellness check-ins, journal entries, emotional trends, behavioural patterns, reflection exercises, and progress tracking.

These features are intended to assist users in understanding their wellbeing over time. Mood analytics are informational and should not be interpreted as medical diagnoses.

Where supported, users may communicate with the AI Counsellor or therapists using voice. Depending on the feature and user settings, we may process audio recordings, speech transcripts, voice commands, language preferences, and interaction metadata.

Where recordings are retained, users will be informed of the applicable retention practices.

To operate and secure the Platform, we may collect technical information including: device type, operating system, browser type, application version, IP address, approximate location derived from IP, device identifiers, crash logs, diagnostic information, network information, and security events.

This information helps maintain service reliability, security, and performance.

Soul AI may use cookies, SDKs, pixels, local storage, and similar technologies to maintain user sessions, remember preferences, improve functionality, measure performance, prevent fraud, enhance security, and understand feature usage.

Users may manage certain cookie preferences through browser settings or Platform controls where available. A separate Cookie Policy may provide additional information.

We may use information to: provide Platform services, respond to user requests, deliver AI conversations, facilitate therapist appointments, improve user experience, detect safety risks, identify misuse, prevent fraud, secure accounts, process payments, send service communications, improve multilingual support, conduct product research, develop new features, and comply with legal obligations.

Where required by law, additional consent will be obtained before using information for purposes that are materially different from those described in this Notice.

Where applicable, Soul AI processes information based on one or more of the following legal grounds:

• Your consent.
• Performance of a contract to provide Platform services.
• Compliance with legal and regulatory obligations.
• Protection of vital interests in emergency situations.
• Legitimate business interests, provided such interests do not override your rights and freedoms.
• Other lawful grounds recognised under applicable data protection laws.

Where consent is required, you may withdraw it at any time, subject to legal or contractual limitations.

Soul AI uses artificial intelligence to provide personalised mental wellness support. AI may generate conversational responses, recommend wellness exercises, identify recurring mood trends, suggest journaling activities, recommend professional support, detect potential indicators of emotional distress, personalise educational content, and improve user engagement.

AI-generated insights are intended to support users and are not medical diagnoses or clinical opinions. Users should not rely solely on AI-generated information when making important medical or mental health decisions.

Soul AI believes that mental wellness should remain human-centred. Accordingly:

• AI is designed to augment, not replace, qualified professionals.
• High-risk conversations may trigger recommendations to consult a Human Therapist.
• Certain safety alerts may be reviewed by authorised personnel for quality assurance, abuse prevention, or platform safety, subject to applicable law and user rights.
• Clinical advisors may periodically review de-identified interactions to improve AI quality and safety.

Human oversight helps improve response quality while reducing the risk of inappropriate or harmful outputs.

Soul AI may analyse user-provided information to identify long-term wellbeing patterns including emotional trends, stress levels, mood fluctuations, engagement patterns, journaling consistency, wellness goals, and self-reflection progress.

These insights are intended solely to help users better understand their wellbeing. They should not be interpreted as clinical diagnoses.

Where enabled, Soul AI may process information necessary to support safety-related features, including emergency contacts designated by the user, safety preferences, SOS activation history, user-selected crisis support settings, and communications necessary to facilitate safety features.

Soul AI does not sell personal information. Information may be shared only where reasonably necessary for purposes described in this Notice. Recipients may include:

Service Providers: Such as cloud hosting providers, payment processors, identity verification providers, customer support providers, analytics providers, infrastructure providers, and security service providers. Service providers are contractually required to protect information and use it only for authorised purposes.

Human Therapists: Where users book therapy through the Platform, relevant information may be shared with the selected therapist to facilitate the requested services. The information shared will generally be limited to what is reasonably necessary for providing therapy, unless additional sharing is authorised by the user or required by law.

Clinical Partners: Soul AI may collaborate with hospitals, clinics, universities, research organisations, NGOs, or other healthcare institutions. Where appropriate and permitted by law, information used for research or product validation will be de-identified or anonymised where reasonably practicable, and identifiable information will not be disclosed without an appropriate legal basis, user consent where required, or another lawful justification.

Corporate Wellness Programmes: Where users access Soul AI through an employer, insurer, educational institution, or organisational wellness programme, Soul AI will not disclose individual therapy conversations or personal journal entries to the sponsoring organisation without the user's consent or where otherwise required by law. Aggregate or anonymised reports may be provided for programme evaluation purposes.

Soul AI continually improves its services. Information may be used for: AI quality evaluation, language improvements, safety testing, clinical validation, bias detection, product development, academic collaboration, statistical analysis, and service optimisation.

Where reasonably practicable, research datasets will be anonymised or de-identified before use. Participation in formal research studies requiring identifiable information will occur only with appropriate consent and approvals where required.

Soul AI may use technology infrastructure located in multiple jurisdictions. Where information is transferred across national borders, Soul AI will implement appropriate safeguards consistent with applicable law, such as contractual protections, technical safeguards, encryption, organisational measures, and other lawful transfer mechanisms.

Protecting user information is fundamental to Soul AI. Security measures may include:

Technical Measures: Encryption in transit, encryption at rest, access controls, multi-factor authentication for administrative access, network monitoring, security logging, vulnerability management, and malware protection.

Organisational Measures: Confidentiality obligations, staff training, role-based access, security policies, vendor assessments, and incident response procedures.

Although Soul AI employs reasonable safeguards, no system can guarantee absolute security. Users should also take reasonable steps to protect their own accounts.

Soul AI retains information only for as long as reasonably necessary to: provide requested services, comply with legal obligations, resolve disputes, enforce agreements, improve platform safety, maintain security, and conduct legitimate business operations.

Retention periods vary depending upon the nature of the information, applicable legal requirements, user preferences, and ongoing service relationships. Where appropriate, information will be securely deleted, anonymised, or de-identified once no longer required.

Subject to applicable law, users may request deletion of their personal information. Certain information may need to be retained where required for legal compliance, fraud prevention, dispute resolution, security investigations, accounting obligations, or protection of legal rights.

Where complete deletion is not legally possible, Soul AI will restrict further processing where appropriate.

Users may close their accounts through the Platform or by contacting Soul AI support. Account closure does not necessarily result in immediate deletion of all information. Certain records may be retained for legal, regulatory, security, or operational purposes consistent with this Notice.

Subject to applicable law, you may have the right to:

• Access your personal information.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal information.
• Request restriction of certain processing activities.
• Object to specific processing activities where permitted by law.
• Withdraw consent where processing is based on consent.
• Request a copy of information you have provided, where technically feasible and legally required.
• Request clarification regarding how your information is processed.

Soul AI will respond to eligible requests within the timeframes required by applicable law.

Certain requests may be declined or limited where required to comply with legal obligations, protect the rights of others, maintain platform security, or preserve records that must be retained.

Where consent is required for the collection or processing of information, Soul AI will seek consent through appropriate mechanisms. You may withdraw consent at any time for future processing by using available account settings or contacting Soul AI.

Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal. Certain Platform features may no longer be available if consent for essential processing is withdrawn.

Soul AI may send communications relating to: account management, security notifications, appointment reminders, service updates, billing, platform improvements, wellness reminders, educational resources, product announcements, and marketing communications.

Users may manage communication preferences within the Platform or unsubscribe from non-essential communications where applicable. Certain operational or legal notices may continue to be sent even if marketing communications are disabled.

Soul AI is intended primarily for adults. Where services for minors are introduced in the future, Soul AI will implement additional safeguards consistent with applicable law, including obtaining parental or guardian consent where required.

If Soul AI becomes aware that information has been collected from a child in violation of applicable law, appropriate steps will be taken to delete or otherwise manage that information in accordance with legal requirements.

Users may manage certain cookie and tracking preferences through browser settings, device settings, mobile operating system permissions, or Platform controls where available. Disabling certain technologies may affect the functionality or performance of the Platform.

Additional information regarding cookies and similar technologies may be provided in the Soul AI Cookie Policy.

Soul AI maintains procedures designed to identify, investigate, contain, and respond to security incidents. Where required by applicable law, Soul AI will notify affected individuals and relevant authorities of certain data breaches within legally prescribed timeframes.

Following a confirmed incident, Soul AI may: investigate the scope and impact, implement remediation measures, strengthen security controls, cooperate with regulatory authorities, and provide guidance to affected users.

Soul AI is committed to complying with applicable data protection and privacy laws in the jurisdictions in which it operates.

For users in India, Soul AI seeks to process personal information in a manner consistent with the Digital Personal Data Protection Act, 2023, and other applicable laws.

As Soul AI expands into additional jurisdictions, this Privacy & Health Information Notice may be supplemented or updated to address additional legal or regulatory requirements.

Soul AI is committed to responsible AI development. We aim to: use AI in ways that support human wellbeing, reduce the risk of harmful or biased outputs, continuously evaluate AI performance, maintain appropriate human oversight, improve multilingual accessibility, respect user autonomy, protect user privacy, minimise unnecessary data collection, and promote fairness and inclusivity.

Where feasible, improvements to AI systems will rely on anonymised, aggregated, or de-identified information.

Soul AI may establish governance structures to support the safe operation of the Platform. These may include Clinical Advisory Boards, safety review committees, ethics advisors, external healthcare experts, product quality review processes, incident review procedures, and AI performance monitoring.

The purpose of these activities is to improve safety, quality, and user experience while respecting applicable privacy obligations.

As Soul AI evolves, additional services may be introduced, including but not limited to: wearable device integration, wellness coaching, personalised care pathways, remote wellbeing monitoring, educational programmes, group sessions, digital therapeutics, clinical research initiatives, and enterprise wellness services.

Where new features require materially different processing of personal information, Soul AI will provide updated notices and obtain additional consent where required by law.

Soul AI may update this Privacy & Health Information Notice from time to time to reflect changes in law, new technologies, new Platform features, operational improvements, security enhancements, or business developments.

Material changes will be communicated through appropriate channels, such as the Platform or email where required by applicable law. The "Last Updated" date will indicate the most recent revision.

Soul AI is committed to the following principles: